May 4, 2020

DATE FILED: May 4, 2020 4:16 PM
FILING ID: 9496BF76F4C96
CASE NUMBER: 2014CW3043

Need for and Financial
Feasibility of Developing Wolf
Creek Reservoir Water Rights
Case No. 14CW3143, Water Division No. 6

Prepared for

Rio Blanco Water Conservancy District

Prepared by
Harvey Economics
469 South Cherry Street, Suite 100
Denver, Colorado 80246
720.889.2755 fax 720.889.2752
www.harveyeconomics.com

he@harveyeconomics.com

Harvey Economics

EXHIBIT A-2 TO RIO BLANCO WCD EXPERT DISCLOSURES

 Table of Contents
SECTION 1: Introduction and Summary Opinions
1.1 Colorado River Compact Curtailment Risk Analysis ............................. 1-1
1.2 Recreation Demands and Benefits .......................................................... 1-1
1.3 Financial Feasibility of Water Rights Development ............................... 1-2

SECTION 2: Colorado River Compact Curtailment Risk Analysis
2.1 Background............................................................................................... 2-1
2.2 Colorado River Risk Study ...................................................................... 2-2
2.3 Methodology and Key Assumptions from the Colorado River
Risk Study ................................................................................................ 2-3
2.4 Scenario Results ...................................................................................... 2-4
2.5 Summary Opinion ..................................................................................... 2-6

SECTION 3: Recreation Demands and Benefits
3.1 Initial HE Studies ...................................................................................... 3-1
3.2 Attributes Required to Support Reservoir-Based Recreation ............... 3-2
3.3 Visitation Estimates for Wolf Creek Reservoir ....................................... 3-2
3.4 Economic Benefits of Recreation at Wolf Creek Reservoir ................... 3-4
3.5 Summary Opinion ..................................................................................... 3-5

SECTION 4: Financial Feasibility of Water Rights Development
4.1 Background .............................................................................................. 4-1
4.2 District ....................................................................................................... 4-2
4.3 Other Direct Beneficiaries ........................................................................ 4-3
4.4 Indirect Beneficiaries ............................................................................... 4-4
4.5 Alternative Funding Mechanisms and Pathways to Feasibility ............ 4-5
4.6 Summary Opinion ..................................................................................... 4-7

Appendix A: Sources Relied Upon

Harvey Economics

 SECTION 1
Introduction and Summary Opinions
Commissioned by the Rio Blanco Water Conservancy District (District), Harvey Economics
(HE) is working with a multi-disciplinary team exploring the prospects for development of
the Wolf Creek water rights into storage within the White River Basin in northwestern
Colorado. As these conditional water rights were contested, the District retained counsel who
requested that HE report on certain studies and opinions it has formed thus far in this
planning process. These studies and opinions are summarized in this report.

1.1

Colorado River Compact Curtailment Risk Analysis

The District is concerned that the State of Colorado (and the rest of the Upper Basin states)
might be subjected to a Colorado River Compact Curtailment of post-1922 water rights. Such
a curtailment could jeopardize existing water users in the White River Basin. HE reviewed
the risk of such curtailment and evaluated the potential number of the curtailments which
water users might face. HE’s work is based on a review of the work of Hydros Consulting
Inc. (Hydros), who prepared the Colorado River Risk Study Phases I, II, and III, and my
familiarity with the Compact. This report describes the model assumptions, inputs, and
results of the Colorado Risk Study, and estimates the frequency of a Compact Curtailment
over a 25-year cycle.
Summary Opinion. Based upon HE’s evaluation of the available information discussed

below, it is my professional opinion that users of post-1922 Colorado River water rights
within the State are vulnerable to a curtailment for as many as five years over a 25-year
cycle. It is also my professional opinion that prudent water providers in the White River
Basin, which has minimal storage and whose existing water uses would be affected, should
consider mitigating those effects through storage, including storage in Wolf Creek Reservoir.

1.2

Recreation Demands and Benefits

HE was asked to evaluate whether the District should consider developing its water rights for
recreational water use. HE evaluated the demand for additional water-based recreational
opportunities and related amenities in northwest Colorado, specifically associated with a
Wolf Creek Reservoir. Section 3 of this report addresses the recreational need for the
reservoir, offers projections of future reservoir visitation, and estimates the economic and
financial benefits which would be forthcoming from this recreational amenity. Economic and
financial benefits of water development can provide a foundation for project funding and
feasibility.
Summary Opinion. Based on HE’s evaluation of the information discussed below, it is my

opinion that the Wolf Creek Reservoir with a minimum recreational pool of 15,000 acre-feet
would fill a recreational need for northwestern Colorado, attracting visitors from that region
Harvey Economics
Page 1-1

 and beyond. This reservoir would support economic development in the region and would
produce economic and financial benefits for the residents and public entities.

1.3

Financial Feasibility of Water Rights Development

As part of the development and planning process for the Wolf Creek Reservoir, HE has
investigated the financial feasibility of future development of this project. We have evaluated
the financial capabilities of the District and other local governments to help support the
funding of the proposed reservoir. HE has also identified funding sources from the State of
Colorado and the Federal government. Section 4 describes the financial feasibility aspects of
this water rights development.
Summary Opinion. Based upon HE’s evaluation of the available information discussed

below, it is my professional opinion that, using the funding sources described in this report,
there is an ability to fund this project, relying on local, regional, State and Federal sources,
and private entities. These entities will benefit from this project, justifying its support. There
are multiple pathways and opportunities for financing the development of the Wolf Creek
Reservoir Project that can make it financially feasible. Funding commitments and final
feasibility determination will be pursued once the conditional water right is obtained and
design level planning can proceed.

Harvey Economics
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 SECTION 2
Colorado River Compact Curtailment Risk
Analysis
2.1

Background

The Colorado River Compact of 1922 (Compact) is an agreement between seven U.S. states
to share water from the Colorado River.1 The Compact stipulates that, assuming average
annual flows of 16.5 million acre-feet (Maf), these flows would be allocated as follows: 7.5
Maf of water to the Upper Basin states (Colorado, New Mexico, Utah, and Wyoming), and
7.5 Maf to the Lower Basin states (Arizona, California, and New Mexico). In 1944, the
Mexican Water Treaty allocated an additional 1.5 Maf to Mexico.2
As long as the ten-year rolling average annual flows at Lee Ferry, the location where flows
from the Upper Basin to the Lower Basin are measured, are greater than 82.5 Maf, the Upper
Basin is generally considered in compliance with the Compact.3 If the Upper Basin delivers
an insufficient amount of water over a ten-year period, the Lower Basin states can make a
“Compact Curtailment” requesting that the Upper Basin states fulfill the allotment.
The Colorado River Basin has been in a drought since 2000.4 Due to this drought, average
river basin annual flows during the period 2000-2017 were approximately 12.6 Maf annually,
or 3.9 Maf (24%) less than would be needed to meet the full Compact allotments of the seven
basin states and Mexico.5 A repeat of the particularly dry 2001-2006 period could threaten
the Upper Basin’s ability to deliver 82.5 Maf over a ten-year period.6
Because of this recent dry period in the Colorado River Basin, Lake Powell is presently only
49 percent full, with a water elevation of 3,602 feet, and Lake Mead is 44 percent full, with a
water elevation of 1,097 feet.7
Two water elevations in Lake Powell are important to this analysis – 3,525 feet and 3,490
feet:

1

U.S. Bureau of Reclamation. The Law of the River, The Colorado River Compact of 1922.
https://www.usbr.gov/lc/region/g1000/pdfiles/crcompct.pdf
2
U.S. Bureau of Reclamation. The Law of the River, The Mexican Water Treaty of 1944.
https://www.usbr.gov/lc/region/g1000/pdfiles/mextrety.pdf
3
82.5 Maf is calculated as 75 Maf (7.5 Maf times 10 years) to the Lower Basin, plus 7.5 Maf (1.5 Maf
divided by 2, to represent the Upper Basin’s assumed portion, times 10 years) to Mexico.
4
U.S. Bureau of Reclamation. Another dry year in the Colorado River Basin increases the need for
additional state and federal actions. 9 May 2018.
https://www.usbr.gov/newsroom/newsrelease/detail.cfm?RecordID=62170
5
Hydros Consulting. Colorado River Risk Study, Phase III Final Report. 11/20/2019.
6
Hydros Consulting. Colorado River Risk Study, Phase III Final Report. 11/20/2019.
7
U.S. Bureau of Reclamation. Lower Colorado Water Supply Report. 3/9/2020.
Harvey Economics
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 •

3525’ represents the elevation that the Bureau of Reclamation (Reclamation) has
indicated below which they would get “nervous” about the use of turbines and power
generation because of possible air entrainment in the turbines and other hydraulic
issues.8

•

3490’ is the nominal minimum power pool below which no generation is possible.
This level would store 2 Maf less water than 3525’.9

Glen Canyon Dam contains eight hydroelectric generating units that annually generate about
5 billion kilowatt hours10 of electricity. If Lake Powell falls below minimum power pool
elevation, electricity generation at Glen Canyon will cease, causing a host of problems in
addition to a water shortage.
The 10-year flow of the Colorado River at Lee Ferry for water years 2010-2019 is 92.54
Maf.11 The Upper Basin’s delivery obligation is likely to be in compliance over the next two
years, primarily because the current 10-year rolling average is about 10 Maf more than what
the Upper Basin has agreed to deliver. Barring a catastrophic drought, the Upper Basin
should be able to deliver the appropriate amount of water in the next few years; however,
once the 2011 water year12 drops off the 10-year rolling average, the 10-year rolling average
will be closer to 82.5 Maf.13

2.2 Colorado River Risk Study
The Colorado Risk Study (Study) was commissioned primarily by the Colorado River
District and performed by Hydros.14 The Study contains 3 phases:
•

Phase I lays the groundwork for the key study questions:
o What are magnitude and duration of Powell shortages below elevation 3525’?
o How much of the above shortages can be met by contributions from Drought
Operations of Colorado River Storage Project (CRSP) reservoirs?

8

Hydros Consulting. Colorado River Risk Study, Phase I and II Summary Report. 8/1/2018,
Phase III Final Report. 11/20/2019.
9
Kuhn, Eric. Colorado River District. “Joint West Slope Roundtables Risk Study Results Summary and
Thoughts on the Next Steps.” 13 September 2016. Pg. 2.
10
U.S. Bureau of Reclamation. Glen Canyon Unit Quick Facts: https://www.usbr.gov/uc/rm/crsp/gc/
11
U.S. Bureau of Reclamation. Annual Operating Plan for Colorado River Reservoirs 2020. December
2019, p. 18. https://www.usbr.gov/uc/water/rsvrs/ops/aop/AOP20.pdf
12
The gauge at Lee Ferry recorded 12.731 Maf for the 2011 water year, which is 34% higher than the
gauge recorded in any other year within the 10-year period. U.S. Bureau of Reclamation. 24-Month Study
Reports. April 2012 24-Month Study Report. https://www.usbr.gov/uc/water/crsp/studies/
13
U.S. Bureau of Reclamation. 24-Month Study Reports. April 2020 24-Month Study Report.
https://www.usbr.gov/uc/water/crsp/studies/
14
Hydros Consulting. Colorado River Risk Study, Phase III Final Report. 11/20/2019.
Harvey Economics
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 o How much consumptive use reduction (“demand management”) would be
needed by Upper Basin states – AFTER use of stored CRSP water – in order
to maintain Lake Powell pool elevations?
•

Phase II focuses on the hydrologic modeling. Initially the Study incorporates the
Colorado River Simulation System (CRSS), Reclamation’s “big river” model that it
uses for Basin-wide planning studies.15 Secondly, the study then applies and
integrates StateMod16 to address in-state questions related to demand management,
resulting yields of conserved water, and water banking.

•

Phase III builds on Phases I and II to evaluate system-wide risks in the Colorado
Basin. This final phase offers numerous projections regarding water scarcity issues
for Lake Powell and scenarios in which the Upper Basin states may not be able to
deliver sufficient water for Compact compliance.

2.3 Methodology and Key Assumptions from the Colorado
River Risk Study
The Hydros models project water delivery shortages in a 25-year period from 2019-2043.
The assumptions for the 25-year period are described below.
1. Risk Profile for Compact Deliveries
a. The Upper Basin’s obligation to the Lower Basin under Article III(d) of the
Compact is to “not cause the flow of the river at Lee Ferry to be depleted
below an aggregate of 75 Maf for any period of ten consecutive years.”
Hydros defines the Upper Basin’s obligations as the need to deliver 82.5 Maf
over a ten-year period, which includes an additional 7.5 Maf to cover half the
obligation to Mexico according to Article III(c).
2. “Stress Test” and Simulation Protocol
a. Hydros used hydrologic data from 1988-2015, termed the “Stress Test”
period because of its lower-than-average flows. The average flows were 13.3
Maf during this 28-year period.
b. CRSS utilizes the Index Sequential Method (ISM) to generate multiple model
runs using a single input dataset. In ISM, each year of the simulation period is
used once as the first year of a trace.
c. A “trace” describes one set of hydrology and demand projections that is run
through the model. For the Stress Test period, there are 28 years of data, and
15

The CRSS is a model utilized by the Bureau of Reclamation to develop probabilistic projections of future
Colorado River system conditions over the timeframe of two years to several decades.
16
StateMod is a monthly and daily surface water allocation and accounting model capable of simulating
various historical and future water management policies in a river basin.
https://www.colorado.gov/pacific/cdss/statemod
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 thus 28 different traces that comprise a single CRSS scenario simulation. For
example, when simulating the current demand schedule with the Drought
Contingency Plans (DCP), CRSS will cycle through the dataset 28 times,
each time using a different starting year. Each trace can be thought of as a
possible future, and Hydros treats the 28 Stress Test traces as their collection
of all possible futures for the analysis.
d. Hydros analyzed the first 25 of 28 years within each simulation. There are 28
traces and 25 years per trace, hence a total of 700 years is used to generate the
frequency data described in the results section below.
3. CRSS and StateMod
a. Hydros synchronized the demands and hydrology between the two models.
4. “Current Demands” vs. “Future Demands”
a. Hydros developed demands for “future conditions” through cooperation with
Basin Roundtable technical representatives and staff from the Colorado River
District and the Southwestern Water Conservation District. The Study
assumes a total future increase in demands of 384 thousand acre-feet (Kaf), or
an increase of 13.7 percent over current demand levels. Depletions from these
demands are projected to increase 11.5 percent.
5. 2007 Interim Guidelines for Coordinated Operations of Lake Powell and Lake Mead
a. Hydros used these guidelines as the operational policy throughout the
simulation period.
6. DCP
a. The Study defines DCP implementations as cloud-seeding and re-operations
of the Upper Basin CRSP reservoirs, and mandatory contributions in the
Lower Basin. The CRSP reservoirs contribute about 2 Maf of storage. This
amount is not always required to offset water delivery shortages, but it is
insufficient in the worst events to fully offset shortages; hence, additional
mechanisms are necessary beyond re-operations of CRSP reservoirs to
overcome water delivery shortages.17
HE evaluated this methodology and these assumptions and finds them reasonable for the
purposes of Wolf Creek Reservoir planning. Since Colorado’s population is expected to
increase by 33 percent over the next 25 years, HE accepts Hydros’ models with regard to
future water demands.18 We also assume that if Hydros model results indicate water
17

Hydros Consulting. Colorado River Risk Study, Phase I Summary Report. 8/1/2018.
Colorado Department of Local Affairs. Population Forecasts – years (2000 to 2050).
https://demography.dola.colorado.gov/population/population-totals-colorado-substate/#population-totalsfor-colorado-and-sub-state-regions
18

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 deliveries at Lee Ferry are less than 82.5 Maf over a ten year period, Colorado water users
and the rest of the Upper Basin will be vulnerable to a Compact curtailment.

2.4

Scenario Results

For the Colorado River Risk Study, Hydros described and modelled four hydrological
scenarios:
1. BASELINE—No mitigation actions taken.
2. BASELINE PLUS USE OF STORED WATER ABOVE MINIMUM POWER
POOL IN LAKE POWELL—assumed utilization of stored water in Lake Powell
between 3525’ and 3490’ feet of water to offset any shortage of water.
3. BASELINE PLUS 500 KAF DEMAND MANAGEMENT PROGRAM—assumed
an existing 500 Kaf account of water in Lake Powell provided by the Upper Basin
states available to offset deficits under the baseline scenario. This scenario assumed
that a full 500 Kaf is available at the onset of each event, even though longer term or
more frequent events would reduce or eliminate the volume in this storage account.
4. BASELINE PLUS 500 KAF DEMAND MANAGEMENT PROGRAM AND USE
OF STORED WATER ABOVE MINIMUM POWER POOL IN LAKE POWELL—
assumed availability of a 500 Kaf pool of water from an Upper Basin demand
management program, plus the stored water in Lake Powell between 3525’and 3490’
feet of water to offset any shortage.
Scenario 1 above would result in the most deficits at Lee Ferry, and Scenario 4 would
produce the fewest deficits.
To identify the risk of shortages at Lee Ferry, Hydros defined 28 sequences of years in terms
of hydrologic condition. Next, they examined the first 25 years of each sequence for the
number of times the Lee Ferry deliveries would be below 82.5 Maf in any ten year period
during that 25-year cycle. Hydros repeated this identification process for each of the 28
sequences. They found that, in essence, 17.9 percent of all the 10-year periods in the data set
resulted in a shortfall at Lee Ferry under Scenario 4. Therefore, the likelihood of any ten-year
average flow dropping below 82.5 Maf is 17.9 percent (5 ÷ 28). Applying this probability to
any ten-year hydrologic sequence that that could occur in the future over a 25-year period
(.179 times 25), a deficit at Lee Ferry can occur five times over a future 25-year cycle.
It is my opinion that this projection of a frequency of a curtailment of 5 times over a 25-year
period is conservative because:
a. Scenario 4 is contingent upon the successful implementation and multiple utilization
of a demand management program by the Upper Basin states which does not exist
now.
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 b. The BOR has not approved the use of Lake Powell water at an elevation of 3,490
feet.
c. Even though the Colorado River flows from 1988-2015 were lower than average,
they might be optimistic.19 Other historical periods could produce lower averages, as
could future periods.
d. Because of climate change, 21st Century warming is expected to cause higher
temperatures and increased evaporation, which will decrease the Upper Basin’s
ability to deliver 8.25 Maf annually at Lee Ferry.20 A recent report published by
researchers with the U.S. Geological Survey estimated that by 2050, Colorado River
flows could drop by 19 percent to 31 percent.21 This sentiment is shared by other
climate research scientists, who estimate that by 2050 there could be a 20 percent
reduction in river flow, and as much as a 35 percent reduction by the end of the
century.22

2.5

Summary Opinion

Based upon HE’s evaluation of the available information discussed below, it is my
professional opinion that users of post-1922 Colorado River water rights within the State are
vulnerable to a curtailment for as many as five years over a 25-year cycle. It is also my
professional opinion that prudent water providers in the White River Basin, which has
minimal storage and whose existing uses of water would be affected, should consider
mitigating those effects through storage, including storage in Wolf Creek Reservoir.

Kuhn, Eric. Colorado River District. “Joint West Slope Roundtables Risk Study Results Summary and
Thoughts on the Next Steps.” 13 September 2016. Pg. 12.
20
Udall, Brad. “When Hydrology and Management Collide: How Lake Powell got Hammered.” Colorado
River District, Annual Seminar 2019. 18 September 2019. https://bit.ly/2lTDWf6
21
P.C.D. Milly and K.A. Dunne. Colorado River flow dwindles as warming-driven loss of reflective snow
energizes evaporation. Science. 13 March 2020: Vol. 367, Issue 6483, pp. 1252-1255.
https://science.sciencemag.org/content/367/6483/1252.abstract
22
Castle, Anne and Fleck, John. The Risk of Curtailment under the Colorado River Compact (November 8,
2019). Available at SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3483654
19

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 SECTION 3
Recreational Demands and Benefits
3.1

Initial HE Studies

HE began the investigation into recreational demand for a Wolf Creek Reservoir in 2014.
Those efforts are detailed in HE’s 2014 White River Storage Demands study, of which
recreation was one of several components.23 HE’s conclusions regarding the potential
demand for additional recreational opportunities in Rio Blanco County were largely based on
the compilation and evaluation of information gathered during a series of interviews and
through additional secondary source research, such as data from Colorado Parks and Wildlife
(CPW). Interviews were conducted with staff from the District, the Western Rio Blanco
Metropolitan Recreation and Parks District and CPW over the course of 2014.24
HE researched the recreational opportunities offered at existing lakes and reservoirs in Rio
Blanco County, including Kenney Reservoir, Rio Blanco Lake and Lake Avery (also known
as Big Beaver Reservoir). Each of those water bodies has different physical characteristics,
offering a suite of water and land based recreational opportunities. However, each of these
reservoirs also has certain limitations when it comes to water-based recreation. For example,
Kenney Reservoir is silting in, Rio Blanco Lake has a small number of surface acres and
Lake Avery has boating restrictions. HE’s interviews also provided information on visitation
to each area.
Interviews in 2014 indicated that there was likely demand for a new reservoir in the region
and that such a facility could be a draw for both local people and visitors from outside the
area. Interviewees also thought that annual visitation would likely depend on the type and
quality of the fishery and on the recreational amenities offered at the reservoir.
As stated in HE’s 2014 study report:
“It is HE’s opinion that there is demand for additional reservoir based recreational activity
in Rio Blanco County. That conclusion is supported by the following facts: (1) There are
currently only three large lakes available to recreation in the county; however, Kenny
Reservoir is becoming increasingly silted in and will likely become unavailable to
recreators at some point in the future; (2) only two of those reservoirs allow motorized
sports and one of them is the silting in Kenney reservoir; (3) many Rio Blanco County
residents currently travel to areas outside the County for better quality fishing and
boating experiences; (4) potential reservoir locations are accessible from a number of
larger regional cities and towns, including Grand Junction and Glenwood Springs; the
right reservoir characteristics and amenities are likely to attract visitors from a wide
geographic area.”
HE’s study is Appendix D to Wheeler’s White River Storage Feasibility Study Final Report, March 2015.
Dan Eddy with the District; Tim Webber, Western Rio Blanco Metropolitan Recreation and Parks
District; Kyle Battige, Bill Divergee Ron Velarde, and Ron Dellacroce, CPW.
23
24

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 The recreational prospects at the Wolf Creek site were investigated by Logan Simpson
independently, and they concluded that there was need for water-based recreational
development in this northwest Colorado region. They indicated that visitation at that site
would likely resemble that of Vega State Park.25

3.2

Attributes Required
Recreation

to

Support

Reservoir-Based

The interviews HE conducted in 2014 indicated that a new reservoir should have the
following characteristics in order to attract a substantial number of visitors and support a
number of recreational opportunities:26
➢ A minimum of 700 to 1,500 acres of surface area. This would provide enough space
for multiple activities to occur simultaneously, including fishing, motorboat activities
and others, and would avoid a crowded feeling;
➢ An elongated shape to enhance motorboating and other activities;
➢ Minimum depth of 50 feet in some areas of the lake. This would provide varied
habitat for a number of fish species, and would provide the cooler temperatures
required by species such as rainbow trout in the summertime;
➢ Variable bottom shelving. This is another feature that would support a variety of fish
habitats;
➢ Interesting and variable lakeside topography. A scenic area and nooks along the
lakeshore are desired amenities for many recreators;
➢ Good road access for visitors with boats and other equipment.
Based on the characteristics described above, Wheeler staff estimated the reservoir storage
volume to be a minimum of between 15,000 AF to 24,000 AF.27 The existence of access, a
high-quality fishery and a range of topographical conditions around the reservoir, was
assumed to support potential visitation and demand for amenities.

3.3

Visitation Estimates for Wolf Creek Reservoir

As part of HE’s initial work in 2014, we estimated that Wolf Creek Reservoir would generate
as many as 124,000 visitor days per year given a 20,000 AF reservoir and as many as
161,000 visitor days per year given a 90,000 AF reservoir. Given a minimum recreational
pool size of between 15,000 AF and 24,000 AF, HE assumed a recreational pool size of
20,000 AF as reasonable for the purposes of visitation projections. About 25,000 visitor days

25

Discussions with Jana McKenzie, Fall 2019.
Interviews with CPW staff, including Kyle Battige, (Area 6 Aquatic Biologist in 2014); Bill Divergee
(Area 6) and Ron Velarde (Northwest Regional Manager in 2014) and with Ron Dellacroce (Park Manager
for Yampa State Park and Elkhead Reservoir in2014).
27
WW Wheeler, White River Storage Feasibility Report, Phase 2, September 2018.
26

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 were assumed to come from existing visitation at other lakes in the region; the rest of the
estimated visitor days would be new recreational visitors to the area.
Visitation estimates for Wolf Creek Reservoir were largely based on available visitation data
for comparable recreational areas in western Colorado, including Elkhead Reservoir in
Moffat County.28,29 Elkhead Reservoir was identified as a comparable reservoir due to the
number of surface acres, recreational opportunities offered and available facilities.
Subsequent review by Logan Simpson suggested that “Wolf Creek Reservoir could capture
more users than Elkhead Reservoir State Park because Wolf Creek Reservoir would be closer
to areas with larger populations and would be similar to that seen at Vega State Park in Mesa
County.
HE developed a revised estimate of visitation for a 20,000 AF recreational pool within Wolf
Creek Reservoir. HE estimates that 210,000 visitor days would occur at Wolf Creek
Reservoir within ten years of completion, including 185,000 new visits.30,31 Assuming
decreasing visitation growth rates over time, visitation at Wolf Creek Reservoir would reach
299,00 visitor days in year 20 and 359,000 visitor days in year 30.32

3.4

Economic Benefits of Recreation at Wolf Creek
Reservoir

Growth projections for Rio Blanco County as a whole have decreased noticeably in recent
years, as have economic measures such as retail sales.33,34 The County needs economic
diversification, moving away from its historically heavy reliance on oil and gas. Uncertainty
in the oil and gas sector is a real concern. Rio Blanco County is actively pursuing tourism and
expansion of other economic sectors.35
Tourism and recreation industries have become a focus for future economic development.
The County is planning to leverage different recreational environments and opportunities
available in the region. Wolf Creek Reservoir would provide an additional draw for visitors
from across Colorado and neighboring states, resulting in economic benefits to local residents
and businesses, as well as local governments.
HE translated Wolf Creek Reservoir visitor day estimates into estimates of total annual
visitor spending in the region (Rio Blanco and Moffat County). Visitors at Wolf Creek
28

https://cpw.state.co.us/placestogo/parks/ElkheadReservoir/Pages/default.aspx.
Stagecoach Reservoir, Steamboat Lake and Vega State Parks were also considered for comparability and
visitation data for those locations were also evaluated.
30
Visitation to Vega State Park was about 210,000 visitor days in 2017 according to CPW’s 2017 Fact
Sheet for that Park.
31
HE estimates that about 25,000 visitor days at Wolf Creek Reservoir would be due to people substituting
activity at Wolf Creek Reservoir for previous recreation at other local lakes.
32
HE assumed visitor growth rates of about 3.5 percent per year between Year 10 and Year 20 and about
1.8 percent per year between Year 20 and Year 30.
33
Colorado Department of Local Affairs, State Demography Office, Population Projections data.
34
Colorado Department of Revenue, Retail Sales Reports.
35
Makala Barton, Rio Blanco County Economic Development Coordinator, April 5, 2019, personal
interview with Susan Walker of HE.
29

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 Reservoir were assumed to spend $60 (2019 dollars) per visitor day on items such as food,
gas, camping/ lodging, equipment and other tourist type items.36 That $60 was multiplied by
the number of visitor days in each year to calculate total direct visitor spending. Total direct
spending in the County due to Wolf Creek Reservoir visitation would amount to about $7.1M
in Year 10, $10.5M in Year 20 and $12.8M in Year 30. Regional multipliers for the
recreation industry were applied to estimates of direct expenditures to capture the effects of
those transactions circulating throughout the local economy.37
Exhibit 3-1 presents economic benefits, including direct visitor spending, total sales, new
employment and additional sales tax revenue for Rangely, Meeker, Rio Blanco County as a
whole and Moffat County associated with visitation to Wolf Creek Reservoir. Estimates are
provided for Years 10, 20 and 30 and cumulatively over a 30-year period.
Exhibit 3-1
Wolf Creek Reservoir Recreational Economic Benefit Summary
30 Year
Year 10

Year 20

Year 30

Cumulative

Rangely
Direct Spending (M's)
Total Sales (M's)
Employment
Sales Tax Revenue (K's)

$3.53
$5.73
83
$206.28

$5.23
$8.48
122
$305.35

$6.38
$10.34
149
$372.22

$121.99
$197.79
149
$7,120.57

Meeker
Direct Spending (M's)
Total Sales (M's)
Employment
Sales Tax Revenue (K's)

$3.39
$5.50
79
$198.03

$5.02
$8.14
117
$293.13

$6.12
$9.93
143
$357.33

$117.11
$189.88
143
$6,835.75

Rio Blanco County
Direct Spending (M's)
Total Sales (M's)
Employment
*Sales Tax Revenue (K's)

$7.07
$11.46
165
$8.25

$10.46
$16.96
244
$12.21

$12.75
$20.68
298
$14.89

$243.98
$395.59
298
$284.82

Total Moffat County
Direct Spending (M's)
Total Sales (M's)
Employment
Sales Tax Revenue (K's)

$1.51
$2.45
35
$137.29

$2.24
$3.63
52
$203.22

$2.73
$4.42
64
$247.72

$52.19
$84.62
64
$4,738.99

Note:

Rio Blanco County data reflects total benefits for the entire county, including Rangely and Meeker, except for
the sales tax revenue, which is only that amount collected by Rio Blanco County government.

36

The Economic Contributions of Outdoor Recreation in Colorado: A regional and county-level analysis,
developed for Colorado Parks and Wildlife by Southwick Associates, February 2014; Spending Patterns of
Outdoor Recreation Visitors to National Forests, Eric White, October 2017 PNW-GTR-961; 2018 National
Park Visitor Spending Effects, National Park Service, May 2019.
37
Bureau of Economic Analysis, RIMS II Multipliers, Region: Garfield, Moffat and Rio Blanco County,
Industry: Amusements, Gambling and Recreation.
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Page 3-4

 The proposed Wolf Creek Reservoir would create substantial economic benefits for
northwestern Colorado and the State.

3.5

Summary Opinion

Based upon HE’s evaluation of the available information, it is my professional opinion that a
reservoir at the Wolf Creek site with a minimum 15,000 AF38 recreational pool would fill a
recreational need for northwestern Colorado, attracting visitors from that region and beyond.
This reservoir would support economic development in the region and would produce
economic and financial benefits for the residents and public entities. These economic benefits
can provide State and local government with the justification to financially support this
project.

38

A range of recreational pool storage volumes between 15,000 and 24,000 are all considered feasible. A
20,000 acre-foot recreational pool was considered for purposes of this analysis.
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 SECTION 4
Financial Feasibility of Wolf Creek
Reservoir
4.1

Background

The financial feasibility for developing the Wolf Creek water rights can be determined by:
a) identification of entities that will benefit from the development;
b) demonstration of the capabilities of those entities to fund, finance or support that
development; and
c) formulation of a pathway or funding plan supported by the beneficiaries.
Steps (a) and (b) have been completed based on Wolf Creek project planning to date. Project
beneficiaries include those jurisdictions and the people they represent who will experience
either direct or indirect benefits from the Project, such as increased economic activity, or
higher tax revenues. Those benefits were projected in the previous recreational benefits
section.
In this section, we summarize the financial resources and mechanisms the beneficiaries have
to support this project. Together, these entities have the capability to fund this proposed Wolf
Creek water rights development and make it financially feasible. Although there are multiple
pathways to finance this project, further progress toward finalizing the financial plan for the
project cannot be made until the conditional water right is secured.
The final size of the proposed Wolf Creek Reservoir has not yet been determined; that will
depend on future water needs and funding support forthcoming from Project beneficiaries.
Identified project needs include municipal and industrial use, recreational use, hydrocarbon
development, environmental needs and augmentation, including for Colorado River Compact
compliance.
Based on studies to date, the size of this reservoir would range from 66,720 to 72,720.39 As a
working assumption for financial planning, HE utilized an estimated reservoir cost of
between $88 million and $170 or a cost of between $1,300 to $2,300 per acre-foot, with an
annual operation and maintenance cost of between $100,000 and $371,000.40 Financial
feasibility is based on the following plan for funding these costs.

39

WW Wheeler, White River Storage Feasibility Report, Phase 2, September 2018.
Steve Jamieson, April 2020, based on WW Wheeler, White River Storage Feasibility Report, Phase 2,
September 2018.
40

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 4.2

District

The District’s financial capability to support this project and their sources for raising monies
are described here. With its Taylor Draw Dam, the District has experience in raising monies
and successfully funding water storage projects.
The District receives almost all its revenue through property taxes and sales of hydroelectric
power. From 2017-2019,41 the District’s General Fund revenues averaged $486,000. Over the
same time period, the District balanced its budget, with expenses more or less equaling
revenues. From 2017-2019 the Hydroelectric Fund revenues averaged $409,000. Over the
same time period, the Hydroelectric Fund averaged an annual net loss of $143,000 due to
capital improvements, although 2020 appears to be positive and results vary annually.
The District has approximately $3.0 million in unobligated funds. This includes $1.4 million
in the General Fund and $1.6 million in the Hydroelectric Fund. At least a portion of these
funds could go toward the funding of the Wolf Creek project.
Another financing mechanism available to the District is to borrow. The District has no debt.
The District’s borrowing capacity is limited by its net revenue margin, the wholesale power
price, and a current mill levy of 0.623 mills.
The primary means for the District to support this development is by raising additional
revenues through new bond issues. Table 4-1 shows the District’s potential annual revenues
and bond issuance, given an assumed mill levy increase.
Table 4-1.
Examples of New Mill Levies, Projected Revenues and Bond Amounts

Rio Blanco Water Conservancy District. “Financial Statements and Independent Auditor’s Report.”
12/31/2017. Rio Blanco Water Conservancy District. “Fiscal Year 2018 Budgets.” Division of Local
Government, Colorado Department of Local Affairs. 12/13/2017. Rio Blanco Water Conservancy District.
“Fiscal Year 2019 Budgets.” Division of Local Government, Colorado Department of Local Affairs.
12/06/2018.
41

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Page 4-2

 It is important to note that the District has not committed to seeking any new bond issues,
which would require a majority vote among its electors. The above table demonstrates the
District’s bonding capabilities to contribute to this project.
Financing structures and revenue mechanisms. As the District puts together the

financing package for the Wolf Creek project, there are a number of structures and pricing
mechanisms it can consider. To pursue a bond issue, the District could form another legal
entity such as a subdistrict or an enterprise fund for the special purpose of financing a portion
of this project. Pricing the water could include volume charges per AF, allotment contracts,
or mill levies in the example above.

4.3

Other Direct Beneficiaries

In this instance, direct beneficiaries are those entities who will experience revenue increases
or whose constituents will receive direct economic benefits from the Wolf Creek Reservoir.
These include the Towns of Rangely and Meeker, and Rio Blanco County. The City of Craig
and Moffat County will also directly benefit from this Project, but we have not addressed
them here.
Rangely. From 2017-2019, Rangely’s General Fund revenues averaged $3,237,000.

42

A
small portion of revenue comes from property taxes, with most revenues coming from sales
tax and intergovernmental transfers (i.e. mineral lease distributions). Rangely typically runs a
balanced budget. As of 2019, Rangely has about $7,157,000 in its unobligated fund balance.
Rangely currently charges 10 mills in property taxes.
Besides allocating a portion of its unobligated funds, Rangely’s opportunity to contribute
financially to this project could include tax increment financing or a bond issue, through
utility rates and fees, or as part of a special district or enterprise as discussed above. Tax
increment financing could be formulated in a manner that allows a percentage of sales tax
revenue increases to go toward a Wolf Creek financing. Ten years after project completion,
Rangely is projected to experience sales tax revenue increases of more than $200,000 per
year attributable to the Wolf Creek project.
Meeker. From 2017-2019, Meeker’s General Fund annual revenues averaged $2,342,000. 43

Similar to Rangely, Meeker receives most of its revenues via sales taxes but additionally,

Town of Rangely. “2017 Budget.” Division of Local Government, Colorado Department of Local
Affairs. 12/13/2016.
Town of Rangely. “2018 Budget.” Division of Local Government, Colorado Department of Local Affairs.
12/12/2017.
Town of Rangely, “2019 Budget.” Division of Local Government, Colorado Department of Local Affairs.
12/11/2018.
43
Town of Meeker. “Annual Budget Beginning January 1, 2017.” Division of Local Government, Colorado
Department of Local Affairs. 12/14/2016.
Town of Meeker. “Annual Budget Beginning January 1, 2018.” Division of Local Government, Colorado
Department of Local Affairs. 12/13/2017.
Town of Meeker. “Annual Budget Beginning January 1, 2019.” Division of Local Government, Colorado
Department of Local Affairs. 12/12/2018.
42

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Page 4-3

 from mineral-related distributions. As of 2019, Meeker is debt free and has an unobligated
fund balance of more than $7.0 million. Meeker has a current mill levy of 9.781 mills.
Meeker’s capability to help fund the Wolf Creek Project is similar to Rangely. Options
include a portion of unobligated funds, a bond issue, or tax increment financing, utility rates
and fees, or as part of a special district or enterprise as discussed above. If the Project were to
be completed, HE estimates that Meeker could expect to receive sales tax revenues of more
than $1.0 million during the first ten years, $3.5 million in the first 20 years, and almost $7.0
million in the first 30 years.
Rio Blanco County. From 2017-2019, Rio Blanco County’s annual General Fund

revenues averaged $12,670,000. 44 From 2018-2019, the revenues minus expenses averaged
an annual net addition to County coffers of $2.1 million. The bulk of these higher revenues is
attributable to a large payment (approximately $6.8 million in 2018) from the Federal
government via the Oil Shale Trust Fund. The General Fund currently has nearly $12.0
million available for appropriation.
In addition, Rio Blanco County has about $24.0 million in its County Capital Improvement
Trust Fund, $800,000 in its Impact Fee Trust Fund, and about $48.0 million in all other funds
combined. The total fund balance between the three funds is approximately $73.0 million.
About 90 percent of the County’s total fund balance is currently invested. The County
currently collects 9.050 mills. Rio Blanco County has no debt and has no large capital
projects on the horizon.
The County could use a portion of its unobligated funds or issue new bonds to help pay for
this project. HE estimates that the Wolf Creek Project will produce $11.5 million annually in
County economic benefits by year ten of the Project, and $21.0 million annually by year 30
of the Project.
Yellow Jacket Water Conservancy District (YJWCD). This conservancy district is located
east of the Rio Blanco Water Conservancy Disrict. The YJWCD has a need for augmentation
for the Taylor Dam Power Call and has expressed an interest in participating in the Wolf
Creek Reservoir project.45 An IGA is being negotiated between YJWCD and the District.

4.4 Indirect Beneficiaries
Indirect beneficiaries are those typically outside the local area who will benefit from the
Project through increased economic activity, additional tax revenues or progress toward
policy goals. The State of Colorado and the U.S. represent indirect beneficiaries of the
Project. Both will experience increase economic activity and higher tax revenues from the
Rio Blanco County. “Adopted 2017 Budget.” Division of Local Government, Colorado Department of
Local Affairs. 12/22/2016.
Rio Blanco County. “Adopted 2018 Budget.” Division of Local Government, Colorado Department of
Local Affairs. 12/22/2017.
Rio Blanco County. “Adopted 2019 Budget.” Division of Local Government, Colorado Department of
Local Affairs. 12/21/2018.
45
Applegate Group, Yellow Jacket Water Conservancy District, Water Storage Feasibility-2016, November
2016.
44

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 Wolf Creek Reservoir. The Colorado River Water Conservation District could be a source or
project funding. Private entities, both for profit and not-for-profit, might also participate in
project funding
Northwest Colorado’s economy is characterized by an over-dependence on petroleum
extraction and a modestly viable agricultural sector. Indirect benefits include enhanced
economic development opportunities, increased employment and income levels. The State
and Federal Governments have the ability to contribute funds for this Project and can justify
that support.

4.5 Additional Funding Mechanisms and Planning Pathways
to Funding
Beyond the local funding described above, there are additional funding sources available to
the District for the Project that will be pursued, after a conditional water right is obtained.
Financing Mechanisms Available to Direct Beneficiaries. Each of the local

governments described above will experience direct benefits from the Project and have the
ability to contribute to its funding. Each has unobligated funds as part of their financial
assets, and an ability to issue bonds. The latter would require a majority support among the
electorate, but the economic benefits of the proposed Wolf Creek Reservoir can justify that
support.
The County’s opportunity to contribute to the Wolf Creek project stems from its unobligated
funds or the prospect of a new bond issue. The District has an intergovernmental agreement
with the County, indicating its support.
Besides allocating a portion of its unobligated funds, Rangely’s and Meeker’s opportunity to
contribute financially to this project could include tax increment financing or a bond issue,
perhaps as part of a subdistrict or enterprise as discussed above. Tax increment financing
could be formulated in a manner that allows a percentage of sales tax revenue increases to go
toward a Wolf Creek financing.
Federal Government Funding. The US Government offers several programs to help

fund water projects:
1) The Natural Resources Conservation Service’s Regional Conservation Partnership
Program (under the U.S. Department of Agriculture) is a standalone program that
offers about $300 million annually to projects that address watershed and regional
natural resource concerns.
2) The US Fish and Wildlife Service is in the process of firming interim flow targets for
the White River flows that are needed to recover endangered fishes. The White River
Management Team, of which the District is a member, will seek Federal monies for
water releases from Wolf Creek Reservoir for protection and recovery of endangered
fishes. An approach similar to support for Elkhead Reservoir is a model; $13.5
million was contributed for endangered fish purposes. The District is an active

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 participant in the Cooperative Agreement which is formulating a management plan
for the White River.
3) The Bureau of Reclamation’s WaterSMART Water and Efficiency Grants (under the
U.S. Department of the Interior) provides cost-share funding to participants with
water or power delivery authority.
4) The U.S. Department of the Interior’s Land and Water Conservation Fund (LWCF)
supports the protection of federal public lands and waters and voluntary conservation
on private land.
5) The District could also seek direct appropriation through Congress.
State Government Funding. The District plans on seeking state funding from the State

of Colorado.
The Colorado Water Conservation Board (CWCB) has numerous grants and programs
designed to address water security issues for the state:
1) CWCB’s Colorado Water Plan Grants help support projects. The Wolf Creek project
has already received support from this source.
2) The CWCB’s Water Supply Reserve Fund Grants Program provides grants and loans
to assist Colorado water users in addressing their critical water supply issues and
interests.
3) CWCB also has supported individual projects through State appropriations, a
financial option for larger projects and loans are available at reasonable rates.
4) The CWCB pre-qualifies water projects which are defined, engineering has been
performed, and have reasonable cost estimates. The Wolf Creek project is on this list
in an amount up to $100 million. The CWCB has not committed to a loan at this
time.46
The Colorado Water Resource and Power Development Authority can provide lower interest
financing for water projects.
Another source of funds that could be used are through Proposition DD, the measure that was
passed in 2019 that may provide as much as $27.2 million annually for goals outlined in
Colorado’s Water Plan.47 Among other goals, the Water Plan could use funds for projects
meeting interstate obligations such as the Colorado River Compact.

46

Memo from Anna Mauss, March 3, 2019
Sackett, Heather. “Breaking down what Prop DD could mean for Colorado water, gambling” The Aspen
Times. 10 Oct. 2019. https://www.aspentimes.com/news/breaking-down-what-prop-dd-could-mean-forcolorado-water-gambling/
47

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Page 4-6

 Other Sources of Funding. The Colorado River Water Conservation District (CRWCD)

issued a draft outline on April 8, 2020 of a ballot issue it is considering, which would raise at
estimated $4.9 million, most of which would be dedicated to funding West Slope water
projects.48 In addition, funding from private entities will be sought. In sum, there are
numerous combinations of funding sources and pathways for financing the development of
the Wolf Creek water rights.

4.6 Summary Opinion
Based upon HE’s evaluation of the available information discussed above, it is my
professional opinion that, using the funding sources described in this report, there is an ability
to fund this project, relying on local, regional, State and Federal sources, or private entities,
These entities benefit from this project, justifying their support. There are multiple pathways
and opportunities for financing the development of the Wolf Creek Project that can make it
financially feasible. Funding commitments and final feasibility determination will be pursued
after the conditional water right is secured and detailed design level planning can proceed.

48

CRWCD, Draft Ballot Issue, April 8, 2020.
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 Appendix A.
Sources Relied Upon by Harvey Economics for
Wolf Creek Reservoir Water Rights Case
1) Anna Mauss, Memo, March 3, 2019.
2) Applegate Engineers, Yellowjacket Water Conservancy District, Water Storage
Feasibility-2016, November 2016.
3) Bureau of Economic Analysis, RIMS II Multipliers, Region: Garfield, Moffat and
Rio Blanco County, Industry: Amusements, Gambling and Recreation.
4) Castle, Anne and Fleck, John. “The Risk of Curtailment under the Colorado River
Compact,” November 8, 2019
5) Colorado Department of Local Affairs, State Demography Office, Population
Projections data.
6) Colorado Department of Local Affairs. Population Forecasts – years (2000 to
2050).
7) Colorado Department of Revenue, Retail Sales Reports.
8) Colorado Parks and Wildlife, 2017 Fact Sheet for Vega State Park.
9) CRWCD, Draft Ballot Issue, April 8, 2020.
10) Discussions with Dan Eddy with the Rio Blanco County Water Conservancy
District; Tim Webber, Western Rio Blanco Metropolitan Recreation and Parks
District; Kyle Battige, Bill Divergee Ron Velarde, and Ron Dellacroce, Colorado
Parks and Wildlife (CPW).
11) Discussions with Jana McKenzie, Logan Simpson, Fall 2019.

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 12) Eric Kuhn. Colorado River District. Joint West Slope Roundtables Risk Study
Results Summary and Thoughts on the Next Steps.
13) Eric White, pending Patterns of Outdoor Recreation Visitors to National Forests,
October 2017.
14) Hydros Consulting. Colorado River Risk Study, Phase I Summary Report.
8/1/2018.
15) Hydros Consulting. Colorado River Risk Study, Phase III Final Report.
11/20/2019.
16) Interviews with CPW staff, including Kyle Battige, (Area 6 Aquatic Biologist in
2014); Bill Divergee (Area 6) and Ron Velarde (Northwest Regional Manager in
2014) and with Ron Dellacroce (Park Manager for Yampa State Park and
Elkhead Reservoir in2014).
17) Makala Barton, Rio Blanco County Economic Development Coordinator, April 5,
2019, personal interview with Susan Walker of HE.
18) National Park Service, 2018 National Park Visitor Spending Effects, May 2019.
19) News article. U.S. Bureau of Reclamation. “Another dry year in the Colorado
River Basin increases the need for additional state and federal actions.” 9 May
2018.
20) P.C.D. Milly and K.A. Dunne. “Colorado River flow dwindles as warming-driven
loss of reflective snow energizes evaporation.” Science. 13 Mar 2020: Vol. 367,
Issue 6483, pp. 1252-1255.
21) Rio Blanco County. “Adopted 2017 Budget.” Division of Local Government,
Colorado Department of Local Affairs. 12/22/2016.
22) Rio Blanco County. “Adopted 2018 Budget.” Division of Local Government,
Colorado Department of Local Affairs. 12/22/2017.
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 23) Rio Blanco County. “Adopted 2019 Budget.” Division of Local Government,
Colorado Department of Local Affairs. 12/21/2018.
24) Rio Blanco Water Conservancy District. “Financial Statements and Independent
Auditor’s Report.” 12/31/2017.
25) Rio Blanco Water Conservancy District. “Fiscal Year 2018 Budgets.” Division of
Local Government, Colorado Department of Local Affairs. 12/13/2017.
26) Rio Blanco Water Conservancy District. “Fiscal Year 2019 Budgets.” Division of
Local Government, Colorado Department of Local Affairs. 12/06/2018.
27) Sackett, Heather. “Breaking down what Prop DD could mean for Colorado water,
gambling” The Aspen Times. 10 Oct. 2019.
28) Southwick Associates, The Economic Contributions of Outdoor Recreation in
Colorado: A regional and county-level analysis, developed for Colorado Parks
and Wildlife, February 2014.
29) Town of Meeker. “Annual Budget Beginning January 1, 2017.” Division of Local
Government, Colorado Department of Local Affairs. 12/14/2016.
30) Town of Meeker. “Annual Budget Beginning January 1, 2018.” Division of Local
Government, Colorado Department of Local Affairs. 12/13/2017.
31) Town of Meeker. “Annual Budget Beginning January 1, 2019.” Division of Local
Government, Colorado Department of Local Affairs. 12/12/2018.
32) Town of Rangely, “2019 Budget.” Division of Local Government, Colorado
Department of Local Affairs. 12/11/2018.
33) Town of Rangely. “2017 Budget.” Division of Local Government, Colorado
Department of Local Affairs. 12/13/2016.
34) Town of Rangely. “2018 Budget.” Division of Local Government, Colorado
Department of Local Affairs. 12/12/2017.
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 35) U.S. Bureau of Reclamation. 24-Month Study Reports. April 2012 24-Month
Study Report.
36) U.S. Bureau of Reclamation. 24-Month Study Reports. April 2020 24-Month
Study Report.
37) U.S. Bureau of Reclamation. Annual Operating Plan for Colorado River
Reservoirs 2020. December 2019, p. 18.
38) U.S. Bureau of Reclamation. Glen Canyon Unit Quick Facts.
39) U.S. Bureau of Reclamation. Lower Colorado Water Supply Report. 3/9/2020.
40) U.S. Bureau of Reclamation. The Law of the River, The Colorado River Compact
of 1922.
41) U.S. Bureau of Reclamation. The Law of the River, The Mexican Water Treaty of
1944.
42) Udall, Brad. “When Hydrology and Management Collide: How Lake Powell got
Hammered.” Colorado River District, Annual Seminar 2019. 18 September 2019.
43) W.W. Wheeler, White River Storage Feasibility Report, Phase 2, September
2018.
44) W.W. Wheeler, White River Storage Feasibility Report, Phase 2, September
2018.
45) W.W. Wheeler, White River Storage Feasibility Study Final Report, March 2015.

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