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<br />. <br /> <br />. <br /> <br />Daria J. Zane <br />Page 2 <br /> <br />which are suggested by the comments on the Draft SEIS may be ad- <br />dressed in the Bureau's response to the comments. <br /> <br />II. CUMULATIVE IMPACTS <br /> <br />The 1980 EIS and the Draft SEIS appear to contain an ade- <br />quate discussion of the cumulative impacts of water projects on <br />the Colorado River system. The 1980 EIS also contains an exten- <br />sive discussion of the potential environmental impacts from coal <br />development that may arise as a result of the proposed action. <br />However, neither of those documents indicate that the Bureau has <br />examined the potential cumulative impacts of other reasonably <br />foreseeable development in the project area. While there may not <br />be any cumulative impacts from such activities, our concern is <br />that the Bureau has failed to demonstrate that it properly con- <br />sidered the issue. For example, at page V-2 of the Draft SEIS, <br />the Bureau summarily concludes that the cumulative impacts from <br />coal bed methane gas development in the San Juan River basin is <br />outside the scope of the SEIS. A consideration of cumulative im- <br />pacts is clearly within the scope of the SEIS and where public <br />comments identify a potential cumulative impact, the Bureau <br />should either evaluate it or set forth a reasoned basis for <br />excluding it from the scope of the SEIS. <br /> <br />III. THE UTE LADIES' TRESSES <br /> <br />At page 111-23, the Draft SEIS states that "priority habi- <br />tat sites" for the Ute ladies' tresses "are believed to be within <br />the Project area." However, there is no evaluation of the poten- <br />tial impacts to that habitat or to the species or any indication <br />that Section 7 of the Endangered Species Act has been complied <br />with. Additional analysis is necessary to satisfy NEPA and the <br />Endangered Species Act. <br /> <br />IV. PHASED DEVELOPMENT IMPACTS <br /> <br />While the Draft SEIS points out that two-phased development <br />of the Animas-LaPlata Project is one of the main changes in the <br />proposed action since 1980, the environmental impact discussion <br />in the SEIS largely ignores this change. For most of the envi- <br />ronmental parameters there is no mention of any potential changes <br />in impacts due to phased development. The sections discussing <br />potential impacts to archaeological resources and to the local <br />economy do discuss the potential impacts under each phase and a <br />similar discussion would be appropriate for the other environmen- <br />