Moffat Collection System Part 2: The Conservationists Perspective

In my last post, I dissected Denver Water’s mitigation plan for the proposed Moffat Collection System expansion.  In this post, I will present a critique of the plan based on the views of Trout Unlimited (TU) and other conservationists who feel the plan is insufficient to effectively mitigate the future harm the project will cause.  Last week, I sat down with Randy Scholfield, Communications Director for TU’s Western Water Project, who has been keeping a close eye on the project and involved in much of the conversation around it.

Randy Scholfield, Communications Director for Trout Unlimited’s Western Water Project. Source: Colorado Trout Unlimited

“The current mitigation plan only addresses previous damage to habitats in the upper Colorado system, and it doesn’t address future impacts of the project,” said Scholfield.  Scholfield is referring to the impact of the existing diversions by Denver Water and Northern Colorado Water Conservancy District (NCWCD), which amount to around 60 percent of native flows of the upper Colorado River basin. NCWCD’s proposed Windy Gap Firming Project, combined with Denver Water’s Moffat expansion project, will draw an additional 15 percent of native flows from the upper Colorado basin, according to a TU press release.

“While the mitigation package the [Colorado Wildlife] Commission approved [June 9, 2011] is an improvement over the plans Denver and Northern offered originally, it is not enough to protect the rivers and streams of the upper Colorado River basin from the impacts of the new projects,” said Drew Peternell, Director of TU’s Colorado Water Project.  Indeed, most of the actions outlined in Denver Water’s Mitigation Plan and Enhancement Plan appear to address problems that are already occurring, namely high water temperatures, low flows, and damaged habitat.

According to an October 26, 2012 letter from seven conservation groups, including Western Resource Advocates, Colorado Environmental Coalition, and American Rivers, parts of the Fraser and Upper Colorado system already suffer from high temperatures and sedimentation issues.  “Already sections of Ranch Creek, the Fraser River, and the Upper Colorado exceed water quality standards for temperature and are listed on the Colorado 303(d) list of impaired waters.” Citing “obvious” and “significant” sedimentation issues, the letter calls for mandatory flushing flows or mitigation measures, such as channel reconfiguration to support sediment transport at lower flows.

Trout Unlimited supports these requests.  TU, along with Western Resource Advocates, and the Colorado Environmental Coalition, outlined seven “smart principles” to guide water supply management and development efforts.  In the spirit of these principles, TU is asking Denver Water and NCWCD to take the following measures:

A Colorado River headwaters stream just below the Denver Water diversion point. Source: Summit County Voice

  • Reconnecting the Colorado River by creating a “bypass” around Windy GapReservoir
  • A halt to diversions when water temperatures are on the verge of state “impaired” standards – water warm enough to kill trout.
  • Adequate spring flushing flows to keep the rivers healthy and sustain riparian areas that are critical to wildlife.
  • An ongoing adaptive management plan to monitor stream conditions andidentify needed habitat restoration projects.
  • An endowment fund to pay for those restoration projects as an “insurance policy” for river health.

“Basically they’re turning a river into a creek,” said Scholfield. “They need to commit more money to habitat, as the current plan doesn’t address future impacts.  Taking these steps will keep the river off of life support.”  TU estimates that these additional measures could cost “several millions dollars,” according to Scholfield.  At the onset of this project, TU made the decision to cooperate with Denver Water in an effort to ensure proper mitigation, instead of fighting to kill the project entirely.

This spirit of cooperation between the utilities, conservationists, and western slope communities was outlined in the Colorado River Cooperative Agreement.  However, “at this point, Denver Water is firmly resisting further concessions,” said Scholfield.  The conservation community echoes this sentiment in its letter to the Corps of Engineers:

Any suggestion that the Cooperative Agreement has somehow reduced or eliminated concerns about the Moffat Collection System Expansion Project or the need to rigorously evaluate its impacts and design mitigation is simply wrong. Our constituencies are not satisfied with Moffat Collection System Expansion Project moving forward without significant further environmental disclosure and mitigation requirements.”

The letter comes in response to a June 5 letter from Colorado Governor John Hickenlooper to President Obama, urging an “expeditious conclusion” to the federal permitting process for the Moffat project.  In his letter, Gov. Hickenlooper cites the Colorado River Cooperative Agreement, which was formed in May 2012, as an approval by the conservation community.

“Governor Hickenlooper’s letter has not been a help to our cause,” Scholfield said.  “He essentially told the President that everyone is happy, we need to fast track this project.”  When in fact, there is clearly staunch opposition to both projects, at least until additional commitments to mitigation.  “Trout Unlimited is trying to raise public visibility to issues like this…people care…this is where we play and where we live…this is what makes Colorado Colorado.”

Governor Hickenlooper called for approval of Denver Water’s Environmental Impact Statement by the end of the year, followed by a Record of Decision early next year.  Whether the project is approved in its current state remains to be seen, yet the effects of Front Range diversions on the Fraser River are already too evident.  Speaking on behalf of Defend the Colorado, fishing guide Terry Peterson describes the visible effects he has seen on the Fraser in the video below.

Click on the picture of Terry to see him describe adverse effects on the Fraser. Source: Defend the Colorado

In a future post, I will examine how TU scientists are working to make river systems more resilient to higher temperatures, whether caused by increased diversions to the Front Range, or climate change.


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