I sent in a comment on the draft EIS. My comment letter is below. I asked for more data on flow impacts on the Big T and the St. Vrain.
Also, in general the NEPA process is supposed to quatify impacts of a proposal and to propose mitigation to minimze impacts. The draft EIS does a good job identifying negative impacts of loss of boating days on Gore, and potentially NSV. What the draft did not do is propose any mitigation to minimize this impact.
The answer to me is simple: provide scheduled recreational in stream releases at optimal kayaking flows. It has been said many a time that colorado water laws are too complex etc for this to happen. I whole heartedly disagree. I think that there is an opportunity here to voice our collective concern that projects that reduce the number of kayaking days on a river should in some way find a way to compensate for it.
In my comment letter, I have proposed scheduled recreational releases for Gore Canyon, NSV below Ralph Price Res, and on the Big Thompson. I would hope that AW will get involved in this and I have sent similar info to AW. I know most folks won't take the time to read the draft much less write a comment, but a comment might be what it takes to get the ball rolling to getting some recreational releases in colorado, and it certainly can't hurt.
As a vision of the future imagine a reliable scheduled release on the Big T, NSV, Bailey, Gore, Black Canyon, Big South, Boulder Creek, with each one being on a different weekend in August and September. Dreaming... yes, but why not ask for it. You never know, you might just get it. Why not think big?
Mr. Will Tully
My name is Ian Foley. I would like to provide some comments on the draft EIS for the Windy Gap Firming Project. I am an engineer living in Denver, Colorado, and I am an avid whitewater kayaker. I understand the complex water needs of Colorado's communities, and I feel that water and energy needs can be supplied in a way that minimizes impact while also taking into account community and recreational issues.
-The "no action" alternative notes that Ralph Price Reservoir will be increased in size. I did not fully understand how the North St. Vrain and Ralph Price are connected to the Windy Gap issues. Perhaps it is simply that Windy Gap shortfalls need to be filled by either the firming project or by storing more water from the North St. Vrain. This should be clarified. The no action statement of impact notes that kayaking opportunities will be decreased below Ralph Price Reservoir, but there is no data on what stream flow impacts will be in cfs numbers. I am interested in what the cfs impact will be over the course of a season. The North St. Vrain below Ralph Price Reservoir has some excellent stretches of water for kayaking, yet flows are very low as is with the current reservoir. I am concerned that boatable flows will be completely lost below Ralph Price Reservoir if it is enlarged. Also this would impact the flows of the St. Vrain river though Lyons which has a whitewater park that is a tourist draw and a recreational opportunity as well. Although not considered in the EIS, setting up scheduled recreational releases of water that provide optimal kayaking flows would be a good form of mitigation for the reduction in flow that these projects have produced.
-The proposed action notes a potential small increase in Big Thompson in stream flows, but does not quantify the numbers in cfs or # of kayaking days. I would be interested in this data as well and it should be clarified. As an overall comment, the Colorado-Big Thompson project has delivered much needed water and power to the Front Range, but unfortunately it has all but dried up the Big Thompson, which is an excellent kayak run through one of the Front Range's more impressive canyons. The impact of the CBT project has been to reduce the number of kayaking days on this wonderful stretch from what would likely be 60 days per year without any dams, reservoirs or flow changes, down to usually less that 5. As the project is being reviewed, I suggest that recreational flow releases of optimal kayaking flows be scheduled in the Big Thompson river to mitigate the loss of recreation that this project has incurred. Water can be conveyed down the river corridor and can still be stored in downstream facilities. What would be lost is the power generated during that time. This type of arrangement has been negotiated on several stretches of river across the nation, and should be considered on the Big Thompson.
-There appears to be a loss of optimal kayaking and rafting flows on the Colorado River through Big Gore Canyon as well. I suggest that this stretch should also have scheduled recreational releases to mitigate the loss of kayaking that the project incurs.
In short, I understand that water must be stored and transported to supply the large metropolitan areas with water and energy, and to also satisfy the needs of water rights holders across the state and the west. I also understand that one of the unfortunate consequences of this is that river flows can be dramatically altered and the net impact is that recreational in stream flows can be significantly reduced resulting is a loss of recreation to many river users. Part of the NEPA process seeks to identify impacts and find acceptable mitigation of these impacts. This draft EIS does a good job at identifying the negative impacts and costs associated with recreational flows in the rivers, but seems to do nothing to attempt to mitigate these impacts. I propose that scheduled recreational in-stream flows would be a reasonable mitigation to loss of recreational flows incurred by these projects. Scheduled recreational flows are possible now with the current and proposed infrastructure. Proper planning and notification is all that would be required to make this a reality. Colorado has been a national leader in showing the recreational in-stream flows provide a valuable resource for communities from a recreational and economic standpoint. As the Windy Gap Firming Project is being reviewed, I urge you to take recreational flows into consideration as a just and fair mitigation to return even a small fraction of what has already been taken away.
A national resource to help craft recreational in-stream flow agreements is the organization American Whitewater. American Whitewater has successfully negotiated in-stream recreation flows on multiple rivers, in multiple states with multiple stakeholders. American Whitewater can be contacted via: 1-866-BOAT-4-AW or [email protected]
I am certain that a mutually beneficial agreement could be reached if impacted parties could discuss this issue with an open mind.