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.
Provided by Trout Unlimited’s Website – visit www.cotrout.org for more information and updates on this project