Moffat Firming & Windy Gap Projects

SURPRISE! We Agree With Denver Water

Science or Politics? July 22, 2014

Mr. Elliott’s letter of July 16 regarding the Moffat Firming Project purports to present a scientist’s point of view, but reads like a politician’s campaign, right down to unsupported accusations of “backroom dealings” and catchy sound bites that completely misrepresent the facts and the views of those who support a solution for the Moffat Firming Project.

Supporters of a solution, including the County, care deeply about developing accurate, scientific information about our rivers and the impacts of Moffat and other issues impacting our rivers. That is why they have invested millions of dollars to develop real information that documents stream conditions today so we can tell whether conditions in the future get better or worse. That is why the have reached an agreement (the Mitigation and Enhancement Coordination Plan or “MECP”) with Denver Water to continue to collect real information and do something to not only prevent deterioration, but to improve current conditions.

Significant amounts of water, money and other resources have been committed to protect and improve stream conditions as part of the MECP. Mr. Elliott omits mention of these benefits so that he can make his point — for a true list of MECP benefits, please go to Mr. Elliott and his Front Range clients can continue to dedicate their resources to politics and to more technical “models” that generate controversy and consultant fees but don’t get us any closer to a solution for the rivers. Those who support a solution will be here protecting and improving our streams long after Mr. Elliott and his clients move on to other projects.

Kirk Klancke

Please be sure to see the Mitigation & Enhancement Plan Summary lower on this page. It contradicts Mr Elliot's comments.

Call for Action April 28, 2014

In the early 1900’s, long before any environmental regulations were in place, Denver Water  started diverting water from the Fraser River Valley through the Moffat Tunnel to supply water to the Front Range. Presently, they divert over ½ of the flows of the Fraser River and its tributaries. DW is seeking a Federal permit to triple the size of Gross Reservoir so that they can divert an additional 20% of their water rights in the Fraser Valley. 

For the last 8 years, Trout Unlimited has been working hard to make sure that approval of the Gross Reservoir expansion doesn’t happen unless the Fraser River and its tributaries are protected and their degraded condition improved. After years of diligent work, TU, Grand County and Denver Water have reached an agreement on a package of measures designed to improve stream conditions and prevent additional impacts from the Moffat Project. This agreement is called the Grand County Mitigation and Enhancement Plan and is commonly referred to as the MECP. 

Trout Unlimited now believes that, if included as a requirement of the federal permit, the mitigation and enhancements included in the MECP give the Fraser River a better chance for stream health than not having the project go forward. To help TU save the Fraser River, we need everybody who wants to see the Fraser flow  healthy for generations to take a few minutes to write the US Army Corps of Engineers and ask them to make Denver Water’s compliance with the MECP a condition of the federal permit. 

The MECP requires DW to be involved in stream monitoring and adaptive management for as long as they divert. This language is our best chance to maintain healthy rivers in the Fraser Valley. Please be part of the solution and send in a letter now and for the rest of your life you will be able to proudly say that you helped save the Fraser River. Be sure to copy your letter to the list provided so that your elected officials know that you are speaking up and what you’re saying.  

Ready to call, write or send emails? For suggestions on what to say and names and addresses of the right people to contact, go to our What to Do Today page by clicking HERE.

Moffat Firming & Windy Gap Projects

The Moffat and Windy Gap Firming Projects are intended to "firm up" the rights of water owners. As is usually the case with water-related subjects, there is plenty of controversy surrounding the proposals.

The latest TU comments regarding the Final Environmental Impact Statement (FEIS) for these projects (as of February 7, 2012) are from TU's legal council, Mely Whiting. They make a strong case that not enough is being done to protect the rivers. These documents are a "must read" for everyone concerned about the future of our rivers. For the complete letter to the Bureau of Reclamation and Department of the Interior, click here. The supporting tables are available here.

To see the official Bureau of Reclamation December 1, 2011 FEIS (Final Environmental Impact Statement) on the Windy Gap Firming Project, click here. To read TU's December 5, 2011 comments on why the FEIS doesn't go far enough to protect the Colorado and the Fraser, click here. For a link to Denver Water's information on the Moffat Collection System Project Update, click here.

Below, we've posted some of our thoughts relating to the Moffat Firming Project. We encourage you to be informed about this important issue, analyze the information and make your opinions known to your local, state and national representatives, the Department of Wildlife, EPA, Denver Water and others. Write a comment to your local papers. Write letters to anyone who will listen and express your opinion.


The Problem:

  • Denver Water presently diverts 60% of the Fraser River in the Fraser Valley through a trans-basin diversion. A trans- basin diversion is a 100% consumptive loss to the river.
  • Denver water, through their proposed Moffat Firming Project will divert another 20% of the Fraser River. The 20% additional diversion will be taken from the Spring flushing flows.
  • Flushing flows are essential to remove sediment which can smother the spawning beds and bug life that fish need for their food source. Reduced flows in the Spring will also extend the period of time that the river experiences high temperatures. The flushing flows are also vital to the recharge of the riparian plants. 3% of Colorado is riparian while 90% of the wildlife relies on the riparian zone.
  • Denver Water has written a draft Environmental Impact Statement that recognizes only minor impacts and proposes no mitigation. Through the Wildlife Commission hearings, Denver Water has shown no compromise on their position and clearly intends to divert the flushing flows for perpetuity without addressing the impacts that will result to the river, the riparian zone and the economy in Colorado that relies on a healthy environment attracting people to our State.

The Solution:

  • The future of Colorado’s rivers should rely on science and not the political game that the trans-basin diverters use to avoid addressing the impacts that they are the direct cause of.
  • The large trans-basin diverters should be held by permit requirements to be responsible for a comprehensive stream monitoring program that tracks the changes in stream health.
  • If scientific study finds a decline in stream health conditions, the large trans-basin diverters need to be held accountable for repairing the damages that they have caused to Colorado’s environment. This responsibility needs to be tied to their permit as a permanent responsibility to the river.
  • Potential solutions to declining stream health are:

1.      Stream restoration improvements

2.      Curtailed diversions when stream temperatures are within 1 degree of the States acute and chronic stream temperature standards.

3.      Extended flushing flow periods to satisfy sediment transport needs.

4.      Purchase of additional water in the watershed to be converted to in stream flows to add additional water during low flows.

Windy Gap Final Environmental Impact Statement

On August 1 and 2, the 1041 review process had it's most recent review. For the SkyHi News article on the latest step in the process, click here. To view the entire Bureau of Reclamation document click on Statement.

Mitigation & Enhancement Plan Summary




February 27, 2014



     After years of dispute over Denver Water’s proposed Moffat Collection System Project (Moffat Project), Trout Unlimited, Grand County and Denver Water have reached an agreement on how to protect the Fraser River and its tributaries from the project’s impacts.

·         Denver Water currently diverts water from the Fraser and Williams Fork basins through an extensive network of tunnels and pipes that funnel water to the Moffat Tunnel for delivery and use in the Front Range.  Water funneled through the Moffat Tunnel is stored in Gross Reservoir.  It is estimated that over 60 percent of the native flows of the Fraser River are currently diverted through the Moffat Tunnel on an annual average basis.  The proposed Moffat Project would triple the size of Gross Reservoir, allowing Denver Water to increase its diversions.

·         The Fraser River system supports valuable trout fisheries that attract thousands of anglers annually and help support the local economy.  Trout Unlimited has fought for years, along-side Grand County, Fraser River land and business owners, and other partners, for measures to ensure that, if built, the project will not further degrade these valuable fisheries.  Of primary concern to Trout Unlimited has been the potential for the project to worsen already high stream temperatures and to exacerbate existing sediment problems by reducing available peak flows.  Above all, Trout Unlimited has been concerned that existing models cannot properly predict impacts in a stream system that is already so depleted, and TU has consistently called for a monitoring and adaptive management program capable of detecting and preventing unanticipated impacts.    

·         Our efforts are paying off.  In February of this year, Trout Unlimited, Denver Water and Grand County agreed to a package of measures that will not only address impacts from the proposed Moffat Project, but will also pave the way to improve existing stream conditions.   

·         The measures, embodied in the Grand County Mitigation and Enhancement Coordination Plan (MECP), include both “mitigation” measures designed to address Moffat Project impacts identified in the US Army Corps of Engineers’ (Corps) final Environmental Impact Statement, and “enhancement” measures that Denver Water has voluntarily committed to undertake to improve existing conditions.  A list of these measures is included below.

·         At the heart of the MECP is Learning by Doing (LBD), a monitoring and adaptive management program to be implemented by a committee that includes Grand County, Trout Unlimited, Denver Water, and Colorado Parks and Wildlife.  The LBD Committee would implement an extensive monitoring program to assess stream health based on specific parameters including stream temperature, aquatic life, and riparian vegetation health.  Water and financial resources committed by Denver Water (listed below) would be deployed to prevent declines and improve conditions where needed.  Denver Water also commits to use flexibility in how it can operate its extensive water diversions system to help reduce impacts and where possible provide benefits to the streams.  LBD would also be the vehicle through which mitigation measures imposed by the Corps would be implemented.

·         Given its importance, Denver Water will ask the Corps to include LBD in the 404 permit.  If for any reason LBD ceases to function, the requested permit condition would commit Denver Water to implementing the MECP through an alternative mechanism approved by the Corps.  It should be noted that inclusion of this “fail-safe” permit condition is critical to the agreement.  Without it, Trout Unlimited cannot support either the MECP or the Moffat Project.

·         Trout Unlimited has fought hard to protect the Fraser River basin streams.  The MECP not only provides the tools needed to protect and even improve stream conditions, but it also puts Trout Unlimited in a position to influence their future. 

Mitigation Measures include:

·         Measures to address stream temperature issues:

o   Monitor stream temperatures and bypass up to 250 AF of water annually if stream temperatures reach state standards

o   Bypass sufficient additional flows to reach defined minimum flows if stream temperature problem persists after the 250 AF have been bypassed

o   Contribute $1 million to LBD for projects if temperature problems persist

·         Measures to address sediment issues:

o   Work to provide flushing flows as recommended in Grand County’s Stream Management Plan

o   Operate and maintain sediment pond that catches highway sand

o   Contribute $1 million to LBD for projects if sediment problems persist

·         $750,000 for fish habitat restoration projects

·         $72,500 for fish barrier and restoration of cutthroat habitat plus any additional measures required by the USFWS in its Biological Opinion

Enhancement Measures include:

·         Through LBD, implement an extensive monitoring program including stream temperature, sediment transport, benthic macroinvertebrates, and riparian areas and wetlands

·         Use Denver Water’s system operation flexibility to address identified problems (so long as yield is not affected)

·         Provide in-kind contributions of people, equipment and material to benefit LBD

·         $3.75 million for aquatic habitat improvement projects ($1.25 million available before the project is built)

·         $2 million for water quality projects (available before the project is built)

·         $1 million to pump water at Windy Gap to Granby for release for the benefit of the Colorado River below Granby and below Windy Gap Reservoir

·         $2 million for stream improvement projects in the Colorado River

·         $1 million for the Colorado River Wild and Scenic Stakeholder effort in the Colorado River

·         1000 AF of water each year released from Denver Water’s Fraser collection system for the benefit of Fraser basin streams

·         1000AF of water each year released from Williams Fork reservoir (including up to 2,500AF of storage) for the benefit of the Colorado River below its confluence with Williams Fork

Denver Water commits to implement both mitigation and enhancement measures through LBD.  If LBD ceases to function, Denver Water commits to implement these measures through an alternative process to be approved by the Corps.  Denver Water has asked to include these commitments as a term and condition of its 404 permit.