highlight some of the best feedback from the 162 pages submitted by various
departments and agencies to the Boulder County Planning Manager on Denver
Water’s 1041 Application. We encourage you to view all of the comments that can be found here. You can also read all 1,967 pages of comments from individuals
here! It is encouraging to see so many organizations and individuals stepping up to clearly detail the issues with the application and the project as a whole. GO TEAM!
Boulder County Engineer
2-1 of the 60%DM indicates that truck traffic will not be expected to travel
through the city of Boulder. However, p. 3-4 of the 60%DM states the route of
truck traffic for tree removal is expected to travel on SH 93 in order to reach
the city of Longmont as its final destination. As such, travel through the city
of Boulder would be unavoidable.
FERC hydropower license requires construction of the project according to
specified deadlines and milestones. The applicant needs to provide a concise
schedule for review prior to approval of the 1041 Permit
Plans Examiner Supervisor
building permits, plan reviews and inspection approvals are required for all; temporary
structures, permanent structures and electrical equipment that are part of this
proposal. This includes but is not limited to; the dam control building, the
quarry operations, construction of a temporary concrete batch/production plant,
aggregate processing plant, batch plant offices, crusher office, pump station
building, relocated or reconstructed maintenance building, powerhouse, testing
lab building, receiving office trailer, office complex trailers, staging area
trailers, shop trailers, storage area trailers, all recreation facilities, any
retaining walls greater than four feet (measured from the bottom of the footing
to the top of the wall), and fences greater than 6 feet tall.
Planning Division Manager
recognizes that the nature and extent of the proposed project involves the
potential for significant potential for environmental damage (i.e., loss of
natural resources, alteration of wildlife habitat, changes to groundwater,
increased disturbance along roadways, etc.) and so requires Denver Water
provide specifics related to less environmentally damaging alternatives
inconsistent information, out-of-date data, and lack of information contained
in the application related is insufficient for staff to conduct a comprehensive
review and analysis of the code criteria. Staff understands Denver Water’s
application materials rely heavily on materials submitted for federal
permitting processes but points out that the Boulder County land use
application and review process is significantly different from those federal
processes. Based on reviews conducted in the initial referral period staff
finds significant additional information is necessary before the application
can be considered complete.
- The out-of-date nature of the data and
information used for the applicant’s analysis presented in application
materials does not allow staff to conduct a thorough review and analysis of the
- Multiple phases of construction are proposed by
the applicant. Updated plans must be provided as part of the approval of this
1041 permit which reflects activities associated with each phase of
construction, including, but not limited to: traffic impacts, trail
construction, construction staging and parking, staging locations, erosion
control and stabilization of disturbed earth, cut and fill locations for earthwork,
grading and drainage plans.
traffic estimates must reflect actual conditions more so than outlined in the
60% TIA, which included a traffic count conducted in December 2015, and were
adjusted by 10 trips to and 10 trips from the site to account for seasonal
differences. Staff does not feel that the recreational traffic estimates
accurately reflect the current conditions, nor the peak recreational traffic
during the summer months and must be updated.
Community Planning and Permitting Long Range Planner
- Denver Water’s Gross Reservoir Expansion Project
application (the application) dated 9/21/20 is a 370 page document which then
includes multiple exhibit documents which mustbe referenced to obtain pieces of
information not included in the application. These exhibit documents are each
100s of pages and present different information than is presented in the application.
The application should provide complete summary information of the detailed reports
provided as exhibits. The application should be amended to provide all relevant
information in a complete and consistent manner so that it may be understood
when reviewed by agencies, the public, and decisions makers.
- Denver Water’s need for the project is discussed
in an 18 year old Integrated Water Resource Plan (2002)… and state “the problem is not lack of
overall water supply…but unequal distribution of the available water. That is,
Denver Water currently has adequate water supply in its supply systems but not
enough water is available for treatment at the Moffat plant” …The Moffatt
Treatment Plan is being replaced by a new plant at Ralston Reservoir so the
conclusions of the 2002 IWRP which are based on the problems with the MTP are
hard to understand given the changes in the Denver Water system Neither the EIS
or the 2002 IWRP reflect the new Northwater Treatment Plant next to Ralston
Reservoir, the system analysis is out of date. Additionally, much of the
analysis and rationale for the project is based on a system analysis where lack
of available water at the Moffatt Treatment Plant is the critical flaw being
resolved by this project. Updated materials reflecting a more accurate picture
of the Denver Water system should be provided.
materials also lack information related to the proposed project’s potential
impacts on climate change. Climate change is an issue identified by Boulder
County elected officials as one that is significant. County Commissions have
consistently instructed staff to review applications with an eye on proposed
projects’ potential impact on climate change and to recommend conditions of
approval intended to mitigate any potential negative impacts. Denver Water’s
application materials do not address this issue in any detail, and staff
requests additional, detailed information related to the potential impacts of
the Dam and Reservoir Expansion project on climate change.
- As proposed Boulder County bears a significant
burden to meet the needs of Denver Water yet the application fails to describe
any actions by Denver Water which attempt to relieve this burden and locate the
impacts of the water utility needs within the Denver Water service area meaningful
conservation and land use planning programs. Given the lack of information and
the concerns identified it is difficult to find the application on compliance
with Comprehensive or the Land Use Code.
Floodplain Program Planner
review of the application materials revealed that the applicant has not
provided a quantitative analysis of the project’s impact on regulatory base (1%
annual chance) flood discharges, flood elevations, and floodplain extent on
South Boulder Creek. Without a quantitative analysis based on regulatory data,
the county cannot evaluate the impacts of the project on the regulatory floodplain.
Gilpin County Board of County
Gilpin County Board of County Commissioners expresses their opposition to the
Gross Reservoir Expansion Project. Impacts on Gilpin County and other eastern
slope communities have not been adequately considered and addressed.
County requests more specific information about the planned routing of trucks
accessing Gross Reservoir to and from both the east and west sides of the
project. Jefferson County’s concerns include the noise and traffic impact of
trucks to unincorporated areas of Jefferson County and incorporated areas
including the cities of Golden, Arvada, and Wheat Ridge.
Nederland Board of Trustees
oppose the project and respectfully request that you (Boulder County) deny it.
Boulder County Parks and Open
concludes that the local impact of the proposal does represent a significant
loss of wildlife habitat for species remaining in the area. There are also no conclusions or even
discussions about the project’s likely impacts on the county’s wildlife species
of concern. ” In the instances that field work was completed for species, the
surveys for many of those appear to be about 15 years old. The applicant shall
update the Recreation Management Plan for the area and address: how the future
recreation sites in the project area will accommodate increased visitation;
measures to reduce traffic on local roads by recreationists; input from local
stakeholders including BCPOS; and the proposed BCCP regional trail in the area.
has never been a project with such a magnitude of impacts since before the
county’s first Comprehensive Plan was written in 1978, 42 years ago. The
application (page 65) states that “Denver Water has concluded that the Project
is consistent with the [Boulder County] Comprehensive Plan.” Staff disagrees;
the proposal is not in conformance with the Comprehensive Plan.