GUEST COLUMN: In response: SDS has been thoroughly studied and researched
On August 3, the Gazette published an “Open Letter to the Citizens of Colorado Springs” by an entity called The Consumer Advocate Inc. The same letter was presented to Colorado Springs City Council, Pueblo City Council and other media. This entity claims to “represent interests of and investigate consumer complaints” and “have conducted research on the Southern Delivery System (SDS) and other viable options.” It’s both unfortunate and irresponsible that The Consumer Advocate Inc. made no effort to contact Colorado Springs Utilities prior to the wide spread publication of this letter, especially since it says its “mission is to get the facts on both sides of a consumer issue and present them in an unbiased fashion.”
The assertions by Consumer Advocate Inc. are inaccurate, misleading and unduly alarming. As part of the extensive public review process and record, the issues they raise have been completely addressed and refuted through rigorous analysis. This letter was the first contact that Colorado Springs Utilities has received from this entity – despite the fact that the Secretary of State Website indicates Consumer Advocate was established as a for-profit corporation in Manitou Springs in 2001.
During the five-and-a-half-year Environmental Impact Statement (EIS) analysis for SDS, public comment was actively solicited through several, well-advertised public comment periods, dozens of public meetings held in three counties and news stories. Additionally, had Consumer Advocate Inc. reviewed the publicly available EIS technical reports, Final EIS and Record of Decision (www.sdseis.com) as part of its research, they would have found detailed responses to public comments which fully address their issues.
Safety of Pueblo Dam: Pueblo Dam is managed by the Bureau of Reclamation (Reclamation) within the U.S. Department of the Interior. As noted in Reclamation’s SDS Record of Decision, “…Reclamation’s facilities must be operated and maintained safely, in order to protect our nation’s security, economy and environment. Reclamation ensures safety through inspections for safety deficiencies, analyses that use current technologies and designs, and corrective action if needed based on current engineering practices.”
Reclamation is constantly monitoring and inspecting the dam to ensure its continued safe operation. There are more than 150 monitoring instruments on and around Pueblo Dam measuring water pressure, seepage, and movement. The equipment is checked daily, weekly, or monthly, per a prescribed schedule. Inspections and analysis of Pueblo Dam using current technology and safety standards also occur on a set schedule. Facility reviews were completed in 2006 and 2009 and another comprehensive review is scheduled for 2012.
They cite a 1977 report on dam safety, yet fail to mention that since then Reclamation has implemented a dam safety program in 1978 with passage of the Safety of Dams Act (Public Law 95-578) and Pueblo Dam has undergone several technological updates.
Consumer Advocate’s claims regarding SDS impacts on water levels in Pueblo Reservoir are also false. The Reservoir stores up to 357,000 acre-feet of water and SDS water will be part of that same total volume. Their assertion that “the current SDS proposal calls for the water level to be raised substantially above the current level” is opposite of what will actually occur. The Final EIS indicates that when SDS is fully operational water levels would be, on average, about 6 feet lower over the course of an entire year than they have historically been. Additionally, there are no restrictions on filling the reservoir as claimed.
Fremont County Alternative: In a 1978 supplement to the Fountain Valley Conduit’s FEIS, a Fremont County alternative was dismissed and replaced by the conduit’s current alignment due to construction challenges, cost, as well as environmental and operational issues.
The Fremont County Pipeline Alternative was suggested for SDS previously by proponents who could benefit financially from construction of that alternative. Their concept, which included the use of an enlarged Brush Hollow Reservoir and a pipeline along Highway 115, was dismissed due to anticipated cost, environmental impacts, and construction challenges.
Reclamation did consider high level concepts offered by these proponents, however details substantiating those concepts were never provided. It was Colorado Springs Utilities that ensured that those concepts were studied as the Highway 115 Alternative in the SDS EIS.
The Highway 115 Alternative was determined to cost a minimum of $190 million more than the Preferred Alternative from Pueblo Reservoir. Beyond cost factors, the engineering analyses on both alternatives identified significant advantages of the Preferred Alternative. A reservoir intake at Pueblo Dam is superior to a river intake in Fremont County for water quality and operations and maintenance. SDS from Pueblo Dam will require fewer miles of pipeline and the terrain from Pueblo Dam poses fewer construction challenges. Also, using Pueblo Reservoir leverages our community’s more than $68 million investment in the Fryingpan-Arkansas Project.
Consumer Advocate Inc. recommends that we stop SDS immediately until “due diligence” on the project is done. Exhaustive due diligence has been done on SDS. And, all the issues they raised have been completely addressed through the extensive public processes already completed.
After a decade of analysis and completion of the five-and-a-half-year-long EIS process, a connection to Pueblo Dam was deemed the Preferred Alternative by Reclamation. The U.S. Environmental Protection Agency, U.S. Army Corps of Engineers, U.S. Fish and Wildlife Service and other agencies were extensively involved in the NEPA review. The Preferred Alternative has also received approvals and permits from a number of local, state and federal agencies.
City Council has selected the best alternative for Colorado Springs and our project partners and authorized a 2016 in-service date for SDS with an 8-1 vote. In order to ensure our community has the water when we need it, SDS construction is scheduled to begin this year.
We think it’s unfortunate that The Consumer Advocate Inc. is able to make public claims with no substantiation of facts.
We hope the public will carefully consider the source of this information, and their motivation to stop our water project.
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Lionel Rivera is the mayor of Colorado Springs and chair of the
Colorado Springs Utilities Board.
