This is the cover letter for the white paper to the Grand County Commissioners.   November 22, 2005

Commissioners James Newberry, Nancy Stuart, and Duane Dailey

Grand County

Hot Sulphur Springs, CO

Dear Commissioners,

Our organizations represent citizens of Grand County, Grand Lake shoreline residents and other property owners who are becoming increasingly concerned about the degrading water quality of Grand Lake and of Shadow Mountain reservoir.  We feel that the proposed Windy Gap Firming Project will further accelerate this degradation by increasing the flow of contaminated water through these lakes.   

Attached is our evaluation of the situation and of the circumstances leading to this degradation.  We believe that it is of vital importance to move the dialog about the water quality in these lakes toward the discussion of alternative permanent solutions, including the pipeline solution proposed last year, to pick the best solution and to move on to implementation. 

To make certain that this request is taken seriously, we ask the County to be prepared to enforce the Anti-degradation statutes within the Clean Water Act to preserve and protect water quality within Grand Lake.  It is highly likely that a recurrence of algae and algal toxins will occur within Shadow Mountain reservoir during the summer of 2006.  We believe that the NCWCD should consider cessation of pumping operations during such periods, until the threat to Grand Lake is alleviated.  At the very least, the County should be convinced that less damaging alternatives have been considered, and that plans are in place to permanently eliminate the problem.  Otherwise we will see continued degradation year after year while studies go on without mitigation.

We believe that practical less damaging alternative approaches, such as a pipeline, are possible and must be considered to prevent the loss of an irreplaceable natural resource.

Sincerely,

K. John Stahl, President                                              Elwin Crabtree, President

GREATER GRAND LAKE                                        THREE LAKES WATERSHED

SHORELINE ASSOCIATION                                    ASSOCIATION

GRAND LAKE AND SHADOW MOUNTAIN RESERVOIR:

DEGRADING WATER QUALITY AND REQUEST FOR MITIGATION

NOVEMBER 2005

GREATER GRAND LAKE SHORELINE ASSOCIATION

K. John Stahl, President

THREE LAKES WATERSHED ASSOCIATION

Elwin Crabtree, President

At the southern entrance to Rocky Mountain National Park, Grand Lake is the largest natural lake in Colorado and a recognized irreplaceable scenic attraction.  Natural flows from the East Inlet and North Inlet streams provide pure snowmelt of remarkable clarity.  The water quality of this unique natural resource is deserving of protection under the Antidegradation section of the Clean Water Act.

North Inlet under Grand Avenue Bridge (9/05)

East Inlet under Pedestrian Bridge (9/05)

For many millennia, Grand Lake itself enjoyed similar water quality.  Unfortunately the unintended consequences of several water projects are reducing the lake to a Shadow[1] of its former self and whose impacts if left unchecked will irreparably harm the aquatic environment. 

Until the creation of the Colorado-Big Thompson (CBT) water project[2] more than 50 years ago, flow into Grand Lake was provided by the aforementioned East and North Inlet streams.  The CBT project created Granby reservoir to collect runoff water from various mountain basins in Grand County.  A pumping station was constructed to lift water from Granby reservoir into a canal, through which water flows to enter Shadow Mountain reservoir.  Shadow Mountain reservoir, created at the same time, connects via the old Colorado River headwaters to Grand Lake itself.  The Adams tunnel was drilled underneath the Continental Divide to drain water from Grand Lake, exiting near Estes Park, to provide water for many Front Range communities. 

When the pumping station at Granby is operating, the natural flow out of Grand Lake is reversed bringing Granby reservoir water into Shadow Mountain reservoir, and then into Grand Lake and out through the Adams tunnel.  During these periods Grand Lake water quality is seriously degraded by the influx of silt, weeds, algae and alga toxins.  During periods of peak flow, the water draw through Adams tunnel can exceed 1000 acre-feet of water per day.  Since the volume of Shadow Mountain reservoir is only 18,000 acre-feet, this means that a volume equal to the entire contents of the reservoir can be drawn into Grand Lake every 18 days.

During the summer of 2004 the lake water in Shadow Mountain reservoir, and later in Grand Lake itself, began to turn green.  Samples of lake water taken that summer showed the presence of Anabaena algae (a cyanobacteria).  The Grand County Water Information Network[3] has been tracking the growth of these aquatic bacteria.  Anabaena is a blue-green algae known world-wide for its detrimental effects.  To quote from one source[4],

“Bodies of water containing high numbers of blue-green algae pose a health risk to humans when used as domestic water supplies or for water-based recreation. As blue-green algae numbers increase so does the risk of adverse health impacts, hence it is important to monitor blue-green algae levels.”

The World Health Organization has issued global standards for cyanobacteria, and several States have adopted these standards.  A short summary of these standards, and the associated health risks, can be found at the National Oceanic and Atmospheric Administration website[5].  When Anabaena bacteria die off, the green tinge of the water begins to disappear, but the health risk intensifies.  Dying Anabaena bacteria produce a neurotoxin, which as the name implies can be toxic to animals and humans.  To quote from the NOAA site:

“Consumption of large amounts of these toxins by animals or humans can result in muscle cramps, twitching, paralysis and cardiac or respiratory failure. Symptoms can appear within a few hours of exposure, but may take up to 36 hours to manifest.”

In both of the past two summers the toxin levels in Shadow Mountain reservoir have pushed into the range of concern.   At the peak in late summer and early fall, the water in Shadow Mountain reservoir grossly exceeds the limits for safe drinking, and at times exceeds the limits recommended for recreational use.  Data from the Grand County Water Information Network[6]  (GCWIN) is plotted below:

These data from the summer of 2004 show that several weeks after the algal bloom in Shadow Mountain reaches its peak, Anabaena bacteria transported from that lake appears in Grand Lake also.  Reference 5 summarizes World Health Organization recommendations for cyanobacteria:

Summary Table of WHO Guidelines for Cyanobacteria Levels in Water

In addition, the World Health Organization has established 2000 cells/mL as the upper limit for Anabaena in drinking water.  Normally, Grand Lake water is acceptably below that standard, and is only been pushed out of that range by the transport of water from Shadow Mountain reservoir.

The above data shows that water from Shadow Mountain reservoir grossly exceeds the drinking water guideline.  The water there has also exceeded the low WHO recreational limit, has been within close range of the WHO moderate limit, even showing surface scum along shorelines.  Although no information has yet been provided to recreational water users of these facts, GCWIN has been working with the Colorado Department of Public Health and the United States Forest Service to determine criteria for posting warnings to the public.

This problem is occurring and worsening because Shadow Mountain reservoir was constructed as a shallow water body originally averaging 15 feet in depth.  Due to silting the current average depth now is roughly 10 feet.  Over the decades the reservoir has transformed itself into wetlands on the western shore, barely inches deep in some areas.  The result is that Shadow Mountain reservoir now serves as a Petri Dish for algal growth, weeds, and silt, all of which are transported into Grand Lake through the old Colorado River headwaters connecting the two lakes:

Pedestrian Bridge over the old headwaters connecting Grand Lake to Shadow Mountain Reservoir (9/05)

Mills Bunger, the author of the original 1937 Colorado-Big Thompson Project Report[7] would likely be aghast at the condition of the water in Shadow Mountain reservoir during the algae bloom.  To quote him directly from his CBT Report[8]:

“The approach to the western gateway of Rocky Mountain National Park will be along the shores of Shadow Mountain Lake and a view of clear water will take the place of the pools of stagnant mosquito breeding water and exposed mud flats that are now visible during low water.”

Note Bunger’s emphasis on clear water, not green water with cyanobacteria blooming annually.

The CBT Report is a masterful document, completely detailing the eastern slope agricultural water needs (crop by crop) and the cost impacts of inadequate water, the western slope supplies and forecast needs under peak irrigation, and the excess water made available through the project.  Twenty major construction projects[9] are completely described with 150 engineering drawings in exquisite detail including complete geographical considerations and accompanied with precise cost estimates.

It is interesting to note that in the CBT Report very little space is spent discussing water quality issues.  Clear water seems to be an implicit assumption.  The exception is in the discussion[10] of Green Mountain reservoir on the Blue River, which was also part of the original CBT project.  In that section Bunger considers the suggestion of others that upstream mining operations “…might result in the silting up of a reservoir at the Green Mountain damsite.”  In this section on silting and pollution he also notes that:

“The pollution of streams of the state is prohibited by law, and the State Supreme Court has upheld several cases where action has been brought against mining companies for the pollution of the streams.”

Bunger dismisses these possibilities with a three page description of the prior legal cases which he felt certain would prevent such calamities from happening, concluding:

“It is hard to conceive how such a condition (silting and pollution) would be allowed to progress to the point where the capacity of the Green Mountain Reservoir would be destroyed or that the pollution of the waters of the stream would be tolerated to the point where it was a menace to the public use of the stream in the face of ample authority to stop the same through the enforcement of the laws of the state.”

Certainly no consideration was given to the possibility that the Colorado River headwaters exiting Grand Lake (now the channel between Grand Lake and Shadow Mountain reservoir) would be silted and polluted by the slow deterioration of the supply waters.  His note that “It is hard to conceive how such a condition would be allowed to progress…to the point where it was a menace to the public use…”  could be directly applied to the silt, algae and cyanobacteria growing in Shadow Mountain reservoir and transported into the waters of Grand Lake by reverse flow through the old Colorado River headwaters.

This problem will only get worse if the Windy Gap Firming Project[11] goes through unmodified.  The Firming Project expects to draw another 30,000 acre-feet per year of this water through this canal.  Recall that the volume of Shadow Mountain reservoir is 18,000 acre-feet, so this is nearly equivalent to emptying the contents of that reservoir into Grand Lake twice more each year.  Silting in Grand Lake is already evident in the bays and on the shorelines near the pedestrian bridge pictured above.  This is attributable to the influx from Shadow Mountain reservoir, and could be verified by taking sediment core samples of that area. 

A draw-down of Shadow Mountain reservoir to kill weeds by freezing was done in 1990 and 1991.  Based on observations of those who live in the area the abatement of weeds by this approach was successful but temporary.  The large number of governmental agencies required to accomplish any drawdown is a serious impediment, however.  The proposal for the 2005 draw-down was negated by the Colorado Department of Wildlife, to protect the annual Kokanee salmon egg collection.  Despite the stated DOW fears of a statewide salmon egg shortage, we now read in the Rocky Mountain News[12] that this year’s harvest will easily exceed statewide goals.  Further, we see that the contribution from the local harvest provides less than 10% of the State’s annual goal.  Yet the fears of this one agency derailed the proposed 2005 draw-down, meaning that the summer of 2006 will bring another (likely worse) contamination of Grand Lake by algae and the associated toxins, unless something is done.

Our organizations, the Greater Grand Lake Shoreline Association, and the Three Lakes Watershed Association, believe that it is necessary for the CBT and the Windy Gap Firming Project beneficiaries to not only consider, but rapidly implement, permanent alternatives that will immediately alleviate water quality degradation in Grand Lake.  Last year in a letter to the Grand County Government, the Three Lakes Watershed Association recommended the consideration of a pipeline to mitigate continued contamination of Grand Lake.  As far as we know, no serious analysis of this alternative or any other alternative, has yet been considered.  

We believe that it is of vital importance to move the dialog toward the discussion of alternative solutions, to pick the best solution and to move on to implementation and mitigation, lest we lose an irreplaceable natural resource through inaction.

In reviewing the documentation describing the Windy Gap Project, we see absolutely no mention of the issues raised here.  The Windy Gap Alternatives Report considers only where and how to store water.  Our organizations encourage Grand County Government to make certain that the Environmental Impact Statement for the Windy Gap Project includes funded actions to restore the water quality in Grand Lake. 

We believe that it is within our rights as citizens of Grand County to request that the County enforce the Anti-degradation statutes within the Clean Water Act.  If no feasible alternatives have been selected for consideration before the next algal bloom, we believe that this statute should be applied to prevent further harm to the Grand Lake environment.

We will be glad to participate in discussions on maintaining Grand Lake water quality as appropriate. 

____________________________                            _____________________________

K. John Stahl, President                                              Elwin Crabtree, President

GREATER GRAND LAKE                                        THREE LAKES WATERSHED

SHORELINE ASSOCIATION                                    ASSOCIATION

PO Box  1096                                                              PO Box 702

Grand Lake, CO 80447                                               Grand Lake, CO 80447