Help Save the Poudre River
Send Comments in to the Corps of Engineers by September 13, 2008

The Fort Collins Audubon Society has thoroughly reviewed the Draft Environmental Impact (DEIS) for the Northern Integrated Supply Project (NISP) and received input from numerous scientists regarding the document. We are convinced that building Glade Reservoir and the rest of the NISP project would be an ecological disaster for the Poudre River and seriously harm communities like Fort Collins that live along its banks. We have also concluded that the DEIS is so flawed as to be worthless as a guide for making a decision about whether or not to build NISP.

Accordingly, we encourage our members (1) to ask the Army Corps of Engineers to deny the request of the Northern Colorado Water Conservancy District (NCWCD) to build this project; and / or (2) to ask the Corps to require NCWCD to redo the EIS in a competent and honest manner.

The full DEIS can be accessed from the Save the Poudre website at www.savethepoudre.org. Don’t be daunted by its size and complexity, or feel you have to read the whole thing in order to comment! The Corps and area politicians need to hear from you about your environmental concerns. Below we note some key points gleaned in our review of the DEIS, but you should feel free to comment in your own words about why you believe we should “Save the Poudre.”

Remember: every comment counts! Send your comments by September 13 to Chandler Peter, U.S. Army Corps of Engineers at: chandler.j.peter@usace.army.mil.

Key Points

The Army Corps of Engineers should deny NCWCD permission to build NISP, because . . .

1. NISP will cause ecological degradation to the river: The Poudre already is severely degraded with 60% of its water drained out before it gets to Fort Collins. This project, if built, would drain another 40%, leaving less than 25% of the natural flow. The river, and all of the species which depend on it, would be even more severely impacted. Fish, birds, mammals, aquatic insects and even several rare plant species would all be negatively effected. The riparian corridor through Bellvue, Laporte, Fort Collins, Timnath, Windsor, and Greeley would be even more severely degraded. The river is already often dry. It is a working river, but this project, if built, will work it to its death.

2. NISP will cause severe degradation to our investment in area natural areas: Fort Collins, Larimer County, and GOCO have invested tens-of-millions of dollars in the natural areas and bike paths along the corridor all the way from Bellvue out to I-25, and soon, beyond. It makes no sense to drain the river when this investment is entirely dependent on a healthy river to provide the recreational, aesthetic, and ecological assets that the citizens of Fort Collins, Larimer County, and Colorado have invested heavily in.

3. NISP is a threat to Fort Collins' economy: The City calls the river one of its "economic engines." The downtown economy is increasingly dependent on the river's proximity as a cultural and recreational resource. The Downtown River District, Beet Street, UniverCity Connections all identify the river as a major driver in the downtown economic experience. Draining the river would permanently threaten this economy.

4. If NISP is built, the city of Fort Collins potentially faces tens of millions of dollars in upgrades to wastewater treatment facilities to meet standards in its wastewater discharge permits, because there will be less water in the river to dilute pollutants. Fort Collins also potentially faces tens of millions of dollars in upgrades to drinking water treatment facilities if NISP is built, for the same reason.

5. NISP is a debt disaster in the making: The entire NISP/Glade project is debt-funded and, if built, would thus fuel unrealistically rapid growth just to pay the debt back. Small cities with very few resources would be required to mortgage their citizens' livelihoods for 30 years. When there's a blip in the economy and housing starts plummet (like now), these cities would have to raise taxes and fees on citizens or start wildly marketing their desire for new growth. Including the interest on the capital costs, NISP/Glade is nearly a billion-dollar debt-ridden boondoggle.

6. NISP will dry up and pave over farms, harming area agriculture: If this project is built, at least 25,000 acres of farms would be paved over in order to pay the debt back. By fueling more rapid growth, farms will be paved over faster and our agricultural heritage will be lost. Draining the river, which NISP/Glade will do if built, won't provide more than a drop in the bucket of the total new water demand for the South Platte basin. Our growing cities need to first conserve all the water they can, and second, enter into mutually beneficial water-exchange agreements with farmers, rather than draining the river. Save farms, by conserving first! No more water out of the Poudre!

Environmental Impact Statements are supposed to fully and fairly assess the full environmental costs and benefits of important projects; the NISP DEIS fails to do so. The Army Corps of Engineers should require NCWCD to completely redo the NISP EIS, because . . .

1. The DEIS analysis of water quality downstream of the diversion points is incomplete. It doesn’t include the city of Fort Collins’s Drake Treatment facility in its analysis, and appears to come to cursory “no effects” or “minimal effects” conclusions in nearly every analysis without providing substantive data to back up those conclusions. Much of the river stretch downstream of the diversion points is on the state 303(d) “watch list” because of high pollution levels, yet the DEIS does not address the impact this project would have on these pollution levels.

2. The DEIS analysis of impacts on riparian forests and aquatic habit contradicts itself and its technical reports in numerous places, in some places stating that the river is no longer functioning to rebuild the cottonwood forest lining the river, and in other places saying that the dramatic reduction in peak flows would not affect the regeneration of the cottonwood forest along the river. Though it is well understood that the cottonwood and willow forest along the river is highly dependent on the water table recharge from peak flows, and the technical reports indicate the peak flow levels would drop by nearly two feet if the project were built, the DEIS concludes the cottonwood and willow riparian areas would not be affected by the project.

3. The DEIS fails to adequately consider the likely impacts on fish and bird communities along the riparian corridor. Its analysis of fish impacts relies on an outmoded model that have been criticized extensively in the conservation literature, rather than on more up-to-date models which would likely show more negative impacts of the project. It has virtually nothing to say about impacts to bird populations in the riparian corridor, one of the most important bird areas in northern Colorado.

4. The DEIS analysis of impacts to agriculture is fatally flawed. The DEIS claims throughout the document that the project is being built to protect agriculture. Yet none of the yielded water would go to agriculture. Approximately 100,000 acres of farmland would be dried up because agricultural water would be rented away from farmland in order to fill the reservoirs. In addition:

- The DEIS categorically excludes alternatives that would reduce farmland loss, such as fallowing and water sharing agreements with agriculture.

- If built, Glade would require developing at least 25,000 acres of farmland in Larimer, Weld, Morgan, and Boulder counties, in order to pay for the project. Most of this is prime irrigated land on excellent quality soils. The American Farmland Trust classifies the region as “endangered” because of its high value for farming and because of development pressures.

5. The DEIS does not address the socio-economic impacts Glade would have on Northern Larimer County, and in particular the operations of the North Poudre Irrigation Company and farmers depending on that water in the area in and around Glade Reservoir and the Highway 287 re-alignment. If built, the project would lead to the rapid development of this currently rural area, and disruption of one of the last remaining viable agricultural centers in Larimer County.

6. The DEIS does not adequately address issues of public Health. The project would likely lead to longer periods of low flows and stagnant water pooling on the river, yet the DEIS does not address how Culex mosquitos bearing West Nile virus would be affected by flow reductions. In addition, the DEIS does not adequately address pollutants like nitrates, nitrites, and ammonia currently at high levels downstream of the diversion points would be affected by the proposed action. If NISP is built, the river flows through and below Fort Collins would mostly be smelly treated sewage water. Depriving the river of clean snowmelt and mountain runoff could threaten the health of people who use the river.

7. The DEIS fails to acknowledge that economic and social harms NISP will cause to the investment made in natural areas and open space by Fort Collins, Larimer County, and the State of Colorado GOCO program. This investment runs into the tens of millions of dollars.

8. The DEIS analysis of wetlands loss estimates is fatally (and obviously) flawed. The DEIS fails to adequately census riparian-associated wetlands, particularly those in Natural Areas owned and maintained by the City of Fort Collins and in the river stretch below Fort Collins. It is incorrect to compare the habitat quality of irrigation-associated wetlands with river-associated wetlands that are maintained by peak flows from the river. It is also incorrect to assert that the “no action” alternative will dry up tens of thousands of acres of wetlands because of ongoing development pressures, since the “no action” alternative is not the cause of those pressures. At a minimum, it is dishonest to saddle the “no action” alternative with these wetland losses and then pretend that no such losses will occur under the preferred alternative, as if the forces drying up irrigated farmlands and their associated wetlands will just disappear if we build Glade Reservoir.

9. The alternatives Analysis for the project is fundamentally flawed for a number of reasons, including:

- The DEIS arbitrarily used a 30% threshold figure for the alternatives analysis. Set to a more reasonable level (10%, or even 20%), a large number of viable alternatives like agricultural fallowing agreements, water sharing agreements, irrigation efficiency improvements, and other options would be viable and NISP/Glade would not be needed.

- Water conservation and efficiency measures were categorically excluded from the alternatives analysis, when they should be fundamental to supplying water to the NISP subscribers. Water conservation and efficiency are being utilized as new sources of water supply throughout the American West and Mexico. The most basic water use efficiency and conservation measures would immediately yield at least 10% of the project’s stated demand, and a firm commitment to conservation would take them much further than that. It is imperative that conservation and efficiency be used as supply-side measures in the Alternatives Analysis.

10. The discussion of “purpose and need” for NISP is also fundamentally flawed because:

- The population growth estimates in the DEIS are inflated well above the regional growth rates in the area served by this project. The DEIS needs to evaluate the purpose and need in the context of realistic population growth projections from the state demographer’s office. Projecting water needs based on “dream scenarios” for municipal development is not a sound basis for municipal planning, nor is it a wise basis for exploiting an endangered resource like the Cache la Poudre River.

- The analysis of current water use in the subscribing communities is incomplete, and it greatly overstates the water conservation and efficiency measures adopted by the subscribers. Two years ago almost none of the NISP subscribers even had water conservation programs. Many just completed universal metering. It is preposterous to believe that the subscribing entities have already captured the “low hanging fruit” in water conservation measures, as the DEIS claims.

- The water use calculations in the DEIS are fundamentally flawed. The water used by the largest industrial users was removed from the analysis, non-potable water deliveries in the system were not completely assessed, and the projections do not include any further water conservation or efficiency reductions over the life of the project. After removing these industrial users and leaving out major non-potable water uses among the suscribers, the DEIS compares the suscribers water use against other Western communities whose water use estimates include industrial and non-potable water deliveries. The document does not make the “apples to apples” water use comparison that it claims to make.