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  TEG - The Environmental Group - Actively Dealing with current and future environmental issues that affect our community.

                     Hello TEG Friends and Supporters!

The Federal Energy Regulatory Commission must approve an application from Denver Water to increase the size of Gross Dam. Public Comments are being accepted until April 3rd.  TEG will be submitting a lengthy document outlining why this application should be denied.  We need individuals to submit comments as well.  The proces for submitting comments is below, along with a summary of our comments for your reference.  

To submit your comments by April 3rd follow this process:

Here are some summary comments from our document for you to use in preparing your input:

The Federal Energy Regulatory Commission (FERC) is tasked with considering environmental effects of proposed hydropower facilities.  Denver Water (DW) is applying to FERC for a license amendment on Gross Reservoir because the project has major effects on the environment around Gross Reservoir and on the Western Slope water drainages. We ask that the license amendment application be denied on failure to demonstrate sufficient purpose and need for the project and because impacts to the natural environment are contrary to the goals of land management established by FERC.

Insufficient need for the project / Inadequate analysis of alternatives

  • DW Assertion: Total water supply will equal demand in 2022.
    • No numeric data are given to support this. The purpose and need for the Moffat Project based on projections of water supply and demand cannot be validated. The demand model used is faulty.
    • Per DWs own 2015 Comprehensive Annual Financial Report, treated water consumption is decreasing as population is increasing.
    • All calculations of demand are based on unrestricted use of water during a drought which is not realistic.
  • DW Assertion: Gross Reservoir must be expanded to address an imbalance between the north / south system.
    • The entire supply system is immense, has built in flexibility and is reliable as has been demonstrated during the drought of 2002-2004.
    • Reservoir capacity does not tell the entire story. The critical pinch point is the capacity of the Moffat Treatment Plant. Additional storage in Gross Reservoir does not change that capacity.
  • The alternative analysis required by NEPA and the Clean Water Act is highly flawed.
    • Criteria used by the Army Corps of Engineers to identify acceptable alternatives for study was too narrow (selection must deliver water to the Moffat Collection System) and hence the Least Environmentally Damaging Practicable Alternative was not appropriately evaluated.
      • Consequences of not increasing supply to the Moffat Treatment Plant are speculative. No quantitative analyses are provided.
      • Problem to be solved is not lack of stored water – it is lack of a conveyance system. The solution to getting water north is not by compensating with a bigger reservoir, but by building conveyance systems that bring raw water directly to Moffat Treatment Plant.
    • Alternatives were eliminated based on faulty cost estimates and biased the analysis in favor of the selected preferred alternative.
      • The EIS estimates a total cost of $139.9 million while the FERC application estimates $364.1 million. The higher figure can be corroborated so the alternatives were evaluated based on faulty data.
      • Recent upgrades to Moffat plant enable it to handle agricultural / reusable water. All cost estimates that included the costs to build an advanced water treatment plant are now inaccurate as upgrades are no longer needed.

 Impacts to the environment

  • Tree removal: Destruction of over 200,000 trees is obviously environmentally damaging and the method of cutting and disposal of the trees is not clear.  If burned on site, the air pollution will be significant.  If hauled out, the steepness of the terrain and the lack of accessibility to the areas is only via steep, curvy dirt roads so safety is a prime concern.
  • Quarry: Destruction of land for the in-site quarry cannot be mitigated.  The sound and dust pollution from operation of the quarry will have significant impacts on residents and wildlife alike.
  • Loss of habitat: 465 acres of inundated land affect the human residents and will eradicate critical habitat for the deer, elk, moose, coyote, bobcat, mountain lion and innumerable bird species that inhabit the area.  
  • Road safety: Concern for public safety is a FERC mandate. Impacts to residential traffic along Highway 72 will be significant.  DW has not addressed the traffic hazards in any meaningful manner.  Even if one ignores the impact of up to 50 truck trips a day in terms of noise and slowing of traffic, the hazards to drivers, pedestrians, motorcyclists and bicyclists is extreme.
  • Lack of water: There is simply not enough water available from involved Western Slope drainages to fill an expanded reservoir most years. Residents and recreationalists will see a barren shoreline with the reservoir less than half full at least half the time. The effects of climate change on the water supply available from the Western Slopes is not even considered.
  • Recreation: Visitor numbers to Gross Reservoir are significant. The disruption of recreation activities due to construction, years of blasting, tree removal, and traffic interruptions will be huge.  The loss of scenic areas, the drowning of Forsythe Falls, and closures to boating, fishing, hiking, picnicking and other visitor activities have not been addressed. A public review of DWs yet-to-be written plan for how they will address the impact on recreation should be conducted before the project is finalized and the FERC license amended. 
  • Seismology: Earthquake potential due to increased pressure caused by a larger reservoir has not be analyzed.  DW states that these studies will be conducted during the design and construction phase of the project.  This research needs to be done prior to the issuance of permits so that the approving agencies can base their decisions on a complete picture.
  • Western Slopes: Acres of wetlands on the Western Slope will suffer, streams will run dry and ultimately the Colorado River, already the most endangered river in the United States, will be effected.

In summary, there is strong evidence that the preferred alternative, the Moffat Collection System Project, is not the least environmentally damaging practicable alternative as required by the Clean Water Act.  It is also clear that the alternatives analysis required by NEPA was faulty. The failure of DW to demonstrate need, their lack of using accurate data to analyze alternatives, and their neglect in considering less environmentally damaging solutions should result in a denial of their application to FERC for a license amendment.  

You can also make a tax deductible contribution to help us in the fight for our neighborhoods and against a wasteful water project...


                       Please click here to donate now!

                       Or you can make out a check out to BCRLDF 

and send it to:

TEG-BCRLDF, PO Box 7014, Golden, CO, 80403



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Tell the Army Corps not to approve Denver Water's Moffat/Gross Reservoir project

Tell the Army Corps not to approve Denver Water's Moffat/Gross Reservoir project.

Use the easy "1-Click" form on our website to make your voice be heard by submitting public comment directly to the Army Corps.

The project would cause irreversible damaging effects to our precious natural resources as well as devastate the Fraser and Upper Colorado Rivers, and cause numerous harms to the fish, people, and businesses that depend on healthy rivers.

Go directly to the "1-Click" comment letter submission form and make your voice heard!

Or email your own comment to the Army Corps at: This email address is being protected from spambots. You need JavaScript enabled to view it.

Denver Water’s Moffat Project FEIS Released -- a Lose-Lose Boondoggle

Denver, CO –  Today the U.S. Army Corps of Engineers made available online the much-awaited Final Environmental Impact Statement (FEIS) for Denver Water’s Moffat Collection System Project (Moffat Project).  The FEIS is available here.  The Moffat Project proposes to drain even more water from the headwaters of the already endangered Colorado River, including the Fraser River, and pump that water through a tunnel under the Continental Divide from Grand County to the Denver area.  The siphoned flows would flood unique natural areas of rural Boulder County in a greatly enlarged Gross Dam and Reservoir before being piped to the sprawling lawns and suburbs in Denver Water’s service area

The FEIS may be the public’s best opportunity to understand the costs and impacts of this massive scheme and to make their voices heard. The $360-million, 18,000-acre-foot project has so-far faced a headwind of controversy through the multi-year permitting process and is likely to be contested for years into the future.

Statements from opponents of the project:

"Denver Water proposes to spend an extraordinary amount of money to further drain the Colorado River and destroy the quality of life in rural Boulder County, all to slake the thirst of Kentucky Bluegrass in our semi-arid climate.  Instead of raising water rates to perpetuate this unsustainable behavior, let’s ditch the Moffat Project and focus on a real and collaborative solution: conservation.” – Chris Garre, Director of The Environmental Group of Boulder County and a resident near Gross Dam 

“Denver Water's Moffat Project is a gross disappointment -- it's bad for the river, bad for West Slope ranchers and farmers, and bad for Grand County.  Our headwater rivers and streams are already severely depleted and will not survive more strangling by Denver Water.  This project should be stopped in its tracks."  -- Geoff Elliott, Grand County scientist and resident

"The Moffat expansion is far from a done deal.  This project should not be approved unless the long-term health of the river is assured and our nation's environmental standards are met.  We and our partners are committed to keeping the Colorado River flowing." – McCrystie Adams, Senior Attorney, Earthjustice office in Denver

 

“The Colorado River is endangered from the source to the sea – its flows are depleted or drained, its habitat is suffering, its endangered fish are on the brink of survival – this river has already given more than it can.  The extremely controversial Moffat Project will face intense scrutiny and analysis in the coming months and years.”  -- Gary Wockner, Coordinator for the Save The Colorado River Campaign.

 
The Army Corps of Engineers is expected to open an official public comment period starting Friday, April 25, 2014A full scientific review of the project by opponents is forthcoming.

Feb 11: Eighteen Groups Give Hickenlooper Input on State Water Plan

Eighteen Conservation Groups Give Gov. Hickenlooper Input on State Water Plan
1. Focus on Healthy Alternatives, 2. No New Diversions from Colorado’s Rivers, 3. Prioritize River Restoration

Denver, CO — Today, eighteen Colorado conservation and citizen groups sent a letter to Governor John Hickenlooper with recommendations for the Colorado Water Plan.  The local, regional, and statewide groups pointed out that the Governor’s Executive Order creating the Water Plan called for "Healthy Watersheds, Rivers and Streams, and Wildlife," and asked the Governor to prioritize these values in the Plan.

"Most of Colorado’s rivers are extremely imperiled, diverted, and diminished — some are at times drained completely dry," said Gary Wockner of the Save The Colorado River Campaign.  "As the Governor’s Executive Order stated, the Plan needs to focus on 'a strong environment that includes healthy watersheds, rivers and streams, and wildlife.'"

The letter is posted here; a video version of the letter is posted here.

Read more: Feb 11: Eighteen Groups Give Hickenlooper Input...

August 5-9: Denver Water to Perform a Truck Hauling Test

Denver Water has announced, via a letter mailed to residents in the areas surrounding Gross Reservoir, that they will be "conducting tests on current ambient noise levels, noise caused by the truck traffic and transportation safety issues that might be created by construction truck traffic."

The testing will occur one morning (8:30am-noon) during the week of August 5th and will be observed and filmed via helicopter and cameras mounted on the trucks.

A pdf version of the mailed letter is available for viewing/download here.

A facebook event page has been set up to facilitate public community discussion here.

EIS Delayed Another Year

Denver Water's Destructive Moffat Project Delayed Another Year

Denver, CO -- Today the U.S. Army Corps of Engineers announced that it was delaying the release of the Moffat Collection System Project for another year.  Previously, the Final Environmental Impact Statement (FEIS) was scheduled to be released at the beginning of 2013 -- it has now been delayed until February of 2014.

Read more: EIS Delayed Another Year

SUCCESS! Draft IGA Denied!

The InterGovernmental Agreement (IGA) offered to the Boulder County Commissioners that would have signed away the County's 1041 Authority has been denied (for now)!

A powerful turnout Monday night (January 7th) was able to change the course of history.  It was the second part of a two-part public hearing where the Boulder County Commissioners took public comment regarding on an InterGovernmental Agreement (IGA) with the Denver Board of Water Commissioners for the Moffat Collection System Project (Expansion of Gross Dam Reservoir).

Read more: SUCCESS! Draft IGA Denied!

Boulder County Drains Denver Water's Moffat Project

January 8, 2013

Boulder, CO -- On Monday, January 7, 2013, the Boulder County commissioners unanimously rejected a proposed agreement with Denver Water to support the "Moffat Collection System Project."  The project proposes to drain 18,000 acre feet of water out of the Fraser and Upper Colorado Rivers, pipe that water through Moffat Tunnel at the continental divide and down into a proposed massively expanded Gross Dam and Reservoir along South Boulder Creek in the mountains southwest of Boulder. Over 200 people attended the public hearing for the project, with dozens eloquently speaking in opposition offering a plethora of facts and arguments that swayed the Commissioners' position on the project.

Read more: Boulder County Drains Denver Water's Moffat...

Boulder County rejects Moffat Firming Project deal

A great article was published in SkyHi News on Saturday, January 12th reporting on Monday night's Boulder County Commissioners' decision not to sign Denver Water's IGA.

Read the article here - http://www.skyhidailynews.com/article/20130112/NEWS/130119990/

Press Release: January 7th Public Hearing

Public Hearing on Monday, January 7th, 5pm regarding proposed expansion of Gross Dam Reservoir

On Monday, January 7th, 5pm on the 3rd floor of the Downtown Boulder Courthouse at 1325 Pearl Street, the Boulder County Commissioners will hold a public hearing to take comment on a draft Intergovernmental Agreement (IGA) with the Denver Board of Water Commissioners for the Moffat Collection System Project (Expansion of Gross Dam Reservoir).

This Intergovernmental Agreement (IGA) is a document drafted by Denver Water and County Staff that would override Boulder County’s well-established Land Use Code Article 8, better known as their 1041 powers. The citizens of Boulder County have long hoped that the County would exert its 1041 powers to the maximum to stop the project entirely – a point they made clear at a Public Hearing on the matter in September, 2011.

Last month, when Boulder County announced it would hold this public on December 20th, just 4 days before Christmas, citizens responded by submitting over 120 letters requesting the meeting be postponed until after the holidays. Due to this pressure, the Commissioners scheduled two dates for the hearing – December 20th and January 7th – with public comment to be taken at both. On December 20th, seventy-five citizens showed up and, unanimously, urged the Commissioners not to sign the draft IGA. (The entire December 20th hearing can be viewed here: http://www.youtube.com/watch?v=V_8ouIJ1sF8 )

Denver Water’s attempt to coerce Boulder County to abandon proper mitigation of the proposed expansion of Gross Dam Reservoir is the final check-mate in a game Denver Water has played over the past 9 years with the numerous counties of Colorado who would be affected by the expansion. The majority of those counties signed into the Colorado River Cooperative Agreement – each one accepting the expansion project in exchange for money (in the millions) and promises from Denver Water.

This Monday, January 7th, 5pm at the Boulder Courthouse at 1325 Pearl Street, the Boulder County Commissioners will take comment from citizens. Everyone is encouraged to attend and speak their mind for up to 3 minutes, or donate their 3 minutes to one of several organizations that have prepared extensive comment.

A copy of the draft IGA can be found online at TEGColorado.org

12/20/12 - KGNU Reporting on Gross Dam Expansion

12/20/12 - KGNU, Morning Magazine - Reporting on Gross Dam Expansion (7 min)

Click the wording above to play the audio, or download via this link.

Press Release: December 20th Public Hearing

Denver Water Tries to Coerce Boulder County

This Thursday, December 20th, 4pm on the 3rd floor of the Downtown Boulder Courthouse at 1325 Pearl Street, the Boulder County Commissioners will hold a public hearing to take comment on a draft Intergovernmental Agreement (IGA) with the Denver Board of Water Commissioners for the Moffat Collection System Project (Expansion of Gross Dam Reservoir).

This Intergovernmental Agreement (IGA) is a document drafted by Denver Water and County Staff that would override Boulder County’s well-established Land Use Code Article 8, better known as their 1041 powers. The citizens of Boulder County have long hoped that the County would exert its 1041 powers to the maximum to stop the project entirely – a point they made clear at a Public Hearing on the matter in September, 2011.

Since the 2011 hearing, Denver Water has gone back and forth only a few times with the county negotiating this draft IGA. Now, suddenly, during the holiday season, Denver Water has strategically forced Boulder County to either accept an incomplete IGA or run the risk of acquiescing to the project with no mitigation whatsoever.

Denver Water’s attempt to coerce Boulder County to abandon proper mitigation of the proposed expansion of Gross Dam Reservoir is the final check-mate in a game Denver Water has played over the past 9 years with the numerous counties of Colorado who would be affected by the expansion. The majority of those counties signed into the Colorado River Cooperative Agreement – each one accepting the expansion project in exchange for money (in the millions) and promises from Denver Water.

The proposed expansion of Gross Dam Reservoir is made all the more contentious an issue by the hugely inflated price that oil & gas drilling companies are paying for water (now as high as $5,000 per acre-foot, which a farmer would normally pay $30 for). Expanding Gross Reservoir would provide Denver Water a surplus of 18,000 acre-feet of water for, at least, nine years. In other words, the windfall profits from selling Gross Reservoir’s water for fracking would more than pay for construction of the project – before the Reservoir was ever even put to use for its intended purpose of serving residents with clean drinking water.

This Thursday, December 20th, 4pm at the Boulder Courthouse at 1325 Pearl Street, the Boulder County Commissioners will take comment from citizens. Everyone is encouraged to attend and, if possible, speak their mind for up to 3 minutes. Denver Water will be present at the hearing.

A copy of the draft IGA can be found online at TEGColorado.org

August 8 - American Rivers speaking at CCCIA regarding proposed Gross Dam expansion

AmericanRiversCCCIAWEDNESDAY, AUGUST 8TH
6:00-7:30pm at Coal Creek Canyon Community Center (CCCIA), 31528 Highway 72, 80403

This is the new date for this event which was previously cancelled due to the fire.

In the spirit of learning more about what options the community may have to delay or stop the expansion of Gross Reservoir come hear from American Rivers Conservation Director, Matt Rice.

The meeting, organized by TEG (The Environmental Group, TEGColorado.org) is for community members to learn more about the FERC (Federal Energy Regulatory Commission) permitting processes and how it relates to the potential expansion of Gross Reservoir. American Rivers (http://www.americanrivers.org/ ) has expertise on FERC permitting processes and often testifies (for or against) particular projects. There may be appropriate interventions that could be applied to delay Gross Dam expansion (when the time comes). The meeting with American Rivers will explore options.

The meeting is free and open to the public.