From the League of Women Voters of Larimer County (Sarah Pitts) via the Fort Collins Coloradoan:
As part of its long history of studying and participating in public discussion on water and other environmental issues, the League of Women Voters of Larimer County delivered comments to the Army Corps of Engineers on the second draft environmental impact statement (SDEIS) for the proposed NISP/Glade Reservoir project. The league recommended the Corps defer issuing a permit for the project until the Corps corrects data inadequacies and omissions, addresses compatibility with the draft state water plan, and better defines and quantifies short- and long-term costs related to environmental impacts.
Inadequate data cited by the league include:
•Population growth projections are overstated because they fail to use the reliable and objective data provided by the Colorado State Demography Office.
•Per capita water consumption projections are overstated because they fail to factor in already implemented conservation measures (e.g., Fort Collins reduced per capita consumption from 188 gallons/day in 2003 to 140 now) as well as new and developing conservation initiatives.
•Water supply projections underestimate the potential for acquiring water from annexed farm land, from alternative agricultural transfers, and from growing supplies of reuse water.
•The SDEIS omits essential water quality and temperature models.
The SDEIS fails to analyze the project’s compatibility with the draft Colorado state water plan. It is also at odds with the South Platte River Basin Implementation Plan statement that the costs of building and maintaining reservoirs are questionable: “The basin, in a typical year, has little unappropriated water available for new uses. Unappropriated flows . . . come in sporadic, high peaks during wetter years, making the economics of building a reservoir to capture these supplies questionable because of the large carryover storage requirements.”
Unsubstantiated assumptions about long-term, as well as short term environmental impacts, call into question the SDEIS’s already insufficient disclosure as to the allocation, sources of funding and impact of costs to build and mitigate the effects of the NISP project.
Copies of the league’s full comment letter to the Army Corps of Engineers is available at http://www.lwv-larimercounty.org.
Sarah Pitts is spokeswoman with the League of Women Voters of Larimer County.