Last week, Save The World’s Rivers (STWR) inserted a comment letter into the permitting process for the proposed “Wild Horse Reservoir,” a project of the City of Aurora, CO, that would be built in Park County. The comment letter highlights the deficiencies in the application, which is the first consequential Rule 87 “dredge and fill permit” process undertaken by the Colorado Dept. of Public Health and Environment (CDPHE), after the federal Clean Water Act no longer protected the applicable State waters.
Save The World’s Rivers comment letter argues that:
The application is “not complete” — it is missing several analyses that are required to be included.
The application makes clear that the reservoir will be filled with West Slope water from Homestake Valley (which flows into the Eagle River) abutting Holy Cross Wilderness Area.
The application completely fails to disclose how much water will be diverted out of the Eagle River tributaries, which is a violation of Rule 87 which requires the environmental impact of the source waters to be analyzed.
The application fails to analyze an applicable ‘No Action Alternative’ that would not have any environmental impact on the source waters or on the State’s waters/wetlands in Park County.
And others.
STWR’s comment letter is posted here.
This project would further drain the Eagle and Colorado Rivers, an impact that must be analyzed pursuant to CDPHE’s new Rule 87. The people of Eagle County deserve to know how their rivers will be impacted by this project and the law requires the City of Aurora to reveal that information.
STWR is using Anthropic’s Claude for Nonprofits AI tool to help analyze the 743-page highly technical and legal permit application.
The use of AI allows a small organization like ours to protect the public’s interest to ensure that our members are represented and ensure that the State’s waters are protected as required by Rule 87.
The 30-day public comment period for the permit was set to end on October 5, but was extended 45 days to November 19.
Gary Wockner, PhD, is a scientist and conservationist based in Colorado. Follow him on Twitter, @GaryWockner. Learn more at savethecolorado.org