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.- <br />City of Fort Collins NISP DEIS Comments <br />September 10, 2008 <br /> <br />EXECUTIVE SUMMARY <br />The City of Fort Collins (City) respectfully files these comments on the Northern Integrated <br />Supply Project (NISP) Draft Environmental Impact Statement (DEIS) issued by the United <br />States Army Corps of Engineers (Corps) on April 29, 2008. I3ased on a thorough, scientific <br />review of the DEIS by expert City staff and consultants (see biographies in Appendix A to these <br />Comments), the City has concluded that the DEIS fails to sufficiently analyze the impacts of <br />NISP and does not provide for the avoidance of the extensive impacts NISP would have on the <br />City and its residents. It would be illegal to approve a permit for NISP based on the current <br />record and project definition. <br />Accordingly, a Supplemental Draft Environmental Impact Statement (SDEIS) is necessary to <br />meet the Corps' legal obligations under Section 404 of the Clean Water Act (Section 404) and <br />the National Environmental Policy Act (NEPA). Because NISP would cause extensive impacts <br />to the City's environment, quality of life, economy, property and budget, and NISP does not <br />provide adequate safeguards, the City opposes NISP as it is described in the DEIS. <br />1. NISP Would Cause Significant Impacts to the Water Quality of <br />Horsetooth Reservoir and to the Cache la Poudre River in Fort Collins <br />The City would be directly affected by NISP. NISP would build, among other things, the new <br />170,000 acre-foot Glade Reservoir just north of Ted's Place on U.S. Highway 287, a pipeline <br />between the Glade Reservoir and Horsetooth Reservoir (a critical source of the City's drinking <br />water) and a relocated U.S. 2871. NISP would take as much as 71 % of the water out of the <br />Cache la Poudre River upstream of the City and place it into the Glade Reservoir. As described <br />in the DEIS, a portion of the Glade water would be conveyed to Horsetooth Reservoir, where it <br />would degrade the quality of the water that enters the City's drinking water treatment facility. <br />The City depends on the quality of its water supplies. The City provides customers some of the <br />best water in the country, which is critical to both residents and businesses. Many of the City's <br />largest employers -high tech companies like Hewlett-Packard and Kodak and breweries like <br />Anheuser Busch, New Belgium and Odell -depend on this high-quality water for their <br />processes. Degradation of one of the City's two primary sources of water, Horsetooth Reservoir, <br />could require the City to spend in excess of $90 million in capital costs and almost $3 million <br />annually to maintain the quality of the water delivered to customers. NISP would cause <br />reductions in the Poudre River's flows through Fort Collins as predicted in the DEIS, which may <br />require the City to spend up to $125 million on upgrades to wastewater treatment facilities to <br />protect the River. <br />~ For the purpose of these comments, the Cache la Poudre River is also referred to as "the Poudre River" and "the <br />River." <br />2 <br />