Letter: 45 days not enough time to review Moffat EIS
May 6, 2014
To the Editor:
An Open Letter to our County Commissioners: Grand County voters need more time to review Denver Water's Final Moffat EIS.
Please join us requesting the U.S. Army Corps of Engineers (Corps) extend the comment period for the Final Environmental Impact Statement (FEIS) for Denver Water's proposal to increase trans-mountain diversions from our Colorado River headwaters. The current period is 45 days, ending June 9, 2014, which is just not long enough. We need 90 more days because:
1. The FEIS is huge, with 27 documents and over 4,200 pages of text, tables and figures. (The Table of Contents alone is 60 pages long, and with appendices the document is 11,000-plus pages). In order to see how Denver responds to Grand County's comments dated March 17, 2010, for instance, we asked for a printed copy of the FEIS but the Corps' response was that "it's too big to print." If it's too big to print, it's too big to review in only 45 days.
2. The FEIS is complex, taking four years to complete with significant new information unavailable before. Your own review said the Draft EIS "understates the magnitude of depletions caused by the Project, misrepresents their timing, used flawed methodology and arbitrary screening criteria…and fails to ask or evaluate critical questions." Expert teams will work full-time to make sure your concerns are addressed, but to expect hard-working citizens, many of whom are volunteers without technical expertise, to review in 45 days is unfair.
3. We agree that Denver's proposal is highly controversial with potential to impact hundreds of miles of rivers and millions of people on both sides of the Continental Divide. We all have a stake in these decisions and should have enough time for a thoughtful review and discussion with neighbors.
4. The FEIS doesn't include your Mitigation and Enhancement Coordination Plan since that agreement is new. Anyone wanting to know how it mitigates the loss of more than 80 percent of our native headwater flows during the irrigation season will have to do the math themselves, not an easy task in even 120 days.
An extended comment period would give Grand County voters time to participate in these important Federal decisions by reviewing and commenting on data and analyses in the FEIS. Please support democracy in action by asking the Corps for an additional 90 days for public comment.