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Center for Biological Diversity Comment of Desert Rock DEIS

Posted by Steve Cone on 6:59 AM October 9, 2007.

Submitted Electronically to http://www.desertrockenergy.com; DesertrockEIS@urscorp.com; jennifer_pyne@urscorp.com

October 9, 2007

Harrilene Yazzie
NEPA Coordinator
Navajo Regional Office
Bureau of Indian Affairs
P.O. Box 1060
Gallup, New Mexico 87305

Re: Desert Rock Energy Project DEIS Comments

Dear Harrilene Yazzie:

Thank you for the opportunity to submit supplemental comments on behalf of the Center for Biological Diversity on the Bureau of Indian Affairs’ Draft Environmental Impact Statement for the Desert Rock Energy Project (“Project”). The proposed Project calls for the construction and operation of a coal-fired power plant with a capacity of generating up to 1,500 megawatts of power. Supporting facilities would include a well field that would draw 4,500 acre-feet per year (af/yr) from the Morrison Aquifer for project-related purposes and an additional 450 af/yr for local municipal use, 500 kilovolt (kV) transmission lines, new access roads, and other upgrades and ancillary facilities required for the production and transmission of electricity. The Project would be located on the Navajo Indian Reservation approximately 30 miles southwest of Farmington, New Mexico.

The Center for Biological Diversity (“Center”) is a non-profit conservation organization dedicated to the protection of native species and their habitats through science, policy, and environmental law. The Center has over 35,000 members throughout the western United States and offices in New Mexico, Arizona, California, Oregon, and Washington, DC. The Center’s Climate, Air, and Energy Program works to reduce greenhouse gas emissions to protect biological diversity, our environment, and public health.

The Desert Rock Project is an interconnected action and cumulative effect with the Navajo Gallup Water Supply project. As indicated in a July 23, 2007 email from David Campbell, U.S. Department of Interior and to Brian Millsap, U.S. Fish and Wildlife Service, the Project is an earmarked use for water from the Navajo Gallup Water Supply project. Indeed, the Project can not occur without this water. The EIS, therefore, must examine the impact of the Project in relationship to the Navajo Gallup Water Supply project and how both will impact listed species in light of the cumulative impact of climate change which is certain to reduce water levels in the San Juan River.

The EIS must also take into account the fatal flaws in the U.S. Department of Interior hydrologic determination. The determination concludes that sufficient water is available for the Navajo Gallup Water Supply project because evaporative loss has been and will continue to be lessened by the reduction in surface area caused by lower reservoir levels. However, it fails to account for the fact that lower reservoir levels are themselves a product of decreased water in the river basin. The loss of water that results in decreased evaporation more than offsets any gains by decrease evaporation. The BIA has an independent obligation to consider the flawed hydrologic underpinninings of the DOI determination.

For the reasons set forth above, the Center requests that BIA prepare a revised EIS that complies with NEPA.

Very truly yours,

Matthew Vespa
Staff Attorney
Center for Biological Diversity

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