South Platte Basin Triennial Review 11/7/00
Triennial Review Statement on Behalf of Friends of the Poudre
Delivered by Charles Wanner, Executive Director
My name is Charles Wanner. I am the executive director of Friends of the Poudre. Friends is a conservation organization that has worked over the past 14 years to protect the natural qualities of the Poudre River and its surroundings. The organization is involved in various activities in the basin including efforts to preserve base water supplies, interpret the history of water development in the basin, and the formation of a basin wide stakeholders group to facilitate community decision-making about the use of resources in the basin. We are also, surveying and cataloging existing water quality data in an attempt to get an overall view of the health of the river and in the hopes of eventually encouraging the stakeholders of the basin to implement a comprehensive monitoring program. We have hosted a series of informational seminars about a variety of topics from paleo-flooding of the Poudre to the TMDL process. In the past our group has worked on the creation of Gateway Park at Fort Collins Water Treatment Plant #1 and The Fort Collins/Big Thompson Legacy Project.
Our comments today are not of a highly technical nature nor do they address the legal niceties. We do not claim any special expertise in these areas and we do not hold a permit to discharge into the river. We speak from a broader public view hoping to see a central natural feature of our area protected for the uses to which the residents of the area put it.
We wish to speak in support of all of the proposals the Water Quality Control Division has presented for the Poudre Basin. In light of the thousands of people relying on the waters of the Basin for drinking water, recreation and irrigation it seems imperative that this resource be maintained in such a way that human impacts do not negatively affect the quality of life of those living in the basin. We believe that the population as a whole is willing to make the effort necessary to maintain the water quality that these proposals require. We also believe that the views of the general public are not necessarily reflected in the positions of the permit holders in the basin and the specific needs that they represent. It is our opinion that the re-segmentation and added protections given to the upstream segments of the river are appropriate. We feel that the Wild River reaches of the Wild and Scenic River portion of the Poudre, like the segments that flow through, and bound on, designated wilderness areas, deserve to be designated Outstanding Waters. Given the recreational use of Segment 11 and 12 by fishers that also drink the water from the upstream segments, the addition of the fish ingestion standard for these reaches is appropriate.
The Divisions' proposals for Segment 13 and the Alternative Proposals of the North Front Range Water Quality Planning Association are of special interest to Friends of the Poudre. It is our position that the Segment 13 proposals by the state are appropriate. The state should take a broad and forward-looking view when setting classifications for segments in areas that are rapidly changing in terms of population density and land use. It is necessary for us to look to the future when classifying stream segments rather than to the past.
In response to North Front Range's proposals we offer the following comments regarding Fossil Creek, Spring Creek and Boxelder Creek (Larimer County).
Generally, the objections to the state's proposals seem aimed at lightening the load of permit holders in terms of possible regulatory concerns, rather than looking to the current and future uses of the streams by the general populace. We see no data to support a lack of attainability on the basis of water quality over the next 20 years as a result of background levels of contamination. The water quality data in the Use Attainability Analyses is generally over five years old and does not reflect changes in governmental policies or land uses that have occurred in the recent past. With the exception of Boxelder Creek, the analyses did not involve any public input. Public participation of some type is a part of the process of determining use attainability that we feel should be included in any analysis. It seems that to make predictions that Recreation Class 1A water quality standards would not be attainable in a time frame of twenty years is an extremely broad assumption.
Also, a broad definition of public access should be used which includes both casual and formal access. It is not good to rely on historical land uses and ownership to keep people out of contact with these streams in a rapidly growing and changing area. Finally, insisting that steams must have stretches deep enough for full immersion by adults wishing to 'swim' in the classic sense for those segments to be considered suitable for Recreation 1A protection is overly restrictive. This approach does not take into account the behavior of children who are likely to be attracted to such streams and to engage in play in and around them. Children are less resistant to many diseases and their use of these streams should be enough reason to consider their need to be "swimmable" and under the protection of a Recreation 1A classification. Wording such as the "segment(s) do(es) not have a reasonable potential to support one or more primary contact recreation activities on a recurring basis" and "the vast majority of the stream is too narrow and shallow to support Rec. 1 uses" miss the point. It should be noted that the Fort Collins City Council resolution regarding these segments questions their inclusion solely based on water quality. No objection is made in regard to quantity of water, or to the attainability of the standards of this classification on any other grounds.
Specifically we offer the following observations:
Boxelder Creek (Larimer County):
This stream passes through parts of the largest municipal area in the basin. It is hard to believe that
there is no direct contact by children with its waters. The lower parts of this creek are close to natural
areas owned by the city of Fort Collins. A large part of the lower creek is close to being surrounded
by the city thus becoming part of an enclave, which would be annexed by the city pursuant to city
policy. The surveying of students at Ault High School, while a good effort, does not amount to a
thorough survey of the area's children or adequate public participation in our opinion. The use
patterns in the area are changing, making the argument that the current levels of fecal coliform
contamination cannot be reduced questionable. The age of the water quality sampling data presented
makes one question its relevance as a tool to be used in trying to make long term (20 yr.) projections
of attainability.
Spring Creek:
Spring Creek flows through the western portion of Fort Collins to the Cache La Poudre River. In its
travels it passes through city owned parks and natural areas. Bicycle paths parallel the stream for
most of its length. Clearly the city considers this stream a recreational amenity. Children do play in
this stream on a frequent basis. Land use patterns in the basin have changed dramatically over the
past few years, grazing adjacent to the creek is declining. A recent resolution by Fort Collins City
Council indicates the city's interest in the streams water quality. Clearly this stream is available to
primary contact by many of the residents of the area.
Fossil Creek:
Fossil Creek flows through several natural areas owned by the City of Fort Collins. It does contain
pools deep enough for adult full immersion. It is a central feature of the community park (community
park being Ft. Collins' largest type of city park) known as Fossil Creek Park. It flows into Fossil
Creek Reservoir, which is part of a joint city and county natural area. Access may at present be
limited to half of the stream's length. This will not be true for long, as much of the undeveloped land
along the stream has already been purchased for development. Most of the stream is in one of the
fastest growing parts of the Fort Collins Urban Growth Area.
In conclusion, Friends of the Poudre is concerned that standards for use reflect current and future uses. It seems to us that the rapidly growing population of the Poudre basin, as indicated by the growth of the communities that are adjacent to the river and its tributaries, will occasion many more contacts with all of the streams of the basin. Ownership is being fragmented by development and the acquisition of riparian areas for public use is growing. The population of the counties of Weld and Larimer will probably double in the next 25 years. It seems important that we act now to protect and improve the condition of our water resources, in light of the increased demands for recreation that this increase in population will bring.
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