NEPA EIS/404(b) (1) Coordinator
U.S. Army Corps of Engineers, Omaha District
September 11, 2008
The Mummy Range Institute is a non-partisan research, educational, and policy institute with headquarters in Red Feather Lakes, Colorado. We have evaluated the information included in the Draft Environmental Impact Statement (DEIS) for the Northern Integrated Supply Project. Following are our comments on the DEIS.
Our study has determined that required analysis of important aspects of the preferred alternative and other alternatives listed in the DEIS is missing and/or incomplete. The Institute has concluded that in order for us to properly evaluate the preferred alternative and other alternatives the U.S. Army Corps of Engineers must create a supplement to the DEIS and give the public an opportunity to evaluate and comment on this supplement. The following are items that must, at a minimum, be included in the supplemental statement.
Population growth estimates for the areas that would be served by this project are suspect.
Growth rates used in the DEIS are higher than current regional growth rates. The DEIS assumes that simply because that rate of growth is possible, it must be desirable, and that we must therefore provide the means to make it possible. More analysis needs to be done on the effects of this level of growth on the economics, quality of life, and environment of the region as a whole.
Justification that the project will serve to preserve irrigated agriculture in northern Colorado in the face of continued urban growth is unsubstantiated.
There must be an analysis of the effects of this project on the regional agricultural economy. Specifically, we question whether agriculture will be able to compete for water considering the effect on overall water values resulting from the costs of constructing this project. Due to urban growth in Larimer County and its effect on water prices, for example, farmers can no longer compete for irrigation water on the market, and must instead rely on short term leasing of city of Fort Collins surplus water to keep all the remaining farmland irrigated. The DEIS also must address the effects on the agricultural sector of the loss of thousands of acres of farmland to the urban development which will result as the communities realize the population growth projected in the EIS.
The Draft Environmental Impact Statement does not give sufficient analysis to alternatives other than the preferred alternative.
Alternative 1, the no action alternative, must be completely evaluated. How would the effects on agriculture in Northern Colorado from building the Glade alternative compare to the effects if this project were not built? As we will mention shortly, Alternative 1 could likely be combined with other alternatives given little attention in the EIS, enabling the water needs of the NISP communities to be met with a smaller dollar cost and fewer detrimental impacts on the environment.
Other mixes of alternatives exist that havenít even been considered. The EIS only considered alternatives that would individually yield 30% of the required yield of 40,000 acre feet from the project. This ignores numerous alternatives, that when aggregated, might also provide the same yield with much smaller negative impacts and costs than other alternatives considered. An example would be a combination of area-wide increased levels of conservation in urban water use, improvements in irrigation efficiency, changes to more appropriate crops that yield more income per unit of water applied, and gravel mine storage ponds. The Mummy Range Institute believes that a supplemental draft EIS must be completed to include a wider range of alternatives that in combination could have a similar effect with fewer negative impacts than the larger recommended project.
Far-reaching, negative environmental impacts on the ecosystems which depend upon the river below the takeout point must be thoroughly analyzed.
The draft EIS doesnít consider all the effects on the riparian and aquatic environments of the Cache La Poudre River below the point where the water is extracted. Many of these effects will be gradual, occurring over a long period of time with potential detrimental effects on the very nature of the aquatic ecosystems and the species found there. Flows through the Fort Collins area could be reduced by 71% in May during years of average runoff. August flows in dry years could be reduced by 26%. Although the proposal claims that water would be taken during peak flow times, the truth is that minimum flows would also be reduced.
Reducing peak and minimum flows will have long term effects on both the aquatic ecosystems and the riparian ecosystems along the river, including wetlands. In terms of the riparian ecosystems, peak flows reduce the encroachment of unwanted vegetation and also play an important part in the regeneration and maintenance of the cottonwood tree canopy. A loss of water in the river would also lower the water table, further reducing the area covered by cottonwoods, thus encouraging invasive species such as tamarisk and Russian olive. A loss of peak flows would endanger the understory plants such as willows and non-woody plants and encourage exotics. The aquatic systems would be affected by changes in oxygen levels, water temperatures, and pollutant concentrations. In terms of floodplain wetlands, 43-44 acres of these important ecological areas would be lost.
Other environmental considerations must be addressed in the DEIS.
The Open Lands Advisory Board and the Natural Resource Department of Larimer County each stated that the Glade Reservoir alternative is not consistent with the Open Lands Master Plan. In general, a lot of work among Fort Collins government, Larimer County government, and the Nature Conservancy has recently occurred towards the goal of preserving open space and biodiversity in the Larimie Plains/Foothills region. This is a unique area that still offers the opportunity to preserve open lands and unobstructed migration routes from the plains up into the mountains along with all the biodiversity occurring where these different ecosystems meet.
The County Open Lands Master Plan has designated the mouth of the Poudre Canyon and the U.S. Highway 287 Corridor as Important Natural Resource Areas due to the presence of important cultural, biological, and scenic features. Both of these areas would be permanently and negatively impacted by the Glade Reservoir alternative but not by other alternatives. The preferred alternative 2 with Glade Reservoir and SPWCP is the only alternative considered that has identified detrimental effects on five cultural resources and two threatened species.
Local effects of climate change resulting from human causes must receive intense consideration in the draft EIS. It is very difficult to say with certainty how a particular region will be affected by global warming. There is overwhelming scientific agreement, however, that changes are already occurring and will continue in the future. These changes may include warmer winters, changing boundaries between life zones, and prolonged droughts. How might these changes effect water levels in Glade Reservoir? There is certainly no guarantee that the historic runoff levels assumed in the study will be accurate in predicting future runoff. A wide range of possible climate change alternatives and their effect on reservoir supplies must be considered.
A supplement to the EIS must consider a wider range of costs associated with the preferred alternative. These include but are not necessarily limited to the following:
- Costs of mitigating changes to the river. These would include changes in water quality, river morphology, plant and animal ecology, and recreation potential.
- Costs of dealing with the constraints presented by the geology of the Glade Reservoir site. These geological issues demand that the final EIS completely evaluate the plans and projected costs.
- Costs of the project to the Fort Collins economy. The city has invested significant resources in the Poudre corridor where the river flows through Fort Collins. The value of this river is central to the qualities that make Fort Collins one of the most attractive cities in the country.
- Costs of reduced recreational, real estate, and aesthetic values to those living along the river below the point of water extraction.
- Costs to the taxpayers of the City of Fort Collins. Pumping water from Glade Reservoir to Horsetooth Reservoir (allowed under the proposal) could degrade the water quality of Horsetooth. This would require the city of Fort Collins to make expensive upgrades in water treatment facilities. Reduced flows in the river might also require the city to upgrade its wastewater treatment facilities. These costs to citizens not benefiting from the project itself must be considered and mitigated.
- Costs of funding a revision to the LaPorte Area Plan to deal with land use and transportation impacts of the project.
- Costs of pumping water into Glade Reservoir.
These concerns would generally apply to the consideration of the other alternatives listed in the draft statement and should be applied to additional alternatives not included.
The Mummy Range Institute recommends a supplemental EIS analysis and comment period to consider aspects of the project mentioned in this response. In the absence of more information on these areas, the Institute must recommend that the no action alternative be chosen. Thank you for the opportunity to comment on the Draft Environmental Impact Statement for this project.
Board of Directors
Mummy Range Institute