Rena Brand
Moffat EIS Project Manager
US Army Corps of Engineers
9307 South Wadsworth Blvd, Littleton, CO 80128
By email: moffat.eis@usace.army.mil
Re: Moffat Collection System Project (NWO-2002-080762 DEN)
Request for Extension of Time for Public Comments on FEIS
Dear Ms. Brand,
I respectfully request an extension of time for the public to comment on the Final Environmental Impact Statement (FEIS) for the Moffat Collection System Project (Moffat Project). The current comment period is 45 days, with a deadline of June 9, 2014. We request an additional 90 days, extending the deadline to September 8, 2014. The reasons for our request are as follows.
The FEIS is extremely long: 27 documents, with over 4200 pages of text, tables and figures. (The Table of Contents alone is 60 pages long.) If a commenter wants to verify statements made in the FEIS by checking underlying references, the commenter has to search through an additional 341 documents consisting of several thousand additional pages. When requests were made for a printed copy of the FEIS, the COE’s response was that the FEIS is “too big to print.” If it is too big to print, it is too big to adequately review in only 45 days.
The FEIS is highly complex, addressing dozens of issues through detailed scientific, engineering and technical analyses. The FEIS took more than four years to complete and adds considerable new information that was not available in the DEIS. Professional experts would be greatly challenged to complete a thorough review in only 45 days. To expect everyday citizens – who lack technical expertise and volunteer their time – to review a document of this complexity in 45 days is unreasonable.
This project is highly controversial, with potential to impact hundreds of miles of rivers and millions of people, on both sides of Colorado’s Continental Divide and downstream on the Colorado River. We all have a stake in the outcome of this decision and should be provided with sufficient time to undertake a thoughtful review.
NEPA‘s primary purpose is to create a process where the public can participate in agency decision-making by reviewing and commenting on the data and analyses underlying an agency’s final determination.
Thank you for your recognizing that I, the undersigned, am a critical part of your decision-making process. I appreciate the Corps’ willingness to extend the deadline for public comments to September 9, 2014.
Sincerely,
[YOUR NAME] [YOUR TITLE]