On Sept. 21, Denver Water submitted its 1041 permit application to the Boulder County Community Planning and Permitting Department to begin formal local review of the Gross Reservoir expansion project. (The county’s webpage link on this project is bouldercounty.org/property-and-land/land-use/planning/denver-water-gross-reservoir/. Standards for approval of the permit application are presented in Section 8-511 of the 1041 regulations.)

A public hearing on the permitting process will be held sometime after initial review and before the county commissioners make a decision based on the Planning Department recommendation. It will be most interesting to see whether the county deems the application complete and sufficient to make an informed decision (approve or deny the project), especially regarding the many adverse and extensive impacts the project will impose on the county and its citizens, as well as on the Colorado River and its tributaries.

This is because Denver Water, the U.S. Army Corps of Engineers and the Federal Energy Regulatory Commission have historically avoided presenting necessary and up-to-date information to assess the full magnitude of project impacts to various parties, including Boulder County. (Refer to two letters presented near the bottom of the above-referenced webpage: Boulder County’s Comments on the Final Environmental Impact Statement for the Moffat Collection System Project, dated June 5, 2014, and Boulder County’s Comments on the Supplemental Environmental Assessment of Denver Water’s Application for License Amendment for Gross Reservoir Hydroelectric Project, dated March 20, 2018.)

These Boulder County comments highlight critical information that has been missing. Without this information, agencies and citizens have not been able to discern whether the project’s purpose and need stated in the Environmental Impact Statement are currently valid, and whether the most cost-effective, least harmful alternative was selected as the preferred action.

The purpose and need analysis was conducted in 2002 using pre-2002 data. In today’s fast-changing world, that’s ancient history. Denver Water needs to make a credible case why this project is needed today to meet the needs of Denver residents when water conservation efforts already taken have shown the project is no longer needed. How will it really use additional water obtained at the expense of the Boulder County environment and citizens? Will it sell water to other cities and farmers?

Denver Water also needs to demonstrate how the Western Slope watersheds will be able to provide additional water to fill the increased reservoir capacity in light of our prolonged drought and worsening climate change. Previous assessments did not even consider climate change, and case precedent and current regulations require such projects to consider climate change.

In addition, as of March 2018, Denver Water had not presented a plan to responsibly remove and dispose of an estimated 200,000 trees, including trees within a designated environmental conservation area. That amount of trees represents a significant amount of sequestered carbon that would be released. Without all of this information and lots more to explain and justify other impacts over a four-year construction period, there is no way the county will be able to approve the project.

There are a lot of people in Boulder County who believe this proposed project, which would be the biggest ever undertaken in the County, cannot be justified, and therefore, may explain why missing information has not been provided. The total project cost probably will exceed $450,000,000, in addition to significant social and environmental costs. That amount alone is enough to deny the project in the face of many more pressing societal needs.

Society has limited financial resources that need to be prioritized, and this project does not warrant high priority, especially if increased capacity cannot be used. Spending that amount of money on the project would represent a significant opportunity cost. For example, that amount of money could buy a lot of much-needed climate response and resiliency action, such as climate-related infrastructure.

Therefore, I implore citizens of Boulder County to read the above-referenced letters and attend the project public hearing (for which a date has not yet been announced). Let’s all come together, armed with information, to support the county and demand answers from Denver Water.

We and the county together are a force to be reckoned with against Goliath. We just need to loudly speak up as one unified voice. If adequate answers have not been provided, we all must passionately petition our state and local representatives, including the Boulder City Council and county commissioners, to deny the permit and stop the project.

Gerard Kelly is a resident of Boulder.