More Trans-Basin Diversions on tap for the Colorado River Headwaters

The rivers of the Colorado headwaters provide some of the best trout fishing in the world. These rivers, from the Roaring Fork and the Fryingpan to the Eagle, Blue and Colorado itself, have suffered from the drought. As bad as the drought has been, the impacts from Trans-Basin diversions have been even worse. Ever increasing depletions and operational management more tailored to toilets than natural rivers have taken their toll. And this draining of the rivers may get worse.

Both the Northern Colorado Water Conservancy District (Northern) and Denver Water have plans to increase their Trans-Basin diversions. Northern is planning to expand its Windy Gap project for up to 28,000 acre feet more from the Colorado River. Denver is planning on increasing its diversions from the Fraser, through the Moffat tunnel, by as much as 18,000 acre feet.

So what does this mean for the rivers like the Colorado and Fraser, the fisheries and TU? It means less water in the rivers, which is not a good thing. Northern and Denver will likely come for even more water in the future.

Both these projects require an Environmental Impact Statement (EIS). This is when the public, TU members and others can get involved and influence the outcome. We need to let the principal regulatory agency, the Corps of Engineers, know that there are cumulative impacts which need to be considered in all of the EIS alternatives. Windy Gap and Moffat are being treated as separate projects, as if one will not have an impact with the other except immediately below Windy Gap. They are also taking this view regarding other possible projects and diversions at Williams Fork, Green Mountain, Dillon, Wolcott, Homestake, Ruedi, and others.

To say that there are no cumulative impacts as they take more here and more there, all within the same headwaters drainage is patently absurd. As Windy Gap and Moffat each take more out of the upper Colorado and Fraser, the Colorado River below Windy Gap will be out as much as a combined 46,000 acre feet. Denver also plans to take more from Williams Fork and Dillon, further shrinking the Colorado downstream.

The Corps own regulations require that the EIS consider "...cumulative effects on conservation, economics, aesthetics, environmental concerns, wetlands, historic properties, fish and wildlife, flood hazards, land use, erosion, recreation, water supply and conservation, and water quality." (33CFR § 320.4) The Council of Environmental Quality regulations for implementing NEPA, of which the EIS is a part, define a cumulative impact as "The impact on the environment which results from the incremental impact of the action when added to other past, present and reasonably foreseeable actions regardless of what agency or person undertakes such other action. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time." (40 CFR 1500).

If all these projects in the Colorado Headwaters do not create a "cumulative impact", than I don't know what does. Since 1905 the flow of the Colorado at Hot Sulphur Springs has dropped approximately 88%. This huge decrease in the flows reflects the cumulative diversions from these supposedly 'separate and un-related' projects. If you throw in lower flows from Williams Fork and the Blue, then the possibility of losing the Shoshone Call and a reservoir at Wolcott the situation could get much worse.

CTU and the Colorado Water Project have been working hard to make sure that any future diversions and operations of existing diversions don't harm the Colorado headwaters anymore. All of us in TU will need to be involved in these projects, now and when the draft EIS's come out and the real action begins.

So PLEASE WRITE A LETTER requesting that cumulative impacts with all existing and "reasonably" foreseeable projects throughout the upper Colorado and over the past 100 years, as required by regulations, be considered with all of the alternatives in both the Windy Gap Firming and Moffat Collection System draft EIS's. We will keep everyone posted as the draft EIS's come out for public comment as well. This is just the beginning.

Send letters to:

Chandler Peter Will Tully Gene Reetz
U.S. Army Corps of Engineers U.S. Bureau of Reclamation EPA Region 8
2232 Dell Range Blvd., #210 PO Box 449 999 18th Street
Cheyenne, WY 82009 Loveland, CO 80537 Denver, CO 80202

Copies can also be sent to

Dave Little Don Carlson
Denver Water Northern Colorado Water Conservancy District
1600 W. 12th Avenue 220 Water Avenue
Denver, CO 80204-3412 Berthoud, CO 80513