HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 06/10/2008 - NORTHERN INTEGRATED SUPPLY PROJECT (NISP) STATUS R DATE: June 10, 2008 WORK SESSION ITEM
STAFF: Marty Heffernan FORT COLLINS CITY COUNCIL
Kevin Gertig
SUBJECT FOR DISCUSSION
Northern Integrated Supply Project (NISP) Status Report on Preliminary Review of Draft
Environmental Impact Statement.
EXECUTIVE SUMMARY
The Northern Colorado Water Conservancy District (NCWCD), in collaboration with twelve
municipalities and water districts, is proposing to build the Northern Integrated Supply Project
(NISP). Part of the project would involve diverting water from the Poudre River at the mouth of the
canyon into a new off-stream reservoir(Glade)and conveying the water to the participants through
water exchanges and/or a pipeline into Horsetooth Reservoir. It is anticipated the project would
significantly reduce flows in the Poudre River through Fort Collins and could negatively impact
water quality in Horsetooth, which supplies both the City and much of northeastern Colorado with
drinking water.
Water in Glade Reservoir would likely have higher total organic carbon(TOC)levels than water in
Horsetooth Reservoir. TOC may degrade both the quality of our drinking water and the clean water
needed by local breweries, computer chip manufactures,and many other businesses. The presence
of Glade water in Horsetooth Reservoir could require very expensive and advanced water treatment
facility improvements to deliver the same quality water currently provided to City residents and
businesses, consistent with Council-adopted policy for drinking water quality, in Resolution 1993-
144. The City has two water reclamation facilities(Mulberry and Drake)which can discharge into
the Poudre. Reduced flows could force the City to install and operate advanced wastewater
treatment systems at great additional expense to City water and wastewater customers. In addition,
trichloroethylene (TCE) contamination known to be present in the vicinity of the proposed Glade
Reservoir from a former Atlas missile site could impact the water quality of Glade (and
consequently Horsetooth), or of the Poudre River.
Reduced river flows through town, ranging from 25% to 71%, could have significant detrimental
impacts on the river ecology, including vegetation, fish and wildlife. Reduced flows could also
impact recreational activities along the river including boating, tubing and fishing. Reduced flows
could make the river less attractive, negatively impacting the experience of trail users and visitors
to our parks and natural areas. Fort Collins residents place a high value on maintaining flows in the
river as shown by Dr. Loomis' report. Reduced flows could also impair land development near the
river and undermine efforts to connect Downtown to the river and to the North College area.
Reduced river flows could also significantly impact wastewater treatment.
In order to proceed with NISP, a permit must be issued by the Army Corps of Engineers (ACE)
under Section 404 of the Clean Water Act. A 404 permit cannot be issued until a final
environmental impact statement(EIS)is issued by the ACE. The ACE issued a draft EIS for NISP
on April 30th and specified a comment period of 90 days, ending on July 30th. The draft EIS,
including supporting documentation, is 4,215 pages long. It is a very complex and technical
June 10, 2008 Page 2
document. The City has requested an additional 90-day extension of the comment period to afford
the opportunity to adequately analyze the draft EIS and provide the ACE with solid, factual, well
considered comments regarding the impacts of the project on the City's interests. The ACE has
indicated it will likely not make a decision on an extension until after the public meetings now
scheduled for June 16th, 17th and 19th.
The purpose of this work session is to inform Council of staff s preliminary findings and concerns
from its review of the draft EIS. Discussion is scheduled to continue at the July 1 st regular meeting.
If an extension of the comment period is granted the item will be rescheduled for a later Council
meeting and staff will utilize the time to complete its analysis of the draft EIS and prepare the draft
comments. The purpose of the item at the next Council meeting will be to review the analysis and
comments with Council so that they can be finalized and submitted to the ACE.
Staff reviewed NISP with Council on December 11, 2007, prior to issuance of the draft EIS. The
Summary of the work session is attached and a DVD of staff s presentation is also included. The
DVD provides an overview of how NISP works. A copy of the Power Point slides for staffs
presentation on June 10 is also attached.
GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED
1. Does staff s preliminary analysis of the draft EIS meet Council's expectations?
2. Are there areas of concern that staff has not addressed?
BACKGROUND
NISP is a collaborative water project between the NCWCD and twelve municipalities and water
districts to increase regional water supply. The project involves the construction of two off-river
reservoirs, Glade and Galeton. Glade reservoir, approximately the size of Horsetooth Reservoir,
would have a 170,000 acre foot capacity and would be located just north of Ted's Place along US
287. Galeton Reservoir would have a 40,000 acre foot capacity and would be located northeast of
Greeley. Poudre River water near the mouth of the canyon would be pumped into Glade and
conveyed to participating communities via a pipeline to Horsetooth Reservoir and through water
exchanges. Staff s work so far has focused on identifying potential issues and data gaps. Staff s
work is ongoing, and has not yet addressed proposed or potential mitigation of NISP impacts. The
following is staff s preliminary analysis of the draft EIS.
June 10, 2008 Page 3
WATER MANAGEMENT ISSUES
• SOURCE WATER QUALITY
Issue: Deliveries to Horsetooth Reservoir from the Glade-to-Horsetooth pipeline have the
potential to degrade water quality at the Fort Collins Water Treatment Facility intake at Soldier
Canyon Dam.
Total organic carbon (TOC) is one of the most important water quality parameters for the source
waters of the Fort Collins Water Treatment Facility(FCWTF). TOC levels are important because
they affect water treatment processes and serve as the main contributor to the formation of
disinfection by-products (DBPs). DBPs are potential carcinogens formed when TOC reacts with
chlorine used for disinfection. Other water quality parameters of concern to the FCWTF include
pathogens, turbidity, taste and odor compounds, and manganese. The FCWTF and the City's
improvements to it over the years have been designed to provide removal of these parameters when
they are present at concentrations that have historically occurred at the existing intake structures.
These parameters are generally present at seasonally high concentrations in one source water.
Hence, a treatment strategy used by the FCWTF is to adjust the raw water blend to increase the
amount of water from the higher quality(Horsetooth) source when required due to seasonal runoff
conditions that reduce the water quality in the Poudre.
Preliminary Concerns:
1. High TOC concentrations occur in waters of the Upper Poudre River during the spring
snowmelt runoff when Glade Reservoir would be filled. As a result, TOC concentrations
in Glade Reservoir would be higher than in Horsetooth Reservoir and would be an issue if
the Glade-to-Horsetooth pipeline were built.
2. Analysis in the draft EIS is inadequate and underestimates TOC concentrations in Glade
Reservoir and subsequently at the FCWTF Horsetooth Reservoir intake.
3. For effective drinking water treatment design and operation, worst-case scenarios for raw
water quality must be evaluated. This requires substantially more data and more rigorous
mathematical modeling than is presented in the draft EIS.
4. Careful mathematical modeling requires NISP operational details that have not yet been
provided, including flow quantities and schedules for water delivered to Horsetooth
Reservoir from Glade Reservoir and from the Hansen Feeder Canal.
5. More precise mathematical modeling, combined with future water quality monitoring of
Glade Reservoir, may point toward increases in other water quality parameters of concern
at the FCWTF Horsetooth intake if the Glade-to-Horsetooth pipeline is built.
Significance to the City of Fort Collins:
The Fort Collins City Council drinking water quality policy adopted in 1993 (Resolution 1993-144)
states the following:
"The City will protect raw water sources from contamination or any other activities
that would diminish the quality ofwaterprovided to customers, or that would result
in increased treatment costs. "
June 10, 2008 Page 4
Increases in concentrations or changes in seasonal occurrences of TOC or other water quality
parameters at the FCWTF Horsetooth Reservoir intake would have a major impact on treatment
strategies, process performance, and the cost associated with treatment of water for City water
customers..
• WASTEWATER TREATMENT
Issue: Reduced river flows due to NISP may force the City to design, construct, operate, and
maintain "advanced wastewater treatment"systems at great expense to our community.
The City of Fort Collins operates two water reclamation facilities (WRF): the Mulberry WRF and
the Drake WRF. The former has a maximum-rated capacity of 6 million gallons(mgd)per day and
discharges to the Poudre River. The Drake WRF, rated at 23 mgd, is permit-authorized for
discharge to the Poudre although that outfall has not been used for several years. Both facilities
must meet stringent river-flow-dependent discharge limits when treated wastewater is sent to the
river. Reduced river flows due to NISP may force the City to design, construct, operate, and
maintain"advanced wastewater treatment"systems at great expense to City wastewater customers.
Preliminary Concerns:
1. Degradation of surface water quality: warmer water temperatures, lower dissolved oxygen
levels,higher unionized ammonia levels downstream of City WRFs, and algal blooms that
may, in turn, further deteriorate water quality for fish and other aquatic life downstream.
2. Degradation of river water quality for both Selenium and E. coli. The Poudre is already
303(d)-listed as impaired for these two contaminants. Reduced flows would result in even
higher in-stream levels of both of these contaminants.
3. The draft EIS lacks detailed modeling showing the water quality effects of reduced flows
and resulting increased water temperatures on the river, on regulated stream standards, on
aquatic life,on WRF discharge limits through the City and on communities and dischargers
downstream.
4. Incomplete modeling of wastewater treatment plant discharges to the river: the City's Drake
WRF was omitted from all modeling,analysis and reporting in the draft EIS. The South Fort
Collins Sanitation District treated wastewater discharge location was incorrectly reported.
5. No data was provided for either stream or WRF discharge flow values used for twelve tables
of mass balance calculations that claimed"no effects"or"minimal effects"from NISP. No
wasteload allocation modeling was done for nearby WRF discharges to the Poudre. No
Total Maximum Daily Load(TMDL)calculations were done. No low-flow WRF discharge
ammonia limit calculations were done using the restrictive AMMTOX model that beginning
in 2012 will be the basis for monitoring and setting discharge standards for all WRF
discharges to the Poudre.
Significance to the City of Fort Collins:
With reduced river flows, treated wastewater discharges from the City's two WRFs may, in fact,
become the dominant sources of water flowing in the Poudre River from near Mulberry Street
downstream to I-25. Under reduced river flow conditions due to NISP, City wastewater customers
could be forced to spend millions of dollars to design, construct, operate, and maintain advanced
wastewater treatment systems to meet ever-more stringent regulated discharge limits.
June 10, 2008 Page 5
• TRICHLOROETHYLENE (TCE) GROUNDWATER CONTAMINATION
Issue: TCE contaminates groundwater near the Glade pumping site and public drinking water
supply andlor the Cache la Poudre River could become contaminated due to NISP.
Trichloroethylene(TCE)is a solvent that was used to clean rocket fuel tanks at the former Atlas"E"
Missile Site 13 in Laporte,Colorado. The site was in operation from the 1950s to phase-out in 1965.
TCE now contaminates groundwater at a location immediately northwest of a proposed"forebay"
at the foot of the proposed Glade Reservoir dam. (The forebay would serve as a small reservoir or
sump for water to be pumped into Glade.)
Limited non-seasonal data from groundwater monitoring wells located adjacent to and within the
forebay area show TCE levels ranging from non-detect to approximately 75 parts per billion (ppb
or micrograms per liter). The safe drinking water standard is set at"not to exceed" 5 ppb. Chronic
exposure to TCE near or above that standard can cause liver damage. There is evidence that lifetime
exposure to drinking water at or above that standard may cause cancer. TCE is very persistent in
groundwater environments and difficult to remove. TCE has a"moderate"bio-concentration effect
in fish and a human ingestion standard of 2.5 ppb.
Preliminary Concerns:
1. There is potential for TCE-contaminated groundwater to migrate to the forebay and,in turn,
be pumped into Glade Reservoir. The NISP preferred alternative shows water piped from
Glade to Horsetooth Reservoir. Horsetooth is a primary drinking water supply for both the
City of Fort Collins and northeastern Colorado. TCE-contaminated water should not be
pumped into Horsetooth Reservoir.
2. Because no consistent seasonal groundwater monitoring program has been designed or
completed in the affected area, the nature and extent of changes in groundwater elevations
in the area over time are unknown. In turn,this means that seasonal movement of the TCE-
contaminated groundwater is unknown.
3. Because no groundwater modeling in the TCE-contaminated area has been done, the
potential direction and speed of movement of the plume under pressure from (or under the
weight of) water from within Glade Reservoir are unknown.
4. If Glade Reservoir is authorized,the District and the Corps have committed to installing an
impermeable lining along the walls and bottom of the forebay to eliminate seepage into
groundwater. However water pressure from the reservoir may then redirect TCE-
contaminated groundwater water toward the Poudre River. This is an indirect impact of
NISP that has not been modeled or evaluated.
Significance to the City of Fort Collins:
Without extensive removal or remediation, or in the event of inadequate analysis and design or
improper construction or maintenance, both direct and indirect impacts of NISP could lead to
contamination of our community's drinking water supply and/or the Cache la Poudre River with
TCE.
June 10, 2008 Page 6
ENVIRONMENTAL ISSUES
• RIVER SEDIMENTATION
Issue: Sedimentation within the Poudre River through Fort Collins. Under the proposed action,
peak spring and summer flows would be sharply reduced which could in-turn reduce or eliminate
the natural scouring action and sediment transport functions related to high flows.
Preliminary Concerns:
Increased fine sediment deposition (settling) in the Poudre River through Fort Collins is possible
because of NISP induced reduced flows. Deposition of fine sediments within the gravel and cobble
bed of the Poudre River is likely to significantly change the morphology of the river channel. A
cascade of adverse effects could follow, including increased vegetation encroachment into the
channel causing the channel to narrow and constrict flows under normal conditions and obstruct
flows under higher flow(flood) conditions.
The draft EIS does not accurately portray the severity of fine sediment deposition impacts on the
Poudre River through Fort Collins and instead concludes thatNISP would increase channel stability.
In contrast, the Biological Assessment (BA), which is part of the draft EIS, correctly identified
potential adverse impacts resulting from large flow reductions during spring runoff in wet and
average years,stating "...potential changes include channel narrowing,greater sediment deposition
and less sediment flushing, vegetation encroachment into the channel, increase in the size ofthe in-
channel islands,flow obstruction and bank erosion... "(Biological Assessment,page 29,Appendix
B, draft EIS). The discrepancy between the BA and the draft EIS regarding the range and severity
of potential impacts on the river through town must be resolved.
Significance to the City of Fort Collins:
The City of Fort Collins has a vested interest in maintaining a healthy and functional river system.
The process of sediment deposition without its antagonistic process of sediment flushing through
scouring and erosion could lead to vegetation encroachment and subsequent channel constriction.
These changes could significantly change the river's function as a conveyor of flood water and result
in flow obstruction, increased flood stages and possibly greater flood damage.
Altered flood characteristics could prompt a revision of FEMA maps and place at risk the city's
significant investment and concerted effort in flood protection and mitigation projects it has made
over the past decade and more.
Reduced peak flows and increased sediment deposition would likely result in a significant increase
in the number of small, stagnant pools within the river channel that could become ideal breeding
areas for mosquitoes. This issue could affect mosquito control efforts and exacerbate citizens and
health official's concerns about West Nile Virus.
June 10, 2008 Page 7
• RIPARIAN VEGETATION AND WETLANDS
Issue: It is anticipated that reductions in spring annual flows ranging from 25% to 71% could
have a significant, detrimental, negative impact on the riparian vegetation through the City of
Fort Collins.
Preliminary Concerns:
Riparian ecosystems along snow-melt fed rivers have evolved with high spring flows. Vegetation
in the riparian zone are adapted to and dependent on both high spring flows that cause overbank
inundation as well as flows that do not exceed bank levels yet cause a significant corresponding rise
in groundwater levels. Because the Poudre has been altered by human activities, it is likely that
parts of the system behave differently. The draft EIS does not include the data and scientifically-
based studies required to understand how the components of the riparian ecosystem in Fort Collins
are behaving.
Of significant concern are the conflicting statements regarding the impact of the project to the
riparian vegetation. In Section 4.2.1.4,the draft EIS states the proposed action... "is not anticipated
to cause a loss of riparian and/or wetland vegetation". In contrast,the draft EIS Wildlife Report
and the River Morphology Report conclude that NISP would cause impacts to and losses of riparian
vegetation.
The draft EIS conclusions regarding impacts to river vegetation are not based on a documented,
objective,scientific framework or proper application of ecological concepts. For example,the report
uses monthly hydrologic modeling that ignores short term (less than a month) hydrologic changes
in the river, which are critical to vegetation. The report ignores the influence of flows below
overbank events on vegetation. Groundwater wells were not used to support conclusions regarding
the hydrologic sources and groundwater movement. The report fails to consider a possible shift in
species composition (including noxious weeds such as tamarisk, Russian olive, etc.) and
corresponding treatment costs to landowners including the City.
The draft EIS fails to identify jurisdictional wetlands along the river. This is a serious procedural
flaw. As a result,the draft EIS does not delineate or engage in an effects analysis of wetlands along
the Poudre River through town or provide for any mitigation for loss.
Significance to the City of Fort Collins:
Impacts to the riparian vegetation from NISP could have far reaching consequences to the City. Of
particular concern to the City are potential impacts to stormwater protection, capacity of the
floodplain to perform nutrient and contaminant filtration, the health and quality of critical wildlife
habitat, the social and aesthetic values of the riparian forests, and economic benefits to local
downtown businesses and other interests are of concern.
• AQUATIC HABITAT QUALITY AND AQUATIC LIFE
Issue: NISP could have detrimental impacts on aquatic habitat and aquatic life but nature and
degree of impact cannot be determined from the draft EIS.
June 10, 2008 Page 8
Preliminary Concerns:
The loss of aquatic habitat and aquatic life due to degraded stream conditions is a major adverse
impact that is characterized as a minor adverse effect in the draft EIS.
The draft EIS states: The changes to channel morphology, the increased sedimentation, degraded
water quality, and the greater occurrence of low flows would be detrimental to both fish and
invertebrates. The adverse effects would result in lower abundance and fewer species offish and
invertebrates. These minor adverse effects would occur gradually over time, and the fish and
invertebrate communities would adapt to the new flow regime and channel morphology. The loss
of species or a reduction in abundance of aquatic life is a major adverse effect not"minor adverse
effect" as concluded in the draft EIS.
The draft EIS does not quantify changes to water temperature resulting from reduced flows. The
report states: `,flow decreases during the spring and summer months could result in stream
temperatures exceeding the chronic standard more frequently". The amount of change and
frequency of change is not quantified. Without quantification, it is not possible to accurately
determine impacts to water quality, loss of cold water fish species and invertebrates.
Significance to the City:
Decreased flows, increased sedimentation, channel narrowing, increased water temperature, and
degraded water quality could adversely impact habitat quality and aquatic life in Cache La Poudre
River through Fort Collins.
• TERRESTRIAL WILDLIFE
Issue: The draft EIS fails to adequately identify and analyze potential impacts on terrestrial
wildlife within the Poudre River's riparian corridor.
Preliminary Concerns:
The primary focus of the draft EIS and Wildlife Technical Report was impacts to wildlife associated
with the "footprint" of Glade Reservoir and the U.S. 287 realignment. The document fails to
identify direct or indirect effects on terrestrial wildlife,including migratory and resident songbirds,
along the Poudre River despite acknowledging adverse impacts to riparian and wetland habitat
typically utilized for feeding, cover, nesting and other activities.
Significance to the City of Fort Collins:
Birds found within City natural areas along the Poudre River in Fort Collins account for two-thirds
(223 of the 353 species)of the total bird diversity in Fort Collins. The City has documented that this
bird diversity along the Poudre River through Fort Collins is comparable or exceeds the diversity
of birdlife in many of the nation's National Parks.
Many species of wildlife find habitat along the river in many of the City's natural areas. Over the
course of several decades the City's Natural Areas Program has invested nearly $6 million (not
adjusted for inflation) to protect 1,305 acres of public land (17 different natural areas) along the
June 10, 2008 Page 9
Poudre River from Overland Trail to I-25. In that same time the City received an additional
$524,000 in grants and$633,000 in donations to help protect these public lands. All combined the
public/private investment in natural areas along the Poudre River through Fort Collins is just under
$7 million. Wildlife and habitat protection were two of the main reasons those investments were
made.
In a series of user surveys conducted in 2006 and 2007,citizens of Fort Collins routinely responded
that "wildlife viewing" is one of the primary activities they engaged in while enjoying the City's
natural areas along the Poudre River. The Poudre River through Fort Collins is a biologically rich
and diverse, and is a frequent, local destination for the citizens of Fort Collins to observe and enjoy
wildlife.
SOCIO-ECONOMIC ISSUES
• RECREATION
Issue: Reduced river flows would negatively impact recreation along the Poudre, including
boating, tubing,fishing, hiking, and wildlife viewing.
Preliminary Concerns:
The draft EIS acknowledges that reduced flows would negatively impact water based recreation in
Fort Collins but seeks to offset the impacts by providing additional recreational opportunities in the
Poudre Canyon and at Glade. Adverse impacts to recreation in Fort Collins would not likely be
adequately or effectively mitigated by recreational opportunities elsewhere.
The draft EIS does not adequately analyze recreational impacts in a dry year scenario when flows
would be significantly reduced by NISP.
The draft EIS concludes that NISP would cause no impact to wildlife-related or other forms of
recreation at City parks and natural areas along the river and concludes that visual impacts from
reduced flows would be negligible because surface water would persist and because the draft EIS
predicts that views of the river would be partially screened by vegetation. These conclusions are
not well supported in the report and run contrary to the City's preliminary findings.
The reduced flows, unless properly mitigated, would undermine the feasibility of constructing a
kayak course because the course would not have sufficient flow to be useable except for short
periods of time.
Significance to the City of Fort Collins:
The City has invested over $8 million to construct over ten miles of trail along the Poudre River.
The trail is extremely popular and residents consistently place high value on the quality and
importance of the City's trails in the Citizen Survey. Reduced of river flows by NISP could
diminish the quality of the Poudre trail user's experience.
The City has invested over$14 million to provide parks along the river,including Lee Martinez,Old
Fort Collins Heritage, Legacy, and Buckingham. In 2011 the City, in partnership with Discovery
June 10, 2008 Page 10
Science Center will open a new museum/science center on the east end of Martinez Park. Proximity
of the new museum to the river was a critical element in selecting this location. Reduced river flows
could diminish the experience of visitors to these parks and to the museum.
The City engaged economist Dr. John Loomis to conduct a survey of Fort Collins residents to
determine the economic value to them of maintaining flows in the Poudre. The survey asked
residents how much they would pay to avoid a 50% reduction in peak spring and summer flows.
Survey results show that the citizens of Fort Collins place great value on preserving Poudre River
flows.
• ECONOMIC, AESTHETIC AND QUALITY OF LIFE IMPACTS
Economic Impacts. The draft EIS limits its assessment of economic impacts on the City to
recreation. No analysis is provided on the impacts of reduced flows on other economic values in
Fort Collins.
• The draft EIS should provide a comprehensive accounting of all economic impacts,
including recreation, the impact to property values of City and privately-held land and
investments made along the river, and the economic value Fort Collins' residents place on
the river.
• The draft EIS should address the findings from the Loomis Report, which estimates that
average annual recreation losses would be between $30 and $48 per household with a flow
reduction of 50%.
Aesthetics and Intrinsic Value of the River. According to the draft EIS,reductions in river flows
from NISP would impact river aesthetics. However, neither the Visual Resources nor Aesthetics
sections of the draft EIS nor the Visual Resources Comprehensive Technical Report include any
reference to the river corridor in its assessment, even though the river corridor is one of the study
areas identified. The draft EIS describes the impact from NISP on the intrinsic value of river
projects and development as "slight."
• The draft EIS does not include any basis for this finding of a"slight"impact. The draft EIS
needs to provide the rationale and underlying data and analysis for this finding and describe
in detail the intrinsic value of the river to the community.
• The Visual Resources sections should describe and analyze the impacts to river visual
resources and should include a photo-simulation of the river to compare existing flows to
future flows.
Community Impacts. The draft EIS concludes that"All the components of the action alternatives
would be located outside of community boundaries. No community cohesion or quality of life
impacts area associated with any of the action alternatives."
• The socioeconomic section of the draft EIS should include secondary impact areas in its
analysis, not just the proposed reservoir sites. The draft EIS should describe these
secondary areas and analyze the potential quality of life impacts to Fort Collins.
Cumulative Impacts. The draft EIS limits its description of"reasonably foreseeable actions"to
the water craft course and future development projects along the river corridor. The draft EIS
June 10, 2008 Page 11
should consider and more fully address the project's cumulative impacts on additonal past,present
and future river corridor plans and projects. Some of the existing plans and projects not discussed
in this regard include:
• City Plan
• Downtown Plan
• Downtown Strategic Plan
• Poudre River Enhancement Project
• Downtown River District Streetscape Improvement Project
• River District revitalization
• National Heritage Area
• Oxbow amphitheater
• Downtown River Corridor Environmental and Cultural Interpretive Program
• Downtown River Corridor Poudre River Trail Enhancements
• Past development activities, such as In-Situ and the Old Power Plant
• Relevant UniverCity Connections objectives, including:
0 Maintain or enhance in-stream flows
o Explore channel improvements to create continuous habitat for sustainable
fish populations,including a self-sustaining trout population,while providing
recreational opportunities for people of all ages.
0 Improve gateway vistas at key locations along the river corridor (e.g.,
College, Linden, and Lincoln).
MITIGATION
Proposed mitigation in the draft EIS is generally inadequate to fully address anticipated impacts
recognized in the report. Staff s preliminary review of the draft EIS indicates the project impacts
would be significantly greater than those recognized in the report. No mitigation is offered to
address these impacts. The draft EIS relies, in part, on the concept of adaptive management as a
mitigation strategy. Essentially,this process involves monitoring impacted areas to assess impacts
after the project is constructed and operating, and implementing mitigation measures in response
to identified impacts. The adaptive management approach provides the City with little if any
assurance that the project's impacts could or would be effectively mitigated.
PROCESS SCHEDULE
The National Environmental Policy Act(NEPA)process was started when the NCWCD,on behalf
of the participating communities, applied for a permit under Section 404 of the Clean Water Act to
proceed with NISP. Because the environmental effects of the project may be significant, an
environmental impact statement was required. The ACE issued the draft EIS on April 30th and
provided a 90-day comment period. City staff and our consultants have been reviewing and
analyzing the draft EIS. The City has requested a 90-day extension of the comment period. The
additional time is needed to fully analyze the draft EIS and to develop solid,factual,well considered
comments regarding the impacts of NISP on the City's interests. The information provided in this
Agenda Item Summary is preliminary. More time is needed to fully understand possible impacts
and to identify draft EIS deficiencies. After the comment period ends,the ACE will determine if a
supplemental EIS is needed or will prepare and release a final EIS.
June 10, 2008 Page 12
The ACE has scheduled three public meetings to gather input on the draft EIS. The meetings are:
• Monday, June 16 at the Fort Collins Hilton beginning at 4:00 P.M., with comments
beginning at 6:00.
• Tuesday, June 17 at the Fort Collins Senior Center beginning at 4:00 P.M.,with comments
beginning at 6:00.
• Thursday, June 19 at the University of Northern Colorado University Center in Greeley
beginning at 6:00 P.M, with comments beginning at 7:00.
NEXT STEPS
In order to meet the current comment period deadline of July 30, Council consideration of the item
is scheduled for a regular Council meeting on July 1. Staff will seek Council's authorization to
submit a proposed set of comments to the ACE. If an extension of the comment period is granted
prior to July 1,the item will be rescheduled for Council consideration at a later date. Staff will use
the additional time to continue the analysis of the draft EIS and to develop a proposed set of
comments for Council's consideration.
ATTACHMENTS
1. Work Session Summary, December 11, 2007 Work Session.
2. Powerpoint presentation.
ATTACHMENT
-' Culture,Parks,Recreation and
Environment
P.O.Box 580
215 N. Mason St.
City of Fo Fort collets co 80521
970-224-6064
fcgov com
MEMORANDUM
DT: December 12, 2007
TO: Mayor and City Council Members
TH: Darin Atteberry, City Manager 01
Diane Jones, Deputy City Manager
FR: Marty Heffernan, Director of CPRE �w
RE: December 11, 2007 Work Session Summary—Northern Integrated Supply Project
Staff reviewed the Northern Integrated Supply Project (NISP) with Council. All Council
Members were present. The purpose of the meeting was to provide Council with a better
understanding of the NISP project, review staff s work regarding NISP and ensure staff s
upcoming work on the draft NISP environmental impact statement (EIS) meets Council's
expectations.
Council Members expressed concern about the NISP project, particularly regarding potential
reductions in flows in the Poudre River and resulting anticipated negative environmental and
water quality impacts. Council directed staff to continue its work to better understand the
potential impacts of NISP on the reach of the river from Overland Trail to I-25, including water
quality, ecological, recreational, aesthetic and economic impacts. Council also directed staff to
analyze the draft EIS when it comes out and inform Council of Staffs findings and conclusions.
Three Council Members stated their opposition to NISP, noting anticipated significant negative
impacts to the river and to Fort Collins generally. Some were also concerned that NISP will
drive residential growth in participating communities. Other Council Members expressed
concern with NISP but wanted to better understand the project and possible mitigation options
before taking a position on the project.
Council Members asked for the following information:
1. A schedule of the draft EIS review and comment process noting all opportunities
available to Council to provide input and impact the outcome.
2. The number of homes within the Fort Collins growth boundary that will be served by a
water district (not the City Utility) at build out.
3. The number of future Fort Collins residents who would be served or benefited by the
NISP project.
4. Maps that show (water) district boundaries.
Council indicated that staffs intention to review and analyze the draft EIS and provide Council
with the Staffs findings and conclusions met Council's expectations for staff work on this
project.
Status Rep Prelimin
Review P Draft
0
10 , 2008
N EPA Process
The NCWCD and project participants applied for a 404
permili.or NISP .
A draft Environmental Impact Statement ( EIS) wa
prepared to deter ,e possible " acts of the pro]
the environment
y The U . S . Army Corp . of Engineers published the draft
EIS on April 30t" and provided a 90 day comment period .,
City staff, ow consultants, and citizens are in the
process of iewin the draft-EIS and develo in
comments .
Work Session Purpose
y The purpose of this Work Session is to inform Council of
Stafs preliminary findings regarding possible NISP
impacts, and dradnEWndeficiencies .
Questions for Council :
Does staff's preliminary anal
Council 's ex ectations?
Are they of concern sta
The Project
The Northern Colorado Water Conservancy District
( NCWCD) in collaboration with 12 municipalities and
water districts, is proposingto build the Northern
Integrated Supply Project NISP) .
y Project involves diverting water from the Poudre, at the
mouth of the canyon , into a new reservoir (Glade) .
Water may be conveyed to participants by a pipeline
from Glade to Horsetooth , and by water exchanges .
Project Impacts to Water Flow & Qualit
a nAated :
NISP will reduce flows in the river by 25 % to 71 % .
NISP may degrade the quality of the city's sources for
drinking (treated ) water .
y NISP may require expensive advanced water treatmen
ate r facilities .
Project Impacts to River Function
It is r pated :
NISP may increase sedimentation in the river through
Fort Collins, causing channel constriction and possible
greater flood damage .
y Reduced flows may increase stagnant water areas
during mosquito breeding season .
Reduced flows may negatively impact riparian
vegetation and wetlands along the river through
town .
pacts to Wm & Habitat
� It is
� Reduced flows may degrade aquatic habitat and
aquatic life by
increasing water temperatures and sediment
buildup and
reducing dissolved oxygen levels
resulting in lower abundance and fewer species of
fish & invertebrates .
y Reduced flows may impact wildlife habitat along the
river and may diminish the abundance and diversi
of wildlife, particularly bird life .
Project Impacts to Visitor Ex erienc
� It is anticipated reduced flows :
� Could shorten the kayaking , t
season .
� May undermine the feasibility of constructing a
watercraft course, without proper mitigation .
Could diminish the experience of people using parks,
trails and natural areas along the river .
� Reduced flows may ne a ively impact the property
values of lands along " ear the river .
; Reduced flows may undermine development i
vicinity of the river and plans to better integrate the ri
into the Downtown and N . College area .
Draft EIS Deficiencies
; Lacks detailed modeling showing water quality effects o
reduced flows a increased temperatures on regulated
stream standard aquatic life and wastewater discharge
limits .
� Omits the City's Drake Water Reclamation Facility from
all modeling , analysis and reporting
y Incorrectly reports the discharge location of wastewater
for S . Fort Collins sanitation district .
Draft EIS Deficiencies
y Insufficient data and modeling to support conclusions of
" no effects" or " minimal effects" of redu4Fflows on
wastewater discharges into the river .
Inadequate analysis of anticipated levels of total organic
carbon (TOC) in Glade Reservoir .
Absence of worst case analysis of water quality impacts
to Horsetooth Reservoir, which are critical to effective
water quality treatment design and operations .
Draft EIS Deficiencies
Lack of NISP operational details, including water delivery
schedules and quantities for water transfers fro Glade
to Horsetooth , needed to determine water qual '
impacts .
Assumption Glade water will4MV mix with Horsetoot
water even though Glade pipeline will deliver water very
near the r our w ter Q treatment fa i.
Lack of consistent, seasonal groundwater monitoring in
the area of the TCE plume, needed to determine the
seasonal movement of the TCE-contaminated
groundwater and how the plume will move under
pressure from Glade water.
Draft EIS Deficiencies
r Inconsistencies between the draft EIS and the Biological
Assessment regarding the range and severity of river
sedimentation and associated impacts .
Inconsistencies between the draft EIS, and the Wildlif
Report and River Morphology Report, regarding impacts
to riparian vegetation .
y Insufficient hydrologic and groundwater data to support
draft EIS conclusions regarding impacts to river
vegetation .
Draft EIS Deficiencies
Failure to identify jurisdictional wetlands along the river
or delineatWA analyj&mpactsWVhese1 ds .
y Discrepancy between draft EIS finding that reduced
flows will lower the abundance and variety of fish and
invertebrates and the characterization of this result as a -
" minor adverse effect" ff
Failure of the draft EIS to quantify changes to water
temperature resulting from redM flows .
Draft EIS Deficiencies
y Failure to identify direct or indirect effects on terrestria
wildlife, including birdlife, despite acknowledging
adverse impacts to habitat typically utilized for feeding
cover, and nesting .
y Failure to assess economic impacts, other than possible
impacts to recreation .
Failure to analyze the aesthetic impacts of reduced
flows .
y Failure to analyze the impact of reduced flows on
adopted plans and projects involving the river .
Draft EIS Deficiencies
Proposed mitigation in the draft EIS appears to be
inadequate to fully address anticipated impacts noted
the report .
NISP impacts may be significantly greater than those
recognized in the draft EIS and no mitigation is ro ose
for these impacts .
The draft EIS relies on the concept of adaptive
management . The draft EIS suggests monitoring an
responding to impacts after the project is in operatio
Mitigation stres should have been developed in th
DEIS .
Next Steps
y The City has requested a 90 day extension of the draft
EIS comment period .
The NISP item is on Council 's agenda for the July 1st
regular meeting .
Staff will present our proposed draft EIS comments at
the July 1st meeting and seek Council 's authorization to
submit the comments to the ACE .
y If the comment period is extended , staff will reschedule
the NISP item for a later Council meeting and use the
additional time to analyze the report and develop
comments .
Public Meetings
The ACE will hold three public meetings regarding th
NISP project :
Monday, June 16th at the Fort Collins Hilton beginnin at
4 : 00 PM with comments at 6 : 00
Tuesday, June 17th at the Fort Collins Senior Center
beginning at 4 : 00 PM with comments at 6 : 00
Thursday, June 19th at the UNC University Center in
Greeley beginning at 6 : 00 PM with comments at 7 : 0