I'm working with the Nevada Seniors Coalition to try and avoid an big water project here in Las Vegas that could have disastrous impacts on air pollution in the Las Vegas Valleym and water pollution in Lake Mead. Seniors are especially concerned because of a Cryptosporidium out break that occurred in our drinking water back in 1994. Wastewater from Las Vegas is discharged back to the lake just six miles up stream of the drinking water intake. Now they want to build another one, at a cost of 1.7 Billion Dollars, right next to it. There are so many problems that it's hard to know where to begin. I've attached a press release and letters the Seniors Coalition sent to the Secretary of Interior Bruce Babbitt, EPA Administrator Carol Browner, and the Clark County Commission. I've also attached a summary of the report I did on the EIS for the water plant. Could you help us get the word out on this. It's hard to do it here because the water authority has such a lid on the local media. Thank you. Incidentally, I think I meet you several years ago. I did my Ph.D. dissertation at the Castle Lake Limnological Field Station. Call if you need more information. Thank you. Larry J. Paulson, Ph.D. 702-566-1466; 702-739-8786

LAS VEGAS SENIORS COMPLAIN TO CLINTON ADMINISTRATION ABOUT LACK OF ENFORCEMENT OF CLEAN AIR AND CLEAN WATER STANDARDS. THEIR HEALTH IS IN JEOPARDY.

Newsdesk:
If our situation in Las Vegas is an example of this nation's commitment to the environment, then we are in deep trouble. This EIS prepared for the 1.7 Billion Dollar Southern Nevada Water Authority project makes a mockery of the National Environmental Policy Act, the Clean Water Act, the Clean Air Act and the Endangered Species Act.

I have attached a review of the EIS that was done for us by Dr. Larry J. Paulson, a Colorado River Water Quality expert. I have allso attached copies of letters that we recently sent to Secretary of Interior Bruce Babbitt and EPA Administrator Carol Browner about problems with the EIS released on September 30, 1996.

The Bureau of Reclamation has until October 31 to take action on the EIS. We fear it will be approved and result in disastrous environmental consequences to Lake Mead and the Las Vegas Valley. Can you help us spread the word? Thank you.

NEVADA SENIORS COALITION
A Better Quality of Life for Seniors
3371 E. Astoria Dr.
Las Vegas, NV 89121 Tel/Fax (702) 737-1377
e-mail KTajMahal@wow.com

October 11, 1996

Mr. Bruce Babbitt
Secretary
Department of Interior
1849 C. Street
Washington, D.C. 20240

Re: (Las Vegas, Nevada). Final Environmental Impact Statement for the Proposed 1.7 Billion Dollar Southern Nevada Water Authority Treatment and Transmission Facility (SNWA-TTF)

Dear Secretary Babbitt:

We are writing to express serious concerns regarding the Final Environmental Impact Statement (EIS) for the proposed SNWA-TTF. We have been working on air pollution problems in the Las Vegas Valley for some time. The effects of this project on air pollution in the valley are not addressed in the EIS and only exacerbates the existing problem, rated 5th worst air quality in the United States. Our concern about water pollution also increased last spring when a local newspaper reported the 1994 Cryptosporidium outbreak here in Las Vegas was caused by contamination of our drinking water. Wastewaters from the Clark County Sanitation District, City of Las Vegas and City of Henderson are discharged into a back bay of the lake. The drinking water intake is located just 6 miles downstream in the same area of the lake.

The proposed project will increase return flows back to Lake Mead by 83,000 acre feet per year (afy) on top of about 130,000 afy now going back. Nevada gets credit for wastewater returned to the lake, thus allowing for more diversions. We sought professional review and advice from Dr. Larry J. Paulson, a local water quality expert with over 20 years experience on the Colorado River, regarding impacts of the proposed project. I have attached a copy of his comprehensive review without the attachments. The full document has been mailed to your office and delivered to the Bureau of Reclamation, Lower Colorado River Region and the Lake Mead National Recreation Area in Boulder City, Nevada. In this report, Dr. Paulson points out several serious problems with the EIS. Based on his review, we are asking you to take the following actions:

1. Insist that the Bureau of Reclamation select the, no action alternative, as the most preferred alternative and deny permits for construction of the proposed SNWA-TTF. The bureau must not consider any other action on this project until the SNWA finds more water and executes contracts with your office for an increase in Nevada's water entitlement. The bureau must then fully reevaluate the need, environmental compliance and environmental impacts associated with the project, including effects on the serious air pollution problem already existing in the Las Vegas Valley. We insist that the Record of Decision be issued on the proposed project by October 31, 1996, the end of the EIS waiting period.

2. Because of the serious water quality effects to razorback suckers, a native Colorado River fish species, the U.S. Fish and Wildlife Service must reevaluate its biological opinion regarding impacts of the proposed project, or related future projects. The razorbacks spawn in an area just 3/4 mile downstream from where wastewaters and stormwaters enter the lake.

3. The 1000 + acres of wetlands in the Las Vegas Wash, which local officials have allowed to erode away in the past 20 years to get more return flows, must be restored as part of the mitigation plan for the no action alternative to protect the endangered razorback sucker and water quality in the bay.

4. Because of serious water pollution, and the extremely heavy recreational use in this bay, the National Park Service must post areas where swimming is already prohibited to warn people of the dangers.

5. Because of the heavy pollution in this bay, it is critical that all fish species be tested for toxic content which may be detrimental to people's health.

L. Kenneth Mahal, A.I.A.
President

cc: 	Mr. Robert Johnson, Bureau of Reclamation, Lower Colorado River
	Region
	Mr. Alan O'Neill, Lake Mead National Recreation Area				
	Mr. Carlos H. Mendoza, Fish and Wildlife Service

October 11, 1996

Carol M. Browner
Administrator
U.S. Environmental Protection Agency
401 M. Street SW
Washington, D.C. 20460

Re: (Las Vegas, Nevada). Final Environmental Impact Statement for the Proposed 1.7 Billion Dollar Southern Nevada Water Authority Treatment and Transmission Facility (SNWA-TTF)

Dear Administrator Browner:

We are writing to express serious concerns regarding the Final Environmental Impact Statement (EIS) for the proposed SNWA-TTF. We have been working on air pollution problems in the Las Vegas Valley for some time. The effects of this project on air pollution in the valley are not addressed in the EIS and only exacerbates the existing problem, rated 5th worst air quality in the United States. Our concern about water pollution also increased last spring when a local newspaper reported the 1994 Cryptosporidium outbreak here in Las Vegas was caused by contamination of our drinking water. Wastewaters from the Clark County Sanitation District, City of Las Vegas and City of Henderson are discharged into a back bay of the lake. The drinking water intake is located just 6 miles downstream in the same area of the lake.

The proposed project will increase return flows back to Lake Mead by 83,000 acre feet per year (afy) on top of about 130,000 afy now going back. Nevada gets credit for wastewater returned to the lake, thus allowing for more diversions. We sought professional review and advice from Dr. Larry J. Paulson, a local water quality expert with over 20 years experience on the Colorado River, regarding impacts of the proposed project. I have attached a copy of his comprehensive review without the attachments. I have also mailed a compelete copy to your office. In this review, he points out several serious problems with the EIS. Based on Dr. Paulson's review, we are asking you to take the following actions:

1. Withhold approval of the proposed project or related future projects until Clark County can demonstrate compliance with the Clean Air Standards for the Las Vegas Valley.

2. Investigate water quality monitoring data collected for Las Vegas Wash and Lake Mead by the City of Las Vegas, Clark County and City of Henderson during the past six years to determine if water quality standards are being met and if these dischargers have been in compliance with terms of their NPDES discharge permits, including the water quality monitoring in Las Vegas Wash and Lake Mead.

3. Assess maximum fines allowable by law, for any violations of the water quality standards or terms of their NPDES discharge permits. If necessary, their discharge permits should be revoked. Any fines issued shall be used for construction of wetlands in Las Vegas Wash.

4. Deny approval of any proposed changes to water quality standards for Las Vegas Wash or Lake Mead unless those changes are more stringent than the present standards.

5. Withhold approval of permits for the proposed project, or other requests, for increases in volume of wastewater discharges to Lake Mead for the City of Las Vegas, Clark County and City of Henderson until they can demonstrate compliance with water quality standards and NPDES permits.

6. Require that restoration of over 1,000 + acres of wetlands in Las Vegas Wash be done to help meet water quality standards and further cleanse wastewater and surface drainage before it is returned to Lake Mead. This should be made a condition for renewal of the discharge permits. The dischargers should submit detailed plans and construction schedules for the restoration project. Fines must be issued if the schedule is not followed. Restoration of wetlands will protect our drinking water, recreation, sport fishing and endangered species in the lake.

7. Because of a serious conflict of interest, do not allow the Clark County Sanitation District, City of Las Vegas and City of Henderson to do their own water quality monitoring in Las Vegas Wash and Lake Mead.

L. Kenneth Mahal, A.I.A.
President

cc: 	Mr. David Farrel, U.S. Environmental Protection Agency, Region IX
	Mr. L. H. Dodgion, Nevada Division of Environmental Protection

NEVADA SENIORS COALITION
A Better Quality of Life for Seniors
3371 E. Astoria Dr.
Las Vegas, NV 89121
TEL/FAX 702-737-1377
KTajMahal@wow.com

October 13, 1996

Yvonne Atkinson Gates
Chairperson
Clark County Commission
500 South Grand Central Parkway
Las Vegas, NV 89106

Re: (Las Vegas, Nevada). Final Environmental Impact Statement for the Proposed 1.7 Billion Dollar Southern Nevada Water Authority (SNWA) Treatment and Transmission Facility (TTF) Dear Mrs. Gates:

We are writing to express serious concerns regarding the Final Environmental Impact Statement (EIS) for the proposed SNWA-TTF. We have been working on air pollution problems in the Las Vegas Valley for some time. The effects of this project on air pollution in the valley are not addressed in the EIS and only exacerbates the existing problem, rated 5th worst air quality in the United States. Our concern about water pollution also increased last spring when a local newspaper reported the 1994 Cryptosporidium outbreak here in Las Vegas was caused by contamination of our drinking water. Wastewaters from the Clark County Sanitation District, City of Las Vegas and City of Henderson are discharged into a back bay of the lake. The drinking water intake is located just 6 miles downstream in the same area of the lake.

The proposed project will increase return flows back to Lake Mead by 83,000 acre feet per year (afy) on top of about 130,000 afy now going back. Nevada gets credit for wastewater returned to the lake, thus allowing for more diversions. We sought professional review and advice from Dr. Larry J. Paulson, a local water quality expert with over 20 years experience on the Colorado River, regarding impacts of the proposed project. I have attached a copy of his comprehensive review without the attachments. The attachments are available from your staff at the SNWA.

In this report, Dr. Paulson points out several serious problems with the EIS. Based on his review, we have already asked Secretary of the Interior Bruce Babbitt and EPA Administrator Carol M. Browner to take the actions described in attached letters. I am also asking that the Clark County Commission take the following actions:

1. The 60 million gallon water tank currently being constructed as part of the Southern Nevada Water System (SNWS) expansion should be completed immediately. To eliminate the need for the 1.7 billion dollar TTF, the SNWA should add more storage tanks as needed to meet the peak water demand.

2. Immediately stop construction on the 12 foot diameter, 600 mgd tunnel through the River Mountains.

3. Require that restoration of over 1,000 + acres of wetlands in Las Vegas Wash be started immediately to help meet water quality standards and further cleanse wastewater and surface drainage before it is returned to Lake Mead. Restoration of wetlands will protect our drinking water, recreation, sport fishing and endangered species in the lake.

4. The SNWA must disclose all sources of Colorado River water and must sign water contracts with the Department of the Interior before any construction can be started on this or related projects.

5. Engineering and construction contracts for the SNWA-TTF, assuming it is approved, or any other related water projects must be put out for competitive bid.

6. Conduct a legal investigation into the activities of the SNWA related to preparation of the EIS. There are numerous examples where the SNWA has grossly misrepresented data to make conditions seem better than they actually are in the wash and the lake. This repeated pattern of misrepresentation must stop. We are suspect that there may be another agenda, and it is time that an independent investigation be conducted by an environmental attorney with no conflict of interest in Clark County. We the voters need to know the truth.

7. Cooperate with the U.S. Environmental Protection Agency should it conduct an investigation into the laboratory practices at the Clark County Sanitation District Laboratory regarding the serious analytical problems discovered during Dr. Paulson's review of the EIS.

8. Establish a committee of knowledgeable citizens, free of political pressures and alliances, to oversee the future activities of the SNWA and Clark County Sanitation District.

Sincerely
L.Kennth Mahal, A.I.A
President

cc:	Paul Christensen
	Jay Bingham
	Lorraine Hunt
	Erin Kenny
	Myrna Willams
	Bruce Woodbury

TECHNICAL REVIEW OF THE FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE SOUTHERN NEVADA WATER AUTHORITY TREATMENT AND TRANSMISSION FACILITY

Prepared for:
Mr. Ken Mahal
President
Nevada Seniors Coalition
Las Vegas, Nevada
(702) 737-1377

Prepared by:
Larry J. Paulson, Ph.D.
West Lakes
Las Vegas, Nevada
(702) 566-1466

October 9, 1996

SUMMARY OF SIGNIFICANT COMMENTS

The existing Southern Nevada Water System (SNWS), a 400 mgd facility built in 1972, is being upgraded to deliver 480 mgd with a peak capacity of 570 mgd to the Las Vegas Valley.

The 12 foot diameter, 600 mgd tunnel, or "Second Straw" as it is called by local water officials, is a key element of the SNWA-TTF. It was drilled through the River Mountains before the final EIS for the TTF was released to the public. Environmental compliance and permitting was handled as part of the SNWS upgrade, not this EIS.

The SNWA estimates withdrawal of Nevada's full entitlement will require an average capacity of 429 mgd with a peak demand estimated at 699 mgd by the year 2007. The SNWA argues it needs the TTF to meet this peak demand. One alternative that seems to have been overlooked is just adding more storage reservoirs to the existing SNWS.

The SNWA also argues it needs the TTF to back up the SNWS. BMI (Basic Management Incorporated) operates a 48 mgd system that has been used in the past to deliver water to the Las Vegas Valley.

Few communities can afford to build a 600 mgd water system to backup a 480 mgd system to draw an entitlement of only 429 mgd!

Nevada gets credit for wastewater discharges returned back to Las Vegas Bay through Las Vegas Wash. Water quality impacts are not adequately addressed and summary data are grossly misrepresented to make conditions seem better than they actually are.

Water quality monitoring in Las Vegas Wash and Lake Mead is conducted by the City of Las Vegas, Clark County and the City of Henderson, the same agencies that discharge the wastewaters.

Wastewater discharges have caused numerous violations of water quality standards in Las Vegas Wash and Las Vegas Bay with existing wastewater return flows of about 130,000 afy (acre feet per year). Return flows with operation of the proposed SNWA-TTF will add another 83,000 afy of return flows. The SNWA, citing a 1992 document, concludes this will have no significant impact on water quality in Las Vegas Wash or Lake Mead.

There are serious analytical problems with the Clark County Sanitation District's Laboratory. Negative numbers frequently are reported for chemical constituents. Ammonia in Las Vegas Bay, near the wastewater inflow, was reported to have the same concentration as distilled water for most of 1996. No data at all were presented in 1996 for chlorophyll, a measure of the amount of algae present in the water.

A serious outbreak of Cryptosporidium occurred in Las Vegas during 1994. The CDC concluded that drinking water was the source of the outbreak that killed 32 AIDS patients. The EIS does not evaluate the possible link between Cryptosporidium in the drinking water and wastewater discharges from Las Vegas Wash, just six miles upstream of the water intake. The SNWA concludes that increased return flows from the TTF will not significantly impact drinking water.

A small population of razorback suckers, an endangered fish species, occurs 3/4 mile downstream of the wastewater inflows. The Fish and Wildlife Service ruled that another 83,000 afy of discharges from operation of the proposed SNWA-TTF would not affect the razorbacks, even though they use this area for spawning.

Over 1000 acres of wetlands in Las Vegas Wash have been destroyed by erosion in the past two decades, which was neglected by local officials. Return flow credits are thought to be higher without the wetlands. Therefore, efforts to restore the wetlands never get beyond the planning phase.

No evaluation is made of the SNWA-TTF impacts on stormwater runoff, storm drain capacity or stormwater quality.

The valuable recreational resources and fishery resources in Lake Mead are ignored in the EIS. Return flows from operation of the SNWA-TTF will limit body contact recreation in more areas of Las Vegas Bay.

The EIS does not evaluate how a significant decline in lake level could affect water quality, drinking water, endangered species and recreation in Lake Mead for present and proposed wastewater return flows.

lars@vegas.infi.net