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HomeMy WebLinkAbout20180715.tiffTo: Weld County Board of Commissioners 1150 O street P.O. Box 758 Greeley, Colorado 80631 From: Patrick and Kelly Auker 2793 CR 17 Brighton, Colorado 80603 Re: Thornton Water Project Dear Weld County Commissioners, 2/5/2020 RECEIVED FEB 12 2020 WELD COUNTY COMMISSIONFRC As owners of property involved with the Thornton Water Project, we are writing this letter to Weld County to bring your attention to our concerns of the litigation with the City of Thornton's Water Project. We realize the importance of this project, however there is only one way the City of Thornton is handling the litigation, and that is their way. Our concerns are mounting, and it is time that you as commissioner know that this is a one-sided deal. The pipe in question is designed to come down CR 17, mainly on the east side of the road. At our location of CR 8 and CR17 to CR 6 and CR 17, it is designed to come across the road to our property on the west side. Since the beginning of the litigation we have asked several questions, with no response to our concerns, only a contract that is loaded in their favor. We have enclosed a plan that shows Thornton's pipeline alignment and the home they are trying to get around at this junction. There is only a need for 180' x 25' of easement on our property. Not 942' x 50'. No response of this issue from The City of Thornton. The Auker property on CR 17 is already overburdened with several easements. Another 50' easement will over distress the property immensely. There is no answer for the cause/reason by The City of Thornton due to their non response. County Road Easement Electric Easement Telephone Line Easement High pressure Gas Easement Irrigation Water Easement Total feet prior to City of Thornton Water Easement o_ib two V n i ca+ ; can s oa/ 19 /ao cc: PLC -re). oc, cam), Ca C s r sc.). ROCCCKF), PcvcJen ERICH). V(-tcSFIU-) 30' 10' 10' 25' 10' 85' aOIg-o71S The amount of compensation this project is offering is not enough to pay for attorney fee's to litigate property owners rights. We have been offered a fraction of other easements within our boundaries within the last 18 months. These are not fair offers, and the City of Thornton will not respond to any communications regarding the easement they are wanting. In November 2019 correspondence again was attempted to the City of Thornton to no avail. We have included this correspondence. Again, their response was, no response. A contract arrived by mail in January 2020 with no changes in design and that there would not be any design changes. We would like response from Weld County Commissioners regarding your position in this matter. This is to serve as public notice to all parties involved. Sincerely, Patrick Auker Kelly Auker CC: City of Thornton Mayor Western States Land Services Weld County Commissioners ENC: City of Thornton's Design Plans Letter dated 11/18/19 to City of Thornton Mayor & Western States Land Services 1 2 3 4 5 MATCHLINE, SEE DWG PA1-11 NOTES: 1. FOR PROPERTY 3-5 NOTES SEE DWG PA1 •' 1. 2. FCR PROPERTY 4-1 AND 4.2 NOTES SEE DWG PA•13. 3. TAP PA -I WATER PIPELINE LOCATION SHOWN ON DRAWINGS IS APPROXIMATE AND SUBJECT TO FINAL DESIGN. BARBED WIRE FENCE 15° CMP 0 50 100 150 �• /- FENCE 40 C-- •• - e•/a. .tee- 4. • ••ems ••w -w• ---- •••. a— BARBED WIRE 1► FENCE wait r....•...•..► w+-.•..•... 414.1•010 OEMS I I ea.. —1 —&-elf teala WM. MIS See C RIF Sca'e it Feet C. NO P 3-5 PN: 146921000006 REC 3711365 REC 3711366 (BLANKET IN NATURE • EXCEPTIONS 5, 6) J •- - C) N1/2, NE1/4 SEC. 20 T -1-N, R -67-W 3-8 PN: 146920000019 ze-- TAP PA -1 40' TE1: PCR ARY CONSTRUCTION EASEMENT r C TVia PA -1 50• PERMANEN- EASEMENT s.4,10a EL •••.•• L3-7: PN: 146921000073 W. 526'. N. 990'. N1/2, Mp1/1/4. SEC. 21 LOT A AMENDED RECORDED EXEMPTION 1469 -21 -2 -RE 287 REC. 1987560 (EXCLUDES RIGHT-OF-WAY) EASEMENT NOTES • PARCEL 3-7 • PARCEL IS SUBJECT TO A WATER WELL AND EASEMENT TO THE WELL AS DESCRIBED IN WARRANTY CEED RECORDED MARCH 27, 1943 IN BOOK 1107 AT PAGE 436 LOCATED In rrdE Nall OF THE NW1/4 OF SECTION 21. THE EASEMENT IS SAID TO BEGIN AT THE WELL AND A TANK AND RUNS SOUTH TO TI -E W1/2 OF THE S'Wt/4 OF SECTION 2'. NEITHER -HE WELL NOR THE EASEMENT IS t/ATI-V,IATICALLY DEFINED AND THERE=CRE IS NOT SHOWN ON THIS MAP. (EXCEPTICN 4) i! ems. •a•... • INS _.•. S. ED WIRE •: RN, 60 ROW. EXST AND FUTURE CC 0 0 ._..- C -- C .../.__........._.a.. w can av GATE 1 FSEPSIt:TERAL ,.ON 1 HOUSE DECK 25e YELL 6 WATERLINE ESM T RICI IARD OLSON REC. 4284724 (EXCEPTION 11 3.7) APPROXIMATE LOCATION (NO SIGNAL) .e.. Write w..+• - }\j flee .--. •-.•. ..,r at r of CMP = BARBED WIRE.........-- i FENCE /• ( III an"41 •-.. .• • [ .•....r0.......1...1 Z • II.- •--.1_-... a•. W N ..e••-•.• .•-w EL He MTL SHdD 12 _not:, u 4► fi r• s4- Y t I V,14 i • GRAVEL ROAD ( ) h L.,z, -- 60' ROW. EXST AND FUTLRE I I -" • i I h is) I To: City of Thornton Colorado: Mayor Heidi Williams 9500 Civic Center Drive Thornton, CO 80229 To: Western States Land Services 505 N Denver Ave Loveland, CO 80537 From: Patrick and Kelly Auker 2793 CR 17 Brighton, CO 80603 Dear Mayor, November 18, 2019 Over the past six months we have tried to contact the City of Thornton and Western States Land Services regarding the water pipeline you have proposed to property owners on which you seek an easement. No one person from either entity find it necessary to respond. On June 6, 2019 (Patrick and Kelly Auker) owners of property of which city of Thornton is proposing an easement, met with Nancy of Western States Land Services to discuss what Thornton needs are. Upon review, Thornton is running a water line up and down east side of CR 17. The reason for needing to cross over to West side into at 2793 CR 17, is to bring a pipeline around the dwelling at 2990 county road 17. Located on the South East corner of County Roads 17& 8. We downloaded Thornton's plan of this area for the pipeline and plans show the pipeline crossing to the west side for approximately 900 feet, then back over to east side of county road 17. The only part of property needed on West side of county road 17 is 160' to accommodate water line around the above said dwelling at 2990 CR 17. The West side of County Road 17 at address of 2793 has an over burden of easements: telephone line, high pressure gas line, electrical lines and irrigation easements, for a total of 40 foot wide. Another 50' would render 90' of property unable to be used for any future developments on road 17. We do understand the need to get the pipeline around dwelling on east side of county road 17, but only 160' or close to this distance is necessary for said pipeline. As there is a need to get pipeline of this nature around obstacles, and seeing on plan that the pipeline is on east side of County Road 17 and will return to east side of County Road 17 after dwelling at corner, therefor there is only a need for 160' of easement needed on the West side County Road 17 Please review plan attached, to understand what our position is. In closing I would like to say that I have been trying to get this resolved for many months without any response from the City of Thornton or Western States Land Services, with the exception of November 11, 2019 contact that only states your position. We have reached out to Nancy on several occasions and could not get any answer back or call back regarding this matter. It appears that we are being ignored and that this is part of the tactics being used to push this pipeline through without any regards to anyone but the City of Thornton. We would like to meet and see if we could come to an agreement on this matter as soon as possible. Thank You, Patrick & Kelly Auker (303)921-0804 patsgreenacres@gmail.com Patrick and Kelly Auker 2793 CR 17 Brighton, Colorado 80603 WELD COUNTY BOARD OF COMMISSIONERS WELD COUNTY CLERK TO THE BOARDS OFFICE 1150 O STREET GREELEY, COLORADO 80631 Patrick and Kelly Auker 2793 CR 17 Brighton, Colorado 80603 CITY OF THORNTON MAYOR HEIDI WILLIAMS 9500 CIVIC CENTER DRIVE THORNTON, COLORADO 80229 Patrick and Kelly Auker 2793 CR 17 Brighton, Colorado 80603 WESTERN STATES LAND SERVICES 505 N DENVER AVE LOVELAND, COLORADO 80537 To: TWP Stakeholders From: Mick Ondris Re: Compromise Alternative February 25, 2019 Dear Stakeholder, Enclosed is a revised copy of the Shields Street/Poudre River Alternative: A Compromise Proposal for the Thornton Water Project. This is a citizen -initiated, compromise Alternative that provides for the delivery of Thornton's water, protects existing water rights, and re -vitalizes twenty miles of the Cache la Poudre River in Larimer County. Please feel free to share this proposal with any interested party. If you have any questions or comments, do not hesitate to contact me. RECIPIENTS Larimer County: Commissioner Tom Donnelly Commissioner Steve Johnson Commissioner John Kefalas Rob Helmick, Planning Department City of Thornton: Emily Hunt, Director of Water Resources Mark Koleber, Thornton Water Project Director Water Supply and Storage Company: Dennis Harmon, General Manager City of Fort Collins: Mayor Wade Troxell Fort Collins City Council Windsor Town Board: Mayor Kristie Melendez Weld County Board of Commissioners: Barbara Kirkmeyer, Chair No Pipe Dream Save The Poudre Sincerely, Mick Ondris (970) 225-0083 micksspralt@gmail.com Cc' rvw'‘ca„ iota s 31n11q Cc. PUT P),cAW /Pc.), PLOCEiti3111/ aG��sr�� 2O1$-0-1 15 THE SHIELDS STREET/POUDRE RIVER ALTERNATIVE A COMPROMISE PROPOSAL for the THORNTON WATER PROJECT In the mid -1980s, the City of Thornton began purchasing farms and their attendant water rights in eastern Larimer County and Weld County. Given the population growth that has occurred since that time, and based on future population growth projections, Thornton would now like to develop a delivery system to transport that water for the use of its current and future residents. In order to develop such a system, it is necessary for Thornton to obtain a "1041 permit" from Larimer County. There have been five alternatives proposed for the delivery of water to Thornton. The "Canal Option," as proposed by the Larimer County Water Projects Working Group, would utilize the existing Larimer County Canal (LCC) to convey water east of Interstate 25 to Black Hollow Reservoir, where it would then be pumped to existing treatment facilities in the City of Thornton via the proposed pipeline (discussed below). The advantages of this option are the use of existing infrastructure, elimination of a considerable amount of construction activity and the associated negative impacts of that construction on Larimer County residents, delivery of water that is similar in yield and quality as the water held under the original agricultural rights, and proximity to the designated Pipeline Corridor as proposed by Thornton. Thornton expressed concerns that the Canal Option would require improvements to the canal system, would necessitate the construction of additional water storage, might require additional water treatment, and stated the opinion that Thornton is entitled to the quality of water stored in the Water Supply and Storage Company (WSSC) Reservoir #4 as opposed to the quality of water purchased from the individual farms located along the LCC. WSSC expressed concerns that at times the LCC would lack the capacity to simultaneously convey water to Thornton and to the other water right owners who utilize the LCC, that portions of the LCC would need to be modified in order to meet the new conditions of operation, and that required annual maintenance and repair could not be performed with year-round use of the system. The non-profit organization "Save the Poudre" proposed the "Poudre River Alternative" to convey water to Thornton. As described by Save the Poudre, this option would bypass the "Canyon Mouth" diversion structure that supplies water to the LCC and WSSC reservoir system and instead utilize the Poudre River to deliver water through Fort Collins and downstream to Windsor, where it would then be diverted and pumped to Thornton's water treatment facilities via the proposed pipeline. The majority of the Thornton allocation would be supplied during peak runoff to create a more natural flow regime, which would enhance stream and floodplain functions. This option has overwhelming public support, an indication of the value that Larimer County residents place on what many consider to be the most important asset in the County. Thornton expressed concerns that there would be a decrease in water quality relative to water stored in WSSC #4, that additional storage would have to be constructed, that this construction would require federal permitting (a process Thornton has stated it wants to avoid), and that delivery via this option would violate an existing Agreement with WSSC and the Water Court Decrees (see below). WSSC concurs with Thornton's assessment of the Agreement and Decrees; and emphasizes its responsibilities to owners of other water rights on the LCC. The City of Thornton has offered two proposals via the 1041 permitting process. The original proposal was to draw water from WSSC #4 and convey it through a buried forty-eight inch diameter, pressurized pipeline across private property to the Douglas Road right-of-way. The water would then be piped east to County Line Road (CR 13), and then be conveyed south, where it would be processed in Thornton's two existing water treatment plants. A forty million gallon per day pump station would be constructed on the private property located immediately south of WSSC #4. This proposal was met with strident opposition by Larimer County residents, especially those who would be negatively impacted by the two to four year construction project. In response to the proposal, the citizen organization "No Pipe Dream" was formed to oppose the pipeline. Residents consistently expressed concern that the true costs of the project were being externalized; and that few benefits accrued to Larimer County as a result of bearing those external costs. In view of these negative impacts, and the social and economic benefits of a re - watered Poudre River, No Pipe Dream supports the Poudre River Alternative. In response to the intense public backlash to the Douglas Road proposal, Thornton resubmitted its 1041 permit application with a modified "North Route" proposal that would still rely on the pressurized pipeline, but reconfigured the alignment to cross private property to the south, west, and north of WSSC #4, and then run in or along the County Road 56 (CR 56) right-of-way, north of Douglas Road. While fewer people would have been impacted by the modified proposal, vehement public opposition remained. Thornton's claims of benefit to Larimer County faced considerable skepticism. In particular, the notion that "return flows" to the Poudre River as mandated in the Water Court Decrees could be monetized at current market rates, and touted as the major portion of the "benefits" provided to the County, was perceived to be without merit. Section 14.4 of the Larimer County Land Use Code delineates twelve "review criteria" that must be met before the Commissioners can approve a 1041 permit application. The Larimer County Board of Commissioners determined that some of these criteria had not been met in view of the impacts associated with the pipeline proposals, and also determined that Thornton failed to meet Criteria #2. Criteria #2 states "The applicant has presented reasonable siting and design alternatives or explained why no reasonable alternatives are available." As a result of these deficiencies, on February 11, 2019 the Board unanimously voted to deny the "Thornton Water Project Supplement #3" 1041 permit application. There is one reasonable alternative that considers the benefits and concerns expressed by a majority of participants throughout the 1041 permitting process. The "Shields Street/Poudre River Alternative" (SS/PR Alt) is a citizen -initiated, compromise Alternative that provides for the delivery of the water that Thornton is entitled to, protects the existing water rights of other users on the LCC, and revitalizes twenty miles of the Cache la Poudre River in Larimer County. The Alternative provides, but does not mandate, several opportunities for regional cooperation among a number of stakeholders. This compromise Alternative builds on numerous ongoing efforts by a variety of entities that continue to improve the fluvial and biological functions of the Poudre River. While these improvements are often done as individual projects, each of these efforts positively reinforces and compliments the others. As these efforts continue, the overall stream function and health of the Poudre River will continue to improve. The following is a revised version of the SS/PR Alt originally submitted to the Larimer County Board of Commissioners, the City of Thornton, and numerous other stakeholders on September 19, 2018. This version of the actual SS/PR Alt should not be conflated with the similarly titled "Shields Street to Poudre Option" devised by the City of Thornton and presented in lieu of the original SS/PR Alt at the November 15, 2018 "Community Open House." POINT OF DIVERSION / EXISTING WATER RIGHTS The SS/PR Alt utilizes the existing Poudre River Canyon Mouth point of diversion to the Larimer County Canal (LCC) and the proposed outlet at Water Supply and Storage Company Reservoir #4 (WSSC #4). Utilization of these existing facilities is mandated in the 1986 operational Agreement between the City of Thornton and WSSC. When the "beneficial use" of a water right is re -adjudicated (a "change of use" proceeding), the Courts apply a "no injury" doctrine to protect other existing water rights that might be impacted by the change of use. In this case, the original agricultural uses of the individual WSSC water rights (shares) were converted to municipal use rights held by the City of Thornton. The 1994 District Court, Water Division No. 1, State of Colorado (i.e. the "Water Court") decision, the 1996 Colorado Supreme Court decision and remand, and the final 1998 "Thornton Northern Project Decree" all mandate that the existing Canyon Mouth point of diversion continues to be utilized and that the general operational functions of the WSSC reservoir system and the LCC continue in a manner as to avoid injury to the remaining WSSC shareholders and any other existing water rights. At virtually every public opportunity to comment, WSSC has repeatedly and emphatically stated that it has a legal obligation to, and absolutely will, vigorously defend the water rights of all LCC users as set forth in the existing Agreement and Decrees. ALIGNMENT The SS/PR Alt is comprised of three segments (please refer to the attached sketch map that outlines the general routing): SEGMENT #1 — approximately 1.1 miles. Outtake at WSSC #4 at 5080 ft. elevation. Buried pipeline generally contouring (with consistent gradient) with the Dry Creek Ditch easement, south across Douglas Road, and then to the west side of Shields Street at 5040 ft. elevation. As will be described below, most of the pipeline alignment and other components of this Alternative have some flexibility as to the ultimate siting. Unfortunately, the WSSC #4 outtake is a specifically defined location with no other viable option. As a result, pipeline construction would still need to occur on private property immediately south of the WSSC #4 dam and along the east side of Starlite Drive. These properties, as well as properties immediately south of Douglas Road at the Starlite intersection, would be negatively impacted during the construction phase of the project. Auger boring technologies (such as those proposed for numerous and extensive wetlands along the CR 56 "North" alignment, under Interstate 25, and under the Poudre River along the CR 13 alignment in the Thornton pipeline proposals) could be employed at this location in order to minimize some of the negative impacts. The 40 foot elevation differential (approximately 36 ft./mile gradient) allows for gravity flow through the pipeline and thereby eliminates the need for the controversial pump station and its redundant power feed, lighting, and maintenance access on private property. While there would still be significant negative impact on residents in this area, the removal of the pump station does, to some degree, address one of the major concerns expressed by impacted property owners during public comments. SEGMENT #2 — approximately 2.1 miles of buried pipeline (or 1.9 miles of pipeline and 0.2 miles of lined ditch south of the Larimer Weld Canal) south to the North Shields Ponds at 4980 ft. elevation. The 60 foot elevation differential provides for an average 29 ft./ mile gradient, allowing for gravity flow through this segment of the alignment. This routing utilizes the existing Shields Street utility right-of-way or could be sited immediately adjacent to the right-of- way. The majority of property on this route is undeveloped agricultural land, though there are approximately eleven private residences and two commercial structures that may require some adjustment of the alignment or negotiated easements. The Highway 287/Union Pacific Railroad corridor crossing could also employ the aforementioned auger boring technologies. Open trench construction bisecting the Larimer Weld Canal would need to occur outside of irrigation season. To reduce surge effects, water entering the Shields Street Ponds would be baffled and then dispersed through a series of riprap check dams and vegetated distributary channels flowing into. the Poudre River. The Fort Collins Natural Areas Program and Larimer County have already cooperated in developing public access and interpretation at this location. It seems reasonable to assume that they would coordinate with Thornton to develop this aspect of the project to the benefit of visitors, residents, and the natural habitat. As stated in Thornton's pipeline design parameters, the maximum delivery capacity for the project is 40 million gallons per day. This equates to a flow of 61.9 cubic feet per second (cfs), thus any fluctuations in river discharge would be well within the existing range of variation that occurs during the irrigation season. The total distance from the WSSC #4 outtake to the North Shields Ponds is approximately 3.2 miles. The Douglas Road and Shields Street crossings and the 2.1 mile segment paralleling Shields Street would impact traffic in this area. These negative effects would be similar to those created by the CR 56 pipeline configuration, although the duration of these impacts would be considerably less in view of the significantly reduced length of pipeline in the SS/PR Alt. SEGMENT #3 — approximately 20 miles within the Poudre River (with the 14 mile Shields Street to 1-25 reach within the city limits of Fort Collins) to the general vicinity of the Poudre River and County Line Road (CR 13) intersect, in the Town of Windsor, along the proposed Thornton Pipeline Project Corridor (hereafter referred to as the "CR 13 intake"). In this general vicinity, a diversion weir/intake works, settling and short-term storage basins (see below), and a pump station (relocated from WSSC #4) would need to be constructed. Approximately twenty- one miles of pipeline are eliminated from either of Thornton's proposed routes, therefore the CR13 pump station would be located 24.5 to 26.5 miles (as opposed to 45.5 to 47.5 miles) from the proposed Firestone/Frederick pump station. As a result, it is possible that one or both of the pump stations could be downsized; or could be consolidated into a single pump station, thereby reducing project and operational costs (refer to http://thorntonwaterproject.com for locations). This alignment, particularly the Poudre River Segment, provides the greatest benefit with the least disruption to Larimer and Weld counties, while protecting water quality and quantity (discussed below) for the City of Thornton. The approximately 45 mile long (CR 13) Windsor to Thornton segment of the pipeline remains identical to the existing Thornton Pipeline Proposal and is therefore not impacted by the SS/PR Alt. OPERATION The SS/PR Alt would utilize a seasonal and daily operational fill and drawdown schedule from WSSC #4 that would be essentially identical to either of the Thornton pipeline proposals. WSSC #1-4 and Kluver Reservoir would remain operational in order to provide primary storage and "release -on -demand" water deliveries to the CR 13 intake. These releases would be coordinated to account for in -river conveyance flow time and sediment settling requirements. Fluctuation of the WSSC #4 shoreline elevation, and any aesthetic impacts on surrounding properties as a result of reservoir drawdown, would be the same for the SS/PR Alt or either of the pipeline proposals. WATER QUALITY MITIGATION The City of Thornton has expressed a concern that water that would flow through the Poudre River may be degraded relative to the quality of raw water delivered from WSSC #4. Neither source would directly supply potable water to consumers in Thornton. It is the intent of the SS/PR Alt to deliver water to the Thornton water treatment facilities that is of similar quality as the non -potable irrigation water delivered from WSSC #4; i.e. a level of water quality that allows for treatment at Thornton's existing facilities as provided for in the pipeline proposals. Several factors need to be considered in regards to water quality. Among these factors are sediment load, agricultural runoff in the reach from the Canyon Mouth to CR 13, municipal stormwater runoff, discharge from wastewater treatment facilities in the City of Fort Collins, reduced biological function as a result of this combination of factors and, most importantly, the current depleted flow regime within the Poudre River. The single most effective long-term water quality mitigation is simply the re -watering of the Poudre River from Shields Street to CR 13. Sedimentation: With the exception of some periodic storm -induced increases in sediment load as a result of recent (2012) fire scars in the upper basin, the Poudre River has relatively low turbidity. A considerable amount of watershed restoration has been performed by the Coalition for the Poudre River Watershed and other volunteer organizations. These notable efforts are ongoing and help reduce the base sediment load throughout the entire river system. As a result, the stream water that would be "mixed" with outtake from WSSC #4 contains less sediment than pre -mitigation runoff. The Coalition's "Upper Poudre Watershed Resilience Plan" (2017) provides a framework for future mitigation and presents a "Sediment Transport Model" for the Lower Basin. Turbidity is a function of river discharge and therefore fluctuates on a seasonal basis, with maximum sediment load occurring during the spring runoff. The existing WSSC reservoirs, in conjunction with Kluver Reservoir, function as "settling basins" for waters diverted from the Poudre River via the LCC. While this water is relatively sediment free, it is not classified as potable and treatment is still required. In order to achieve similar water clarity, the SS/PR Alt would require the construction of settling and short-term storage basins in the vicinity of the CR 13 intake. These settling and short-term storage basins and any pipeline connecting to the CR 13 Pipeline Corridor would be constructed, off river, near Jodee (JoDee) Reservoir in Larimer County or in the vicinity of the Frank State Wildlife Area (WSA) in Weld County. As mentioned above, WSSC Reservoirs #1-4 and Kluver Reservoir would remain operational in order to provide primary storage and allow for demand -based water releases. The CR 13 short- term storage basins would be operated in conjunction with Thornton's existing water storage system in order to moderate peak demand on any one storage facility as it supplies the Thornton and/or Wes Brown Water Treatment Plants. A major advantage of an on -demand model of delivery is that the need for short-term storage and pump station forebay capacity can be minimized. In view of the storage capacity in the WSSC system, the water delivery schedule could (especially in late summer) also be coordinated to provide steady supply to maintain storage levels throughout Thornton's existing water storage network. As with all works of this type, inlets to the settling basins would be grated, screened, and skimmed; and would utilize headgates to shunt water during extreme flood events or anomalous incidents such as forest fire sediment load increases. During such events, drawdown of system wide storage would occur. The use of three different sources of supply in Thornton's domestic water system provides flexibility and redundancy. In the event of an extreme and unpredictable occurrence, Thornton maintains an emergency raw water interconnection with Denver Water as do most municipalities in the metropolitan area. Depending on configuration, a low -head pump might be required to move water from the diversion structure to, or within, the settling and short-term storage basins. The final outtake from the basins would require a pump station similar to the station proposed for the WSSC #4 outlet in the various pipeline proposals, and a segment of pipeline leading from the pump station to the CR 13 Pipeline Corridor. The annual hydrograph of the Poudre River (USGS Lincoln Street gauge) indicates that the maximum stream discharge, and therefore maximum sediment load, typically increases in May, peaks with the "June Rise," and diminishes rapidly by early July. The water demand curve for the City of Thornton begins its annual rise from May to June, then peaks during the July and August lawn watering season, and begins to diminish in September. The implication of this lag in peak consumption demand relative to peak flow/sediment load is that maximum stream withdrawal would occur during periods (July and August) when the sediment load is naturally reduced as a function of reduced streamflow. This also coincides with maximum annual agricultural demand and the resulting maximum water diversion at the Canyon Mouth; thereby further reducing the peak flow and peak sediment load in the reach from the Canyon Mouth to CR 13. In fact, average stream discharge from mid -July through August ranges from 140 cfs to 50 cfs, levels at which minimum sediment transport occurs. During the roughly five month Thornton peak demand season, there would be on average twenty-nine days in which the Poudre River flow would exceed 600 cfs, a threshold that might be considered as requiring maximum settling duration and/or the possibility of some need for flocculation in the settling basins. Should Glade Reservoir of the Northern Integrated Supply Project (NISP) be constructed, considerable reductions in sediment load would be realized during peak demand season. By design, the peak flow/sediment load would be significantly truncated as this is the exact flow regime from which NISP would be drawing water out of the Poudre River at the Canyon Mouth diversion structure, per the Northern Colorado Water Conservancy District's 1980 priority right. Agricultural Runoff: Agricultural runoff can negatively impact water quality by introducing nutrients, primarily phosphorous and nitrogen compounds, into the stream system. These nutrients may create conditions favorable to algal growth, and in turn increase Biological Oxygen Demand; which would have a deleterious effect on stream ecology. While generally moderate, agricultural runoff in the Canyon Mouth to CR 13 reach could be further reduced by utilizing voluntary, market -driven Conservation Easements to create buffer zones along the river corridor. With the advantage of tax benefits or other economic incentives for property owners, entities such as the Larimer County Open Lands Program, the City of Fort Collins Natural Areas Program, the Coalition of Colorado Land Trusts, and other non -governmental organizations (NGOs) could identify willing participants and negotiate mutually beneficial agreements that reduce non -point source pollutants while preserving the agricultural heritage of Larimer County. These agreements could include a menu of non -point source mitigation strategies such as berms, vegetated swales, improved fertilizer management, manure management, conservation tillage to reduce soil compaction and runoff, and the use of seasonal cover crops. Additionally, ongoing improvements in floodplain connectivity (e.g. Fort Collins Natural Areas Program "Riverbend Ponds" enhancement) would increase the amount of time and surface area that river water would be filtered through plants and alluvium, thereby increasing the uptake of nitrogen and phosphorus compounds (while also providing the ancillary benefit of reducing sediment load). Stormwater Management: Most stormwater runoff occurs in urban areas, particularly from non -permeable surfaces such as roofing and pavement. The primary source of stormwater runoff in the relevant reach of the Poudre River is the City of Fort Collins. Fort Collins continues to address this issue through its Stormwater Management Program. A typical stormwater management approach is demonstrated by the recently completed West Vine Drive Stormwater Project. This Project utilizes a catchment basin to collect stormwater and dampen the surge of stormwater run-off. That captured water is then more gradually directed to dispersed filtering areas that utilize native phreatophytes to remove contaminants and allow infiltration into the water table. The remaining filtered surface and subsurface flow is then channeled to the Poudre River via the Soldier Creek outfall located immediately upstream of the proposed North Shields Ponds distributary channels. Also included in the Management Program are public education and enforcement components that focus on automotive byproducts and lawn care products; and in some cases provide rebates for stormwater or surface run-off improvements. "Low Impact Development" practices are encouraged for new and retrofit construction projects. Construction site runoff and erosion are more effectively controlled through improved on -site management techniques. Building code modifications permit semi -permeable parking and other hardened surfaces to be substituted for pavement in some applications. The Colorado State University Stormwater Center also provides resources for Best Management Practices for stormwater districts, "green infrastructure" design and construction guidance, and additional Low Impact Development strategies. Wastewater Treatment Discharge: The Boxelder Sanitation District and the City of Fort Collins Mulberry, Drake, and Fossil Creek wastewater treatment plants are operated in a manner that meets or exceeds all state and federal standards for wastewater reclamation. Physical, biological, and chemical processes are used to treat wastewater prior to discharge into the Poudre River (Mulberry and Drake facilities) and into Boxelder Creek and Fossil Creek Reservoir (tributaries of the Poudre). This reclaimed water is essentially free of organic, pathogenic, and metal contaminants that may pose an environmental or human health risk. Aeration is utilized as a means of odor control. The City of Fort Collins has a cooperative service agreement with the United States Geological Survey to monitor water quality within the Poudre River. As with the raw water in WSSC #4, reclaimed municipal wastewater is not categorized as potable and must be treated prior to household consumption. Treatment of reclaimed wastewater is a standard practice in municipal water supplies and is utilized numerous times in the Platte River drainage throughout the Front Range Urban Corridor. In view of the fact that the City of Fort Collins would receive considerable quality of life and economic benefits from a re -watered Poudre River, it is reasonable to suggest that Fort Collins may be willing to enter into an Intergovernmental Agreement (IGA) with the City of Thornton to further improve the quality of effluent water from its reclamation operations (especially the Mulberry and Drake points of discharge), in order to compliment the currently planned treatment of WSSC non -potable irrigation water at Thornton's existing treatment facilities. Increased aeration or ultraviolet irradiation are examples of enhanced treatment. While desirable from Thornton's perspective, these potential enhancements are not required for the functionality of the SS/PR Alt. Nonetheless, opportunities for regional cooperation, when feasible, should be viewed as the preferred approach. It is again important to emphasize that these mitigations would take place in conjunction with, and would complement, existing and future efforts designed to improve overall river health. Biological Function: Functioning, intact river systems deliver a variety of ecosystem services. The services most relevant to municipal supply water quality are chemical and nutrient uptake, algae control, water temperature moderation, and the resulting dissolved oxygen content. When healthy, the benthic and riparian plant communities and streambank alluvium can remove much of the dissolved chemical and nutrient load, further enhancing the above mentioned mitigations related to agricultural and stormwater runoff. The amount of algae in a stream will remain in general equilibrium unless impacted by increases in nutrients such as phosphorous and nitrogen. Water temperature and exposure to sunlight also influence algal growth. Hence, so called "algal blooms" occur most frequently in warm, standing water that is exposed to sunlight and a high nutrient content; conditions frequently found in irrigation water storage reservoirs. A flowing Poudre River would rarely present conditions conducive to algal blooms. Furthermore, a more natural stream ecosystem cools (shading and alluvial flow) and oxygenates the waters within it. These natural stream functions are so effective that the City of Aurora utilizes them as a major purification component in its Prairie Waters Project. That Project provides treated wastewater effluent of such high quality that it is directly mixed into the potable water supply. Increased flows from WSSC #4 would enhance these purifying functions of the stream ecosystem as well as improve ecosystem connectivity. It is important to note that while some degradation of water quality in the Shields Street to CR 13 reach might occur as a result of agricultural runoff, stormwater runoff, and water reclamation discharge; the biological and fluvial functions of a healthier, re -watered Poudre River would simultaneously mitigate or negate many of those impacts. INSURING FULL ALLOTMENT The City of Thornton is entitled to its full allotment of water as specified in the 1998 Water Court Decree. A legitimate concern with the SS/PR Alt is loss in yield during conveyance within the Poudre River. The SS/PR Alt provides for options should loss mitigation be required. Some reduction in yield would occur as a result of increased evapotranspiration from a somewhat more densely vegetated stream course, infiltration to the adjacent alluvium, and direct evaporation from the surface of the river. The amount of consumed water would decrease over time as the stream system moves towards equilibrium under the new flow regime. Water use would be greatest during the early increase in streambank plant growth and the initial recharge of alluvial bank storage (not actually "consumed," but retained in bank storage) of the Poudre River under the SS/PR Alt. During this beginning phase of operation, Thornton's consumptive demand would be considerably less than the full 14,000 acre foot annual allotment (anticipated to meet Thornton's water needs through 2065); thereby reducing or negating the need for supplemental water sources. In particular, alluvial bank storage would reach a seasonal equilibrium within the first year of operation. While some WSSC water would be stored in the alluvium, the majority of recharge would still be the result of the (diminished) seasonal peak flows that currently occur within the Poudre River watershed. This dynamic bank storage function of a more naturally flowing Poudre River would dramatically reduce any potential for reduction in yield. As an additional benefit, when water is released from bank storage during periods of low flow it is cooler, more oxygenated, and contains less algal growth than water stored in a reservoir. If needed, there are three mechanisms available to mitigate any potential reduction in yield. Since full allotment would not be required during the initial phase of alluvial recharge, Alternative Transfer Methods (ATMs) could be employed to compensate for any potential shortage. The Colorado Water Plan calls for acquisition of 50,000 acre feet of water through these mechanisms. The most frequently used ATM approach is the "interruptible water supply agreement." Under recent State legislation, these agreements allow agricultural users to fallow lands and lease water (held under an agricultural right) for municipal use for three out of ten years. That agricultural use right may not be challenged as "abandoned" when it is leased for municipal consumption through such an agreement. This is an ideal mechanism for compensating for any possible short term reduction in yield (or construction delays) in that the quantity of leased water can be readily adjusted to meet existing demand, the quantity leased can be easily reduced over time, agricultural land is not permanently taken out of production, and the cost is considerably less than outright purchase and conversion of agricultural water rights. A second mechanism is the continued purchase and change of beneficial use of existing agricultural rights within the Poudre River drainage. This is the least desirable option as it results in permanent removal of productive agricultural lands, has the potential to injure other existing water rights, and is expensive. A final option that could be used to mitigate the long term evapotranspiration/evaporative loss is an in -kind exchange of water rights between entities that receive benefits from a re -watered Poudre River, especially the City of Fort Collins. Fort Collins would need to analyze the value of any potential water rights transfer vis-�-vis the economic benefits inherent in a healthier, aesthetically more pleasing re -watered Poudre River flowing through a significant portion of the City. From a legal perspective, any such transfer should be relatively free of contentious litigation as it is a municipal -to -municipal transfer with little potential to injure other existing water rights. Any such voluntary, good faith transfer of rights is not a requirement of the SS/PR Alt, but would represent an ideal compromise in which both parties would benefit. Should Glade Reservoir be constructed, the Northern Colorado Water Conservancy District has committed (as a condition of its U.S. Army Corps of Engineers permit application) to providing a minimum flow of 18 cfs in winter and 25 cfs in summer as a component of the NISP operational plan. This flow would originate just downstream of the Canyon Mouth and be withdrawn at Mulberry Street, thereby partially re -watering the reach of river that is upstream of the Shields Street gravity flow pipeline. These flows would help eliminate the seasonal "dry up points" below irrigation diversion structures along this reach of the Poudre River and provide ecosystem connectivity, which in turn would enhance stream function. This release would help maintain alluvial bank storage and partially compensate for evapotranspiration and evaporative losses in this reach of river. The net result would be a decrease in the long term need to acquire water to compensate for any possible loss in yield in the Thornton allocation. COST COMPARISON Until a more detailed engineering and construction cost analysis for the SS/PR Alt and the final alignment of either of the Thornton pipeline proposals is completed, it is difficult to provide much more than a general comparison of the Alternatives. Obviously, with a net decrease of approximately 18 miles of buried 48" pipeline (25% of the total proposed length), significant cost reduction would be realized with the SS/PR Alt. This cost reduction could be used to defray the cost of the CR 13 diversion structure, the settling and short-term storage basins, and any pipeline needed to rejoin the CR 13 Pipeline Corridor from the Jodee Reservoir or Frank SWA diversion site. As previously mentioned, construction costs and operational costs would decrease as a result of downsizing or consolidating the relocated CR 13 and Firestone/Frederick pump stations, although more information on pump capacities would be needed to quantify this reduction in cost. Other costs would remain similar regardless of which Alternative is constructed. The potential for litigation exists in all of the proposals. The outlet works at WSSC #4 would be virtually identical in cost for any of the three pipeline configurations. The cost of the (CR 13) Windsor to Thornton pipeline and connection to existing water treatment facilities would be identical for all five of the options. Additional costs that might be incurred with the SS/PR Alt would be Section 404 permitting (see below) and water rights acquisition, if needed. Perhaps the most difficult cost to estimate is the possibility that a treatment plant or a pre- treatment process, such as flocculation, would be needed if the Poudre River is utilized as a means of conveyance. An important consideration is that the SS/PR Alt need only supply water of a quality that is comparable, from a treatment perspective, to that supplied by WSSC #4. Again, neither source would supply potable water, so water from either source would need to be treated at the existing Thornton water treatment facilities as provided for in the Thornton pipeline proposals. During the Public Hearing on August 1, 2018 the City of Thornton presented a table summarizing cost projections for a generic Poudre River Alternative withdrawing water at CR 13. Included in that table was an estimate of $440 million to $760 million for "water treatment." The City of Thornton recently upgraded the Wes Brown Water Treatment Plant at a cost of $75 million. The costs of land acquisition and the basic infrastructure associated with a treatment plant are not reflected in the $75 million retrofit. Based on the figures provided by Thornton, $365 million to $685 million is the estimated cost for the basic footprint of a treatment facility located near CR 13 or some point down pipeline (i.e. treatment facilities, if actually needed, could be located in Adams County or the City of Thornton). Such a cost implies design criteria based on water quality parameters far exceeding the existing water quality in WSSC #4, or Thornton's current sources of supply - Clear Creek and the South Platte River. The Wes Brown Water Treatment Plant is described by the City of Thornton as a facility that "uses advanced water treatment processes including state-of—the-art ultrafiltration membranes." The quality of Thornton's current primary sources of raw water (Clear Creek and the South Platte River) should be considered when addressing treatment requirements. While mitigation has since occurred, it should be noted that the Clear Creek/Central City site was placed on the Superfund National Priority List in 1983. Clear Creek runs adjacent to Interstate 70 for roughly twenty-eight miles and adjacent to Hwy 6 for roughly sixteen miles, subjecting it to direct surface runoff containing de-icing agents and automotive byproducts. In addition, two wastewater treatment facilities discharge reclaimed water directly into the stream; and other wastewater facilities in the metropolitan region discharge into tributaries of Clear Creek or the South Platte River. In the twenty-one mile reach from Chatfield Reservoir to the Burlington Canal diversion (which conveys raw water to the Wes Brown facility) the South Platte River flows through the southern portion of the largest and most densely populated metropolitan area in the State of Colorado. This reach of river contains some of the oldest stormwater infrastructure in the state and has numerous heavy industrial sites immediately adjacent to the river. Reverse osmosis treatment (implied as needed for Poudre River conveyance in various cost estimates provided by Thornton) is not utilized, nor is it required, for these significantly degraded raw water sources. The City of Thornton reports that "aesthetic changes" of a "pondy or dirty taste and odor in your drinking water" occur on an annual basis as do algal blooms in the reservoirs that feed the two Thornton water treatment facilities. It seems improbable that water that flows from an outtake at WSSC #4 through approximately twenty miles of the Poudre River could be as degraded as the water in the South Platte River at the Burlington Canal diversion. A treatment facility that is estimated to cost 5.8 to 10.1 times more than the Wes Brown Water Treatment Plant retrofit is difficult to reconcile with the water quality currently documented in the Poudre River. It might be possible that some pre-treatment, such as occasional flocculation, would be needed for water drawn from the CR 13 settling and short-term storage basins in order to insure that it is of similar quality/clarity as water drawn from WSSC #4. That such a process could possibly cost multiple times more than one of the most sophisticated water treatment facilities in the State of Colorado is simply implausible. At the December 17, 2018 Larimer BoCC meeting Thornton's Water Resources Manager and a "principal technologist" with Jacobs Engineering stated that water treatment costs might range from "$50 million to more than $100 million." Most of Thornton's references to the need for any additional water treatment contain phrases such as "treatment, if needed" or "treatment may be needed." It is difficult to compare Alternatives when there is no definitive statement that additional water treatment is, in fact, actually required; and when a range of $50 million to $760 million is the point of reference for any such treatment. To be valid, any cost comparison between Alternatives must be based on similar water quality standards and use the same technical and financial platform of analysis. PERMITTING and CONSTRUCTION Construction of the CR 13 outtake diversion structure and the construction of the settling and short-term storage basins of the SS/PR Alt could potentially impact wetlands. As a result, this activity would be subject to environmental review and federal permitting requirements. Thornton has stated that it would prefer to avoid obtaining any federal permit in order to complete its pipeline project. The appropriate permitting process for the SS/PR Alt is the Clean Water Act Section 404 Permit. Large scale projects with the potential for significant environmental impact require the expensive and time consuming "Individual" permit process administered by the U.S. Army Corps of Engineers. Smaller scale projects with minimum potential for negative environmental impacts, such the CR 13 outtake component, only require a "General" permit under Section 404. This type of permit application process is often completed within one year. When compared to the possibility of lengthy and expensive litigation over 1041 permitting or eminent domain disputes related to the Thornton pipeline proposals, permitting of the SS/PR Alt lies within a timeframe that appears to be less than onerous. A recent, local example of the Section 404 permitting process exists. During the September 2013 Poudre River flood, the Fossil Creek Reservoir diversion structure, owned and operated by the North Poudre Irrigation Company, was destroyed. North Poudre redesigned the structure (including a fish passage component), obtained the required Section 404 permit, and completed construction in a two and one-half year period at a cost of $860,000. The project is another example of regional cooperation along the Poudre River. The City of Fort Collins, the Colorado Water Conservation Board, and Colorado Parks and Wildlife coordinated with North Poudre to analyze the design of the overall structure, particularly the fish passage "ladder," and provided grant and loan funding to complete the project. The City of Thornton began acquisition and planning for water delivery over three decades ago and expects the Project to meet future water needs through 2065. Relative to that timeframe, a reasonable amount of time is required for a thorough and transparent review and planning process that incorporates the involvement of the citizens of Larimer County and other impacted parties; and that utilizes a clearly defined, consistent platform of analysis. While Thornton has stated a desire to begin water delivery in 2025, it should be noted that the full allotment of water would not be required at that time. It should also be noted that federal, state, and local permitting processes are not required to be completed based on that proposed timeline; nor are these processes bound by Applicant defined "Exclusion Areas" that implicitly disqualify the Poudre River as a means of conveyance. A combination of continued water conservation, such as the commendable efforts under the Thornton Water Conservation Plan, and possible augmentation through temporary ATMs would be adequate to address any potential short-term water deficits until permitting and construction of any of the Alternatives is completed. Since the Poudre River provides a natural physical break between segments in the SS/PR Alt, construction of various segments of the supply system could occur simultaneously. For example, the WSSC #4 outlet works and Shields Street pipeline component could be built while simultaneously building the CR 13 diversion structure, settling and short-term storage basins, pump station, and any pipeline required for connection to the proposed CR 13 Pipeline Corridor. Regardless of which of the five alternatives may ultimately be developed, the segment of pipeline from the Firestone/Frederick pump station to Thornton would be identical. Similarly, any infrastructure needed to deliver raw water to Thornton's existing water treatment facilities would also be identical. Construction of these components of the Project could begin at any time, assuming the local permits have been acquired and easements have been negotiated. A GENERATIONAL LEGACY The SS/PR Alt represents an irreplaceable opportunity to re -water a significant portion of the Cache la Poudre River and create what would truly be a generational legacy for Larimer County, Weld County, and the State of Colorado. The twenty mile Shields Street to CR 13 reach would serve as a functional, permanent anchor and provide an incentive for continued restoration of the health of the entire length of the Poudre River. As mentioned above, a variety of entities are currently working to restore the Poudre River and have made significant improvements in river health and stream function. SB 97 (1973) created the legislative authority for the Colorado Water Conservation Board (CWCB) to acquire water rights for "in stream flows" in order to "protect environmental values to a reasonable degree." Subsequent legislation has provided further opportunities to enhance in stream flows though leasing arrangements similar to ATMs and clarified that in stream flows may exceed flows that merely "preserve" minimal stream functions. The Colorado Water Trust is actively engaged in acquiring and transferring to the CWCB such in stream flow rights. While it is imperative to protect the interests of the existing agricultural users and communities in Larimer County; even small, incremental increases in summertime flow would lead to a more connected river system in which the biological and hydrological functions of the Poudre River could be significantly restored. These flows could help reduce or replace any potential loss in yield that might result from an in -river conveyance, and thereby deliver the full allotment under the City of Thornton's water rights. The benefits of even minimal in stream flow rights would positively impact the entire River system, including the 30 mile reach from the CR 13 intake to the confluence with the South Platte River at Greeley. One can envision a future in which "the hardest working river in Colorado" would continue to deliver its historical benefit to the agricultural communities of Northern Colorado, while enhancing the quality of life for a growing population along the Colorado Front Range. The compromise SS/PR Alt represents a unique opportunity for intergovernmental and NGO cooperation that respects the concerns and rights of all stakeholders, while providing the least disruptive and most beneficial solution to address one of Colorado's most important needs. Revised by Mick Ondris on February 25, 2019. Questions or comments are welcome at micksspralt@gmail.com. a • • 506.E N • • • • • • • • • • i0.15. 1• a . t i 5077• I'. • • ,, • Rocky = 'cdge_J 4 Sch :iM 51 at_enyrs ••• 1 0955 ea 0 • September 19, 2018 At the Larimer County Board of Commissioners meeting on August 1, 2018, a decision was made to table the City of Thornton's 1041 Application for the Thornton Water Project. In issuing the decision, the Commissioners articulated several reasons for their unanimous decision. Among these reasons were inadequate levels of public input during the application process and a lack of comprehensive analysis and consideration of viable Alternatives that would utilize the Poudre River as a means of conveyance. Enclosed is a discussion of such an Alternative that is based on a model of regional cooperation and compromise. The intent of the Alternative is to deliver Thornton's full allocation of Poudre River water rights in the least disruptive, most beneficial manner at a reasonable cost. Attached is a list of stakeholders/commentators who have also received a copy of this Alternative. Should you wish to share this document with other interested parties, I request that the document be shared in its entirety. If you would like to discuss any material in this document, please feel free to contact me. F1 SEP 2.6 MR Respectfully, (7Lt /LL7c Mick Ondris 3761 Dalton Drive Fort Collins CO 80526 (970) 225-0083 C�(Y'mu co'4iarNS 10/1/t$ cc• PLCTPA,CA_CFH),CT(3CTJ) PwCICH/Jm) 9/97/II? tw- 01 IS d Larimer County Board of Commissioners Larimer County Planning Office Larimer County Open Lands Program Mark Koleber, Thornton Water Project Director c/o City of Thornton Fort Collins City Council City of Fort Collins Natural Areas Program City of Fort Collins Utilities Weld County Commissioners Windsor Town Board Northern Colorado Water Conservancy District Colorado Water Institute / PRTI Study Action Group Coalition for the Poudre River Watershed Stop Thornton's Pipe Dream Save the Poudre: Poudre Waterkeeper Fort Collins Coloradoan North Forty News KUNC Community Radio SHIELDS STREET/POUDRE RIVER ALTERNATIVE TO THE THORNTON PIPELINE PROPOSAL During the ten month 1041 Permit review process, and particularly during the two public comment periods before the Larimer County Board of Commissioners, several concerns were expressed by the Commissioners, the Larimer County Planning Commission, citizens, and various organizations representing stakeholder groups. These concerns centered on the disruptive nature of the Douglas Road Pipeline Proposal, the lack of public engagement in the decision making process, the short Proposal review period, the perception that the evaluation of Alternatives that utilize the Poudre River as a means of conveyance were superficial, and the summary dismissal of those Alternatives. In reference to Alternatives that utilize the Poudre River as a means of conveyance, the City of Thornton expressed concerns regarding water quality, delivery of the full allotment of water, compliance with the Colorado Water Court and Colorado Supreme Court Decrees that authorized the change in beneficial use from agricultural (Water Supply and Storage Company original rights) to municipal use (City of Thornton), and potential increases in the cost of the overall Project. The Shields Street/Poudre River Alternative (SS/PR Alternative) is a compromise Alternative, based on the principle of regional cooperation that is designed to provide the least disruptive, most beneficial option for the delivery of water from the Poudre River to the City of Thornton in a cost effective manner. This Alternative builds on numerous ongoing efforts by a variety of entities that continue to improve the fluvial and biological functions of the Poudre River. While these improvements are often done as individual projects, each of these efforts positively reinforces and compliments the others. As these efforts continue, the overall stream function and health of the Poudre River will continue to improve. ALIGNMENT The SS/PR Alternative utilizes the existing Poudre River point -of -diversion to the Larimer County Canal (aka Larimer County Ditch) and the proposed outlet at Water Supply and Storage Company Reservoir #4 (WSSC #4). Therefore, this Alternative complies with the Colorado Water Court and Colorado Supreme Court Decrees that authorized the change in beneficial use. As a result, no injury to existing water rights related to the Canal, ditches, or laterals and the subsequent agricultural applications occur. The Alternative is comprised of three segments (please refer to the enclosed sketch map): SEGMENT #1 — approximately 1.1 miles. Outtake at WSSC #4 at 5080 ft. elevation. Buried pipeline roughly contouring (with consistent gradient) with the Dry Creek Ditch easement, south across Douglas Road to the west side of Shields Street at 5040 ft. elevation. The 40 foot elevation differential (approximately 36 ft./mile gradient) eliminates the need for the controversial pump station within the residential/agricultural properties in the vicinity of WSSC #4. Some private residences might be affected by this routing, though considerably fewer than the more than 200 residential properties that would be impacted by the Douglass Road Proposal. By minimizing residential impacts and eliminating the pump station, this Alternative addresses many of the concerns expressed by Larimer County residents and their respective Home Owners Associations during the two Board of County Commissioners public hearings. Note that the properties in the immediate vicinity of the WSSC #1 outlet would be equally impacted regardless of which Alternative might be constructed. Equipment access via privately owned Starlight Drive would most likely still be needed during the construction phase. SEGMENT #2 — approximately 2.3 miles of buried pipeline (or 1.9 miles of pipeline and 0.4 miles of lined ditch south of the Larimer Weld Canal) south to the Poudre River at 4980 ft. elevation. The 60 foot elevation differential provides for an average 26 ft./ mile gradient, allowing for gravity flow through this segment of the alignment. This routing utilizes the existing Shields Street utility right of way or could be sited immediately adjacent to the right of way. The majority of property on this route is undeveloped agricultural land, though there are approximately eleven private residences, two commercial structures, and one public facility that may require some adjustment of the alignment or negotiated easements. The Highway 287/Union Pacific Railroad corridor crossing and the Larimer Weld Canal crossing could employ boring technologies similar to the proposed borings under wetlands as described in the Thornton Pipeline Proposal. To reduce surge effects, water entering the Poudre River would be dispersed through a series of riprap check dams and vegetated distributary channels in the vicinity of the North Shields Ponds Natural Area. Total distance from the WSSC #4 outtake to the Poudre River is approximately 3.4 miles. SEGMENT #3 — approximately 20 miles within the Poudre River (with the 14 mile Shields Street to I-25 reach within the city limits of Fort Collins) to the intersection of the Poudre River and County Line Road near the Town of Windsor per the proposed Thornton Pipeline Project Corridor (hereafter referred to as the "Windsor intake"). In this vicinity, an intake works, settling basins, a pump station, and possibly a (pre)treatment facility would need to be constructed. Since approximately twenty miles of buried 48" pipeline are eliminated, and the Windsor pump station is located 24.5 miles to 26.5 miles from the zone proposed for the Firestone/Frederick pump station, it is possible that one or both of the pump stations could be downsized; or could be consolidated into a single pump station, thereby reducing project and operational costs. This alignment, particularly the Poudre River Segment, provides the greatest benefit with the least disruption to Larimer and Weld counties while protecting water quality and quantity (discussed below) for the City of Thornton. The Windsor to Thornton segment of the pipeline remains identical to the existing Thornton Pipeline Proposal and is not impacted by the SS/PR Alternative. OPERATION The SS/PR Alternative would utilize a seasonal and daily operational reservoir fill and drawdown schedule that would be essentially identical to the Thornton Pipeline Proposal. Fluctuation of shoreline elevation, and any aesthetic impacts on surrounding properties as a result of reservoir drawdown, would remain the same for either Alternative. WATER QUALITY MITIGATION The City of Thornton has expressed a concern that water that would flow through the Poudre River may be degraded relative to the quality of water delivered from WSSC #4. Neither source would directly supply potable water to consumers in Thornton. It is the intent of this Alternative to deliver water to the Thornton water treatment facilities that is of similar quality as water delivered from WSSC #4. Several factors need to be considered in regards to water quality. Among these factors are sediment load, agricultural runoff in the reach from the Canyon Mouth to Windsor, municipal stormwater runoff, discharge from three wastewater treatment facilities in the City of Fort Collins, reduced biological function as a result of this combination of factors and, most importantly, the current depleted flow regime within the Poudre River. The single most effective long-term water quality mitigation is simply the re -watering of the Poudre River from Shields Street to Windsor. Sedimentation: With the exception of some periodic storm -induced increases in sediment load as a result of recent (2013) fire scars in the upper basin, the Poudre River has relatively low turbidity. A considerable amount of watershed restoration has been performed by the Coalition for the Poudre River Watershed and other volunteer organizations. These notable efforts are ongoing and help reduce the base sediment load through the entire river system. As a result, the stream water that would be "mixed" with outtake from WSSC #4 contains less sediment than pre -mitigation runoff. The Coalition's "Upper Poudre Watershed Resilience Plan" (2017) provides a framework for future mitigation and presents a "Sediment Transport Model" for the Lower Basin. Of course, turbidity is a function of streamflow (volume, velocity, and gradient) and therefore fluctuates throughout the course of the year. The existing four WSSC reservoirs, in conjunction with Kluver Reservoir, function as a "settling basin" for waters diverted from the Poudre River via the Larimer County Canal. While this water is relatively sediment free, it is not classified as potable and treatment is still required. In order to achieve similar water clarity, the SS/PR Alternative would require the construction of settling basins in the vicinity of the Windsor intake and pump station. As with all works of this type, inlets to the settling basins would need to have the capability to shunt water during flood events or anomalous incidents such as forest fire sediment load increases. This presents an opportunity for a collaborative effort in which the City of Fort Collins Natural Areas Program, Larimer County, and The Town of Windsor might cooperate in the design and construction of the settling basins in conjunction with a floodplain enhancement and/or recreational development. The annual hydrograph of the Poudre River indicates that the maximum volume, and therefore maximum sediment load, typically increases in May, peaks with the "June Rise," and diminishes rapidly by early July. The water demand curve for the City of Thornton begins its annual rise from May to June, then peaks during the July and August lawn irrigation season, and begins to diminish in September. The implication of this lag in peak consumption demand relative to peak flow/sediment load is that maximum stream withdrawal would occur during periods (July and August) when the sediment load is naturally reduced as a function of reduced streamflow. This also coincides with maximum annual irrigation demand and maximum water diversion at the Canyon Mouth, thereby further reducing the peak flow and peak sediment load in the reach from the Canyon Mouth to Windsor. Should Glade Reservoir of the Northern Integrated Supply Project (NISP) be constructed, considerable reductions in sediment load would be realized. By design, the peak flow/sediment load would be significantly truncated as this is the exact flow regime from which NISP would be drawing water out of the Poudre River at the Canyon Mouth diversion structure per the Northern Colorado Water Conservancy District's 1980 priority right. Agricultural Runoff: Agricultural runoff can negatively impact water quality by introducing nutrients, primarily phosphorous and nitrogen compounds, into the stream system. These nutrients often create conditions favorable to algal growth, and in turn increase Biological Oxygen Demand (BOD). Agricultural runoff in the Canyon Mouth to Windsor reach could be significantly reduced by utilizing voluntary, market -driven Conservation Easements to create buffer zones along the river corridor. With the incentive of tax benefits for property owners, entities such as the Larimer County Open Lands Program, the City of Fort Collins Natural Areas Program, the Coalition of Colorado Land Trusts, and other non -governmental organizations (NGOs) could identify willing participants and negotiate mutually beneficial agreements that reduce non -point source pollutants while preserving the agricultural heritage of Larimer County. These agreements could include a menu of non -point source mitigation strategies such as berms, vegetated swales, improved fertilizer management, manure management, conservation tillage to reduce soil compaction and runoff, and the use of seasonal cover crops. Additionally, ongoing improvements in floodplain connectivity (e.g. Fort Collins Natural Areas Program "Riverbend Ponds" enhancement) would increase the amount of time and surface area that river water would be filtered through plants and alluvium, thereby increasing the uptake of nitrogen and phosphorus compounds (while also providing the ancillary benefit of reducing sediment load). Stormwater Management: Most stormwater runoff occurs in urban areas, particularly from non -permeable surfaces such as roofing and pavement. The primary source of stormwater runoff in the relevant reach of the Poudre River is the City of Fort Collins. Fort Collins continues to address this issue through its Stormwater Management Program. Infrastructure improvements, such as catchment basins that collect and temporarily retain stormwater runoff to facilitate plant and soil filtration, are a primary component of the Program. Also included are public education/enforcement components that focus on automotive byproducts; lawn care contaminants such as fertilizer, pesticides, and herbicides; and construction site runoff and building code modifications that encourage semi -permeable parking and other hardened surfaces. In some cases, rebates are available to facilitate reductions in surface runoff (and reduce overall water consumption). The Colorado State University Stormwater Center also provides resources for Best Management Practices for stormwater districts, so-called "green infrastructure" design and construction guidance, and Low Impact Development strategies. Wastewater Treatment Discharge: The City of Fort Collins Mulberry, Drake, and Fossil Creek wastewater treatment plants are operated in a manner that meets or exceeds all state and federal standards for wastewater reclamation. Physical, biological, and chemical processes are used to treat wastewater prior to discharge into the Poudre River (Mulberry and Drake facilities) and into Fossil Creek Reservoir. This reclaimed water is essentially free of organic, pathogenic, and metal contaminants that may pose an environmental or human health risk. Aeration is utilized as a means of odor control. The City of Fort Collins has a cooperative service agreement with the United States Geological Survey to monitor water quality within the Poudre River. As with the raw water in WSSC #4, reclaimed municipal wastewater is not categorized as potable and must be treated prior to household consumption. In view of the fact that the city of Fort Collins would receive considerable quality of life and economic benefits from a re -watered Poudre River, it is reasonable to suggest that the City of Fort Collins may be willing to enter into an Intergovernmental Agreement (IGA) with the City of Thornton to further improve the quality of effluent water from its reclamation operations, especially the Mulberry and Drake facilities that discharge directly into the Poudre River. This IGA could consist of enhanced treatment (e.g. increased aeration or ultraviolet irradiation) at the Fort Collins points of discharge or a financial/in-kind contribution to a pre-treatment facility located at, or down pipeline of, the proposed Windsor pump station (in addition to the aforementioned settling basin/floodplain improvement). It is again important to emphasize that these mitigations would take place in conjunction with, and would complement, existing and future efforts designed to improve overall river health. Biological Function: Functioning, intact river systems deliver a variety of ecosystem services. The services most relevant to municipal supply water quality are chemical and nutrient uptake, algae control, water temperature moderation, and the resulting dissolved oxygen content. When healthy, the in -stream and riparian plant communities and streambank alluvium can remove much of the dissolved chemical and nutrient load, further enhancing the above mentioned mitigations related to agricultural and stormwater runoff. The amount of algae in a stream will remain in general equilibrium unless impacted by increases in nutrients such as phosphorous and nitrogen. Water temperature and exposure to sunlight also influence algal growth. Hence, so called "algal blooms" occur most frequently in warm, standing water that is exposed to sunlight and a high nutrient content; conditions frequently found in water storage reservoirs. A flowing Poudre River would rarely present conditions conducive to algal blooms. Furthermore, a more natural stream ecosystem cools (shading and alluvial flow) and oxygenates the waters within it. These natural stream functions are so effective that the City of Aurora utilizes them as a major purification component in the Prairie Waters Project that treats wastewater effluent to such a high quality that it is mixed into the potable water supply. Increased flows from WSSC #4 would enhance these purifying functions of the stream ecosystem as well as improve ecosystem connectivity. It is important to note that while some degradation of water quality in the Shields Street to Windsor reach would most likely occur as a result of agricultural runoff, stormwater runoff, and water reclamation discharge; the biological and fluvial functions of a healthier, re -watered Poudre River would simultaneously mitigate many of those impacts. INSURING FULL ALLOTMENT The City of Thornton is entitled to its full allotment of water as specified in the Colorado Water Court and Colorado Supreme Court Decrees. A legitimate concern with the SS/PR Alternative is water loss during conveyance within the Poudre River. Some loss would occur as a result of increased evapotranspiration from a more densely vegetated stream course, infiltration to the adjacent alluvium, and direct evaporation from the surface of the river. The amount of consumed water would decrease over time. The initial increase in plant growth and the initial recharge of alluvial bank storage (not actually "consumed," but retained in bank storage) would be greatest in the earliest operation of this Alternative; a timeframe in which full allotment exceeds consumptive demand. In particular, alluvial bank storage would reach a seasonal equilibrium within the first year of operation. While some WSSC water would be stored in the alluvium, the majority of recharge would still be the result of the (diminished) seasonal peak flows that currently occur within the Poudre River watershed. As an additional benefit, when water is released from bank storage during periods of low flow, it is cooler; more oxygenated, and contains less algal growth than water stored in a reservoir. There are three mechanisms available to mitigate these potential losses. While full allotment would not be required during the initial, somewhat higher consumption phase of alluvial recharge and stimulated plant growth, Alternative Transfer Methods (ATMs) could be employed to compensate for any potential shortage. The Colorado Water Plan calls for acquisition of 50,000 acre feet of water through this mechanism. The most frequently used ATM approach is the "interruptible water supply agreement." Under recent State legislation, these agreements allow agricultural users to fallow lands and lease water held under an agricultural right for municipal use for three out of ten years. The agricultural right may not be challenged as "abandoned" under this legislation. This is an ideal mechanism for compensating for any possible initial shortage in the SS/PR Alternative in that the quantity of leased water can be easily reduced over time, agricultural land is not permanently taken out of production, and the cost is considerably less than outright purchase and conversion of agricultural water rights. A second mechanism is the continued purchase of existing agricultural rights within the Poudre drainage. This is the least desirable option as it results in permanent removal of productive agricultural lands, has the potential to injure other existing water rights, and is expensive. Fortunately, only the water annually consumed in increased evapotranspiration and the baseline surface evaporation losses would need to be replaced on a long term basis. A final option that could be used to mitigate the long term evapotranspiration/evaporative loss is an in -kind exchange of water rights between entities that receive a benefit from a re -watered Poudre River, especially the City of Fort Collins. Fort Collins would need to analyze the value of any potential water rights transfer vis-�-vis the economic benefits inherent in a healthier, aesthetically more pleasing re -watered Poudre River flowing through a significant portion of the City. From a legal perspective, any such transfer should be relatively free of contentious litigation as it is a municipal -to -municipal transfer with little potential to injure other existing water rights. One other potential should be considered. While no formal agreement has been reached, the Northern Colorado Water Conservancy District has discussed a mitigation plan with the City of Fort Collins that would allocate a minimum base flow for the Poudre River as a component of the NISP operational plan. Should such an agreement be reached, the minimal flow would eliminate the seasonal "dry up points" below irrigation diversion structures along the Poudre River and thereby provide ecosystem connectivity, enhancing stream function. This release would help maintain bank storage and partially compensate for evapotranspiration and evaporative losses. The net result would be a decrease in the long term need to acquire water to compensate for any possible depletion of the Thornton allocation. COST COMPARISON Until a more detailed engineering and construction cost analysis for the SS/PR Alternative and the final alignment of the Thornton Pipeline Proposal is completed, it is difficult to provide much more than a qualitative comparison of the two Alternatives. Obviously, with a net decrease of approximately seventeen miles of buried 48" pipeline, some cost reduction would be realized with the SS/PR Alternative. The segment eliminated also represents some of the most expensive per mile costs of the pipeline as it includes the replacement of Douglas Road and increased costs associated with minimizing disruptions and maintaining emergency access during the construction phase. As previously mentioned, construction costs and operational costs would decrease as a result of downsizing or consolidating the Windsor and Firestone/Frederick pump stations. Other costs would remain similar regardless of which Alternative is constructed. The outlet works at WSSC #4 would be essentially identical as would be the various "appurtenant structures" referred to in general terms in the Thornton Pipeline Proposal public presentations. Components of the SS/PR Alternative that could be more expensive than the Thornton Pipeline Proposal include the intake works and settling basins in the vicinity of the Windsor intake (see prior reference to potential collaborative approach). Permitting, water rights acquisition (if needed), and potential adjudication might also be additional costs associated with the SS/PR Alternative. Perhaps the most difficult cost to estimate is the possibility that a treatment plant or pre- treatment plant would be needed if the Poudre River is utilized as a means of conveyance. An important consideration is that the SS/PR Alternative need only supply water of a quality that is comparable to that supplied by WSSC #4. Again, neither source supplies potable water. During the Public Hearing on August 1, the City of Thornton presented a graph summarizing cost projections for a generic Poudre River Alternative withdrawing water at Windsor. Included in that graph was an estimate of $440 million to $760 million for "water treatment." The City of Thornton recently upgraded the Wes Brown Water Treatment Plant at a cost of $75 million. Obviously, the costs of land acquisition and the basic infrastructure associated with a treatment plant are not reflected in the $75 million retrofit. Based on the figures provided by Thornton, the estimate indicates a cost of $365 million to $685 million for the basic footprint of a treatment facility located at Windsor. Such a cost implies a design criteria based on a water quality parameter far exceeding the existing water quality in WSSC #4. The Wes Brown Water Treatment Plant is described by the City of Thornton as a facility that "uses advanced water treatment processes including state-of—the-art ultrafiltration membranes." The current primary sources for Thornton's raw water are Clear Creek and the South Platte River. While considerable mitigation has since occurred, it should be noted that the Clear Creek/Central City site was placed on the Superfund National Priority List in 1983. The South Platte River flows through the largest and most densely populated metropolitan area in the State of Colorado and contains some of the oldest stormwater infrastructure in the state. The City of Thornton reports that "aesthetic changes" of a "pondy or dirty taste and odor in your drinking water" occur on an annual basis as do algal blooms in the reservoirs that feed the two Thornton water treatment facilities. It seems improbable that water that flows from an outtake at WSSC #4 through approximately twenty miles of the Poudre River could be similarly degraded. A Windsor (pre)treatment facility that is estimated to cost 5.8 to 10.1 times more than the Wes Brown Water Treatment Plant retrofit is difficult to reconcile with the water quality currently documented in the Poudre River. It is possible that some pre-treatment would be needed for water drawn from the Windsor settling basins in order to insure that it is of similar quality as water drawn from WSSC #4. That such a facility could possibly cost multiple times more than one of the most sophisticated water treatment facilities in the State of Colorado seems implausible. To be valid, any cost comparison between Alternatives must be based on similar water quality standards and use the same platform for analysis. PERMITTING and CONSTRUCTION The SS/PR Alternative could potentially impact wetlands and would therefore be subject to environmental review and permitting. While these processes are time consuming, some factors suggest a somewhat more rapid timeline through permitting and construction. A considerable amount of stream function data, hydrologic modeling, and environmental impact projections are available for the reach contained in the SS/PR Alternative as a result of the extensive National Environmental Policy Act (NEPA) Environmental Impact Statement (EIS) requirements for NISP. In addition to this body of work, the City of Fort Collins "River Health Assessment Framework" (2015) and the aforementioned "Sediment Transport Model" provided by the Coalition for the Poudre River Watershed (2017) could be directly incorporated into an assessment of the SS/PR Alternative. While public comment is required for any permitting process, it seems reasonable to assume that there would be far fewer, if any, major objections to an Alternative that provides so many tangible, positive environmental benefits as the SS/PR Alternative. When compared to the possibility of lengthy and expensive litigation over permitting or eminent domain disputes related to the Thornton Pipeline Proposal, permitting of the SS/PR Alternative lies within a timeframe that appears to be less than onerous. The City of Thornton began acquisition and planning for water delivery over three decades ago and expects the Project to meet future water needs through 2065. Relative to that timeframe, a reasonable amount of time is required for a thorough and transparent review and planning process that incorporates the involvement of the citizens of Larimer County and other impacted parties; and that utilizes a clearly defined, consistent analysis platform. While Thornton has stated a desire to begin water delivery in 2025, it should be noted that the full allotment of water would not be required at that time. It should also be noted that the 1041 Permit process is not required to be completed based on that proposed timeline. A combination of continued water conservation, such as the commendable efforts under the Thornton Water Conservation Plan, and possible augmentation through temporary ATMs would be adequate to address any potential short-term deficits until permitting and construction of any Alternative is completed. Since the Poudre River provides a natural physical break between segments in the SS/PR Alternative, construction of various segments of the supply system could occur simultaneously. For example, the WSSC #4 outlet works and Shields Street pipeline component could be built while simultaneously building the Windsor to Thornton segment of the pipeline. Since the Weld County segment of pipeline remains identical in either Alternative, construction could begin on that segment upon issuance of the Weld county and other jurisdictions' permits. Similarly, any intake works and other infrastructure needed to deliver raw water to either of Thornton's water treatment plants could also proceed. A GENERATIONAL LEGACY The SS/PR Alternative represents an irreplaceable opportunity to re -water a significant portion of the Poudre River and create what would truly be a generational legacy for Larimer County, Weld County, and the State of Colorado. The twenty mile Shields Street to Windsor reach would serve as a functional, permanent anchor and provide an incentive for continued restoration of the health of the entire length of the Poudre River. As mentioned above, a variety of entities are currently working to restore the Poudre River and have made significant improvements in river health and stream function. SB 97 (1973) created the legislative authority for the Colorado Water Conservation Board to acquire water rights for "in stream flows" to protect environmental values to a reasonable degree. Subsequent legislation has provided further opportunities to enhance in stream flows though leasing arrangements similar to ATMs. While it is imperative to protect the interests of the existing agricultural users and communities in Larimer County; even small, incremental increases in summertime flow in the eight miles from the Canyon Mouth diversions to Shields Street would lead to a connected river system in which the biological and hydrological functions of the Poudre River could be significantly restored. These flows could reduce or replace any potential consumptive loss that might result from an in -river conveyance and thereby deliver the full allotment under the City of Thornton's water rights. The benefits of even minimal in stream flow rights would positively impact the entire River system, including the 30 mile reach from the Windsor intake to the confluence with the South Platte River at Greeley. One can envision a future in which "the hardest working river in Colorado" would continue to deliver its historical benefit to the agricultural communities of Northern Colorado while enhancing the quality of life for a growing population along the Colorado Front Range. The SS/PR Alternative represents a unique opportunity for intergovernmental and NGO cooperation that respects the concerns of all stakeholders while providing the least disruptive and most beneficial solution to one of Colorado's most important needs. • 506 i• 1' • - • • . LA • • • 1/4 4, . 016- • • Ij • I I I. . ! • . • • •• I • so O its ` Grave Pits c • 0 61) VA' SEGMENT #2 le y • \k/i. I 5005 • q• . N I . "► \ 1. • -�' c•/ 8 O tj • N 4 °,7c, /'r / a9s4 I •.. ....,I :II..r . • .:•. 4 • a If February 19, 2018 Sent via U. S. Mail and Email Larimer County Commissioners Lew Gaiter Ill Steve Johnson Tom Donnelly 200 West Oak, Suite 2200 Fort Collins, CO 80521 Mr. Rob Helmick Larimer County Planning 200 West Oak Fort Collins, CO 80521 Mr. Mark Koleber City of Thornton 12450 Washing Street Thornton, CO 80241-2405 Weld County Commissioners Mike Freeman Julie Cozad, Barbara Kirkmeyer Sean Conway Steve Moreno 1150 O Street P.O. Box 758 Greeley, CO 80631 Re: City of Thornton 1041 Permit Application and the Thornton Water Project Dear Commissioners, Mr. Helmick and Mr. Koleber: RECEIVED MAR 022018 COMMISSIONERS We are writing in regards to the City of Thomton's 1041 Permit Application currently making its way through the Larimer County process. As residents located along Larimer County Road 1 and Weld County Road 13, we would like to express our desire to have the Thornton Water Project pipeline placed in the middle of the current road right-of-way. We understand that the Town of Timnath has agreed to allow the alignment of the pipeline within the portion of the road located in Timnath immediately north or adjacent to our properties. The current maps supplied to us from Western States Land Services, Inc. show that the proposed pipeline on LCR 1/WCR 13 south of Harmony Road is aligned within the road right-of-way until Larimer County Road 32 where is crosses into private land in Weld County. The maps indicate a placement on the 3i iai tir 1 cc= PAC TP/ m m), cat ecz, mot EP ICWain),C.TBCTS) *J/CO/ l $- 2018-0715 Sondrup parcel in Weld County, then again into the road right-of-way until it crosses into the Hoff parcel in Larimer County. The pipeline continues in Larimer County part way through the George parcel until it crosses over to the Weld County property of Westwind Farm, LLC. This route causes concern for us as property owners in that the proposed route cuts through irrigation ditches that are needed to service our crops and would impact our property values. We would ask that Larimer and Weld Counties require the Thornton Water Project pipeline to remain in the middle of the County Line Road right-of-way from Harmony until Larimer County Road 32/Weld County road 68 1/2. We also note that Larimer County is now asking for additional information/materials from the City of Thornton regarding Field Survey Information, Pipe Alignment, Anticipated Construction Schedule, Pavement Restoration Plan and Utility Coordination. Larimer County requested this information in its January 26, 2018 letter for the 2.6 mile segment along County Road 54. We would request the same type of information for the portion of Larimer County Road 1/Weld County Road 13 that impacts our properties. It is our hope that the City of Thornton will be consistent in its application to Larimer County to include the additional information/materials for all properties along the TWP route. Thank you for your consideration. Sincerely, Is/ See attached signature pages David and Stephanie Hill, Larimer County Parcel No. 8601000008 Ron and Carole Sondrup, Weld County Parcel No. 080707000042 Jim and Sandy Helzer, Larimer County Parcel Nos. 8612406001 and 8612406002 Shawn and Pam Hoff, Larimer County Parcel No. 861200001 Mark and Linda George, Larimer County Parcel Nos. 8613105002 and 8613105001 2 Sincere Al/ ..'/6/1:C egee- David and Stephanie Hill, Larimer County Parcel No. 8601000008 4729 South Larimer County Road 1 Fort Collins, CO 80525 3 Sincerely, Ron and Carole Sondrup, Weld County Parcel No. 080707000042 34310 Weld County Road 13 Windsor, CO 80550 a-)-,--e-e._( a_..=rze_e.ic7 So/7Ji(f 4 Sincerely, Jim and Sandy Hetzar, Larimer County Parcel Nos. 8612406001 and 8612406002 6301 South Larimer County Road 1 Windsor, CO 80550 Sincerely, Shawn and Pam Hoff, Larimer County Parcel No. 8612000012 6405 South Larimer County Road 1 Windsor, CO 80550 6 Sincerely, Mark and Linda George, Larimer County Parcel Nos. 8613105002 and 8613105001 6801 South Larimer County Road 1 Windsor, CO 80550 Hello