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UPPER COLORADO RIVER COMMISSION

355 South Fourth East Street Salt Lake City, Utah 84111

October 17, 1972

MEMORANDUM

TO: Upper Colorado River Commission

FROM: Ival V. Goslin, Executive Director

SUBJECT: Hearings on environmental statements on reclamation projects

On April 18, 1972 a hearing was held in Salt Lake City on the draft environmental statement prepared by the Bureau of Reclamation on Chma Meadows Dam of the Lyman Project in Wyoming. This project was authorized by the Congress in 1956. This hearing was characterized by the attendance of selected dismissed university and school classes and a lot of ballyhoo in support of the so-called environmentalists. The construction of China Mead­ ows dam is still stymied in the Department of the Interior.

On September 2 2-23, 19 72 a hearing was held in Orem, Utah on the draft environmental statement on the Bonneville unit of the Central Utah project. At this hearing t he shoe was on the other foot. The demonstrations and 9 5% of the statements supported the con struction of the Bonneville unit.

In order that you may become acquainted with t he nature of the opposi­ tion, enclosed is a copy of the statement of Mr. Raskin for the Sierra Club and a copy of his letter of October 2, 19 72, nine days after the hearing, to the Regional Director of the Bureau of Reclamation. Al so enclosed is the statement of Friends of the Earth. y /Y .. .;', .. / Stntcmcnt of' DAVID C. HASKI:'-i, Ph.D. Conservation Chairman, Uinta Ch:1pler, Sierra Club on the DHAFT E:-.'VJI10i\;-JE~T,\L 51 J\THU·::;-.;T BO~EVILLE L"NIT, CEr-:TJ1AL liTA!! PI10JECT

My name is David·€. naskin of' Sl\lt Lake City, Utah. I am t11\....-Cul1 :i~1·· v·ation Chairman of the U:i nta Chnpter of' the Sierr.:i Cluh, and -:r;; ..1ai:- -, representing our nearly 600 members i.. Ut.:lh and Hearly 150,0 ~_:.0~1.!.:'. our national organization. I appreciate this opportunity to pre.sent the views of our organization concerning the Draft I-:nvii-onmental Stntemcnt .and proposed construction and opcrc1tion of' the Donncville Unit of the Central Utah P1ojcct. We arc p l eased that the public has f'irially obtained an opportunity to express its views on this project's proposed uses of public funds, public lands, other natural resources in the state of Utah.

Our general €Valuation of' the Draft Environmental Statement is that it is woefully inadequate, it Deriou:.ly fi>ils to comply with Uw content and intent of the N.:ition.:.11 Envirorun~ntal Po1 icy Act .:ind the guidelines of the Cow1cil on Environme ntal Quality, and it r<'presc:nts nothing mpre th.:in u crude ;.ti.empt to provide justific.:ition for an environmentally unsound .:md ccouomicaJ ly out.ras; couc. project. Il pro­

vides no meaningful cconornic ,tnalys is of the project I and it provides only a most cursory and tot,1lly inadequntc trec1tmcnt of alternatives.

There arc so many blatant omissions and misleading and undocumented ·assertions in the Draf't Cnvironmcntal Statement that it is impossible to enumerate and describe all or them at thi..s time. Therefore, I shall attempt to dcnl with only the major deficiencies and problems now, res erving more clct.,ilc<.J comments i'cr- another occasion. ThP. order of considerat:ion "ill follow the ot·Je1· in which sections lire arranged in the Drnf t Environme ntal Statc11,c,,t .

pescription of the Cnvironment B. - / This section contains misleading, inaccurate and undocumented state­

ments. On p. 89 1 only cursory tre.:ttmcnt is given to the proble m o'f · geological hazards associated with the propor;cd Upper Stillwater Tunnel, and there is no documentation concerning the clangers posed and the solutions recommende d. J\ls o, the problems associated Kith tho South Flank Fnult arc not addressed.

The value of the fisheries ' to be af'fectcd by the project arc inade­ quately described on pp. 98-99. No mention is made of the fact that numerous miles of cl.:iss II s t re.-irn:1 "·ill lrn d0 ,;troyccl, which is C'Spccial- .' ly. importnnt in view of the fact that Utah has r.~t.:iincd only 1151 mi.les of such streams. Also, the statement that Utah l.n.ke "is pos sibly the State's most valuable warm wnter :fis hery" is a gross undcrstat0me nt.

The statements on p. 107 and p. 111 re'ferri~ to "needs" for water olong the Wasatch Front and expected increases in population arc misleading and outdated. These "needs" arc based upon 1966 popula­ . tion projections furni s hed by the University of Utah and indicate a projected Utah popul.:ition of 2.9L1-2 million by the yc.-1.r 2020. However, -tho latest projections iss~ed by tl,e fcdcral·Officc of Business Eco­ nomics and the Economic Rese;.rch Scrv:i.ce indicate an n11ticipatc (l population of only 1.995 million by 2020. Thu.'3, the ofi'ic,11 federal projections arc J2% below those being u s ed by the nur<'AU of Hcclamntion to. jugtify this project. J\l s o, on p. 111 it i'.; st.1l<'d th.,t 800,000 'A' of Utaii's share of Color.:tdo I1ivc1· ..r.,Lcr i.s availnhle for development

_,.,, --

I l ·.-..----_·-...... -:-···-""' -···. -.. :-;--.,,... -- -~----- .. -~ -. -··------, --·r..-.-~-·-"'(-.r;--·- ..... - - · ,. which· is not nccurnte. Including the Donncv:llc, Upnlc0, aacl Uintah -. . Units of the Central Utnh Project, Utah hns only ))1,000 to ~92,000 aero f'cct of' uncommitted Colorado Hivcr w.:iter .. ccording to 1:he Ut.ih Division of Water Resources.

The section on soil quality and ~alt content· beginning on p. 115 is totally dcvojcl or docume ntation for the as s e rtions presented nnd there is no quantification associated with t..hc st.:ttcmcnts.

C. _Environmcntol Impnct~ of the Pr·opos <'rl Action

This section is _~xtremely dericicnt . The 1:rcntment of the impact or the proposed Upper Stillw.itcr Heservoir is n gla1·ing ex.i.mplt:. On p. 119 it is stated th.it the recrc~tion vnlue of Upper St{llwater Reservoir "is expected to be 01 State signi:fic,,ncc." Whc:n one con­ siders an nnnunl drawdown of lJJ feet , rocky wnd precipitous sr.ore­ line, a non-svstnining fi s hery mZ1n .::i ged on n " put vnd tnke" bo.sis, and the grcot di s tnnce from heavi] y -po pula1:ed .:.re ;:i s of the s t.:1tc which h ave superi~r r~servoir rishing nearby; the vnlidity of that ossertion is quite doubtful. The ncgntive impac1:s of reduced flows in Rock Creek have been understated. flock Creel< is a "blue ribbon trout strec:1m" ancl will be virtually dcs troy

The impacts on Currant Creek arc ino.dequately rl~ scribeo , since no stream flows will be provided in spitq of recomme ndations of G cf's by the Utah Dcpo.rtment of Fish and Ga me ..i.nd th,~ lJ. S . Durcnu of Sport Fisheries and Wildlife" and 5 cf's bi the U.S. Fores t Service. Also, the effects on big gnme .md other wildlife arc inadequately described.

The effects of the Soldier Creek Dam on the Strnwbcrry River arc not accurately des cribed. The p lrumed releas e of only It cfs into the Strawberry Hivcr will destroy 20 miles of hi"gh qu.:ility strcilm which _is Utah's only designated fly-fishing-only stre~m. The Utah De part­ ment of' Fish and Game originally recommended n minimum of 1 2 cf"s to maintain a rishcry in the Stro.wberry flivcro Also, the loss es of big game and other wildlife habitat and sp.:nming ,"\re .,s for the l.lrgo ·trout population in Strawberry Reservoir nre in~~e quatcly de s cribed.

The section on pp. 128-129 dealing with the effects of diversion structures is extremely inadequate, especially with respect to Vat Diversion Dam on the We s t Fork of the Duchesne River. The Durco.u of Reclamation plans to completely dcwiltcr the strcnm and .des troy · 10 miles of a popular and productive trout strc.\m. The Utah Depnrt­ mcnt of Fi::;h and Game, the U.S. Dureau of Sport Fi5heries and Wild­ life, ond the U.S. Forest S~rvicc have o.11 rccornmcndcd a minimum release of' 8 cfs. Unfortunately , Govcnor R;impt:on of Utah !;Ubs c­ quontly required the Ut..i.h Department of fish am! G.'.\ITIO to wi thdrnw its rocommchdations for minimum flows on Rock Creek, Currant Creek, the West Fork or the Duchesne Itive.r, nnd the Strawberry River. The

... ·.· ,- .. ~; ~.

.:fact that a politician orde red the Fish and Ganie Agency to a lter its public stand docs not in any way alter the bioioiical f'acts and the environmental and recr.c a t ional impacts of the proposed actions.

The described impact of the proposed Jordanelle ncscr voir is inade­ quate and undocumented. Its ef'f'ccts on the water tabl e grc1dients which might affect the opcrntion of local mines arc n ot thoroughly explored, nor is the effect on the reaches of the Provo River to be innWldoted sufficiently describe<..!. Also, the ef'fccts of' an enormous influx of visitors on the surrounding rural conununities are not even mentioned. The inevitable developments and subdivisions will ob­ viously produce major changes in l and-use patterns , cultural and socio-economic factors , and the general quality of l ife of the a~ea and surrounding towns.

Tho treatment of the impacts associated with the diking of Provo and Goshen Buys is· highly inadequate ond v.1gue, the amount of draw­ down ot: Utah Lake .is uns pecified, and the losses to fish and w:ild- 1.ife arc not fully described. Utah L.:i.ke js the mo s t productive vorm-water fishery in the State, and the drying-up or Provo n.:1y wou1d have a significant impact on recreation opportunities in Utah Countyn On p. 137 the assumption i s 'ni.:ule t:hat dik:i ng of the Provo Bay portion would account f'or 1/J of the fi s hing losses bC'cc1u s e it comprises'l/J of' the arc.:i. to be diked: This is n ot neccssorily accurate, since Provo Day probably provid<.'s nruch better s pawning habitat than Goshen Day and provides better rood .ind cc,ve1: f'or immature f'ishes. The a sse ssmC'ut of wildlife losse~; and their mitigation by the proposed Goshen Day Wildlife Manngement area is cursory ond s uperric.i.al. Also, no me ntion js made o r the los s or nesting nreas ond rookeries in Pro,·o Hny and Gos hen Day.

- The treatment or the proposed La mpton neservoir on the Jordnn River exemp1if'ics the whole appronch of this S Z:D.'tcmcnt. It states on p. 1J9 that "although not yet evaluated, the r eservoir should provide significant recreation and fishing opporr.uni tics clos e to metro­ politan Salt Luke City." This statement i s nbs urd and merits no .. further comment. Also, no assess ment i s m.:i cle of the recreation Qlld f'ishcries losses on the Jordan River res ulting from innundation. This is especially pertinent since the State and Solt Lnkc County -are actively pursuing a multimillion dollar recrcacion.:11 development o~ a Jordan River Parkway.

Vith regard to the Diamond Fork power system, we ore told more about the needs f'or electricity and the virtues of this sys t em than the environmental impacts of such a devel opment. Obviously, alternatives or negative impacts just do not seem to be o f any interest to the Bureau.

The Lot-rer Sti1lwater Reservoir is described in glowing terms , but no mention is made of its impact o n a s cenic, mount.:1in area and on ~he excellent trout fishery which currently exis ts on Rock Creek.

Tho treatment of sociologicnl ond economic impncts is ve.ry mislond­ tns. Th.o populntion projections u sed are very much outdat'cd as prcvious1y mentioned. Also, the assertion that population growth in th0 liasatch Front wil l continue without the Donneville Unit cer­ tainly crumot be interprcted·to mean that people will live without ~ater? therefore one can only conclude that alterna tive sources are availab1e or.that current supplies arc sufficient to meet fu~ure popu1ation increases, or that reduction or con sumption can be ac­ ComJ;?lishcd by increas es in efficiency of water u se . Although the

.· · · , ·.

the ·Bureau has not dealt adequ.ltely Kith tho!;(;! pos:;ible alternatives, they will be treated later. in this An,,lysi ~~ Also, the 's t .itement that shortages are now occurring in the 1301,nevil le n.:.sjn mus t rC'fer · to irrigation uses, since m•.micip"l supp1 ies in the metropolitan nreas are currently adequate.

With respect to additional income to +.he Indians, only b ~re assertions arc made. No effort is made to qu.;,ntify new income in r:-ompnrison to current anri projected income fr om cxi.:c't ing recreation;il resourc cs o A,].so, the Durec,u has completely ignorC'd the J.c.. sscs due to innundation of: lands and the inability of' the Indians to dc·velop over 15,000 iew a6res of f'armland due to loss of' water ~o the Donn~ville Basin.

The economic analysis is incomplete and misl,:,:1ding. Fnr cx:irnple, the statement points out on p. 150 that 12(1 j0l.Js will be p!"ovidcd f'tom operation and mnfnten..ince needs on t'n,! l ' ·li.t , which eX<'C'~ds the employment o-f mo s t s ingl.c l.Jusincsse.s in th,· :,•. -:1.te. I d.1resay that a busine.;;s with a capitaliz.:.ition of t.500 m1}11on and lo-...· interest

rates is usually expected to produce mere th;; n 120 jobs'. J\ls ,) 1 t h e f'igurc of' $35 million estimated to result from u.~:-ic.ult•Jr<,l utili­ zation of th<' water developed works out t,:- -,pprcxim::1tC'ly ~JG/acre :foot. This is an extremely poor inve s tment ,,hen one realizes t.har. the estimated S250 million increc\SC in pers on,Jl income -fro m muni­ cipal and industrial water yields c,pproxim;.1tely :'!>2, '.iOO/acre foot developed. Obviously, the dC'vclopment of municipal anrl j11du s~rial w.iter is carrying the economic 0. lly undc ::: ir;.1ble developments -for agricultur.,,l uses. It shoul d be po:i.nt. 0 d o•n .; hat the Donncville Unit Definite Plan Report indicates th'c\t ird ~ittion ace.aunts for ~0% of the project costs but p.lys only 5~ 5~:'. ,;f the reimbursable ·costs, and the remainder of the rep :,y111cnc . corn~s -from public f'unds and direct property taxes .on cveronf 1 jyi n J in the 12 counti~s of the Central Utah Water Conservancy Di .s t ri c..,. l\ls o, mun:i c:i p.il and industrial users pay interest, but the irri~ators pay no intC'res t. The overall direct subsidy to the irrifcl.Z"o•·s corne3 to s om~'whcre between $1,000 and $l,l1QO/acre occordir. l! to the economic ,'ln"\ly~is .performed by the :'.'fader organization·. 1nu.:;, the. owner of a J20 acre farm will receive"a direct subs idy in PX ~ess of SJ50,000. The economics also fail to take into account tl1c 1~3ses resulting from innundation of more than 20 ,000 acres of pro~uctive lands as a re­ sult of reservoirs to be constructcdo ~ The section dealing with the Provo niver is ·contradictory. An increase in fishing on the Upper Provo was claimed as a benefit from the Jordanelle Reservoir, yet a .iater statement indicates that there will. be less water in the Provo River between Jordanelle and Deer Creek than h as occurred hi s tori cally. Als o, there would be a ~eduction from historical f'lows above Jordancllc • .. It appears that flow patterns in the lower Provo niver ~ ill be ~reatly altered in a detrimental way. Minimum flows will he decreas ed in the crit­ ical winter months and flows will be great l y increased in the summer months which coincides with the maximum fi s hing u s e of the rivero Thus, the fishery and the fishability of the river would 9c severely diminished. However, the statement fails to mention any of those ., . impacts • The problem of decreased wa~er quality in ~he Colorado River is lightly dismissed even after admitting th:1t .the nnalysis by the Environmental Protection Agency indicates an increas e of 111 mg/1 at Lake Mead. Since the U.S. Public Health Service has set u limit of 500 mg/l. f'or human cons umption and Los Angeles now rc­ coives rrr..micipal water with 760 mg/1, 1:hat increase in sal inity

'T' . ·- is a serious problem. Also , the recently concluded ngrccmcnts .. between the l.'ni ted St.:1t es ?nd Mexico concerning the unacccpt.,blc w~tcr quality of' Colorado River ~~tcr delivc~ed to ~lexi~o serve to dramatize the problem and provide additional r easons for not increasing the salinity. of' the Colorado Hi ver. · Since the Bureau of Reclamation has announced plans to embark on a !>500 million pro~ram to reduce salinity in the Colorado Hiver, it i s ludicrous ~or them to spend simultnncous ly :,500 million to incrense the l!lalinity by cons tructing a transmountain diversion to the Bonne­ ville Basin. Also, ~he economic a n alysis f'~ils to assign any cost to the estimated salinity increafie of 1 4 mg/1. I understand that the EPA has assigned approximately S500,000 per yenr as the cost of that increase. That f'i3ure mu s t be incorporated into the benefit/cost analysis of the Bonneville Unic.

The. ·treatment of secondary impncts is super·.ficial. Al though additional population and industrial growth :-,re recognized here (having been denied earlier), the extent of' e nvironmental degr~­ dation, water quality deterioration, and decreases in quc1lity of lif6 arc not f'ulli explored. Also, the attitude .seems to b e tha t

some sort of' coordin.:1ted plnru1ing , wat<'r quo. li ty stand.:1rds 1 and improved irrigdtion ru1d processing techniques will be developed e.nd enforced. Obviously, in the c\bscnce of

D. )litigating Measures and Air nnd Water Quality Aspects

The treatment of construction-induced probJ.,;-:ns is mis leading. Tlie scars from access roads and borrO\, areas an

The statement is made that existing facili tie's on property ai'fected by construction will be relocated is inaccurate . For example , Rock Creek Ranch below Upper Stillwater is located in n plmmed borrow "area, and there is no place to relocate it in the area. Also, the restoration of' borrow areas has been notably unsuccessful. The · l:>orrow areas near the Starvation Dam support nothing but a good cr~p of' poisonous weeds. . Tho impression is given that planned minimum stream releases will meet the objectives of' maintaining fisheries. Although the 7-yen.r study of the streams in the Central Utah Project by the U.S. Forest­ 0 Service is mentioned, the Bureau has completely i gnored their recommendations. If' constructe d and operated as currently pl armed, the fisheries will suf'f'er extreme losses a s described enrlier. Tl10 ..,...... Bureau has continued the charade by pretending that tho lates t min­ imum flow reconunendations f.rom the Utah De partment of Fi.sh and Gurne represent desirablo measures. Those 1igures.exis t only because the Governor of Utah forced them to reduce their requests in orde r to' meet demands from the Bureau and the Water Conservancy District •

.... . Also, the conitruction of Soldi~r Creek Oom ·~th two ou ' lct tunnels ror maintining optional oxygen content and water 1; c mpc1·~ture for . •,f'ish" is a cruel joke. With only 11 cf's. mi.nin:u1n relcc1.-, cs th0rc "'ill not be enough water in the · Str.:11,bcrry Hi V(: 1· t:o . s upp91·1; the f'ish population regard1ess of' temperature or oxygen content.·

The entire section is replete with vague .c:issuranccs and unspecified promises-of noble performance an·d good res ults. In spite 01' the assurance that the StillKatrr Tunnel access road hc1s been seeded and MUlched with 0 ~omc good results," the scars arc still ·as bore and ugly es the day they were cut. 0bYiously 1 the V.'\gue promises and high degree 01 optimism by the Bureau do. not guaran1;cc any­ thing but more problems.

E. Unavoidable Adverse P.ffccts

A1though losses of 22,000 acres of curren+.1·:· productive land~: ;ire recognized along l-i"ith t>ther "minor losses ot prr.sent production", no economic value is assigned to tho5c lo~ -.; ,~s.

It is now stated on p. 218 that "ImrrnrtC'd 1,, ·,n :cr thnt would be pro­ vid.cd by the Unit would f'acilitate thi:; £1'",,1..-t. h'' of the url>v.H popu-- 1ation in central Utnh. This contradicts ll,e earlier statcmC'nt thh~ Unit water is not rel..itcd to growth. Ilic treatment L:iils to con­ sider the full cons'cquences of s uch g rmd:h in tcrm:1 of 1urther environmental dtgrndation and pollutiun, incrC'n~cd social

llasatch Front 1 and a detcriorntion in tlH". qudli 1:y of li fc ,,hich vill result from the loss 01 qu.:ili ty st r <:;,m- typc rec.re at ion anc\ the increase in dcmn.nd by the ndditi.o:'1 -,l popuL:-..tion. 1he cstim,,ted 1oss cf 165,000 man days of' s tream fi~hirj i.s certainly d s i gnif'i­ .cant impact.

V. Short-and I,on!l-Term F.nvironmcntr1l. U$~

This section glosses over the serious pr0c,:!. ··ms associated with the Bonneville Unit and attempts to justify c.011~tructinn by a series of IUldocumented assert ions about b encf'i ts. Fo r exampl<', the loss of ·stream i'is heries is minimized and . the .virtuE ;"' ,,r reservoirs arc promoted. The U.S. Fores t Service has st·H.cd th.:i.t " The State of' utah contains only 61.8 miles 01 Class I s treams anct 450.9 mile.,; of

C1ass II streams. These 5~,12. ~ miles re pre :;ent only 10 per cent of' Utah's 5,377 total miles of streams. ApproximatcJy ~,019 milc.s of f"ormer trout habitat has already been elimin,xi::ed in Utah. h'ith a ll. the present reservoirs and natural l a kes in the State, Utah i s rapidl.y becoming a state reaching the point of' imbalance of' f'lat ~.rater recreation in comparis on with the ever-diminis hing resource 0£ stream-type recreation.'-' Since the Bonneville Unit will destroy ~ large proportion of' the small amount of remaining Class II strc«ms, this is obviously a significant loss.

Another problem not dealt with is the impact on the Uinta Basin re­ sulting ~rom the transfer of its water to the Oonncvillc Oasin and the destruction of its streams., Not only will the Uinta I3a s in lose. a valuable natural resource, it will also lose the present ·.:ind future :income :from tourism generated by those si.. r c::i m.5. Als o, the los s of u-ater will preclude future growth and development in the Uinta _,._ Basin. This me.ins further migration to the Wa sat c h Front, ,, hich is already polluted and congcst·ed. ·Also, current water needs of the Uinta Basin arc in.jeopardy. The towns of' Dµchesne, Hoosevelt, and Myton are greatly in need of additional culinary water which could bo obtained :from a 14 ci's spring flowiug into Rock Creek n ear Yellowpine Flats. Hoh"'eVP.r, that water h:1s t ~cn appropriated by the Bonneville Unit.1 Als o, persons in the .Unit p:cojcct nrC'a ,d10 hnvc wells in the last few ycari have been told by the Central Utah Water Conservancy District that they cnru1ot do so wi thout their p ermis­ sion. Certainly, 'the people of the Uinta I3as in will pay a big price t:or the development of heavily-sucsictized water for irriga­ tion in the Bonneville I3asin. 1 G. Irreversible and Irretrievable Commi tmcnts of Resource's ·

This section attempts to miuimize the problems.The reservoir areas on the south slope of the Uinta Mountains arc of great vnluc and heavily used. The Upper Stillwater area is exc:eptionally scenic, receives great visitor u s e and provides a goud deal of high quality f'ishing. The s.tream losses are extremely sc:rious and would repre­ sent a permanent loss of a scarce resource v.·hich is of region.:11 and° perhaps national significance. The rel at jvely permanent in­ c~ense in salinity of the Colorado River is n ot me ntioned, although it· is of national and even interno.tion,,l s i .<; nj_fic ance. This overly brief' section attempts to minimize the losses and provide jus ti­ f:icntion f'or the projrct. H. Alternatives to the Proposed Action

. This section is the mo s t inadequate in the entire stntement. Since the careful and thorough explorntion of alternatives is the very heart of' the environmental statement, the whole attempt of thi s section !'ails miserably. , Cons iste nt with the p..1 ttern throughout this statement, this sect'ion is n blatant ,,t ... crnpt to jus i·if'y the complete ·construction and operation of the project exactly as currently planned. The enviroruncntal statement hns been viewed by the Bureau as an unnecessary and anno:,' "J '-Xa~rcisc.

The alternative o.f halting. construction ~tter completion of features currently underway has not been thorough] y ,,x;,lored. The Bureau has foiled to demonstrate the need for further deve lopme nt no have they considered altcrn,\tives to nice.: further d c m;ind s . They have also given only cursory treatment to 'the futunJ · inr.rc ascs in demnnd f:or water in the Uinta Uasin .for municipol an•l indllstrii,l gro"' t.h.

Rather than enumerating the many specific def'icicncics in this section, I shall describe the following alter11atives which have not been thoroughly discussed: 1.} No additional construction beyond that already underway. \ Th is would mean the elimination of the Currant Creek Dam and any extenson of the Strawberry Aqueduct eastward, That level of development might be combined with the Jord~elle Re s ervoir to provide municipal and industrial water to the Wasatch Front is other means prove to be infeasible.and if a real demand necessitates such a development.

2.) Ground water sources may be developed to meet future needs in the Wasatch Front. The U.S. Geological Survey and the State Division of Water Resource s hnve indicated tl1c avail­ obility of additional groundwater up to 150,000 ncrc fcot -r.. per year. That is considerably less expensive to develop :- -:.._ than the Sl,500 per acre foot developme nt cos t of' the Bon­ neville Unit •. Also, v·irtually nll of' th,e environme ntal losses would be avoided as would be· the cas e with the other a1ternatives below.

-·- ~ . ·1 .. ·- ; 1 SIERRA CLUB Uinta 'r;ha/1/i:r - :. ; ·:.~· -~ I ·, .·:.,~~- 1865 Hcgicrt Avenue f , . . .. ,.... ' .. • \.,. -.~ ••" . .-- ..... 4..~ . Salt L~so<;_ity, Ut;ih 8'1108 ,I i( :_ .:_:·.~: ·t··.-\_{t~ \_-_: . \ [. ----~-.~~:~

October 2, 1972

Mr. David L. Crandall, Regional Director U.S. Bureau of Reclamation P .0. Box 11568 Salt Lake City, Utah 84111

Dear Dave:

Enclosed arc my comments on the Draft Environmental Statement for the Bonnev1"ii:c-·~~-­ Unit of the Central Utah Project. Please include them and tl1is letter as part of the official record. Also, !_have enclosed a statement by George Alderson from the Friends of the Earth. He asked me to hand it in at the public hearing in Orem, but due to my being out of town I did not receive it until after the hearing. Please include Mr. Alderson's testimony in tl1e official hcarinR record.

J.n addition to my enclosed comments, I would like to supplement my official statement made on behalf of the Sierra Clt1b. First, I inadvertently omitted the most important alternative .to the proposed Bonneville Unit. That is the possibility of using water from the Weber Rasin Project instead of importing CUP water from the Uinta Basin. As you know, approximately 65,000 acre feet of irater are still unsubscribed in the lvcbcr Ba sin Project . It would be reJativcly inexpensive to bring that water down for nunicipal and industrial uses in the Bonneville Basin. Such a procedure would involve little _in the tmy of environmental impact, would be cheaper than provi

My other comments refer to the conduct of the hearinr. in Orem on September 22 nnd 23, 1972. ny all reasonable standards, that hen.ring 1vas outrageous and a travesty on the National Environmental Policy Act. The obvious intent was to provide an opportunity for promotion of the CUP, rather th:m to fulfill the # 0, 4 0

from me, even though they often made statements of doubtful veracity and avoided issues to which I had asked them to speak.

I hope that these comments will be helpful to you and serve the purpose of i~proving projects in wl1ich your ~gency is cnEaced. I sincerely appreciate the opportunity to work with you on these matters, and I look fonvard to continued cooperation between your office and my organization.

Sincerely yours, 4~ David C. Raskin, Ph.D. Conservation Chairman

• ,,

.. :. .. . fRIENDS 01~ . THE EARTH

62o" C STREET, S.E., W ASIIINGTON, D. C. 20003

~ ~ .. DAVJO IlROwtR, President

I' Statement of Friends of the Enrth on the Drnft Envih:nn~ r.1entnl Impnct Stn ter.1ent on the Bonneville Unit, .. Central Uto.h Project, September 22-23, 1972, Orem, \Jt~h

Friends of the Eo.rth, a national orcanizo.tion of 25,000 members, devoted to _the preservation, rostoration o.nd r o.tional use of the earth, is absolutely opposed to the construction of the Bonneville Unit of the Centrnl Utnh Project. We urge the Bureau of Reclnraation to abandon this proposnl nnd conccntrnte some productive efforts on wnter conservation measures among them, pricinc that o.ccurntely reflects the costs of the vator, and seekinc local reculntions to di5cournge excess ive waste _of municipnl water. Until such mensures nrc initiated, ve arc going to be cnught in o. vicious circle of self-fulfilling prophecy, leading to more and more wasteful demnnd for wnter, and co.using more and more destruction of Uto.b 1 s unique no.turn! qualities. Friends of the ~arth o.lso . speoifically_cndorses the vievs submitted by Dr. David C. · Rasldn, repr;senting the ·Uinta Chapter of the Sierra Club, with respect to the deficiencies of the Drnft Envi~onme ntal Impnct Statement. The Bureau hes been neither competent nor forthright in its n~nlysis of the Bonneville Unit, if this Draft Impact Statement truly represents the information that lies behind tho proposed project. Competence dictates that the environmental values to be affected be thoroughly assessed; this wns not done. Forthrightness dictates that the impact 0£ the project be accurntcly described; this too vns not done. The Draft Impact Statement is clearly nn inadequnt~·bnsis tor the co::iments of citizens nnd of other government neencies. Friends of the Earth recommends tho.t n second Drnft Impnct Statement be completed and circulated to other agencies, ~s prescribed undo:r the NEI1A procedur~e!;before ilmpilntiQ~ of the Pino.l Impact Statement is done. . - /~e.;:}~

Ger , , lderson, Legislative Director . . .Committtd to the preservation, resto.ratio,i, and rational use of tl,e ecospl,cre