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HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 07/28/2015 - REVIEW OF THE NORTHERN INTEGRATED SUPPLY PROJECTDATE: STAFF: July 28, 2015 John Stokes, Natural Resources Director WORK SESSION ITEM City Council SUBJECT FOR DISCUSSION Review of the Northern Integrated Supply Project. EXECUTIVE SUMMARY The purpose of this agenda item is to provide an opportunity to review and discuss staff’s initial findings and concerns related to the Northern Integrated Supply Project and associated Supplemental Draft Environmental Impact Statement. GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED 1. Are there any questions about the Northern Integrated Supply Project’s impacts to the City? 2. Is there any further guidance from Council as to how the City should respond to the Supplemental Draft Environmental Impact Statement for the Northern Integrated Supply Project? BACKGROUND / DISCUSSION Executive Summary The Northern Colorado Water Conservancy District (Northern) is the project sponsor for a municipal water storage and supply project known as the Northern Integrated Supply Project (NISP). NISP is a project proposed and designed by Northern and fifteen municipalities and water districts, including the Fort Collins-Loveland Water District (FCLWD), a municipal water provider serving a portion of Fort Collins. In 2008, City Council endorsed a set of comprehensive comments to the United State Army Corps of Engineers (Corps) regarding the NISP Draft Environmental Impact Statement. Those comments can be found at: <http://www.fcgov.com/nispreview/> Council also adopted a resolution 2008-082, stating that it opposed NISP as it was described at the time. (Attachment 1) The Corps decided to perform a Supplemental Draft Environmental Impact Statement (SDEIS) which describes the proponents’ preferred alternative (as well as three additional alternatives). It was published on June 19. The SDEIS is a federally-required detailed review of the environmental impacts of the proposed project alternatives. The Corps must issue a permit for the project before it may proceed to construction. Public comments regarding the SDEIS are due to the Corps on or before September 3, 2015. Staff and a consultant team are reviewing the SDEIS and preparing comments for Council’s consideration at its regular September 1 meeting. This work session is an opportunity for staff to share its initial thoughts about the SDEIS and to discuss them with Council. Staff has focused its comments on the preferred alternative (which has two variations). In general, staff believes that in certain areas the SDEIS represent a significant improvement over the 2008 Draft Environmental Impact Statement (DEIS). The Common Technical Platform (CTP) required by the Corps for the hydrological modeling underlying the SDEIS has provided valuable baseline information to its analysts and reviewers. Furthermore, the CTP is being used in the City’s EIS process for the Halligan Water Supply Project. Based on the CTP, the impacts analysis of the SDEIS has been strengthened in certain key areas. In addition, July 28, 2015 Page 2 the SDEIS includes a conceptual mitigation plan put forward by Northern that provides an overview of how the project proponents propose to deal with some of the unavoidable impacts of NISP. Notwithstanding these valuable improvements, as summarized below, staff continues to have significant concerns with respect to NISP’s impacts to the City and the apparent failure of the SDEIS to adequately describe all of the impacts. The concerns include potential water quality degradation that could affect water and wastewater treatment facilities, environmental concerns related to the long-term impacts of NISP on habitat; and, a mitigation plan that does not adequately address these concerns. Introduction NISP is a municipal water supply project designed by Northern and fifteen municipalities and water districts, including the FCLWD, a municipal water provider serving a portion of Fort Collins. As discussed by staff at the May 12 work session, NISP would involve substantial diversions of water from the Poudre River. The preferred alternative for NISP (as well as three additional alternatives) would divert water from the Poudre River below the canyon mouth and above Fort Collins, thereby reducing flows through town. Water from these upstream diversions would be stored in Glade Reservoir north of Fort Collins. The Corps has analyzed the project alternatives in the June 19 SDEIS. Comments on the SDEIS are due on or before September 3. Previous Council Direction At the May 12 Council Work Session, staff presented background on NISP and staff’s proposed approach to commenting on the SDEIS, which Council approved. The approach to the current SDEIS is similar to the City’s approach to commenting on the original DEIS in 2008, such that the City is examining and preparing comments on various “themes” or topics that are directly relevant to the City’s interests, including investments and policy decisions. Pursuant to Council direction, staff has thus taken an analytical and data-driven objective approach, and not taken an approach based on a position either for or against the project. Please note that the comments of the team focus on the preferred alternative. There are two versions of the preferred alternative. The major distinction is the potential in one version for delivery of water into Horsetooth from Glade Reservoir. SDEIS and Staff’s Ongoing Review and Outreach The summary of concerns and other issues in this Agenda Item Summary are based on a preliminary review of the nearly 1,500-page SDEIS, in addition to its various additional models and technical reports. Thus, these are high level comments that are intended to represent what staff perceives as key issues that will have a direct impact to the City. Because these comments are preliminary in nature and there has been limited time to fully develop them, staff wants to emphasize that they are not all-inclusive. Staff has not had time to utilize the City’s Poudre Ecosystem Response Model in order to refine its understanding of NISP-related impacts; nor has staff had time to compare SDEIS predictions for river health with the City’s river health metrics. Nor do the comments, at this point, integrate the various themes and fully consider their interdependency, such as the relationship between water quality issues, peak flows, and fish habitat issues. Finally, staff has not had sufficient time to better understand how the conceptual mitigation plan proposed by Northern could (or should) be improved. Notwithstanding these limitations, the preliminary comments are a reasonably good representation of the core concerns and observations that will underlie more detailed comments to be provided to Council on September 1. In addition to Council meetings, staff plans to make presentations to the Water Board, the Natural Resources Advisory Board, Planning and Zoning Board, and the Land Conservation and Stewardship Board. Brief information also will be provided at the June 29 “super board” meeting. Staff will appear on a Cross Currents broadcast about NISP and provide brief comments at the open house to be held by the Army Corps of Engineers on July 22. July 28, 2015 Page 3 Larger Context for Consideration of NISP Poudre River The Poudre River is the main source of water for a large area of northeastern Colorado. For over 150 years, water has been diverted for agricultural, residential, and commercial uses. The Poudre River is a remarkably successful example of a river that effectively delivers water for these needs. In addition to the economic achievements represented by diversions of water from the stream, significant environmental needs or values also have been achieved; for example, the Wild and Scenic designation of much of the canyon reach of the River provides long-term protection for this beautiful area. Moreover, Fort Collins has taken many actions to enhance the River corridor in and around the City, including its trail and Parks system, as well as restoring and actively managing its natural areas for high value wildlife habitat. In spite of these valuable conservation efforts, however, efforts to conserve the environmental and ecosystem service values of the River below the canyon mouth have been modest when compared to diversions and development. The Poudre River literally dries up at certain times of the year in Fort Collins because of upstream diversions; and furthermore, its flows through town have been reduced by approximately two-thirds. NISP reduces flows by additional 21% as measured at the Lincoln Street Gage in downtown Fort Collins. These significant flow reductions are damaging to the long-term health of the River because flows are the single-most important factor in sustaining habitat as well as a river channel that can handle flood events, among other values. As northern Colorado continues to grow, there will be additional pressure on the Poudre River to be the water source for the new residents, businesses, and other uses. Water providers will continue to purchase agricultural water rights and change them for new uses and to file for new water rights, which further depletes the River through Fort Collins. Given this trend, the long-term challenges to the Poudre River are profound. If Fort Collins and the region are to be successful in achieving a Poudre River that is sustainable and resilient as a river in the future - there will need to be regional discussions, agreements, and collaborations. Given NISP’s size and ambition, it brings the long-term challenges of the Poudre River to the foreground. Perhaps NISP can serve as a fulcrum for a more robust and regional conversation about what it means to ensure a healthy, resilient Poudre River that in 50 or 150 years will continue to provide key watershed services such as clean water for commerce, flood mitigation, wildlife habitat, stormwater attenuation, recreation amenities and aesthetic enjoyment. Fort Collins-Loveland Water District FCLWD is a municipal water provider serving portions of southern Fort Collins, as well as lands outside of the City’s growth management area. FCLWD is one of the NISP participants. In addition to FCLWD’s other water rights, if approved and constructed, NISP would provide the FCLWD with 3,000 acre-feet (AF) of firm yield. Based on information provided by FCLWD, the demand increase within the City’s growth management area served by FCLWD is approximately 1,400 AF through 2040. Thus, while there are various concerns regarding NISP for the City, as described below, NISP also offers benefits to certain Fort Collins residents. Halligan Project The City’s Water Utility is currently pursuing its own permit from the Corps for the Halligan Water Supply Project. Pursuant to the Corps’ direction, the City is using the same CTP (baseline understanding) NISP. The City’s preferred alternative is the enlargement of Halligan Reservoir. The Corps has selected the enlargement of Glade Reservoir as a potential alternative to Halligan. The NISP SDEIS, however, does not analyze the potential enlargement of Glade Reservoir as a substitute for Halligan. This option will be presented in the DEIS for the Halligan Water Supply Project scheduled to be released in the summer of 2016. Staff recognizes that the City’s comments on NISP may affect the Halligan project and have considered potential impacts to the Halligan project in the development of these NISP comments. July 28, 2015 Page 4 Initial Findings and Concerns Regarding the NISP SDEIS Water Quality - Source Water Maintaining or improving water quality is of paramount importance to the City. Water quality can be defined by its physical, chemical, biological, and aesthetic attributes, which are not only important for the protection of public health, but also the environment. Various chemical constituents and temperature constitute key components of water quality. A fundamental gap in the SDEIS is the lack of a quantitative water quality and temperature model. The SDEIS acknowledges that this critically important component is missing and indicates that it will be provided in the Final EIS, on which the City may not have the opportunity to comment. While the SDEIS indicates that water quality and temperatures changes are likely, it does not provide quantitative information that would allow the City or others to understand the potential impacts to its facilities. This is a serious shortcoming. The delivery of NISP water from Glade Reservoir may adversely affect the quality of the City’s water sources in the Pleasant Valley Pipeline (PVP) and Horsetooth Reservoir. The City’s water sources delivered to its water treatment plant come from the Poudre River through Fort Collins’ Pipeline and through the PVP via the Munroe Canal, and from Horsetooth Reservoir. Fort Collins Utilities shares use of the PVP with the Tri-Districts (FCLWD, the East Larimer County Water District, and the North Weld County Water District). Northern may deliver water from Glade Reservoir into the PVP and/or Horsetooth for delivery to the Tri-Districts’ Soldier Canyon Treatment Plant. Thus, if NISP water is of a relatively poor quality which is a concern due to the size and composition of the project, the City’s water sources in the PVP and Horsetooth Reservoir will be affected and the City’s drinking water treatment plant could require substantial and expensive upgrades. The SDEIS summarizes the water quality impacts of the project on Horsetooth Reservoir water quality as minimal to none. The City, however, has concerns about the technical approach used to evaluate the impact of Glade to Horsetooth transfers, and believes the assessment may underestimate the impacts to Horsetooth Reservoir water quality. The SDEIS does not include any mitigation to deal with possible degradation of water quality in Horsetooth Reservoir. Decreased releases of Horsetooth Reservoir water to the Poudre River may increase the hydraulic residence time in Horsetooth Reservoir, which is a measure of the amount of time that water physically stays in a reservoir before being delivered. Longer hydraulic residence times are generally associated with lower water quality. Water Quality - Wastewater Flow reductions impact many of the issues that the SDEIS explores and the NISP preferred alternative substantially reduces flows through Fort Collins. For example, currently the total amount of water on average annual basis that flows in the canyon prior to diversion is approximately 280,000 acre feet (AF) on average. By the time the River flows under the Lincoln Street Bridge in Fort Collins, those flows have been reduced to about 108,000 AF on average. If NISP is built, flows at the Lincoln Street Bridge will likely be reduced to an average of 85,000 AF, or a 21% reduction from current levels. Because the NISP preferred alternative would divert under junior water rights, most of its diverted water will be taken during periods of high flows in the months of May, June, and July although diversion may occur in other months, including late summer and early fall. Monthly streamflows in average years at the Fort Collins Lincoln Avenue Stream Gage in May, June and July are respectively calculated to be reduced by approximately 66%, 25%, and 54%. Diversions of Poudre River water for NISP will affect water quality in the Poudre River below the canyon mouth where the City discharges treated wastewater. Degradation of water quality to the Poudre River as it flows through town could create very difficult issues related to the City’s wastewater discharge permits as well as the need to potentially provide upgrades to those plants. The Poudre River through town already exceeds some water quality parameters or is very close to excursions (violations) of those standards. Thus, what may appear to be modest changes in water quality, such as seemingly small increases in temperature, can have significant impacts to the bottom line of Fort Collins. July 28, 2015 Page 5 Lower flows are problematic for the City’s wastewater treatment plants which operate under strict water quality permit conditions. NISP diversions at the canyon mouth will result in flow reductions downstream at the Mulberry and Drake wastewater treatment facilities. Lower flows would, in turn, potentially lead to increasingly stringent effluent limits for Mulberry and Drake and could cost the City significant amounts of money to remediate. While the mitigation plan for NISP includes a proposal to maintain flows near 10 cubic feet per second (CFS) from November 1 through April 1 (and potentially September) through a portion of town, that flow is proposed to be re- diverted into the Timnath Reservoir Inlet (next to Nix Farm) before it reaches the permitted Drake discharge to the Poudre River. Because of its diversion at the Timnath Inlet, the proposed augmentation flow does not address low flows or dry ups on the lower portion of the River in Fort Collins. Water Quality - Natural Environment Diversions of Poudre River water for NISP will affect water quality in the Poudre River below the canyon mouth through Fort Collins where the City has invested substantially to improve the natural environment. Water quality is fundamental to the health of the fishery as well as other biological attributes of the River. The reduced flows and impacts to water quality affecting the City’s wastewater discharges also directly affect these attributes. Operations The conceptual mitigation plan for NISP’s preferred alternative features a 10 CFS fall and winter augmentation release from Glade Reservoir. However, no other alternative includes augmentation releases. As a result, when impacts among alternatives are compared in the SDEIS, the preferred alternative shows fewer negative impacts than the other alternatives that do not include augmentation releases. This comparison may not be valid. Staff will recommend that winter augmentation flows be incorporated in other alternatives besides the proposed action. In addition, Staff is considering reconfiguration of the other alternatives presented in the SDEIS that could provide for increased flows through Fort Collins while developing the same water supply as NISP. Specifically, Staff is investigating a modification of an alternative featuring Cactus Hill Reservoir that diverts water to storage downstream of Fort Collins, and thus provides significantly more streamflow through town than NISP’s preferred alternative. The SDEIS mentions that the NISP participants Eaton, Severance, and Windsor would receive water from NISP via a direct connection between Glade Reservoir and Soldier Canyon Filter Plant, but the method for such deliveries is not explained. If a new pipeline is required to make these releases, the SDEIS should evaluate the pipeline’s impacts. If deliveries will be made through existing infrastructure (e.g., the PVP), the concern noted above in the water quality comments applies. The SDEIS states that water released from Glade for the proposed 10 CFS augmentation release will be returned to Glade Reservoir, and that the “method of exchange to return the water to Glade Reservoir would be determined between the SDEIS and FEIS.” More information on the method by with augmentation releases will be re-delivered to Glade is needed to properly assess impacts. Recreation The Poudre is a major recreational attraction in Fort Collins, attracting approximately 500,000 visitor days a year. Over many decades Fort Collins has spent tens of millions of dollars beautifying, acquiring land, building recreation amenities, and restoration natural habitat. Fort Collins owns three parks on the River and over 1,800 acres of natural areas. In 2014, City Council adopted a Downtown Poudre River Master Plan that describes a vision for continuing to improve the most heavily visited reach of the River from Shields Street to Mulberry. An increasingly popular activity on the Poudre is summertime boating (kayaking, canoeing) and tubing. The SDEIS acknowledges moderate to major adverse effects on boating recreation in Fort Collins. With the NISP preferred alternative of constructing Glade Reservoir, the SDEIS determines that boatable days will be reduced by 35% from 54 days to 35 days annually. The SDEIS describes boatable days as those days with 150 CFS or more. Based on personal communication with boaters in the community, 150 CFS is regarded the minimum necessary flow for a watercraft. Tubers can float the river with flows of around 100 CFS. According to an analysis commissioned by staff, in dryer periods such as the late 1980s and early 1990s, NISP could reduce boatable days by 50% or more. July 28, 2015 Page 6 Clearly the project will have negative impacts to the potential season length at the proposed kayak park in Fort Collins; however, the City’s kayaking consultant notes that Front Range kayaking facilities regularly experience seasonal highs and lows and the boating community is accustomed to these fluctuations. Also, given that the hydrology on the River has been carefully modeled through the CTP process, the designers would take into account these lower flows and build the facilities to maximize their benefit. The SDEIS notes that there would be flatwater recreation available on Glade Reservoir with extensive access and describes it as potential offset to the loss of recreation on the River in town. Staff, however, does not believe that recreation at Glade is substitute for the user experience along the Poudre in town. NISP, by reducing River flows, impairing water quality and diminishing riparian habitat will undermine the Fort Collins community’s connection to the River. Stream Morphology Flushing flows are critical to a variety of River health indicators in particular transport of sediment, turnover of the bed, and debris mobility. Because most of NISP’s water is diverted during the peaking flows of May, June, and July it has the potential to reduce the ability of the River to provide regular flushing flows. As noted earlier, monthly streamflows in average years at the Fort Collins Lincoln Avenue Stream Gage in May, June and July are respectively calculated to be reduced by approximately 66%, 25%, and 54%. Moving sediment through the system and the Fort Collins reach cleans the bed for fish spawning and insects and prevents large-scale sediment deposition and potential channel encroachment. Reducing flushing flows may have impacts to the ability of the Poudre River to convey storm water and flooding flows through town without causing damage. The SDEIS makes a finding that flows of 10,000 cubic feet a second (CFS) are needed to effectively move material through Fort Collins. However, the City’s Poudre River Ecosystem Response Model and associated hydraulic science indicates that flushing flows of approximately 3,000 (CFS) rejuvenate the River bed. This is an important difference since Glade can divert approximately 1,000 CFS from the River. NISP would reduce the frequency of 3,000 CFS flushing flows from 6.5 years to 13 years. To meet the life-cycle needs of aquatic life a 3,000 CFS flushing flow ideally would occur every 3 years. As noted elsewhere in this AIS the conceptual mitigation plan included in the SDEIS addresses low fall and winter flows. Unfortunately, however, the mitigation plan includes no provision to address the reduction of peaking flows. Fish The Poudre River through Fort Collins supports cold water trout fisheries as well as native warm water fishes. These fisheries are valued by the community for their recreational importance and their role in conserving native plains fish populations. As noted in the morphology comments above, fish and aquatic insects rely on peak or “flushing flows” to maintain clean, mobile and diverse riverbed necessary to support their life cycle needs. The reduction of flushing flows is likely to affect the fisheries because this habitat maintenance occurs less frequently. More regular, continuous base flows (as opposed to peak flows) support fish through dilution of nutrients, chemical pollutants and temperature moderation. The proposed 10 CFS augmentation flow proposed by the SDEIS would represent an improvement over current low flow conditions in certain locations, especially those prone to extreme low flows and dry ups. It is, however, important to note that base flows for fish in the winter months of 20 to 35 CFS are more suitable for supporting trout survival. The SDEIS utilizes an industry-standard “2-D” habitat analysis to understand fish habitat availability. Unfortunately, the data analysis from the 2-D modeling utilizes a nonstandard and greatly oversimplified averaging approach. This unusual interpretation of the data ignores valuable details in the data and precludes opportunities to properly understand effects on various species (which is the intended application of the model). July 28, 2015 Page 7 The potential impact of NISP to the fisheries should be adequately and properly evaluated using accepted and transparent techniques commonly utilized for the 2-D analytical approach. Staff believes this approach is appropriate not only because it is the standard, but because it was recently used for one of the other major water projects and EIS’s in the state, Northern’s Windy Gap Firming Project. It also was recently utilized for development of an instream flow report on the Colorado River. Riparian and wetland vegetation The ribbon of vegetation along the River, often called the riparian forest or cottonwood woodlands, provides critical habitat for wildlife, filters excessive nutrients or pollutants from the waterways, reduces erosion and, constitutes a valuable recreational amenity. The Poudre River recreational trail alone attracts approximately half a million visitors per year. In addition to forest, riparian habitats are typically a mosaic of shrublands, wetlands, and meadows. A close relationship exists between River flows and the quality and extent of riparian habitat. In particular, moderately high flows that extend beyond the River banks saturate soils and maintain shallow groundwater levels. The NISP project will reduce the frequency of these moderately high flows and is the focus of staff’s review related to the riparian corridor. In the City’s 2008 comments to the DEIS staff expressed concern over inadequate analysis regarding potential impacts to wetland and riparian vegetation. The SDEIS includes a series of new analyses including impacts to groundwater, wetlands, cottonwood regeneration as well as overall habitat and long-term trends. Staff has extensive concerns regarding the interpretation of the analyses and the overall conclusions. A central element to Clean Water Act and NEPA implementation regulations is the ability to assess avoidance, minimization, and mitigation of impacts to wetlands across all project alternatives. The EIS used a remote sensing mapping approach to identify the locations of wetlands. However, field verification conducted for the CTP baseline report on Wetland and Riparian Resources demonstrated a low level of site specific accuracy (49% of sites checked in the field were changed to a different category). In 2012 the EPA and the City provided comments on this Baseline report and expressed concern over the use of this particular tool for identification of wetlands. The Corps written response stated this mapping tool would only be used to generally understand the extent and type of riparian areas along the Poudre. However, in the SDEIS it was used to identify wetlands. In the absence of a proper wetland delineation, the EIS should use a rigorous alternate approach or best available dataset. A National Wetland Inventory (NWI) dataset is available for the Poudre and should be used as it is specifically intended to identify wetland locations. Also of concern, the SDEIS applied an unconventional and biologically unsupported approach for understanding potential wetlands loss. The approach is not sensitive enough to predict subtle yet significant changes that could lead to complete shifts in habitat type. With respect to riparian areas, the SDEIS applies the Corps hydrology standard for wetlands (and specifically an inundation requirement of 50% of all years) to cottonwood woodlands. This application of a wetland standard to riparian forest constitutes a fundamental misunderstanding of this habitat type in a number of ways. Yet this misunderstanding is used as the basis for predicting no adverse impact to cottonwood woodlands along the Poudre. While the SDEIS concludes that there may little to no impact to wetlands and riparian areas, staff believe that the analysis is too flawed to draw accurate conclusions. In general, staff’s experience and research on the Poudre supports the view that the lower flows associated with NISP will narrow the riparian zone and lead to the loss of wetlands. July 28, 2015 Page 8 Air Quality and Climate Change NISP would involve pumping substantial amounts of water under the preferred and all alternatives. The storage of water under NISP would thus consume large amounts of electricity and thereby result in increased discharges of emissions to the air, including greenhouse gases that contribute to climate change. The recreational use of Glade Reservoir will also result in increased emissions from vehicular traffic. The additional sources of air pollution will occur in a region that already does not comply with ozone standards (nonattainment area). The resulting impacts include further harm to human health and the environment from regional ozone pollution and regulatory restrictions on economic growth (limits on air permits). Staff has some concerns regarding the adequacy of the analysis of these issues in the SDEIS. General Comments The overall narrative of the SDEIS is that, regardless of NISP, ongoing degradation of the health of the Poudre River is inevitable and irreversible. Staff, however, does not agree. Instead, the health of the Poudre River can be stabilized, maintained, and improved through deliberate, thoughtful, and strategic action similar to those the City has been taking. For example, the SDEIS describes a declining trajectory for riparian vegetation and forests (the SDEIS acknowledges NISP may accelerate the negative trajectory but does not quantify the trend). The SDEIS attributes the ongoing decline to an existing flow regime that no longer supports critical riparian processes. In contrast, however, City research and observations attribute this declining trend primarily to physical constraints imposed on the urban floodplain as well as an altered forest composition. Furthermore, staff believes that that with current flows, or otherwise deliberately managed high and low flows; the departure away from a biologically thriving river is not a foregone conclusion. The window of opportunity for maintaining desired amenities such as a world class fishery, a spectrum of River related recreation opportunities and an aesthetically pleasing river is still open. In addition to the description of a trajectory of decline, the SDEIS predicts that each component of NISP will only degrade the river slightly and therefore the overall impact is small. Staff is troubled by this logic. The sum of numerous minor impacts has the potential to be greater than any single impact. Moreover, as noted in this AIS there continue to be concerns related to technical shortcomings in the interpretation of the SDEIS analyses. Lastly, an overarching question that has not yet been addressed is to what extent NISP closes the window of opportunity for improving overall River health with environmental maintenance flows (both low and high) along with other management actions. Further, to what extent could NISP ensure that appropriate management actions are taken to sustain the future health of the River? In general, the proposed mitigation plan falls far short of what would be needed to alleviate the harms that NISP will cause or to improve the River from its current overall condition. ATTACHMENTS 1. Resolution 2008-082 (PDF) 2. Powerpoint presentation (PDF) ATTACHMENT 1 1 July 28 City Council Work Session The Northern Integrated Supply Project Supplemental Draft Environmental Impact Statement ATTACHMENT 2 2 General Direction Sought 1. Are there any questions about the Northern Integrated Supply Project’s impacts to the City? 2. Is there any further guidance from Council as to how the City should respond to the Supplemental Draft Environmental Impact Statement for the Northern Integrated Supply Project? 3 44 5 Fort Collins Loveland Water District About 25% of GMA boundary served by FCLWD Projected increase of about 2,400 taps in GMA by 2040 Demand increased of about 1,400 AF a year in GMA NISP participant for 3,000 AF firm yield 6 Halligan Water Supply Project 7 150 Years of River Development 8 238,456 108,206 198,990 85,552 0 50,000 100,000 150,000 200,000 250,000 300,000 Canyon Lincoln Annual Acre Feet Current Flows and NISP Flows Current operations 10 0 200 400 600 800 1000 1200 5/1 5/15 5/29 6/12 6/26 7/10 7/24 Flow* in cubic feet per second Average Peak Flows at Lincoln Gage under Current Operations and NISP Current Operations NISP *Flow is presented as the 7-day average 11 Low Flow Mitigation Larimer & Weld Canal Timnath Inlet Canyon Mouth 12 Low Flow Mitigation 13 8.5 CFS at Lincoln Street 14 General Findings • Improved EIS • Benefits of the Common Technical Platform • Conceptual Mitigation Plan 15 General Findings • Continued concerns – Water Quality – Environmental Issues – Inadequate Mitigation 16 Water Quality • Consists of key chemical constituents and temperature • Water quality is highly regulated • Even very small changes can cause serious regulatory and infrastructure impacts • The SDEIS indicates that there will be water quality changes 17 Water Quality Model • SDEIS acknowledges that it is missing a critical quantitative water quality model • Model will not be available until the Final EIS • Makes it impossible for the City (or the Corps) to properly understand potential impacts to our facilities or to understand what mitigation may be necessary 18 Water Quality: Wastewater • Flow regime is critical to the City’s wastewater operations and permits • Lower flows are likely to diminish water quality • Even small changes to water quality can have significant impacts to the City’s bottom line • Mitigation plan for 10 CFS November thru April – water is diverted at Nix Farm 19 Water Quality – Natural Environment 20 Operations • The SDEIS preferred alternative features a 10 CFS fall and winter release • None of the other alternatives includes this release and staff believes they should • Staff is investigating a modified Cactus Hill alternative that could provide substantially more streamflow through Fort Collin 21 Recreation • The SDEIS describes a reduction in “boatable” days from 54 to 35 • Number of days when the proposed kayak park would be at optimal flows would be reduced • Design of waves would need to take into consideration reduced flows 22 Recreation • SDEIS indicates that flatwater recreation at Glade would mitigate loss of river recreation • In general, staff is concerned that reduced flows will harm the community’s overall recreation and visitor experience 23 Flushing Flows 24 Flushing Flows • SDEIS describes 10,000 CFS as needed for flushing flows • The City’s Poudre River Ecosystem Model places that number at 3,000 CFS • SDEIS indicates the frequency of 3,000 CFS flushing flows would be reduced from 6.5 years to 13 years 25 Fish Flushing flows are important Proposed 10 CFS fall and winter flow is helpful 20 to 35 CFS more likely to support trout 26 Fish • New sophisticated 2-D modeling • SDEIS, however, uses a non-standard method to interpret the data • Staff recommends that the approach to the 2-D modeling be revised • Same approach that was used for Northern’s Windy Gap project 27 Riparian and Wetland Vegetation • Critical habitat for wildlife and nutrient cycling • Critical for recreation and aesthetics • Close relationship between flows and vegetation 28 Riparian and Wetland Vegetation • Staff has concerns regarding the adequacy of the SDEIS analysis and conclusions • Low level of staff confidence that the prediction of minor impacts to forest and wetlands is correct • The impacts to the vegetation of the river are likely to be more significant 29 30 Mitigation • Fall and winter low flows • Bypass structures at diversions • No peak or flushing flow mitigation 31 Final Thoughts • Narrative of SDEIS is one of inevitable decline • With current flows, or otherwise managed high and low flows – a biologically resilient river is possible