Eagle Valley Trout Unlimited
2010 January
Take Action Now to Save the Fraser River and Colorado River Headwaters
The Moffat Tunnel has drawn west slope water across the Continental Divide since before World War II, helping supply the Denver metropolitan area – but also dramatically changing the Fraser River and Colorado River headwaters by depleting their flows and, in the case of some tributaries like Jim Creek, drying them up completely.
More than 50% of the Fraser’s flows are presently diverted to the Front Range by Denver Water, and the Moffat Firming Project seeks to divert an additional 18,000 acre-feet, leaving only 25% of the River's historic flows for fish, wildlife, and the headwaters communities.
Trout Unlimited believes that the Moffat Firming Project can be conducted in a manner that respects the needs of the Fraser and Upper Colorado Rivers - but the current proposal does not yet achieve that goal and needs to be improved any several key ways.
Colorado Trout Unlimited is concerned that without a commitment by Denver Water to mitigate potential impacts and make real efforts to conserve water along the Front Range, the Fraser River could reach a tipping point-- becoming a flatlined river that lacks the natural necessary to maintain a healthy fishery and riparian habitat.
Although the public comment period for the Moffat Firming project has ended, you can still submit written comments on the draft Environmental Impact Statement (DEIS) to the US Army Corps of Engineers until March 17, 2010.
click here to enlarge graph
The way in which the natural flows of the Fraser have been changed over time is dramatically illustrated in the graph below – showing pre-Moffat flows (darker blue), post-Moffat flows (light blue), current conditions (yellow), and ultimately, the post-Moffat firming flows (under Denver Water's “preferred alternative” - green).
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Moffat Firming Project Talking Points |
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Trout Unlimited believes that the Moffat Firming Project can be conducted in a manner that respects the needs of the Fraser and Upper Colorado Rivers - but the current proposal does not yet achieve that goal and needs to be improved any several key ways.
We urge the Army Corps of Engineers to require - and the Denver Water Board to support - improvements to the proposal that will ensure a balanced approach that addresses Front Range water needs while maintaining the water quality, fisheries, and overall river ecosystems that contribute so much to Colorado's economy and quality of life.
Major themes that we believe need to be more adequately addressed through the Environmental Impact Statement (EIS) process include:
- Conservation first, diversion second: The Moffat Firming draft EIS proposes to meet Denver’s projected 2030 water shortfall by diverting 18,000 acre-feet from the West Slope and developing another 16,000 acre-feet through conservation (an acre-foot is enough water to cover one acre to a depth of one foot - enough for at least two families of four for a year). We firmly believe that developing water through conservation first before diverting additional water from the West Slope will preserve the West Slope environment longer and give Denver an opportunity to discover how much water can be developed through conservation. While Denver is a clear leader among Colorado municipalities in indoor water conservation measures, they have done far less to address the largest use of water in Colorado’s arid environment: outdoor lawn watering. With over half of residential water use going to keep Kentucky blue grass thriving in a high plains desert, Denver has an opportunity to save large amounts of water before building any new and costly infrastructure. Much can be learned from the Southern Nevada Water Authority, which pays customers to remove blue grass and has dropped their water usage by 30%. A similar reduction in Denver’s water use would develop far more than the 34,000 acre feet. that Denver is hoping to secure by 2030.
- Periodic high flows: The draft EIS does not recognize the importance that the spring high flows mean to the river. A Fraser river without high flows in the spring can not flush the 9,000 tons of traction sand that the Colorado Department of Transportation dumps on the west side of Berthoud Pass every winter. High flows are also critical to the configuration of the stream bed which is a vital component to a healthy river. A “flat-line” river – like what the Fraser is becoming based on past and proposed diversions – will not be able to maintain its health over time. The draft EIS must acknowledge the importance of these high flows and require periodic high flows as part of the mitigation package.
- Combined effects of past and proposed projects: While Denver Water is proposing to deplete flows in the Fraser River, the Northern Water Conservancy District has plans to draw more water from the Upper Colorado River at Windy Gap. Denver Water’s draft EIS fails to acknowledge the impacts that these two projects, which are running simultaneously, will have on the Upper Colorado River. The EIS also fails to recognize the risks this project poses to the Fraser and Colorado Rivers in light of the extensive diversions that already exist. A diversion of 18,000 acre-feet of water from the native flows of the Fraser River might pose little risk – but coming after decades of development that are already diverting more than half of the Fraser’s flows, there is far more risk that the accumulated impacts will overwhelm the fishery and overall river health. The Colorado faces a similar problem from the combination of Denver and the Northern Districts’s past and proposed projects: if both Moffat and Windy Gap Firming move forward, only 26% of the native flows will remain in the Upper Colorado River. The draft EIS must include the impacts and mitigation to address the effects of reducing what was once called the “Mighty Upper” to a trickle of its former self.
- Mitigation requirements, not enhancement promises: In the draft EIS under mitigation, Denver Water refers to additional environmental enhancement opportunities separate from but parallel to the EIS. Since the mitigation measures mentioned in the EIS are so minimal, it appears that these enhancement measures are the only meaningful mitigation that are being proposed. Unless these enhancement measures are tied into the EIS – and required under any permits that are issued for the project – there will be no meaningful mitigation. The Draft EIS admits to some impacts to the Fraser River and must include adequate mitigation, including incorporating the enhancement points that Denver Water is offering as mitigation requirements in the EIS.
- Impacts to Grand Lake: The draft EIS fails to mention that the dewatered Fraser River will be pumped by the Northern Water Conservancy District through the Colorado Big Thompson Project and through Grand Lake. The additional depletions from the Fraser River will come in May, June and July. These are the same months that the Windy Gap Reservoir is pumping into the CBT project. These are also the months when the six wastewater treatment plants on the Fraser River are experiencing high discharge due to infiltration, when agricultural lands are flushing a years worth of nutrients from cattle into the river, and when the highest influx of phosphorus carrying sediment is hitting the river. By depleting the flows in the Fraser River the concentration of these nutrients will increase and be pumped directly into the Three Lakes Region. Grand Lake is already experiencing high algae counts and diminishing water clarity. The draft EIS must acknowledge the impact that increasing the nutrient concentrations will have on the State’s largest natural lake and Grand County’s crown jewel.
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Upper Colorado River an ‘Ecosystem on the Brink,’ says TU
Conservation Coalition Calls for Mitigation Measures in Moffat Tunnel DEIS
( Denver ) – Trout Unlimited, the Colorado Environmental Coalition and a broad group of conservation organizations warned today that a proposal to divert more water from a tributary of the upper Colorado River poses a serious risk to the ecological health of the river system.
“Multiple water diversions have pushed the Fraser River to the brink of collapse,” said Kirk Klancke, President of the Colorado Headwaters Chapter of TU, based in Grand County . “This is a river on life support.”
At present, Denver Water’s Moffat Tunnel and other diversions take about 60 percent of the Fraser’s stream flow. The Moffat pipeline carries most of it under the Continental Divide to supply water for the Denver metro area. Under a proposed expansion of the Moffat tunnel pipeline, Denver would take even more of the river’s native flows.
In 2005, the Fraser was listed as one of the most endangered rivers in America by American Rivers, a national conservation group.
The statement from TU and the Colorado Environmental Coalition came in response to the Friday release of the draft environmental impact statement for the Moffat Tunnel proposal—the first step in a public review of the project by the Army Corps of Engineers.
“We are looking forward to digging deeper into the DEIS, and are hopeful that we can have a substantive conversation with Denver Water in the coming months about how we can ensure our resources are protected,” said Becky Long of Colorado Environmental Coalition.
Looking ahead, the conservation groups identified several broad environmental goals that should be included in the project’s mitigation plan, including:
--Adequate baseline flows in the Fraser throughout the year to sustain fisheries and recreation.
--Sustained peak flows at key times of the year to mimic a natural flow regime and ensure the health and resilience of the river ecosystem.
--Aggressive urban water conservation and efficiency measures to save more water, such as incentives for homeowners to replace Kentucky bluegrass with drought-tolerant landscaping. More than half of residential water use goes to watering lawns.
--Ongoing monitoring of the river’s health and a mitigation plan with the flexibility to adapt to changing conditions.
“We have already met with Denver Water’s staff, and they seem open to discussing some of these concepts,” said Mely Whiting, Legal Counsel for TU’s Colorado Water Project. “We hope the Denver Water Board seizes this opportunity to create a legacy, where water development and environmental protections can go hand in hand.”
“ Front Range residents must recognize the connection between our water use and the health of our rivers and streams, fisheries and wildlife habitat,” said David Nickum, executive director of Colorado Trout Unlimited. “We can’t continue to take and take from these rivers without accounting for our impacts. The glass is not even half full—it’s almost drained dry.”
Trout Unlimited is Trout Unlimited is the nation’s largest coldwater conservation organization, with 140,000 members dedicated to conserving, protecting, and restoring North America ’s trout and salmon fisheries and their watersheds.
