[Note added by SaveChatfield.org: The following letter about Chatfield Water Reallocation was shared with us by a local resident concerned about proposed changes to Chatfield State Park.]

August 2, 2012
Highlands Ranch, CO 80130

U.S. Army Corps of Engineers, Omaha District
ATTN: Chatfield Water Reallocation: PM-AA
1616 Capitol Avenue
Omaha, NE 68102-9857

I am writing to express my strong opposition to the Chatfield Reallocation Project, and conclusions reached in the recently released Draft Feasibility Report/Environmental Impact Statement (FR/EIS). The U.S. Army Corps of Engineers has worked on this project since 1994, and the 15-member consortium of proposed water users has also had also ample time to prepare its position, which is incorporated in the project proposal. However, the FR/EIS only came out for public scrutiny in early June and the public meetings took place a few weeks later. People who regularly use Chatfield are a varied group and need time to digest the 2600-page FR/EIS, organize themselves and formulate responses. The FR/EIS being issued with a short 60-day public comment period (now extended slightly) gives the impression of a rush to judgment and a hidden agenda to advance the project quickly no matter what. The Corps should not sacrifice its integrity as an impartial arbiter in this way; public comment should be extended to 180 days.

Similarly, even a quick scan of the FR/EIS preferred alternative gives the clear impression that the present interests of the few must be sacrificed for the largely future good of the many. But we who use and love Chatfield State Park are not few – we are 1.6 million visitors annually, the largest number for any Colorado state park. Our voices need to be heard. This project would effectively destroy most of the recreational and wildlife-related activities that many thousands of us in the south Denver metro area regularly take advantage of at Chatfield, at a time when – as the FR/EIS points out – the area’s population is projected to increase substantially and all parkland will be subject to heavier use. Chatfield is one of the very few places in south Denver where families can give their children exposure to prairie and wetlands in a large setting. After the project, it would be a wasteland by comparison. Alternatives to the destruction of Chatfield as a park exist but are not evaluated seriously in the FR/EIS.

Chatfield is now a unique, 5400-acre natural jewel, with 43 acres of mature cottonwood trees and rich wetlands that shelter a large variety of wildlife: 350 bird species (the National Audubon Society has designated Chatfield an Important Bird Area), butterflies and insects, bear, coyote, elk, deer, red fox, raccoon, porcupine, beaver, rabbits, prairie dogs, reptiles, amphibians and ten species of fish – many of which are prized by area fishermen. As the Colorado State Parks and Wildlife (CSPW) Report on Anticipated Fish and Wildlife Impacts (of the project) states, almost all of these wildlife species would be adversely impacted or eliminated at Chatfield by the project, largely from cutting down 296 acres of cottonwood trees (Denver Post editorial, July 29), coupled with drastic fluctuation in water levels. Fishermen will note that the CSPW report lists eight separate ways that aquatic species (fish) could be negatively affected, with walleye and smallmouth bass mentioned specifically. Chatfield water quality would suffer with increased sediment, lower dissolved oxygen and increased levels of mercury, phosphate and ammonia, according to the CSPW report.

The Corps’ proposed efforts to mitigate this wildlife devastation appear vague and unsatisfactory. Enhancing land within the park presumably means growing more trees to replace the 296 acres cut down, but the growth of these trees would take decades – the wildlife that depends on forest cover now would be long gone. And Chatfield’s current cottonwood forests exist because the lake’s water level now fluctuates only five feet. It would be hard for new trees to grow in this semi-arid climate if most of the time (post-project low water) they are more than 17 feet above water. The forests, with all their rich diversity of wildlife, would be unlikely to grow back. The other proposed mitigation effort, conservation easements on private property adjacent to the park, may have some marginal benefit for wildlife, but visitors to the park would lose completely the wildlife-viewing opportunities they now so abundantly enjoy.

Wildlife experts on birds, reptiles and amphibians presented their well-documented opinion, at the public meetings, that studies in the applicable FR/EIS appendices were so hastily conducted and inaccurate as to be worthless. Many dozens of bird species present at Chatfield were left out of the study, and well-documented bird counts done over past years, throughout the year, from multiple park locations, were rejected in favor of a cursory two-day bird count for the FR/EIS. The expert on reptiles and amphibians pointed out that FR/EIS information on them came from a field guide with no specific reference to Chatfield, and that it included many Southwest American species not found in the park. The Northern Leopard Frog, designated a Species of Special Concern in Colorado, was also left off the FR/EIS list even though Chatfield is one of the very few places it is currently found. This rushed treatment of critical wildlife species casts substantial doubt on the Corp’s objectivity and commitment to preserving wildlife.

The only way to even partially mitigate the project’s widespread destruction of park wildlife would be to acquire 587 acres of replacement land, a concept endorsed by state park officials (Denver Post, May 23). But where is this land to be found? Postal zip code 80125, where Chatfield is located, has only four land parcels larger than four acres currently for sale, and only one of them has any riparian habitat. To acquire 587 acres in zip code 80125 – almost entirely in widely separated lots that lack woodlands – would cost, with current average real estate valuations, over $23 million (SaveChatfield.org).

The FS/EIS downplays and even conceals the two main project results that would effectively ruin Chatfield for most wildlife habitat and recreational use: cutting down 296 acres of cottonwoods near the present lake and river shorelines, leaving a denuded park landscape virtually devoid of shade, and the “bathtub ring” effect that raising and lowering the reservoir’s water level by an additional twelve feet would cause. Chatfield water levels would be low – around the present level – most of the time, since the 15 water-user consortium would have very junior rights to South Platte River water. Only in heavy snowpack years, perhaps three out of ten, would the reservoir fill up.

Most of the time, the post-project view of Chatfield would include hundreds of acres of mudflats, covered at times with weeds. The CSPW report adds that increased shoreline exposure would lead to soil erosion, increasing Chatfield’s overall ugliness and hurting water quality. The overall effect is that of taking a beautiful, well-developed, popular park with a myriad of recreational and priceless wildlife resources, and turning it into a giant water bucket so unattractive that few would want to visit. Any trees planted post-project would be of absolutely no benefit to today’s 1.6 million annual Chatfield users, who have paid for the current recreational facilities with their park fees and state tax dollars.

The recreational uses that now make Chatfield so unique and well loved by the public – camping, picnicking, swimming, boating, sailing, fishing, walking, running, horseback riding, hot air ballooning, wildlife viewing and photography – would almost all suffer negative impacts, many severe, from the project. Roads, trails and current recreational facilities, including the swim beach, would have to be moved and rebuilt. The 24 miles of Chatfield trails so heavily used now by walkers, runners and cyclists would no longer have the shady resting points that these park visitors now enjoy. The swim beach, so beloved by families with children on hot summer days, would have its new restrooms 600 feet from the water’s edge during prevailing low-water periods, a very long way to go across hot sand.

Picnic areas all around Chatfield that are now at the water’s edge, amply shaded by full-grown cottonwoods, would similarly be separated from the lake most of the time by hundreds of feet of mud flats. The only shade families would enjoy on 90+ degree summer days would be just-planted, scrawny saplings; who knows how many of those would survive? And of course, the hundreds of dedicated bird watchers who now flock to Chatfield to view the richly varied bird species that make their home at Chatfield or use it for migration – including the majestic bald eagle and great blue heron – would just be out of luck.

The FR/EIS visual simulation posters deceptively show the swim beach and three other views at high-water level, which they would rarely have. They also avoid showing the park’s rich cottonwood forest in spring, summer and fall, as park users currently enjoy it. The simulations used at the public meetings were even less accurate, showing (dying?) saplings poking up out of high water. In consultations prior to the FR/EIS’ issuance, photo simulations from many points around the park – showing it denuded of trees at typical low-water levels – were submitted for inclusion in the study, but were rejected. “Before photos” should be taken now, with the trees in full summer foliage, to compare with accurate “after-project” simulations that so far have been hidden. As the Denver Post editorial of May 29 also points out, far more should be done than a few widely dispersed stakes with colored flags to let park users concretely understand just how much forest would disappear. Again, the Corps’ integrity as an impartial arbiter is called into question by the use of such manipulation to deceive the public.

Chatfield users who enjoy the lake waters would be equally and adversely affected. The lake now hosts a harmonious combination of powerboats, jet skis, water skiers and inner tubers, fishing boats, sailboats, canoes, kayaks, sailboards and paddleboards. No-wake zones ensure calm water for smaller vessels. On any summer weekend, hundreds of people in vessels of all sizes are to be seen enjoying the lake. Many boaters probably received the FR/EIS notice that was given out over a short period in June, shrugged and thought, “So what, a bigger lake is better for boaters.” But the CSPW report points out that the shallow waters created by flooding would actually increase boating hazards, and would create no additional boating acreage for motorized vessels.

More important, the beautiful shoreline environment now seen from the water, Chatfield’s towering cottonwoods and sand beaches, would be destroyed. The trees would be gone, or more accurately, visible as ugly stumps poking up from the hundreds of acres of mudflats that would usually surround the water. The project would also eliminate the existing south shore marina facilities, and as the CSPW report and Denver Post (May 23) point out, a new, post-project marina would likely not be feasible due to flooding of the existing breakwater and surrounding land. Few people would find Chatfield a desirable boating venue; instead they would likely go to Cherry Creek Reservoir, the only other boating area nearby – adding to that park’s marine overcrowding.

The CSPW report also states that more low-flow and no-flow water days below Chatfield Dam could be expected as a project result. The many wildlife-viewing and recreational opportunities along the South Platte Greenway Trail, to the Carson Nature Center and beyond, could be as severely affected as those in the park itself. Citizens of Littleton, who consider the South Platte Greenway one of their premier natural environments, are beginning to understand that the project’s detrimental effects would not be limited to Chatfield.

The fundamental FR/EIS justification for choosing Chatfield water reallocation over other options was its lower cost. This may no longer be true. The project’s projected cost has jumped from $100 million (Denver Post, May 23) to $184 million (Denver Post, July 17) – an 80% increase. Add to that $23 million needed to buy the 587 acres nearby desired by state park officials for even partial mitigation of damage to wildlife, and the new total goes well over $200. Also, subtract much of Chatfield’s current $9.5 annual revenue because its degraded, post-project environment, for most users, would no longer be worth the admission price. My family would not spend $80 on a Colorado State Parks annual pass if Chatfield became that wasteland, and we are not alone.

A wider range of alternatives and their costs needs to get real consideration and evaluation. By all means, count on expanding water storage in nearby gravel pits. But in view of the costs listed above, the Corps needs to consider more carefully a range of other proposals suggested to increase available water: conservation, aquifer recharge and use of Reuter-Hess Reservoir. Without being mean-spirited, I would also question whether some of the 15 water users in the consortium should be allocated Chatfield water storage at all. These are new claims on South Platte River water, above and beyond existing users’ water rights. Is it fair that Chatfield State Park as we know it should be destroyed so that Perry Park Country Club can water its golf greens? And with all respect to the Western Mutual Ditch Company, if Weld County farmers have overdrawn their own groundwater perhaps they need to reconsider whether water-intensive irrigation makes sense in that part of Colorado.

Another financial angle to consider: if so much of the needed water is for future growth in our area, maybe the newcomers who need the water should pay more of its cost. Water use above current levels could be charged at a higher rate, just as residential water users in Highlands Ranch Metro District pay higher rates if they exceed an average of past water use (in some cases before we purchased our properties). That would generate additional revenues so that the least-cost option – destroying Chatfield State Park as it now exists – would not be necessary. Cheapest is not best in this case, and in fact the Reallocation Project may not be the cheapest alternative.

Many thousands of us are not prepared to roll over and see our favorite park destroyed by a big-money stealth campaign, which appears intended to “fix the deal” before the public is even aware of it. I request that the following concrete measures be taken:

Thank you for your consideration,

Jeff Irwin

Senator Mark Udall
Senator Michael Bennet
Congressman Michael Coffman
Governor John Hickenlooper
Colorado State Parks

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