Tell the Army Corps not to approve Denver Water's Moffat/Gross Reservoir project. (Deadline: June 9)

The 11,091-page Final Environmental Impact Statement (FEIS) for the proposed enlargement of Gross Dam/Reservoir and draining of the Fraser River in the Upper Colorado, release April 25th, is fatally flawed. Inaccurate, inadequate, and misleading analysis skews the environmental and social impacts of the project.

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.

Use the form below to make your voice be heard by submitting public comment directly to the Army Corps.

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.

Rena Brand
Moffat EIS Project Manager
US Army Corps of Engineers
9307 South Wadsworth Blvd, Littleton, CO 80128
By email: This email address is being protected from spambots. You need JavaScript enabled to view it.

Re: Moffat Collection System Project (NWO-2002-080762 DEN) FEIS and Section 404 Permit Comments.

Dear Ms. Brand,

I respectfully submit the following comments on the (Permit Application NWO-2002-080762-DEN) Final Environmental Impact Statement (DEIS) and Section 404 Permit, collectively referred to as the "Moffat" project in this document.

[OPTIONAL DETAILS ABOUT YOU]

There are fatal flaws within the Final Environmental Impact Statement; including inaccurate, inadequate, and misleading analysis that not only skew the potential project environmental and social impacts but, if allowed to happen, could cause irreversible damaging effects to our precious natural resources. Furthermore, this project if allowed to happen, will devastate the Fraser and Upper Colorado Rivers, and cause numerous harms to the fish, people, and businesses that depend on healthy rivers.

The Analysis in the Moffat FEIS Violates NEPA, the National Environmental Policy Act.

  • The FEIS failed to analyze a reasonable range of alternatives to the proposed Moffat project, and the stated purpose and need statement is unreasonably narrow and foreclosed reasonable alternatives to meet future water demand. The FEIS should fully analyze the available feasible and non-speculative alternatives to fulfill the purpose and need of this project.

The FEIS fails to take a hard look at the proposed Moffat project’s environmental impacts.

  • The "environmental baseline" in the FEIS is inflated.
  • The FEIS does not adequately analyze the proposed Moffat project’s direct impacts, indirect impacts, and cumulative impacts but, rather, hides or obfuscates the severity of these impacts under an inflated environmental baseline.
  • Impacts affecting wildlife and habitat which are either not evaluated or not properly mitigated in the FEIS include:
    • the removal and destruction of 200,000 trees,
    • the potential blasting and quarrying of Winiger Ridge and Windy Point at Gross Reservoir,
    • destruction and inundation of Elk wintering habitat specifically identified in Boulder County's master plan,
    • adverse impacts to threatened and endangered species including Whooping Crane, Piping Plover, Least Tern, Pallid Sturgeon, and Western Prairie Fringed Orchid.
    • severe impacts to aquatic life, wetlands, and stream flow in the Upper Colorado basins.
  • The FEIS downplays the impacts to stream flows essential for operation of municipal utilities, outdoor recreation, irrigation on century old farms, and the economic health of the Upper Colorado basins.

The Corps will violate Clean Water Act Section 404 if it issues a Clean Water Act Section 404 Permit for the Proposed Moffat Project.

  • Several practicable alternatives to the Moffat Project exist that would have less damaging environmental impacts.
  • The Moffat project would result in significant degradation of the aquatic ecosystem and the FEIS does not include appropriate and practicable measures to minimize potential harms.
  • The Corps must conduct additional analysis to make a reasoned decision on the Section 404 permit.

Additionally:

  • The FEIS fails to adequately address climate change impacts.
  • There are still questions regarding the FEIS Bypass Flows.

[YOUR PERSONAL COMMENTS]

Thank you for your recognizing that I, the undersigned, am a critical part of your decision-making process. I would appreciate confirmation of receipt of this letter.

Sincerely,
[YOUR NAME]
[YOUR TITLE]

Submit FEIS Comment

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