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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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