[Note added by SaveChatfield.org: The following letter about Chatfield Water Reallocation was shared with us by James Rouse, a Colorado native who has been an outdoor enthusiast since childhood. Mr. Rouse has hiked, camped and bird watched all over the state and climbed about half the 14ers.]
Centennial, CO 80121
August 27, 2012
Col. Robert Ruch, Commander
US Army Corps of Engineers, Omaha District
1616 Capitol Ave.
Omaha, NE 68102-4901
RE: Chatfield Reservoir Storage Reallocation FR/DEIS
Dear Col. Ruch:
I am a frequent user of Chatfield State Park. It is the State Park that is closest to where I live. I use it for hiking, bird watching, sight-seeing, wildlife viewing, picnicking, etc. I would like to submit the following comments on the Chatfield Reservoir Storage Reallocation FR/DEIS.
I attended the public hearing held at the Wildlife Experience on June 25, 2012, where I first became aware of the massive adverse impact the Chatfield Reservoir Storage Reallocation would have on Chatfield State Park. A common theme from the water providers who spoke was that Chatfield was a readily available “bucket” for them to store their water in when they might have water to store. It was admitted that in most years the water providers would have no water to store and that would leave a bath tub ring around Chatfield. However, people do not come to Colorado for its “buckets” and “bath tub rings”. They come for the wildlife, scenery and recreational opportunities, all of which would be destroyed at Chatfield by the proposed Chatfield Reservoir Storage Reallocation, particularly if the water providers’ preferred alternative #3 is adopted. The proposed Chatfield Reservoir Storage Reallocation causes too much environmental damage and loss, for too little return. I oppose it for the reasons set out hereinafter.
1. The Draft Environmental Impact Statement (“DEIS”) acknowledges that riparian corridors habitat provides crucial stopover habitat for birds during migration and nesting areas for many breeding birds. Draft EIS at pages 3-47 through 3-49. Indeed, Chatfield has been designated an Important Bird Area (“IBA”) by the National Audubon Society. Draft EIS at page 3-49. The proposed Chatfield Reservoir Storage Reallocation would destroy this crucial stopover habitat, and the stopover habitat will not be replaced within our life time, if ever.
2. According to the DEIS, the Chatfield riparian areas have the largest populations of breeding American Redstarts and Least Flycatchers in Colorado. DEIS at page 3-49. This will be lost, and not replaced under the proposed mitigation plan.
3. According to the DEIS, Chatfield is important to endangered or threatened species in Colorado. DEIS at pages 3-49 & 3-50. This will be lost, and not replaced under the proposed mitigation plan.
4. According to the DEIS, Chatfield area contains rare or unique habitat that holds important species or species assemblages largely restricted to a distinctive habitat type. DEIS at page 3-50. This will be lost, and not replaced under the proposed mitigation plan.
5. According to the DEIS, significant numbers of birds concentrate for breeding during migration, or in winter. DEIS at page 3-50. This will be lost, and not replaced under the proposed mitigation plan.
6. According to the DEIS, the Chatfield site is important for long-term research and/or monitoring projects that contribute substantially to ornithology, bird conservation, and/or education. DEIS at page 3-50. This will be lost, and not replaced under the proposed mitigation plan.
7. The mitigation plan proposes to spread out the concentrations of birds and birding habitat along several miles of Plum Creek. Common sense would indicate that the unique situation of concentrated birds and bird habitat at Chatfield cannot and will not be replaced under the proposed mitigation plan.
8. The riparian habitat at Chatfield will be strung out into much smaller areas over a length of many miles under the proposed mitigation plan. Will large flocks of migrating birds be able to use the strung-out smaller areas to the same extent as the large concentrated area of habitat the currently exists at Chatfield? I could not find an answer in the DEIS. However, the DEIS does acknowledge that the greatest adverse impact is to migratory birds. DEIS at page 4-84. While the DEIS claims that the EFU’s lost will be replaced by a like number of EFU’s, there does not appear to be any study of or guarantee that the migratory birds will be able to actually use the replacement habitat to the same extent that they now use Chatfield.
9. Under the proposed mitigation plan, most of the mitigation for destroyed riparian bird habitat will be located outside of Chatfield State Park on private lands. Appendix K to DEIS at page 32. This will result in substantial acreage now available for bird watching being lost forever to the public because of the public’s inability to access the replacement bird habitat on private land. The DEIS does not contain any mitigation for this loss to the public.
10. The DEIS does not appear to have any mitigation planned for habitat lost for grassland birds.
11. According to the DEIS, if alternative 3 (as preferred by the water providers) is adopted, the maximum pool of water would not be reached 82% of the time and fluctuations would be up to 21 feet. DEIS at page 4-36. This is due to the very junior position of the water rights of the water providers proposing the reallocation. This means that the unique habitat now existing at Chatfield would be destroyed and exchanged for a large and unsightly “bath tub ring” the vast majority of the time, just so a relatively small portion of the population in the Front Range could have extra water only in wet years when they need it least.
12. The DEIS itself states that under the proposed Chatfield Reservoir Storage Reallocation plan “large mammals would have fewer areas of Chatfield providing cover and woody foraging areas.” DEIS at page 4-83. Further, the 43 acres of mature cottonwood trees are a special feature of Chatfield State Park. The DEIS goes on to state that:
This area of mature cottonwood forest offers habitat for birds that is rather unique within the Denver Metro area and possibly along the South Platte River. Loss of this habitat for songbirds would cause long-term adverse impacts that are not easily mitigated. Beyond loss of currently mature cottonwoods, there would be loss of additional cottonwoods that would become mature in the next 50 years.
See DEIS at page 4-83. The proposed mitigation plan will not compensate for this loss. Indeed, the loss cannot be mitigated.
13. Where will the migratory birds go while the private land for mitigation is being acquired and converted to replacement riparian wet lands? The DEIS does not say.
14. Even though mitigation will supposedly be accomplished in six years under the proposed mitigation plan, it will take much longer to replace the resources lost at Chatfield. Obviously, 100-year-old cottonwood trees will not be replaced in a mere six years, or in our lifetimes for that matter.
For the foregoing reasons, I request that you not approve the proposed Chatfield Reservoir Storage Reallocation plan. Chatfield State Park is simply too valuable of an asset to our community. The water providers need to find somewhere else to store their water.
James P. Rouse
cc: Gov. John Hickenlooper