DATE FILED: July 6, 2020 3:13 PM
FILING ID: CA5429D7E8776
CASE NUMBER: 2014CW3043

EXPERT SUPPLEMENTAL REPORT
Case No. 14CW3043
Water Division No. 6
July 6, 2020

Prepared for:
Rio Blanco Water Conservancy District

Prepared by:
W.W. Wheeler and Associates Inc.
&
Harvey Economics

EXHIBIT A TO RIO BLANCO WCD
SUPPLEMENTAL EXPERT DISCLOSURES

 This Supplemental Expert Report for Case No. 14CW3043 was jointly prepared by W.W. Wheeler
& Associates, Inc. and Harvey Economics for the applicant in this case, the Rio Blanco Water
Conservancy District (RBWCD). The expert opinions of W. W. Wheeler & Associates, Inc. and
Harvey Economics are identified separately in the text of this report and were prepared by the
undersigned individuals from each firm.

Stephen L. Jamieson, P.E.
W. W. Wheeler & Associates, Inc.
7/6/2020

Gary Burton Thompson, P.E.
W. W. Wheeler & Associates, Inc.
7/6/2020

Danielle Tripp Hannes, P.E.
W. W. Wheeler & Associates, Inc.

Christine Brewer Mugele, P.E.
W. W. Wheeler & Associates, Inc.

_____________________________

Edward Harvey
Harvey Economics

7/6/2020

7/6/2020

 Table of Contents
SECTION 1 INTRODUCTION ....................................................................................................... 2
1.1
1.2
1.3

INTRODUCTION.......................................................................................................................... 2
WHEELER EXPERT OPINIONS ................................................................................................ 2
HARVEY ECONOMICS EXPERT OPINIONS ............................................................................ 3

SECTION 2 RESERVOIR SIZE AND RECREATIONAL BENEFITS .................................. 4
2.1
2.2

INTRODUCTION.......................................................................................................................... 4
COMPARABLE RESERVOIRS IN WESTERN COLORADO ...................................................... 4
2.3.1
Importance of access ............................................................................................. 6
2.3.2
Relationship between reservoir size and visitation ................................ 7
2.4
ALTERNATIVE RESERVOIR SIZES AT THE WOLF CREEK SITE ........................................ 7
2.5
VISITATION PROJECTIONS AND ECONOMIC BENEFITS FROM LARGER WOLF CREEK
OPERATIONAL RECREATIONAL POOL SIZES .................................................................................... 9
2.6
SUMMARY OPINION................................................................................................................ 10
SECTION 3 WATER SUPPLY PLANNING FOR A MULTI-YEAR DROUGHT .............. 11
3.1
INTRODUCTION........................................................................................................................ 11
3.2
DROUGHT AND THE COLORADO RIVER COMPACT (COMPACT) .................................... 11
3.3
DROUGHT IN THE WHITE RIVER BASIN ............................................................................. 13
3.4
STANDARD INDUSTRY PRACTICES RELATED TO DROUGHT IN LONG TERM WATER
SUPPLY PLANNING .............................................................................................................................. 14
3.5
CONSIDERING DROUGHT IN LONG TERM FUTURE WATER SUPPLY PLANNING FOR
THE WHITE RIVER BASIN BY THE RBWCD ................................................................................... 15
3.6
SUMMARY OPINION................................................................................................................ 16
SECTION 4 SECTION 7 CONSULTATION............................................................................. 17
4.1
4.2
4.3
4.4

INTRODUCTION........................................................................................................................ 17
PRECEDENT FOR UPPER COLORADO RIVER ENDANGERED FISH STORAGE .............. 19
WOLFORD MOUNTAIN ENDANGERED FISH WATER RIGHTS PRECEDENT................... 19
SUMMARY OPINION................................................................................................................ 20

SECTION 5 CORRECTIONS IN EXPERT REPORT ............................................................. 21
SECTION 6 REFERENCES .......................................................................................................... 22

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 SECTION 1
Introduction
1.1

Introduction

This Supplemental Expert Report for Case No. 14CW3043 was prepared to provide
supplemental information and clarify certain issues that arose following the first meeting
of experts with the Colorado Division of Water Resources (DWR) on June 11, 2020.
This supplemental report is jointly prepared by W.W. Wheeler & Associates, Inc.
(Wheeler) and Harvey Economics (HE) for the applicant in this case, the Rio Blanco
Water Conservancy District (RBWCD). Wheeler’s Expert Report in May 2020
documented, among other things, that multiple future water needs in Rio Blanco County can
be met by the proposed Wolf Creek Reservoir to help conserve water in the White River for
the benefit of the citizens of Rio Blanco County and the State of Colorado.
Although the original water rights application in this case was filed for a reservoir storage
volume of up to 90,000 acre-feet (AF), Wheeler’s Expert Report documents estimated annual
storage needs for future water storage in the reservoir ranging from 101,792 to 110,792 AF
(Wheeler, 2020). Further, Wheeler’s Expert Report documents that prudent planning for this
reservoir would include storage for a three-year drought, projected at three times the annual
demand, which would range from 275,375 to 284,376 AF.
This report discusses the expected recreational benefits at Wolf Creek based on the reservoir
size (Section 2), the need for multi-year drought planning (Section 3), and supplemental
information on Section 7 consultation and the need for dedicated water storage in Wolf
Creek Reservoir to help recover endangered fish in the White River (Section 4).

1.2

Wheeler Expert Opinions

In reference to this report, “Wheeler’s opinion” refers to the following experts:
•

Stephen L. Jamieson, P.E.

•

Gary B. Thompson, P.E.

•

Danielle T. Hannes, P.E.

•

Christine B. Mugele, P.E.

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 1.3

Harvey Economics Expert Opinions

In reference to this report, “HE’s opinion” refers to the following experts:
•

Edward F. Harvey

•

Susan H. Walker

•

Jessica Harvey

•

Kegan K. Reiswig

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 SECTION 2
Reservoir Size and Recreational Benefits
2.1

Introduction

RBWCD is currently seeking a 72,720 AF water right for the on-channel Wolf Creek Reservoir
and 66,720 AF for the off-channel Wolf Creek Reservoir. Use will include recreation, which
will occur in and upon the entire amount of stored water. An operational recreational pool of
15,000 AF at the off-channel Wolf Creek Reservoir corresponds to a reservoir with 700 surface
acres. A reservoir with 700 acres of surface area is at the lowest end of a range of recommended
minimum surface acres required to meet recreational objectives (HE, 2014). In that report, HE
explained that various reservoir attributes, including size, determine the recreational
attractiveness which leads to visitation and which brings economic benefits.
In its first expert report filed in this case, HE estimated a minimum range for an operational
recreational pool, beginning at 15,000 AF for the off-channel reservoir (HE, 2020). As further
explained below, the surface area and the size of the operational recreational pool at Wolf
Creek Reservoir have a direct relationship.
This section describes how recreational benefits will increase with reservoir surface area
beyond the minimum range previously established. We provide a comparison of other
reservoirs on the Western Slope, discuss attributes which affect reservoir visitation, and
demonstrate how visitation increases as the surface area of a reservoir increases. This section
goes on to discuss the potential for increasing surface acres and the operational recreational
pool at Wolf Creek Reservoir, and associated increases in visitation. We conclude that
recreational benefits will increase from the minimum size of 700 surface acres up to 1,500
surface acres, the latter corresponding to an operational recreational pool of 46,000 AF. This
report section focuses only on the off-channel reservoir site for simplicity, but the same
principles and opinions apply to an on-channel reservoir.

2.2

Comparable Reservoirs in Western Colorado

There are multiple flatwater-based recreational areas in western Colorado, including many
within State Parks and additional reservoirs located on U.S. Forest Service or other public
lands. Those reservoirs vary in location (scenery, degree of remoteness), size (surface acres),
amenities (i.e. type and number of campsites), allowable recreational activities (i.e. motorized
or non-motorized boating), other nearby recreational opportunities and other attributes. Those
attributes can have considerable impacts on annual visitation.
Exhibit 2-1 identifies the reservoirs most comparable to the proposed Wolf Creek Reservoir
and includes estimates of annual visitation. These reservoirs are generally comparable in size
to Wolf Creek in terms of surface acres and are located in areas with relatively open landscapes.

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 Exhibit 2-1.
West Slope Reservoirs Comparable to Wolf Creek

Recreation Area
Elkhead Reservoir State Park
Ridgway State Park
Stagecoach State Park
Steamboat Lake State Park
Vega State Park
Wolford Mountain Reservoir

Water Surface Area
(acres)
900
940
765
1,053
900
1,550

Total Area
(acres)
2,105
3,201
1,630
2,824
1,842
NA

Annual Visitation
152,931
412,058
179,403
408,588
209,176
NA

Sources: Colorado Parks and Wildlife Fact Sheets, 2017; Colorado River Water Conservation District, 2020.

Visitation at these locations vary for a variety of reasons. For example, Ridgway State Park
offers over 250 campsites, some of which are open year-round and many of which have full
RV hook-ups. Ridgway’s campgrounds also offer showers, laundry, playgrounds, and other
camper services. With the high annual visitation, Ridgway is also in a location that offers
access to regional attractions available in Ouray and Telluride and the various recreational
activities provided on nearby public lands. In comparison, Elkhead Reservoir State Park
includes fewer than 50 campsites and offers limited amenities.
As noted in HE’s initial expert report, dated May 4, 2020 (HE’s Initial Expert Report), Vega
State Park was identified as perhaps the most comparable to the Wolf Creek Reservoir site due
to factors such as distance from larger population centers and reservoir size. The lower
elevation and therefore longer recreational season of the proposed Wolf Creek Reservoir site,
as compared to Elkhead or Vega reservoirs, also supports HE’s initial visitation estimates.
Wolford Mountain Reservoir is included on this list because it is one of the largest potentially
comparable reservoirs in the region. It is not part of a state park, which substantially reduces
visitation. The Colorado River District operates Wolford Mountain Reservoir for water supply
and other purposes, but it does not track visitation to the reservoir.
Visitation to Colorado’s State Parks and other recreation areas across the State has increased
in recent years, due in part to a growing population and interest in outdoor activities.
Recreational sites on the West Slope have experienced large increases in visitation, as residents
from the Front Range and other areas of Colorado search out locations that are less crowded.
For example, visitation at Vega State Park has increased by 10 to 15% per year over the last
several years. Other locations on the Western Slope have experienced similar growth in
visitation. Wolf Creek would offer an additional recreational opportunity on the Western Slope,
relieving some of the pressure on resources and facilities in other areas of the region.

2.3

Reservoir Attributes that Determine Reservoir Benefits

Visitation to reservoirs is determined by a wide variety of factors, including:

•

Reservoir size and characteristics—surface area, depth, variable shoreline, bottom
shelving
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 •
•
•
•
•
•
•
•

Location – distance from large populations/ major roads; distance from other area
attractions/ amenities
Available activities – variety of water and land- based recreational opportunities
(i.e. fishing, motorized/ non-motorized boating, swimming, hiking, wildlife
viewing, off-highway vehicles (OHV) trails)
Amenities – number and type of campsites, other overnight options (cabins, yurts),
boat ramps, marinas, swim beaches, picnic areas, day use areas, trails
Quality of amenities and recreational experience – type and variety of fishery,
topography, scenery
Elevation and length of season – longer recreational season for lower elevation
reservoirs
Unique natural features – existence of/accessibility to waterfalls, hot springs, caves
Accessibility – ability for large RVs, boats and other vehicles to safely travel to
and within the area on suitable roads
Management – Colorado Parks and Wildlife (CPW) or local management of
maintenance and operations

Each of these attributes plays an important part in driving interest in and visitation to different
recreational locations. Variations across these attributes can have a large impact on visitation
numbers (USACE, no date; Ecosystems Services, 2017; Larimer County Dept. Of Natural
Resources, 2019).
2.3.1 Importance of access

A reservoir offering a variety of recreational opportunities and amenities will attract the interest
of visitors interested in bringing RVs, motorboats, OHVs, trailers and other gear with them for
recreation. Those visitors must be able to safely access the area, with roads maintained to
support those types of vehicles. In addition, road access to the shoreline of a reservoir is
important. An important example of the importance of maintaining good reservoir access is
provided as follows:
On May 30, 2019, Steve Jamieson, from Wheeler was asked to attend a meeting with
representatives of the local BLM White River Field Office staff and the Rio Blanco County
Commissioners to provide technical input to their discussions. The BLM was drafting its travel
management plan that involved establishing non-motorized areas within their resource area.
One of the BLM’s proposed non-motorized areas would have eliminated access to one of the
off-channel Wolf Creek Reservoir arms. Even though there was no application in place for the
new reservoir or any written agreements for recreation at Wolf Creek Reservoir, all three Rio
Blanco County Commissioners were adamant that they wanted the largest reservoir possible
for recreation.
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 The Rio Blanco County Commissioners also made clear they would not support the BLM’s
entire travel management plan if it did not include at least a ¼-mile buffer around the entire
proposed 90,000 acre-foot, off-channel Wolf Creek Reservoir to maintain good recreational
access. It was clear that the Rio Blanco County Commissioners understood the value of access
to a recreational reservoir at Wolf Creek to the future of their local economy. In the end, the
BLM changed its proposed non-motorized areas to accommodate the Rio Blanco County
Commissioners request (Jamieson, 2019).
2.3.2 Relationship between reservoir size and visitation

The recently completed Northern Integrated Supply Project (NISP) EIS focused on evaluation
of impacts related to the development of the proposed Glade Reservoir (ACE, 2018). Glade
Reservoir would be a new, large (1,700 surface acres) reservoir located along the Front Range
in northern Colorado. The Socioeconomic Resources Technical Report (Technical Report)
completed as part of the EIS estimated annual visitation to Glade Reservoir (ACE, 2008). As
discussed in the Technical Report,
“After consideration of various variables and statistical functional forms, the following linear
relationship was found to be the best balance between good fit and simplicity for estimating
annual recreational visitation:
Annual visitation = (surface acres * 219) + 67,000
The Technical Report also notes that “a range of explanatory variables, including income,
substitute sites, and types of recreation, were examined in order to provide both a rational basis
for the model and a good statistical fit. However, considering the uncertainty of how the
resources will be developed and how Glade Reservoir will be operated, the simple one-variable
model performed best.”
In HE’s opinion, the analysis completed for the NISP EIS suggests a direct, linear relationship
between surface acres and reservoir visitation, regardless of location, supports the idea that a
larger reservoir would attract additional visitors.

2.4

Alternative Reservoir Sizes at the Wolf Creek Site

HE’s Initial Expert Report provided visitation projections for an operational recreational pool
size of 20,000 AF at the Wolf Creek site. However, Wheeler has developed additional
information about larger operational recreational pool sizes, including surface area and
shoreline changes as the size increases.
Exhibit 2-2 illustrates the relationship between reservoir volume and surface area for the Wolf
Creek site, assuming that the entire reservoir pool is dedicated to recreation.

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 Exhibit 2-2.
Volume – Surface Area Relationship for the Proposed Wolf Creek Reservoir
(off-channel) Site

Source:

Wheeler, 2020.

This graphic demonstrates that, as surface area increases, reservoir volume increases. A 700
acre surface area equates to a 15,000 AF operational recreational pool, a 900 acre surface area
would equate to a 24,000 AF operational recreational pool, and a 1,500 acre surface area would
equate to a 46,000 AF pool. As previously demonstrated, a larger reservoir pool would lead to
more visitation and economic benefits.
Exhibit 2-3 illustrates the boundaries for various sizes of Wolf Creek Reservoir, assuming
different reservoir volumes and associated surface areas.

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 Exhibit 2-3.
Alternative Wolf Creek Reservoir Recreational Areas

Source:

W.W. Wheeler and Associates, June 2020.

This graphic illustrates how the shoreline would change as the reservoir size increases. The
blue line in the graphic indicates the shoreline of a 700 acre surface area reservoir. This
shoreline does not provide the variation that a larger shoreline would provide, as indicated in
the larger reservoirs whose shorelines are noted as red, yellow, etc. The greater number of
inlets or “fingerlets” with the larger sized pools suggests a more interesting reservoir from the
standpoint of recreation because of the opportunities to explore and be isolated from others.
The opportunity to explore increases with the number of miles of shoreline.

2.5 Visitation Projections and Economic Benefits from
Larger Wolf Creek Operational Recreational Pool Sizes
In HE’s Initial Expert Report, HE projected visitor days for a 20,000 AF operational
recreational pool (833 surface acres) to be 210,000 visitor days within ten years. With reservoir
size increasing and all other physical attributes of the site remaining the same, visitation can
be expected to increase with 1,500 surface acres, or a 46,000 AF, operational recreational pool.
Assuming a direct relationship between surface area and visitation, the proposed Wolf Creek
Reservoir can anticipate between 350,000 and 400,000 visitor days by year ten of full
operation.
A reservoir of 1,500 surface acres would provide expanded recreational opportunities and
benefits, including:

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 •

Ensuring physical space between visitors, equipment and different activities;

•

More shoreline and fingerlets to explore;

•

Additional opportunities for varied fish habitat and fishing experiences;

•
•

Opportunities for larger boats and variety of boating experiences and site-seeing
from the water;
Potential for expanded shoreline amenities, such as campsites, boat ramps and
marinas.

The variety of recreational opportunities, amenities and experiences at Wolf Creek Reservoir
will drive annual visitation to the area. Visitation, in turn, drives the level of economic benefits
experienced in Rangely, Meeker or other areas of Rio Blanco County. Benefits to local
economies are generated by visitors spending money on accommodations, food, gas, supplies
and other items at local businesses and via sales or lodging taxes paid on those items. As
visitation increases, so do the economic benefits experienced by local residents, businesses,
and governments, including the State of Colorado.

2.6

Summary Opinion

RBWCD is currently seeking a 72,720 AF water right for the on-channel Wolf Creek Reservoir
and 66,720 AF for the off-channel Wolf Creek Reservoir. Use will include recreation, which
will occur in and upon the entire amount of stored water. It is HE’s expert opinion that
recreational benefits of the proposed Wolf Creek Reservoir would increase as the operational
recreational pool increases above 15,000 acre-feet. Recreational benefits as indicated by
visitation are influenced by various factors, but a larger reservoir size (in surface acres) would
be able to attract a greater number of visitors, all else equal. A 1,500 surface acre Wolf Creek
Reservoir with a 46,000 AF operational recreational pool is projected to attract between
350,000 and 400,000 visitor days by year ten of full operation. This would result in larger
economic benefits to residents, businesses, and local jurisdictions within the RBWCD and Rio
Blanco and Moffat Counties, and the State of Colorado.

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 SECTION 3
Water Supply Planning for a Multi-Year
Drought
3.1

Introduction

Wheeler has concluded that three years of drought storage should be considered as part of the
conditional water right application, as a prudent water supply planning practice.
The basis for the Wheeler’s opinion that three years of drought storage is required is based on
the following concepts:
1. The threat of a Colorado River Compact curtailment;
2. The potential for extended drought in the White River Basin;
3. Common water supply planning practices of water providers.
Each of these is described further below.

3.2

Drought and the Colorado River Compact (Compact)

HE’s Initial Expert Report explained the risks of a future Colorado River Compact curtailment.
The Compact states that the Upper Division will not cause the flow at Lee Ferry to be depleted
below an aggregate of 75 MAF for any period of ten consecutive years without becoming
subject to a curtailment by the Lower Basin States (C.R.S. § 37-61-101, Art. III).
The drought of the early 2000s is an example of how drought can impact Compact curtailment.
Due to the very dry 2000-2004 period, (U.S. Bureau of Reclamation [BOR], 2020) it was
critical that in the later years of the rolling average, heavy run-off years would be needed to
make up for the below average period early on. For the years 2001-2010, the 10-year flow of
the Colorado River at Lee Ferry was 84.8 MAF, accounting for the Mexico Treaty (BOR,
2011a), only 2.3 MAF above the threshold of a potential curtailment.
Fortunately for the Upper Basin, 2011 was a big water year, and the 10-year flow at Lee Ferry
increased to 89.29 MAF once 2011 was included in the 10-year rolling average (BOR, 2011b).
Had 2011 not been a big water year, it is likely the “Compact hole” within the 10-year rolling
average created by the early 2000s drought would have resulted in multiple years of Compact
curtailment. The “Compact hole” concept requires flows of less than the Compact obligations
in one or more years to be offset in subsequent years with higher flows in order for the Upper
Basin to remain in compliance with the Compact’s 10-year rolling average.
If the Upper Basin were to deplete flows of water into the Lower Basin at levels close to 8.25
MAF per year, then it is especially critical that a prolonged drought does not occur in the last
three years of the rolling average, which further supports the need for three years of drought
storage. Although the Upper Basin remained in Compact compliance throughout the 2000-

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 2004 drought, hoping for higher than normal precipitation in the final year of a 10-year rolling
average is not a prudent long-term water supply strategy.
The impact of drought and aridification plays a major role in water flowing from the Upper
Basin to the Lower Basin:

•

•
•
•

Drier periods mean less precipitation throughout the year, which means a smaller
snowpack in the Rocky Mountains in the spring, and less rainfall in other months.
A smaller snowpack results in smaller water quantities in reservoirs, rivers and
streams;
Drier periods cause higher evaporation rates, which reduces reservoirs, rivers, and
streams more than normal;
Drier periods lower soil moisture content levels. As soil moisture content lowers,
precipitation must first fall into and re-saturate the ground before water can make
its way down mountains and into reservoirs, rivers and streams; and
Longer growing seasons increase the consumptive use of native plants and
increases irrigation consumptive use.

These drought impacts create a cumulative effect, which makes getting back to pre-drought
levels difficult and prolonged. This cumulative effect can contribute to a “Compact hole” as
described above.
When significant drought occurs, the Upper Basin will most likely use a variety of steps to
maintain Compact compliance, such as operation of Colorado River Storage Project Reservoirs
(CRSP), water above minimum power pool in Lake Powell, and potentially demand
management. However, HE’s Initial Expert Report demonstrated that these steps would not be
enough to alleviate the threat of curtailment. Moreover, once these efforts have been exhausted,
the Upper Basin’s further ability to supplement flows during a prolonged dry spell would be
severely limited. This is one of the reasons the Upper Basin is susceptible to as many as five
Compact curtailments in a 25-year period.
If one Compact curtailment occurs, this means the Upper Basin has utilized all its available
strategies and was still be unable to remain in compliance. This “hole” would need to be
rectified in the next year of the 10-year rolling average through increased natural river flows,
releases from storage, or curtailment of water rights. As discussed in Wheeler’s initial May
2020 expert report (Wheeler’s Initial Expert Report), the White River Basin could be subject
to an approximate 12,000 AF curtailment under a single year of Compact curtailment. Multiple
years of curtailments are a distinct possibility. Additional water storage in the White River
Basin can help offset the negative effects of such curtailments.
The Colorado Water Conservation Board (CWCB) Interbasin Compact Committee (IBCC)
listed new supplies and implementing storage and other infrastructure as two of its six strategies
as part of its No/Low Regrets Action Plan to meet future water needs. The concept behind
implementing storage is the Upper Basin will be better-equipped to handle drought by
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 capturing surplus water in wet years (IBCC, 2013). The Wolf Creek Reservoir will be a
valuable tool for the White River Basin in mitigating the negative effects of Compact
curtailment and mitigating against prolonged drought.

3.3

Drought in the White River Basin

The White River Basin along with many of the adjacent West Slope basins have experienced
drought multiple times over the last 20 years. Per the Colorado Drought Mitigation and
Response Plan (CWCB, 2018) developed pursuant to the Disaster Mitigation Act 2000, Rio
Blanco declared drought conditions with the USDA Secretarial Disaster Declarations in
2003, 2005, 2006, 2012, 2013, 2014, 2015, and 2018. Hence, this drought declaration in Rio
Blanco County applied consecutively for 4-years (from 2012-2015). Rio Blanco County
mainly encompasses the White River Basin.
In addition to declaring drought, the Yampa/White/Green Basin Roundtable (WWG, 2018)
studied the paleohydrology to predict climate changes and the magnitude and length of
droughts in the Yampa Basin located adjacent to White Basin. Because of the proximity of the
White River basin to the Yampa River basin, it is Wheeler’s opinion that paleohydrology in
the White River basin would be similar.
Paleohydrology is a reconstruction of annual streamflow based on a statistical relationship with
tree-ring widths. The Yampa paleohydrology evaluation supported that the longest drought on
record was 13 years at the Steamboat gage and 14 years at the Deerlodge gage, both of which
are located on the Yampa River. The paleohydrology evaluation also indicated that a threeyear or longer drought occurred about 70 times at the Steamboat gage and 82 times at the
Deerlodge gage over the 1000 to 2013 paleohydrology period that was evaluated, which
equates to a drought of at least three years’ duration occurring about every 12 to 15 years. This
supports Wheeler’s opinion that it is reasonable to plan for a three-year drought at least once
over a 50-year planning period.
The CWCB Drought Mitigation and Response Plan (CWCB, 2018) also evaluated climate
changes looking at historical low flow conditions versus future climate-adjusted low flow
conditions to understand how droughts may change in the future. The report summarized three
different scenarios of historical and future flows, all of which resulted in the conclusion that
reductions in flows in the White River near Meeker are expected to occur.
During a non-drought scenario, a 4-percent reduction in flow at the White River was estimated
by comparing the future mean flow with the historical average flow. During a drought scenario,
a 37-percent reduction in flow may occur when comparing the driest 2-year low flow with the
average annual flow, or a 12.7-percent reduction in flow when comparing the driest 2-year
flow with the historical average low flow in the White River.
The CWCB lists Wolf Creek Reservoir as a potential identified project to be “...instrumental
in maintaining water supply reliability and either directly or indirectly meeting demands during
drought periods” (CWCB, 2018).

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 Wheeler also evaluated endangered fish habitat based on existing daily flows in the White
River at the Watson gage, not including future demands. Daily flows at the gage were
compared to the interim endangered fish target flow recommendations recommended by
William Miller’s initial expert report in this case (Miller’s Initial Expert Report) to determine
how the existing flows compare to the interim endangered fish target flows.
Based on the spreadsheet model with a 56-year period of record between 1962 and 2018, the
1977 and 2002 droughts caused consecutive years where supplemental flow would be required
to meet the interim endangered fish target flows. There were at least five times when
supplemental flow would be required during a consecutive two-year period throughout the
different flow targets. During the 2002 drought (including years 2002, 2003 and 2004), the 90percent and 100-percent irrigation flow targets required 3-year consecutive supplemental flows
totaling 12,000 and 16,000 acre-feet, respectively, to achieve the targets.

3.4 Standard Industry Practices Related to Drought in Long
Term Water Supply Planning
Drought is an important event to plan for, according to the US Army Corps of Engineers’
Institute of Water Resources (IWR). The effects of climate change have made the present a
critical time to plan for droughts, as changes to the water cycle, and the impacts of these
changes to water resources, are projected to affect the magnitude and frequency of floods and
droughts, which are likely to impact water supplies nationwide (IWR, 2016).
Changes in water supply are a particular concern for regions of the country whose growing
populations already stress water resources, such as Colorado. The CWCB states that water
supply reliability planning is an important component of ensuring sufficient supplies during
times of drought (CWCB, 2011).
Water supply augmentation is identified as a supply-side mitigation strategy by the CWCB,
although this strategy is often difficult because it cannot be undertaken quickly. Developing
extra water supplies increases water utility credibility with customers by demonstrating that
the water supplier is maximizing its efforts to reduce any effects from a water shortage. Also,
supply augmentation can provide a water shortage buffer in case of multi-year shortages
(CWCB, 2010).
It is common practice for water providers to acquire a supply of water to meet their needs in
times of future, multi-year droughts. This is commonly referred to as “firm yield.” The U.S.
Bureau of Reclamation describes firm yield water supply as the amount of water that is
available during a defined period or condition. Often this encompasses a 50-year historical
record that includes multiple dry years (ERO, 2005).
Denver Water uses a three-year dry period that occurred in the mid 1950s as their “drought of
record.” Currently, Denver Water has a firm annual yield of 345,000 AF, which is about 55,000
AF more than Denver Water’s annual water demands (Denver Water, 2002).

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 Aurora is another municipality that uses this same three-year drought of record in their water
supply planning (Aurora, 2015). Aurora’s firm annual yield is 63,500 AF, which is roughly
13,000 AF more than its current demands of about 50,000 AF.
It is also common practice for water providers to build up water storage in reservoirs to help
meet future demands during times of drought. Denver Water currently has a usable capacity of
518,000 AF, which is 1.8 times their current water demands. In addition to its storage reserves,
Denver Water has a suite of other water rights available to help meet demands, such as direct
flow rights and exchanges and reusable water supplies, which is why it does not need to rely
strictly on reservoir storage during times of drought. Similarly, Aurora has a storage capacity
of over 150,000 AF in 12 reservoirs and lakes, which is about three times its current annual
water demand.
Smaller water providers on the West Slope, such as Glenwood Springs and Grand Junction,
and Craig also rely on storage in reservoirs and lakes to help meet future demands. In each
case, storage exceeds annual demand.
Glenwood Springs has two direct flow water rights and contracts for water in Ruedi Reservoir
totaling 7,500 AF in a dry year (Glenwood Springs, 2015). Glenwood Springs’ “dry year” is
based on an average of historical dry years. Glenwood Springs’ current demands are roughly
2,000 AF, which means it has enough water to carry the city through about 3.5 years of drought.
Grand Junction has about 13,000 AF of raw storage (Grand Junction, 2012). Grand Junction’s
current water demands average 5,200 AF, which means it has water storage capable of carrying
through roughly 2.5 years of drought.
Craig, population 9,000, also relies on storage to ensure that supplies will be adequate in times
of shortage (Colorado River District, 2014; and Craig, CO, undated). Craig’s average demand
is about 2,435 AF per year. This small community has reserved a storage pool of 4,837 AF in
Elkhead Reservoir. Not counting other storage, direct flow rights or other supply sources, Craig
has almost two times its average annual demand stored in Elkhead.
As noted in Wheeler’s Initial Expert Report, there is limited storage on the White River. The
Town of Rangely has no storage and relies solely on direct flows from the White River.
The Wolf Creek Reservoir will help the RBWCD and the CWCB accomplish multiple longterm goals identified in its Basin Implementation Plan process. The CWCB predicts the
Yampa/White/Green river sub-basins could have a municipal water supply gap of 24,000 to
83,000 AF by 2050 (Colorado, 2015).

3.5 Considering Drought in Long Term Future Water Supply
Planning for the White River Basin by the RBWCD
The RBWCD seeks to ensure that the long-term water needs of water users within the RBWCD
are met. In addition to current and future water demands, the RBWCD must consider the effects
of potential future drought on supplies. Multiple year droughts are clearly a risk in the White
River Basin. Beyond the local area, shortages in the Upper Colorado River Basin are a
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Page 15

 significant risk and these could occur for multiple years. In recognition of these risks, the
RBWCD would be prudent to incorporate three years of drought supply protection in its water
supply planning. This would be consistent with common practice among Colorado water
providers as described herein.

3.6

Summary Opinion

In HE’s opinion, the risks of future, multiple year droughts in the White River Basin and
Compact curtailment in the Upper Colorado River Basin are real. Such a drought in either area
could bring shortages and negative impacts to RBWCD water users. The RBWCD would be
prudent in developing long term water supply plans that incorporate a three-year drought,
consistent with many Colorado water providers.
In Wheeler’s opinion, multi-year droughts have occurred and more severe droughts will occur
in the White River Basin based on hydrologic studies completed by two different government
agencies as well as historical flows modeled in the White River Basin as described above. Wolf
Creek Reservoir will provide needed storage to mitigate a three-year drought period.

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 SECTION 4
Section 7 Consultation
4.1

Introduction

This section provides supplemental information to further document the basis for Wheeler’s
opinion that, through the federal permitting process that will be required to permit and construct
Wolf Creek Reservoir, some dedicated water storage in Wolf Creek Reservoir will be required
to help recover endangered fish in the White River.
The off-channel or on-channel Wolf Creek Reservoir will inundate federal lands administered
by the BLM, which will require a Right-of-Way from the BLM. Approval of this Right-ofWay is considered a federal action or “nexus” that triggers compliance under the National
Environmental Policy Act (NEPA), which in turn can trigger consultation under the
Endangered Species Act of 1973 (ESA). A more rigorous NEPA process, an Environmental
Impact Statement (EIS), is required when the project will result in significant impacts to the
environment.
Previous informal, pre-permitting discussions with the BLM have confirmed that an EIS will
be required for BLM Right-of-Way approval because depletions from the White River required
to fill the reservoir are considered to be significant impacts to two federally listed endangered
fish species in the White River: the Colorado Pikeminnow and the Razorback Sucker.
The ESA directs all federal agencies to work to conserve endangered and threatened species
and to use their authorities to further the purposes of the Act (FWS, 2019). The ESA identifies
the U.S. Fish and Wildlife Service (FWS) as the federal agency responsible for administration
and enforcement of the ESA. Section 7 of the ESA, sometimes referred to as “Interagency
Cooperation,” requires the lead federal agency responsible for NEPA documentation to
formally consult with the FWS if the federal action or decision may adversely affect federallylisted threatened or endangered species.
Similar to any other water diversion in the Upper Colorado River basin in Colorado, diversions
to fill Wolf Creek Reservoir will be considered by the FWS as an action that is likely to
adversely affect the Colorado Pikeminnow and the Razorback Sucker. Section 7 of the ESA
will require the preparation of a formal Biological Opinion and the lead federal agency, in
cooperation with the project applicant, the RBWCD, may provide reasonable and prudent
alternative actions to mitigate the project’s adverse effects on endangered species. Based on
numerous pre-permitting meetings with the BLM, the lead federal agency responsible for
preparing the EIS and for Section 7 Consultation with the FWS will be the BLM.
A Section 7 Agreement has been developed between the Program Partners of the Upper
Colorado River Endangered Fish Recovery Program (Section 7 Agreement, 2000). The
Section 7 Agreement allows for the Recovery Implementation Program for Endangered Fish
Species in the Upper Colorado Basin (RIP) along with the Recovery Action Plan (RIPRAP) to
serve as an adaptive management plan to serve as the reasonable and prudent alternative for
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Page 17

 water projects that require Section 7 Consultation for endangered fish in the Upper Colorado
River Basin. The FWS will evaluate the proposed project depletions and determine if the
RIPRAP is making sufficient progress to recover the endangered fish species for the RIPRAP
to be used as the reasonable and prudent alternative under Section 7 Consultation.
The project proponent is not obligated to use the Section 7 Agreement and may choose to
include their own proposed reasonable and prudent alternative in its proposal to remove
uncertainties associated with future species recovery that are inherent in the Section 7
Agreement and provide more certainty for future ESA compliance. A good example of this
approach is provided in the Wolford Mountain Reservoir case that is described in Section 4.3
below. In the case of Wolford Mountain Reservoir, the project proponent, the Colorado River
District, included a 6,000 AF endangered fish pool in the reservoir to be released annually to
improve endangered fish habitat. This endangered fish pool was approved by the water court
and included in the conditional and absolute water rights decrees for the reservoir.
In most Upper Colorado River Basins a Programmatic Biological Opinion and Management
Plan (PBO) has been developed to the address the specific endangered fish issues in that river
basin. After a basin PBO has been developed and signed, the PBO will serve as the reasonable
and prudent alternative for Section 7 Consultation and the project proponent simply pays a
depletion fee based on the calculated project depletions to help fund the Management Plan
developed as part of the basin specific PBO. The other PBOs include specific actions to recover
the endangered fish, including making timed releases from upper basin storage to augment
river flows at critical downstream habitats.
A White River PBO is being developed and formal discussions are occurring through a multiagency group of stakeholders, called the White River Planning Team. These stakeholders
include the RBWCD, FWS, CWCB, representatives from the State of Utah, The Nature
Conservancy (TNC), and the Ute Tribe. The White River Planning Team has developed a range
of interim future depletions that the White River PBO would offset as well as a set of interim
flow recommendations at the Watson Gage, just downstream of the Colorado/Utah state line
on the White River, to help recover the endangered fish.
The CWCB has agreed to be the contracting agent on behalf of the White River Planning Team
and has contracted with an independent consulting team that will prepare the White River PBO
for the FWS. The kick-off meeting for the consulting teams work occurred on June 30, 2020
and the Management Plan is scheduled to be complete in 2021. The Management Plan will
include final flow recommendations at the Watson gage to help recover endangered fish as
well as a volume of future depletions that can be covered by future Section 7 Consultations in
the White River.
The RBWCD has recognized the value of the White River PBO to collaboratively recover
endangered fish in the White River in conjunction with the operation of historical and future
water projects. Some of the RBWCD’s proactive actions have included providing water for
endangered fish storage in Wolf Creek Reservoir in the conditional water rights application for
Wolf Creek Reservoir. The RBWCD will be signatory to the White River PBO and the ensuing
White River Cooperative Agreement along with the FWS and the States of Colorado and Utah.

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 The White River Planning Team has developed an estimated range of future water use
depletions of 25,800 AF in the White River that would be covered by the PBO. As documented
in Miller’s Initial Expert Report, Wolf Creek Reservoir is an excellent location for the storage
of a dedicated pool of water that can be released to augment downstream flows on the White
River to help recover the endangered fish (Miller, 2020). Based on initial discussions of the
White River Planning Committee, water storage in Wolf Creek Reservoir is expected to be a
key element of the White River Management Plan.

4.2 Precedent for Upper Colorado River Endangered Fish
Storage
Exhibit 4.1, provided below, documents the amount of future annual river basin depletions that
are covered in the Colorado River PBO (FWS, 1999), the Gunnison River PBO (FWS, 2009)
and the Yampa River PBO (FWS, 2005). The percentage of annual water released from storage
ranges from 13 to 55 percent of the new annual depletions that are covered by the specific
PBOs in those basins. If these percentages are applied to the interim future depletions of 25,800
AF that have been developed for the White River, the endangered fish storage requirements in
the White River could range from 3,354 AF to 14,190 AF.
However, as documented in Wheeler’s Initial Expert Report, the endangered fish storage pool
in Wolf Creek Reservoir could be much larger to account for expected future water shortages
versus interim target minimum endangered fish flows at the Watson gage (Wheeler, 2020).
Also documented in Wheeler’s Initial Expert Report is that fact that there is currently no other
significant storage in the White River that could be used to augment target endangered fish
flows at the Watson Gage. In addition, the existing White River storage reservoirs: Kenney
Reservoir, Rio Blanco Reservoir, and Lake Avery do not have decreed water rights that can be
released to augment flows for endangered fish in the White River.
Exhibit 4-1.
Endangered Fish Storage in Other Upper Colorado River Basin PBOs

River Basin
Colorado River (15-mile Reach)
Gunnison
Yampa

New
Depletions
Covered by
PBO
(acre-feet)
120,000
37,900
53,500

Endangered
Fish Water
Released from
Storage
(acre-feet/year)
66,000
17,200
7,000

Percentage
of Annual
Storage to
New
Depletions
55%
45%
13%

4.3 Wolford Mountain Endangered Fish Water Rights
Precedent
The Wolford Mountain water rights case, Case No. 87CW283, provides a good example for,
and in our opinion sets a precedent that, water storage for endangered fish can be proactively
included in conditional water rights before a contract for the water or a management plan
element for the endangered fish storage is executed. The project proponent, the Colorado River
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Page 19

 District, filed for a conditional water right for the reservoir on December, 1987 (87CW283,
1987). The application included a provision for endangered fish storage of 3,000 AF to meet
the provisions discussed in the Rock Creek / Muddy Creek Reservoir Final Environmental
Impact Study (EIS) Chapter 4 (BLM, 1990).
A later water rights application for an expansion of the original Wolford Mountain water right
expanded the endangered fish pool to 6,000 AF. The conditional water right included the
endangered fish pool and was approved by the water court and eventually made absolute. The
River District’s proposal to include the endangered fish pool in the project proposal met the
requirements of the Section 7 Consultation with the FWS and the NEPA documentation was
completed with an EIS (BLM, 1990). When the Colorado River PBO was finalized in 1999,
the dedicated 6,000 AF Section 7 endangered fish pool in Wolford Mountain became a part of
the PBO and the Management Plan (FWS, 1999).
Similarly, conditional water rights for the enlargement of Elkhead Reservoir were approved by
the water court well before the PBO was finalized for endangered fish in the Yampa River in
2005. At Elkhead Reservoir, 7,000 AF, 5,000 AF of which is allocated and 2,000 AF is leased
for 20 years, of the 11,750 AF reservoir expansion was dedicated for endangered fish releases
in the Yampa River. This 7,000 AF endangered fish pool represents 60-percent of the reservoir
expansion and 28-percent of the normal expanded storage in Elkhead Reservoir.

4.4

Summary Opinion

The information provided herein supplements and further supports Wheeler’s opinion in
Wheeler’s Initial Expert Report that the federal permitting process will require a dedicated
endangered fish pool in Wolf Creek Reservoir (Wheeler, 2020). Until the White River PBO
and Management Plan is finalized, the amount of endangered fish storage in Wolf Creek
Reservoir can only be estimated. Wheeler maintains that because of the expected requirements
associated with Section 7 Consultation, the amount of endangered fish storage in the proposed
Wolf Creek Reservoir will be significant. It is Wheeler’s opinion that the best estimate of the
total endangered fish pool required in Wolf Creek Reservoir at the time that this report was
prepared, based upon the best information available on the White River, is the estimate
provided in Wheeler’s Initial Expert Report.

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 SECTION 5
Corrections in Expert Report
Three typographical errors in Wheeler’s May, 2020 Initial Expert Report were identified and
should be corrected as listed below.
1. Wheeler Report, page 9, Table 2, Column 1, Row 2: “Maximum Depth (feet)” should
be replaced with “Minimum Depth (feet)”.
2. Wheeler Report, page 34, Table 15, Column 2, Row 4, Endangered Fish Water Storage,
“69,555” should be “60,555” based on 100% flow targets.
3. Wheeler Report, page 34, Table 15, Column 2, Row 9, Total, “110,792 (off-channel)
119,792 (on-channel)” should be “101,792 (off-channel) 110,792 (on-channel)”.

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 SECTION 6
References
1. City of Aurora, Colorado (Aurora, 2015) 2015 Municipal Water Efficiency Plan,
September 22, 2015.
2. Colorado Revised Statute Title 37-61-101, Water and Irrigation, Article 3 (C.R.S.
§ 37-61-101, Art. III).
3. State of Colorado (Colorado, 2015) Colorado’s Water Plan, 2015.
4. Colorado Parks and Wildlife, Elkhead Reservoir State Park Fact Sheet, 2017.
5. Colorado Parks and Wildlife, Ridgway State Park Fact Sheet, 2017.
6. Colorado Parks and Wildlife, Stagecoach State Park Fact Sheet, 2017.
7. Colorado Parks and Wildlife, Steamboat Lake State Park Fact Sheet, 2017.
8. Colorado Parks and Wildlife, Vega State Park Fact Sheet, 2017.
9. Colorado River Water Conservation District (CRWCD, 2006), The Dam Facts,
Elkhead Reservoir Enlargement, https://www.coloradoriverdistrict.org/wpcontent/uploads/2014/12/Elkhead_enlargement_fact_sheet.pdf.
10. Colorado River Water Conservation District, Wolford Mountain Reservoir,
https://www.coloradoriverdistrict.org/wolford-mountain-reservoir-2/.
11. Colorado Water Conservation Board (CWCB, 2018) Colorado Drought Mitigation and
Response Plan, August 2018.
12. Colorado Water Conservation Board (CWCB, 2011) Sample of Municipal Drought
Management Plan, June 2011.
13. Colorado Water Conservation Board (CWCB, 2010) Municipal Drought
Management Plan Guidance Document, August 2010.
14. Colorado Water Court (87CW283, 1987) Application for Water Storage Right,
December 28, 1987.
15. Colorado Water Court (87CW283, 1989) Judgment and Decree, November 20,
1989.
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 16. City of Craig Colorado (Craig, 2019) Water Department, System Overview, 2019.
https://www.ci.craig.co.us/departments/water/system_overview.php
17. Denver Water (Denver Water, 2002) Water for Tomorrow: An Integrated Water
Resource Plan, February 2002.
18. ERO Resources Corporation (ERO, 2005) Windy Gap Firming Project: Purpose
and Need Report, September 2005.
19. Ecosystem Services (Ecosystem Services, 2017) Optimizing recreation services
from protected areas – Understanding the role of natural values, built
infrastructure and contextual factors, December 8, 2017.
20. City of Glenwood Springs, Colorado (Glenwood Springs, 2015) Municipal Water
Efficiency Plan, August 14, 2015.
21. City of Grand Junction, Colorado (Grand Junction, 2012) Grand Valley Regional
Water Conservation Plan, July 5, 2012.
22. Harvey Economics (HE, 2014) Appendix D of the White River Storage Feasibility
Report, Phase 1 and 2, Purpose & Need Evaluation, 2014.
23. Harvey Economics (HE, 2020) Need for Financial Feasibility of Developing Wolf
Creek Water Rights, Case No. 14CW3143, Water Division No. 6, May 4, 2020.
24. Interbasin Compact Committee (IBCC, 2013) No/Low Regrets Action Plan, August
6, 2013.
25. Institute for Water Resources (IWR, 2016) Status and Challenges for USACE
Reservoirs, May 2016.
26. Stephen Jamieson (Jamieson, 2019) Personnel communication with Steve
Jamieson regarding the meeting with the BLM and the Rio Blanco County
Commissioners, May 30, 2019.
27. Larimer County Department of Natural Resources (Larimer County, 2019)
Understanding Our Visitors, April 2019.
28. Miller Ecological Consultants, Inc. (Miller, 2020) Expert Technical Report, Case
No. 14CW3043, Water Division 6, May 1, 2020.
29. Tom Pitts (Pitts, 2020) Personnel communication with Tom Pitts regarding the
how the Section 7 Agreement and the permitting of Wolford Mountain Reservoir,
June 16, 2020.
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 30. Section 7 Agreement (Section 7 Agreement, 2000) Section 7 Consultation, Sufficient
Progress and Historic Projects, Recovery Implementation Program for Endangered
Fish Species in the Upper Colorado River Basin, October 15, 1993, revised 2000.
31. Ray Tenney (Tenney, 2020) Personnel communication with Ray Tenney regarding the
water rights and Section 7 Consultation history of Wolford Mountain Reservoir, June
19, 2020.
32. U.S. Army Corps of Engineers (ACE, 2018) Northern Integrated Supply Project
Final
Environmental
Impact
Statement,
July
2018.
https://www.nwo.usace.army.mil/Missions/Regulatory-Program/Colorado/EISNISP/.
33. U.S. Army Corps of Engineers (ACE, 2008) Northern Integrated Supply Project
Environmental Impact Statement, Socioeconomic Resources Technical Report,
March 2008.
34. U.S. Army Corps of Engineers (ACE, n.d.) Characterization of Park Visitors,
Visitation Levels, and Associated Economic Impacts of Recreation at Bull Shoals,
Norfolk and Table Rock Lakes, no date.
35. U.S. Bureau of Land Management (BLM, 1990) Rock Creek/Muddy Creek
Reservoir Final Environmental Impact Statement, February 21, 1990.
36. U.S. Bureau of Reclamation (BOR, 2020) HydroData Basin Maps, February 10,
2020.
37. U.S. Bureau of Reclamation (BOR, 2011a) Annual Operating Plan for Colorado
River Reservoirs 2011, January 31, 2011.
38. U.S. Bureau of Reclamation (BOR, 2011b) Annual Operating Plan for Colorado
River Reservoirs 2012, December 14, 2011.
39. U.S. Fish & Wildlife Service (FWS, 1999) Final Programmatic Biological
Opinion for Bureau of Reclamation’s Operations and Depletions, Other
Depletions, and Funding and Implementation of Recovery Program Actions in the
Upper Colorado River Above the Confluence of the Gunnison River, December,
1999.
40. U.S. Fish & Wildlife Service (FWS, 2005) Final Programmatic Biological
Opinion on the Management Plan for Endangered Fishes in the Yampa River
Basin, January 10, 2005.

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 41. U.S. Fish & Wildlife Service (FWS, 2009) Final Gunnison Basin Programmatic
Biological Opinion, December 4, 2009.
42. U.S. Fish and Wildlife Service (FWS, 2019) Section 7 Consultation – A Brief
Overview, December 4, 2019, Website:
https://www.fws.gov/midwest/endangered/section7/section7.html
43. Wilson Water Group (WWG, 2018) Yampa/White/Green Basin Roundtable Basin
Implementation Plan Modeling Phase 3 Final Report, April 2018.
44. W. W. Wheeler & Associates, Inc. (Wheeler, 2020) Expert Report for Case No.
14CW3043, Water Division No. 6, May 4, 2020.

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