Keep the Colorado River Alive-Don't Flatline the Fraser
- by: Colorado Trout Unlimited
- recipient: Scott Franklin, US Army Corps of Engineers
BACKGROUND
Currently, over 50% of the Fraser River and 60% of the Colorado River's flows are diverted to meet the needs of Front Range municipal water users, the vast majority of which is used to irrigate water-intensive landscaping and lawns outdoors.
While the Fraser and Colorado Rivers are on "life support," threats continue. Denver Water proposes to meet its projected 18,000 acre-feet shortfall by diverting more water from the West Slope via the Moffat tunnel, a project that has the potential to further reduce flows.
To ensure the Fraser River and the Upper Colorado maintain adequate flows that support fish, wildlife, and the recreational opportunities on which west slope economies depend, Trout Unlimited and other conservation partners are calling on the US Army Corps of Engineers to require Denver Water, as a condition of permit approval, to include the following concepts in the Moffat Project's Draft Environmental Impact Statement (DEIS):
RECOGNIZE AND MITIGATE CUMULATIVE IMPACTS
-As currently written, the DEIS fails to fully consider and recognize the cumulative impacts of the Moffat system's existing and proposed diversions and expansions that alter flow regimes throughout the Upper Colorado Basin.
-Some of the streams affected, including the Fraser River, are already showing signs of deterioration. Will the additional diversions push the stream to a point where it can no longer sustain its fisheries? The DEIS does not ask the question, much less analyze or provide contingencies for that possibility
-The DEIS should Include an analysis of the impacts that will result from diminished flushing and channel maintenance flows. If the project is to move forward, adequate base flows year-round and sustained peak flushing flows that normally result from spring runoff must be a condition of the permit.
-Commit to ongoing analysis of project impacts and use adaptive management to change course if necessary.
PURSUE MORE AGGRESSIVE CONSERVATION MEASURES
-Conservation is the cheapest, fastest, and smartest water supply strategy. Conservation should be maximized to the greatest extent possible before any other options are pursued.
-While Denver and other Front Range communities have made some significant strides in implementing indoor conservation measures, much more can be done to eliminate water waste and boost efficiency outdoors. For example, Denver Water and municipal providers could diversify rebate programs that encourage residents to voluntarily replace water-guzzling lawns with drought-tolerant landscaping.
-According to a recent Denver Water survey, customers are willing to conserve to reduce impacts on mountain regions of the state, even if that means using less.
MAKE YOUR VOICE HEARD
There is enough water to meet a wide range of future needs, from fish, wildlife and recreation, to agriculture and growing cities-- but only if we work together on collaborative, smart water solutions.
Although hearings for the Moffat Firming project have 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.
EMAIL OR MAIL YOUR COMMENTS TO:
Scott Franklin, Moffat EIS Project Manager
Corps Denver Regulatory Office
9307 S. Wadsworth Blvd.
Littleton, Co. 80128
Please also consider taking one or more of the following actions:
-Sign our online petition
-Join our "Save the Colorado--Don't Flatline the Fraser" Facebook group
-Visit our online action center http://www.cotrout.org/
-Write a personal letter to the Army Corps of Engineers
-Tell a friend (send a link to this petition!)
-Take steps to reduce your water use. For ideas, visit http://www.conservationcenter.org/
QUESTIONS?
For more information, please visit our website http://www.cotrout.org/ or contact Erica Stock at estock@tu.org
I am writing to you because I am concerned about the potential impacts of the proposed Moffat Collection System Project on water quality, fisheries, and the overall health of the Upper Colorado River Basin.
The Colorado River and its tributaries, such as the Fraser River, provide valuable habitat and recreational opportunities that are central to Colorado's economy and quality of life. The current DEIS (Draft Environmental Impact Statement), as written, fails to:
- Adequately address potential impacts to water quality on the Fraser River and throughout the Colorado River Basin;
- Include an analysis of the impacts that will result from diminished flushing and channel maintenance flows. If the project is to move forward, periodic peak flows that mimic those flows that normally result from spring runoff must be a condition of the permit;
- Fully consider and recognize the cumulative impacts of the Moffat system's existing and proposed diversions and expansions that alter flow regimes throughout the Upper Colorado Basin. For example, in assessing the impacts of the proposed project, the DEIS does not consider the impacts existing projects are already having on the streams and their resources. Some of the streams affected, including the Fraser River, are already showing signs of deterioration. Will the additional diversions push the stream to a point where it can no longer sustain its fisheries? The DEIS does not ask the question, much less analyze or provide contingencies for that possibility;
- Use data that provides an accurate baseline from which to measure real impacts rather than a projected baseline several years into the future that may not reflect real-world conditions;
- Provide adequate mitigation requirements as conditions of any approved permit;
- Ensure that Denver Water and its customers exhaust all measures to improve water conservation and efficient use of existing resources, including better integration of water deliveries throughout the area served by Denver water and an adequate program to reduce residential outdoor use.
It is the responsibility of the US Army Corps of Engineers to ensure that effective mitigation is in place to protect the habitat, wildlife and local communities that rely on the Upper Colorado Basin streams. Increasing the amount of water diverted from Colorado's already depleted streams and rivers without improving efficiency is at best a temporary fix for a serious long-term problem.
I urge you to work, in partnership with Denver Water and community stakeholders, to find a solution that will both allow the city to meet its municipal needs and ensure the continued existence of one of our most beloved rivers.
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