EAGLE COUNTY 1041 REVIEW
WHITNEY RESERVOIR
Evidence, Applicable Approval Standards and Save Homestake’s Position
EXECUTIVE EVIDENCE OVERVIEW
The evidence at a glance
Existing exports, wetland exposure and wildlife habitat show what Whitney would change. The cards cite the published Chapter VI. The decision roadmap compares it with the rules approved October 27.
Wetlands + fens
About 81.4 acres of mapped wetlands and Potential Fen habitat lie in our full-pool models of the four potential dam sites. The wider connected system contains 362.1 mapped acres through the Eagle River confluence.
§6.04.01(16), (17), (19), (20)
Water + existing export
About 23,400 AF/year exported, compared with 21,500 AF/year passing Gold Park, WY2007-2024.
§6.04.01(15), (16); §6.04.02(3)
Wildlife + aquatic habitat
Historical breeding and trout records, current observations and lidar routes displaced onto valley sides.
§6.04.01(18), (19)
The complete project
The reservoir connects to dam works, roads, pumping, conveyance, power and recurring maintenance.
§6.01.09; §6.03.06; §6.04.01(17)-(21)
Recreation + landscape
Existing trail, river and wildlife-viewing experience; construction and operating noise, access and scenery.
§6.04.01(11), (14), (21)
Need + efficient water use
Credit verified conservation and reuse. Compare further practical savings and reliable annual supply on the same basis.
§6.04.02(1), (3); §6.04.01(5), (24)
Evidence: S01. Full titles and pinpoints in the evidence register.
ATTRIBUTED ADVOCACY
Save Homestake’s position
We oppose new or expanded diversions from Homestake Valley and changes to the Holy Cross Wilderness boundary. Municipal demand does not give the cities a claim on the valley’s future.
The criteria supporting that position
- Wetlands, groundwater, plants and soils: preserve the functioning peat, water and living community, including habitat exposed to modeled inundation and construction.
- Wildlife and aquatic life: protect breeding, seasonal movement, cold-water habitat and the flow-dependent food web.
- Recreation, scenery and nuisance: evaluate the complete construction and operating landscape, including roads, pumps, power and maintenance.
- Necessity, efficient use and County benefits: demonstrate reliable project-specific supply, credit conservation already achieved, and compare additional practical measures and local resource losses.
A decision grounded in the governing record
For a permit application, the Board decides whether every applicable standard is met. Save Homestake asks it to deny any permit where enforceable conditions would leave a standard unmet. The evidence and the campaign’s requested findings are identified separately.
Evidence: S01 · S07 · S08 · S31. Full titles and pinpoints in the evidence register.
HOW TO READ THIS DOSSIER
A record you can inspect
The chapters connect each threatened resource with the County standard that protects it and the evidence relevant to that decision.
| Evidence category | Meaning in this dossier |
|---|---|
| DOCUMENTED FACT | A dated source directly records the fact. |
| MEASURED DATA | An observation or instrument record, with location and period. |
| CALCULATION | A reproducible transformation of stated inputs. |
| MODELED RESULT | An output dependent on identified geometry, scenarios and assumptions. |
| SCIENTIFIC INFERENCE | A mechanism supported by research, applied with its study setting. |
| PROPONENT STATEMENT | The cities’ or applicant’s own attributed project description. |
| SAVE HOMESTAKE ANALYSIS | The project’s interpretation connecting sources and approval questions. |
| SAVE HOMESTAKE POSITION | The organization’s clearly attributed requested decision. |
| UNRESOLVED | A material record that still needs an identified answer. |
Read citations in one consistent way
S01-S34 are established dossier source labels, with canonical project identifiers 1041:S01 through 1041:S34. HWF prefixes preserve ecology source and claim IDs; HWA identifies water-audit sources. MUN identifies municipal sources. Source IDs link directly to the original record; the full register provides titles and pinpoints. Chapter and matrix links open the corresponding sections below.
This edition compares the published Chapter VI with the package approved October 27. The Board tied effectiveness to a separate enacting resolution. The November 2 status appears on page 9. Appendix A helps interpret Chapter VI criteria.
Evidence: S01 · S36 · S35 · S37 · S42. Full titles and pinpoints in the evidence register.
EXECUTIVE MATRIX · 1 OF 2
The decision roadmap
Chapter VI and the October 27 package set out different tests. The rule governing a Whitney filing depends on enactment, transition provisions and the filing record.
| Resource / issue | Key evidence | Chapter VI | October 27 package | Decision question | Save Homestake position | Detail |
|---|---|---|---|---|---|---|
| Fens / wetlands | All alternatives intersect dated wetland/fen polygons; peat function. | 6.04.01(17) | 406(C)(3); 307(F) | Will functions avoid significant degradation after conditions? | Deny if significant loss remains. | Read chapter · PDF p.29 |
| Groundwater | Groundwater-fed peat; excavation, dewatering and channel connections. | 6.04.01(16), (17), (20) | 406(C)(2)-(3) | Which sources, levels and functions would change? | Protect the supply sustaining peat and habitat. | Read chapter · PDF p.31 |
| Surface water / aquatic life | Matched annual accounts; seasonal flow, metals and food-web studies. | 6.04.01(15), (18) | 406(C)(1), (4) | What incremental quality and habitat change would occur? | Deny significant degradation left unresolved. | Read chapter · PDF p.35 |
| Wildlife / plants / soils | Historical records, observations, regional ecological studies. | 6.04.01(18)-(20) | 411-413 | Which communities/functions are exposed and replaceable? | Protect connected habitat and lasting peat function. | Read chapter · PDF p.38 |
| Recreation / scenery | Existing valley uses; modeled landscape and basin boating scenarios. | 6.04.01(11), (14) | 423; 431 | Would existing experience or visual quality significantly decline? | Evaluate existing experience and full operating levels. | Read chapter · PDF p.49 |
| Noise / infrastructure | Applicant pumping/conveyance; dam, roads, power and maintenance. | 6.04.01(21); 6.03.06 | 429; 425-426 | Will construction or operation cause an unresolved nuisance? | Review every connected component and operating phase. | Read chapter · PDF p.51 |
Evidence: S01 · S36 · S37. Full titles and pinpoints in the evidence register.
EXECUTIVE MATRIX · 2 OF 2
Decision roadmap, part 2
Chapter VI and the October 27 package set out different tests. The rule governing a Whitney filing depends on enactment, transition provisions and the filing record.
| Resource / issue | Key evidence | Chapter VI | October 27 package | Decision question | Save Homestake position | Detail |
|---|---|---|---|---|---|---|
| Necessity | Storage concepts and broader program objective; service-area demand. | 6.04.02(3) | Information: 303(D), 331(B); test omitted | Is Whitney necessary under reasonable service-area assumptions? | Chapter VI ties approval to demonstrated necessity. The October package requires demand information. | Read chapter · PDF p.55 |
| Efficient water use | Measured conservation/reuse plus practical additional savings. | 6.04.02(1) | 434(D); 331 materials | Does the project emphasize the most efficient water use? | Credit progress and quantify additional measures. | Read chapter · PDF p.57 |
| Dependable supply | Refill, dry years, senior rights, pumping and releases. | 6.04.01(5); 6.04.02(3) | 403; 409 | Are operation and promised deliveries feasible and dependable? | Deny if the governing feasibility or dependable-supply standard remains unmet. | Read chapter · PDF p.60 |
| County benefits / economy | Binding County benefits versus permanent resource/opportunity losses. | 6.04.01(24), (10), (9) | 422; no equivalent standalone (24) | Do County benefits outweigh County losses? | We support a separate, express County benefit-versus-loss test. | Read chapter · PDF p.62 |
| Cultural / historic | Protected landscape history; inventory needed for affected resources. | 6.04.01(22) | 424 | Which important areas would be significantly degraded? | Protect documented resources with meaningful Tribal participation. | Read chapter · PDF p.53 |
| Rights / public lands | Ownership, protected boundaries, approvals and water decrees. | 6.04.01(1); 6.01.05 | 404; 109 | Are all rights/approvals secured and standards met? | Oppose wilderness-boundary changes; enforce County protections. | Read chapter · PDF p.64 |
Evidence: S01 · S36. Full titles and pinpoints in the evidence register.
CLICKABLE CONTENTS
Find your way through the record
The executive matrix links each approval issue to its criterion chapter. These contents lead to the supporting systems, maps, studies and original records.
Decision rule and crosswalk
When a permit goes to the Board
Chapter VI names the Board as the permit authority (§6.01.07). Under §§6.03.10 and 6.04.01, the applicant bears the burden, and a permit cannot be approved while a criterion remains unmet. Colorado law also requires denial of a noncompliant activity (§24-65.1-501(4)).
In the October 27 package, §§211 and 401 place the burden on the applicant. The Board must deny a permit if any Article 4 standard fails. It may approve with conditions that bring the project into compliance with every standard. The separate exception and FONSI paths are explained on page 67.
| Protected interest | Chapter VI | October 27 package |
|---|---|---|
| Fens / wetlands | 6.04.01(17) | 406(C)(3); 307(F) |
| Groundwater | 6.04.01(16) | 406(C)(2) |
| Surface water / aquatic life | 6.04.01(15), (18) | 406(C)(1), (4) |
| Wildlife / plants | 6.04.01(18), (19) | 411; 412 |
| Recreation / local economy | 6.04.01(11), (10) | 423; 422 |
| County benefits exceed losses | 6.04.01(24) | No equivalent standalone test |
| Demonstrated necessity | 6.04.02(3) | Information required; test omitted |
| Efficient use / conservation | 6.04.02(1); 6.04.01(12) | 434(D); 331 materials |
| Feasibility / dependable supply | 6.04.01(5); 6.04.02(3) | 403; 409 |
| Nuisance / scenery | 6.04.01(21), (14) | 429; 431 |
| Historic / archaeological areas | 6.04.01(22) | 424 |
| Rights and approvals | 6.04.01(1) | 404 |
Chapter VI Appendix A supplies considerations for applying its criteria. The table pairs topics across both texts where the scope or wording differs.
Evidence: S01 · S36 · S06 · S37. Full titles and pinpoints in the evidence register.
COUNTY 1041 RULES · NOVEMBER 2, 2026
The October 27 decision
| Record | What it establishes |
|---|---|
| October 27 vote | The Board approved Attachment 1.2 with the changes in Attachment 1.1. Counsel expected to bring the enacting resolution to the next meeting or the following meeting when ready. |
| November 2 status | No separate enacting resolution, number, effective date, final enacted text or general transition provision was verified in the records reviewed through November 2. |
| November 3 agenda | LUR-009660-2026 is the scheduled general land-use rewrite. Its timetable is separate from the standalone 1041 rulemaking, LUR-009633-2026. |
What this means for Homestake
County review must reach the streams, groundwater, fens and downstream habitat that a reservoir and its operating system would change. Which set of rules applies to a particular filing depends on the final enactment and transition terms and the filing’s status.
Evidence: S35 · S36 · S37 · S38 · S39 · S40 · S41 · S42. Full titles and pinpoints in the evidence register.
The complete project
Whitney’s impact extends beyond the waterline
Colorado Springs Utilities’ March 2022 fact sheet describes gravity pipelines and tunnels carrying water from Peterson, Fall and Resolution Creeks to the proposed reservoir, followed by pumping to existing Homestake Reservoir (p. 1, S08). This collection scheme identifies Resolution Creek itself as a water source. It describes a connected water system with construction and operating effects beyond the reservoir shoreline.
The argument for denial
Inundation permanently converts habitat. Building and operating the supporting system adds clearing, excavation, road use, visible infrastructure and recurring activity. Those effects can reach wetlands outside the flood line, groundwater connections, wildlife movement and the places people come to enjoy. They belong in the same compliance findings as the reservoir itself.
The reservoir and the system needed to operate it
Chapter VI §6.03.06 calls for the project and impact record, including alternatives, construction and operation. The October 27 definitions (§109) include related facilities, storage and operations with new or increased impacts, and direct, indirect and cumulative land-use effects in the county.
How to read the maps
The original Save Homestake system map shows existing Homestake I’s USGS shoreline and tunnel beside Alternative D, the largest modeled Whitney option. Purple dashed connections show the three collection sources named in CSU’s March 2022 fact sheet: Fall, Peterson and Resolution Creeks. Rust dashes show an approximate valley pumping corridor, independently redrawn from the broad corridor in the 2019 utility draft. Stream circles are references, while intake sites and engineered alignments are unlocated. The amber callout identifies pumping power, with the electrical supply route unlocated. The alternative maps use the existing reservoir model and complete archived wetland inventories. They show the modeled dam embankment and mark likely downstream work locations with callouts. The component tables account for permanent access, pump-station and electrical effects together with the reservoir.
Evidence: S01 · S36 · S08 · S09 · S10 · S29 · S37. Full titles and pinpoints in the evidence register.
Original Save Homestake map · reservoirs, tunnels, pumping and power
Whitney would connect a wider water system

The original map shows Homestake I and its existing tunnel beside Whitney Alternative D’s modeled full pool with a 20,000 acre-foot storage target (S10). Purple dashes show one collection scheme: gravity pipelines and tunnels from Fall, Peterson and Resolution Creeks, as described by CSU in March 2022 (S08, p. 1). Rust dashes independently redraw an approximate valley pumping corridor using the 2019 utility draft as a broad spatial reference (S29). Connections and stream circles are approximate references; engineering alignments and intake sites are unlocated. The amber callout identifies pumping power, with the electrical supply route unlocated. These connected impacts belong in the County’s review together.
Evidence: S08 · S10 · S29. Full titles and pinpoints in the evidence register.
Construction footprint and retained works
Roads and downstream dam works
The 2019 applicant map locates the four alternative dam axes, Homestake Creek and the existing road (S09, Figure 1, technical p. 3 / PDF p. 11). The maps that follow show the modeled embankment and the downstream side where related work would occur. The effects below are anticipated construction pathways tied to those components.
| Component and basis | Likely construction effects | Continuing effects |
|---|---|---|
| Dam, foundations and downstream works Mapped alternative axes; modeled embankments. | Clearing and excavation; downstream toe, outlet/spillway work; temporary stream management; equipment access; sediment and groundwater disturbance. | Visible dam and outlet works; inspections, repair access and altered channel/flow conditions. |
| Homestake Road and work/service access Existing road mapped in S09. | Haul traffic, dust and equipment; new or relocated road cuts/fills where selected; potential wetland crossings and temporary access interruptions along affected routes. | Service vehicles; road/drainage upkeep; recurring access needs and any operating restrictions. |
| Staging, materials and excavated spoil Anticipated dam/conveyance work. | Laydown, stockpiles, material handling and runoff can disturb nearby wetlands and their groundwater connections. | Retained access or pads; reclamation performance; disturbance when repairs require renewed work areas. |
Chapter VI §6.04.01(11), (14) and (17)–(21) address recreation, scenery, wetlands, wildlife, plants, soils and nuisance. In the October 27 package, §§406, 411–413, 423, 429–432 address those effects, and §§425–426 cover traffic and road costs. The 2019 drawings depict temporary investigation access.
Evidence: S01 · S36 · S09 · S27. Full titles and pinpoints in the evidence register.
The operating system
Pumping, power and maintenance count
Pumping and water conveyance are explicit in CSU’s description (S08, p. 1). Energy supply, service access and maintenance are necessary to operate that system. Their anticipated effects must be assessed through the selected equipment and layout.
| Component and basis | Construction effects | Operation and maintenance |
|---|---|---|
| Pump facilities Uphill pumping described by CSU. | Foundation/pad, pipe connections, equipment installation, access and energy supply. | Pump/motor and ventilation noise; vibration; visible buildings, lighting and equipment; service trips, inspections and equipment replacement. |
| Pipelines and tunnels CSU description and draft conveyance map. | Trenching or tunnel excavation; portals/shafts where selected; spoil handling; crossings and potential groundwater interception. | Visible portals/valves; inspection access; leak repairs and replacement work that can reopen disturbed ground. |
| Electrical supply and controls Engineering requirement of pumping. | Selected cable/line corridor and equipment pads; installation access and crossings, with poles or generation where proposed. | Equipment appearance, transformer/fan sound where relevant, lighting, testing and servicing; corridor vegetation management where needed. |
Why the operating period matters
Initial construction is only one period of disturbance. Repeated service access, equipment operation, corridor work and repairs can recur over the project’s life. Quiet recreation, wildlife movement, views and property enjoyment must be assessed against that continuing activity.
Evidence: S01 · S36 · S08 · S09 · S29. Full titles and pinpoints in the evidence register.
MEASURED DATA + SAVE HOMESTAKE CALCULATION
More water exported than passing Gold Park
Over water years 2007-2024, more recorded water left through Homestake Tunnel than passed the creek gauge near Gold Park Campground. Gold Park lies below the existing reservoir and all five collection sites.
- Average recorded Homestake Tunnel export · AF / YEAR
- 23,371
- Average recorded passing Gold Park · AF / YEAR
- 21,498
The denominator is explicit
Tunnel export ÷ (Tunnel export + Gold Park flow). Gold Park gauges a 35.6-square-mile drainage. This is a comparison across two recorded routes, not a verified percentage of all natural Homestake runoff.
| WY2007-2024 route | Total recorded volume | Share of these routes |
|---|---|---|
| Homestake Tunnel | 420,676.93 AF | 52.09% |
| Passing Gold Park | 386,968.01 AF | 47.91% |
| Two-route sum | 807,644.94 AF | 100.00% |
Whitney would add a reservoir and collection works to a system already exporting more recorded water than passed Gold Park during these 18 years.
Evidence: HWA:S-GP-ANNUAL · HWA:S-USGS-GP · HWA:S-TUNNEL · HWA:S-REPORT. Full titles and pinpoints in the evidence register.
REPRODUCIBLE WATER ACCOUNTING
The arithmetic and its boundaries
We compared water recorded through Homestake Tunnel with water recorded passing Gold Park over the same 18 water years. The share tells us how those two routes divide their combined recorded volume. We then made a separate 14-year basin check that starts with mapped precipitation and accounts for the two routes and changes in reservoir storage. The calculations and their different boundaries follow.
A matched 14-year basin closure, kept separate
The WY2007-WY2020 closure uses the same Gold Park polygon, current 800-m PRISM precipitation, tunnel export and Gold Park flow. It corrects signed reservoir storage, then tests atmospheric processes without treating literature transfers as observations. The 18-year two-route comparison remains a different calculation.
Red Cliff: a different question
The Red Cliff comparison is approximately 43% across two measured paths during WY2007-2011. Red Cliff has a larger downstream drainage and a shorter period, with additional downstream contributions. Its result is a separate comparison, not the low end of an uncertainty range around Gold Park.
Five intakes: collection within the system
| Collector | Recorded average capture, WY2014-2024 |
|---|---|
| French | ~3,531 AF/year |
| Fancy | ~1,780 AF/year |
| Missouri | ~1,743 AF/year |
| Sopris | ~2,486 AF/year |
| East Fork | ~3,610 AF/year |
| Combined record | ~13,149 AF/year |
The combined mean is calculated from the unrounded collector records. The five displayed rounded means sum to 13,150 AF/year. Collector water overlaps later reservoir/Tunnel accounting and is never added to Tunnel export as another withdrawal.
Evidence: HWA:S-GP-ANNUAL · HWA:S-RESERVOIR · HWA:S-REDCLIFF · HWA:S-COLLECTORS · HWA:S-RAW · HWA:S-PRISM-800M · HWA:S-STAGEVOLUME · HWA:S-CLOSURE-LEDGER. Full titles and pinpoints in the evidence register.
MATCHED WY2007-2020 CLOSURE LEDGER
What the basin balance can account for
Across the matched 14-year period, 800-m PRISM precipitation averages 61,496 AF/year. Recorded tunnel export averages 23,345 AF/year and Gold Park discharge averages 23,341 AF/year, leaving 14,810 AF/year before storage. Homestake Reservoir drawdown adds 45.9 AF/year to closure, producing a 14,856-AF/year storage-adjusted remainder.
| Ledger term | AF/year | Evidence treatment |
|---|---|---|
| Total precipitation | 61,496 | PRISM 800-m modeled input; rain + snow water equivalent |
| Tunnel export to Turquoise | 23,345 | DWR class 13704614, counted once |
| Passing Gold Park | 23,341 | USGS daily discharge integration |
| Gross remainder | 14,810 | P − export − Gold Park Q |
| Homestake Reservoir ΔS | −45.9 | Mean drawdown; signed storage correction |
| Snow sublimation estimate | 7,068-9,402 | 15-20% of terrestrial Oct-May precipitation |
| Gross reservoir evaporation | 812-971 | Alternative fixed-area estimate |
| Mapped-fen partial-season ET | 55-191 | High Creek analogue over 165.324 acres |
| Still unassigned | 4,292-6,921 | ET, storage, groundwater boundary flow and error remain open |
Evidence: HWA:S-PRISM-800M · HWA:S-TUNNEL · HWA:S-USGS-GP · HWA:S-STAGEVOLUME · HWA:S-CLOSURE-LEDGER. Full titles and pinpoints in the evidence register.
WATER-ACCOUNTING VISUAL
Recorded routes, estimated return to air and what remains

The historical September 24 chart uses the normal-year 247-353 mm fen range. The current calculation uses 101-353 mm, including drought: snow, reservoir and fen estimates total about 7,900-10,600 AF/year, leaving 4,292-6,921 AF/year for other plant use, storage, groundwater movement and input uncertainty.
Evidence: HWA:S-CLOSURE-LEDGER · HWA:S-SNOW-SUB · HWA:S-FEN-ET. Full titles and pinpoints in the evidence register.
SIGNED ANNUAL LEDGER / ACRE-FEET
The annual balance changes with storage
| WY | Total P | Tunnel | Gold Park | P−E−Q | Reservoir ΔS | After ΔS |
|---|---|---|---|---|---|---|
| 2007 | 66,447.7 | 20,792.6 | 18,304.4 | 27,350.7 | +1,159.7 | 26,191.0 |
| 2008 | 70,570.3 | 26,533.1 | 34,210.3 | 9,826.9 | −399.4 | 10,226.2 |
| 2009 | 66,406.5 | 51,353.4 | 20,225.2 | −5,172.0 | −20,630.1 | 15,458.2 |
| 2010 | 57,860.0 | 9,023.6 | 16,328.4 | 32,508.0 | +15,909.4 | 16,598.7 |
| 2011 | 75,777.8 | 32,240.0 | 34,149.6 | 9,388.2 | +2,403.1 | 6,985.1 |
| 2012 | 43,862.4 | 42,101.7 | 20,098.7 | −18,338.0 | −39,421.2 | 21,083.2 |
| 2013 | 62,406.7 | 19,125.0 | 17,134.1 | 26,147.5 | +645.3 | 25,502.2 |
| 2014 | 65,617.3 | 16,545.6 | 23,303.8 | 25,767.9 | NA | NA |
| 2015 | 61,732.8 | 4,184.5 | 25,338.7 | 32,209.5 | NA | NA |
| 2016 | 62,496.7 | 4,618.0 | 35,220.3 | 22,658.4 | NA | NA |
| 2017 | 61,062.2 | 23,018.5 | 26,950.9 | 11,092.8 | −16.7 | 11,109.5 |
| 2018 | 46,945.2 | 20,346.4 | 9,909.0 | 16,689.8 | −1,024.6 | 17,714.4 |
| 2019 | 68,062.8 | 34,060.2 | 30,673.7 | 3,329.0 | +111.2 | 3,217.8 |
| 2020 | 51,698.3 | 22,885.3 | 14,931.3 | 13,881.7 | −763.8 | 14,645.5 |
Evidence: HWA:S-PRISM-800M · HWA:S-TUNNEL · HWA:S-USGS-GP · HWA:S-STAGEVOLUME · HWA:S-CLOSURE-LEDGER. Full titles and pinpoints in the evidence register.
PROCESS ACCOUNTING WITHOUT DOUBLE COUNTING
What is recorded, estimated or still unknown
| Process | Current value | Responsible accounting treatment |
|---|---|---|
| Snow sublimation | 7,068-9,402 AF/yr estimate | 15-20% of terrestrial Oct-May P; regional 28% remains a sensitivity, not a basin estimate. |
| Reservoir evaporation | 812-971 AF/yr estimate | Fixed-area gross physical scenarios. DWR's 238-AF/yr administrative account is comparison-only. |
| Fen ecosystem ET | 55-191 AF/yr estimate | Partial season; already includes plant, soil and wet-surface vapor flux over mapped fen acres. |
| Plant transpiration | Unresolved | A 2,575-4,153 AF/yr value is only a 60% conditional closure ceiling if all remainder were land ET. |
| Soil + wet-canopy evaporation | Unresolved | A 1,717-2,768 AF/yr value is only the complementary 40% ceiling; soil-only flux is not isolated. |
| Fen/wetland storage ΔS | Unmeasured signed term | Sensitivity: 16.53 AF per 0.1 ft over mapped fens; 33.21 AF over vegetated wetlands. |
| Groundwater/aquifer | Unmeasured signed terms | Recharge and return baseflow are internal. Net boundary flow and annual aquifer ΔS lack a basin time series. |
| Diversion-pond storage ΔS | Not measured | No feeder-intake stage-volume series or separate basin pond record was identified. No volume is assigned. |
Evidence: HWA:S-SNOW-SUB · HWA:S-SNOW-FIELD · HWA:S-SNOW-SURFACE · HWA:S-FEN-ET · HWA:S-GROUNDWATER · HWA:S-CLOSURE-LEDGER. Full titles and pinpoints in the evidence register.
OPERATING RULES AND BIOLOGICAL CONDITIONS
No single flow number defines ecological safety
The existing project must bypass 24 cfs or natural inflow, whichever is less, at Gold Park while diverting. That is a conditional operating rule, not a site-calibrated sufficiency threshold for trout, wetlands or fens.
| Benchmark | What the evidence supports | Boundary of inference |
|---|---|---|
| Gold Park 24 cfs | Daily means were below 24 cfs on 4,554 of 6,575 days in WY2007-WY2024, including naturally low winter days. | The 24 cfs bypass requirement applies during diversion, or natural inflow if lower. |
| Seasonal proximity | Below 24 cfs on 3.55% of May-June days, 22.58% of July days and 75.68% of August-September days. | The operating number is conditional on natural inflow and is not a habitat curve. |
| Trout habitat | CWCB R2Cross evaluates reach-specific depth, velocity and wetted perimeter; temperature, oxygen, cover and life stage also matter. | There is no universal Gold Park cfs minimum for all trout habitat. |
| Fen condition | CNHP associates peat accumulation with saturation or a water table within about 30 cm of the surface through July and August. | A local water-table depth cannot be converted directly from annual Gold Park discharge. |
Evidence: HWA:S-BYPASS · HWA:S-USGS-GP · HWA:S-R2CROSS · HWF:S28. Full titles and pinpoints in the evidence register.
CONNECTED SYSTEM + SCIENTIFIC INFERENCE
Water timing is habitat
Snow and rain enter headwater streams and groundwater. Seasonal water sustains fens, wet meadows, willow, beaver complexes and aquatic habitat, then moves through lower Homestake Creek toward the Eagle River. These pathways connect the water account with the living resources under review.
Connected hydrology: snow and rain → streams and groundwater → fen, meadow and willow → beaver and aquatic habitat → lower Homestake Creek and the Eagle River.
Existing collection branch: tributary intakes → Homestake Reservoir → Homestake Tunnel export.
Local records and regional mechanisms
Local evidence includes mapped wetlands, field observations and historical upper-Homestake toad breeding and trout documentation. Colorado studies show streamside vegetation shifts below diversions, slower groundwater decline around monitored beaver dams and persistent altered peat properties after drainage. Those results explain how stream flow, groundwater and peat sustain the living landscape.
The exact Gold Park basin clip contains 165.324 acres mapped as confirmed or potential fen and 332.104 acres of vegetated or other NWI wetlands. Those overlapping inventories are not additive. Groundwater-supported peat and wetland complexes regulate local storage, cold-water pathways and late-season habitat.
The relevant comparison is seasonal: spring inundation and recharge, breeding-water duration, summer groundwater and cold-water refuge, plus food transported by flowing water. Annual volumes establish scale; hydrographs and groundwater records connect operation to ecological function.
The approval question
Chapter VI §6.04.01(15)–(20) links surface water, groundwater, wetlands, animals, plants and soils. In the October 27 package, §§307 and 406 bring flow timing, groundwater, wetland functions and aquatic habitat into the same watershed assessment.
Evidence: HWA:S-GP-ANNUAL · HWF:V3-17 · HWF:S31 · HWF:S12 · HWF:V3-07 · HWF:V3-21 · HWA:S-FEN-MAP · HWA:S-WETLAND-MAP · HWA:S-FEN-ET · HWA:S-BYPASS · HWA:S-R2CROSS · HWF:S28 · S36. Full titles and pinpoints in the evidence register.
WHAT IS KNOWN / WHAT MUST BE RESOLVED
What remains unresolved about Whitney supply
Whitney-only dependable yield
Known: CSU describes Whitney storage concepts of 6,850-20,000 AF. The broader Eagle River Joint Use project objective is up to 20,000 AF/year for the East Slope. Storage and annual supply are different quantities, and the broader objective is not Whitney-only annual yield.
| Unresolved quantity or design | Why it matters |
|---|---|
| Whitney-only annual and dry-year yield | Whitney-specific dependable delivery is necessary to interpret necessity, feasibility and alternatives. |
| Initial fill, refill and source collection | Source tributaries, diversion timing and operating levels affect local water and habitat. |
| Evaporation, storage change and bypasses | These terms affect the physical balance and downstream water availability. |
| Pumping, power and conveyance limits | Power and conveyance constraints affect reliability, energy use, noise and cost. |
| Selected footprint and complete works | The selected design determines the actual component footprint and its effects. |
Why the record matters: the County can compare the reliable supply actually delivered with conservation, reuse and alternative portfolios only when the same period, reliability standard, legal availability and losses are used.
Evidence: S08 · HWA:S-REPORT · S01. Full titles and pinpoints in the evidence register.
Four modeled reservoir alternatives
Mapped wetlands and potential fens in modeled flood zones
The archived inventory overlay places about 81.4 acres of mapped wetlands and potential fens inside the shared area of all four displayed flood zones. Alternatives A and D intersect four potential-fen polygons; B and C intersect two. These are inventory-model intersections using the dated older CNHP service; the source-version question is detailed on the next page.
| Alternative | Wetland polygons | Potential-fen polygons | Wetland + fen overlap¹ |
|---|---|---|---|
| A | 29 | 4 | 127.4 acres |
| B | 19 | 2 | 85.4 acres |
| C | 21 | 2 | 94.9 acres |
| D | 38 | 4 | 134.8 acres |
The wider Whitney-to-Eagle assessment maps 362.1 acres in 36 wetland complexes connected to Homestake Creek, extending to the Eagle River confluence near Red Cliff.
¹ Modeled intersection with the union of mapped wetland and potential-fen polygons, with overlapping areas counted once. Pond, river/stream and lake inventory polygons appear for context and are not added to this acreage. Values describe the existing full reservoir presets.
What the maps show
Each map shows the same extent and scale: modeled flood zone; mapped wetlands; CNHP potential fens; mapped ponds, streams and lakes; existing Homestake Road; and the modeled dam embankment. Orange downstream arrows identify the likely toe/outlet/access work vicinity. Work-area boundaries depend on the selected construction design.
Inventory classifications and coverage
All positive-area intersections were checked against the complete September 18 exports: 2,979 CNHP Colorado Wetlands features and 600 Fen Mapping features covering the model area. The four intersecting fen IDs, 3033, 3045, 5490 and 5491, are classified Potential Fen. IDs 3045 and 5491 intersect all four alternatives. Campaign field photographs and observations provide the separate local habitat record.
Method and significance
The overlay intersects the existing 10 m terrain solver’s water-surface triangles with inventory polygons in UTM Zone 13N. These are modeled inventory-area estimates. The per-feature register lists every intersecting ID and modeled area (S31).
Evidence: S11 · S26 · S30 · S31 · S34. Full titles and pinpoints in the evidence register.
FIELD-CONFIRMED FENS + MAPPED INVENTORY
Homestake’s fens and their mapped inventory
CNHP field-confirmed two Gold Park-area fens on September 12, 2011. Site 6982 had 92 cm of peat; site 6969 had 88 cm. Both had saturated peat, groundwater inflow from adjacent slopes and wetland plant communities, with no disturbance or noxious weeds recorded. These observations document healthy, functioning groundwater-fed fen habitat at the surveyed sites in 2011. CNHP 2011, printed pp.92–99 (HWF:FEN-2011-S01).
CNHP’s Fens2025V2 inventory, retrieved October 10, 2026, maps the following features across the complete Homestake Creek watershed.
- Current V2 inventory · Homestake watershed · CONFIRMED FEN POLYGONS
- 15
- Current V2 inventory · Homestake watershed · POTENTIAL FEN POLYGONS
- 160
Current inventory and modeled pools
The October 10, 2026 comparison found 0 current V2 fen polygons and 0 square metres of fen area intersecting each of the four stored A–D modeled full-pool boundaries. Mapped wetlands still overlap the pools (HWF:FEN-MAP-ANALYSIS-S01).
Why the older overlap figures differ
The shared 81.4-acre wetland and potential-fen overlap and the reservoir-overlap maps use the September 18, 2026 inventory. Current V2 and that dated inventory have different mapped boundaries and classifications. The older Potential Fen polygons remain a separately labeled historical comparison; each overlap figure retains its dated source geometry.
Why the record matters
Homestake’s confirmed fens and connected wetlands are living resources worth protecting. Their groundwater supply and saturated peat sustain wetland plant communities, making those water sources part of the habitat that protection must preserve.
Evidence: HWF:FEN-2011-S01 · HWF:FEN-MAP-V2-S01 · HWF:FEN-MAP-ANALYSIS-S01 · S26 · S30 · S31. Full titles and pinpoints in the evidence register.
Modeled flood zone and downstream construction
Alternative A: wetlands and works

Evidence: S09 · S11 · S26 · S30. Full titles and pinpoints in the evidence register.
Modeled flood zone and downstream construction
Alternative B: wetlands and works

Evidence: S09 · S11 · S26 · S30. Full titles and pinpoints in the evidence register.
Modeled flood zone and downstream construction
Alternative C: wetlands and works

Evidence: S09 · S11 · S26 · S30. Full titles and pinpoints in the evidence register.
Modeled flood zone and downstream construction
Alternative D: wetlands and works

Evidence: S09 · S11 · S26 · S30. Full titles and pinpoints in the evidence register.
CRITERION RECORD · EVIDENCE
Wetlands and fens
1 / Resource or issue
Wetlands and fens within the complete construction and operating impact area.
2 / The Chapter VI criterion
§6.04.01(17): “The Project will not significantly degrade wetlands, and riparian areas.” [S01, PDF p.19].
Appendix A directs attention to structure and function, pollutant uptake, extent, species characteristics and diversity, and floodplain function.
Standards approved October 27
The October 27 revisions expressly include fens in “Waterbody” (§109). Section 307(F) addresses fen, wetland and riparian structure, function and hydrology. Section 406 requires compliance with the watershed plans and addresses significant deterioration of wetland functions, extent and vegetation.
3 / What the evidence shows
Whitney threatens Homestake’s fens and connected wetlands. The full inventory overlay shows mapped wetlands and areas classified Potential Fen in every modeled flood zone, including shared portions of potential-fen polygons 3045 and 5491. Campaign photographs and films document the living fen complex. Permanent inundation would replace peat-forming vegetation and groundwater-fed habitat with reservoir habitat. Federal wetland guidelines recognize permanent flooding as a mechanism of habitat destruction (S28).
EPA describes fens as groundwater-fed peat systems whose natural formation can take up to 10,000 years. Federal mitigation regulations expressly identify fens as difficult to replace. The protected value includes the functioning peat, water regime and biological community accumulated here over time.
A construction condition cannot preserve a fen beneath the modeled reservoir. Any compensation proposal must therefore be tested against the full functional loss and its duration, including failure risk. Counting replacement acres or surviving transplanted plants is not a functional equivalence analysis.
Evidence: S01 · S36 · S10 · S11 · S12 · S13 · S14 · S26 · S27 · S28 · S30 · S37. Full titles and pinpoints in the evidence register.
CRITERION RECORD · ANALYSIS + POSITION
Wetlands and fens: the decision
4 / What remains to be resolved
Seasonal wetland/fen delineation, groundwater dependence, peat profiles, functional assessment and the actual mitigation proposal.
5 / Why it matters to this approval standard
The standard protects wetland structure and function. Permanent inundation and interrupted groundwater change the living resource the criterion addresses. Replacement performance and the duration of lost function belong in the compliance finding.
6 / Save Homestake’s position
7 / What the Board must determine
Will the complete project significantly degrade wetland or riparian function after enforceable conditions?
8 / Evidence
Direct source links appear below. Original code, applicant and ecological exhibits are reproduced in the downloadable PDF dossier; the source register retains document pinpoints.
Evidence: S01 · S36 · S10 · S11 · S12 · S13 · S14 · S26 · S27 · S28 · S30. Full titles and pinpoints in the evidence register.
CRITERION RECORD · EVIDENCE
Groundwater and peat water supply
1 / Resource or issue
Groundwater and peat water supply within the complete construction and operating impact area.
2 / The Chapter VI criterion
§6.04.01(16): “The Project will not significantly degrade groundwater quality.” [S01, PDF p.19].
Section 6.04.01(16) protects groundwater quality. Appendix A expressly includes aquifer recharge rates, groundwater levels, aquifer capacity, aquifer-stream interfaces and well function. Apply this with the wetland standard in (17) and the soil/geology standard in (20).
Standards approved October 27
Section 406(C)(2) expressly covers recharge, groundwater levels and aquifer capacity, and protects the capacity, function and quality of wells. Section 406(C)(3) protects wetland function. The §307 assessment extends to peripheral and downstream surface and subsurface resources.
3 / What the evidence shows
Fens depend on sustained groundwater delivery and chemistry. The utility describes collection and pumping to existing Homestake Reservoir. Dam foundations, trenches, pipelines, access works and dewatering can intercept groundwater or change its connection to the creek and peat.
The flood maps identify direct inundation; the dam and downstream-work callouts identify additional construction exposure. Excavation, trenches and dewatering can interrupt the groundwater that sustains adjoining peatland, extending harm beyond the visible reservoir edge (S27, printed pp. 16 and 32).
Evidence: S01 · S36 · S08 · S09 · S12. Full titles and pinpoints in the evidence register.
CRITERION RECORD · ANALYSIS + POSITION
Groundwater and peat water supply: the decision
4 / What remains to be resolved
The applicant’s seasonal water levels, gradients, chemistry, dewatering assumptions and connected surface/subsurface model.
5 / Why it matters to this approval standard
Groundwater sustains the peat, vegetation and creek relationships protected by the groundwater, wetland and soil criteria. Loss of that connection changes the resource itself, beyond any loss of surface acreage.
6 / Save Homestake’s position
7 / What the Board must determine
Which groundwater-quality and connected wetland changes remain under the selected design and operating plan?
Under October 27 §406(A), the project must comply with the watershed plans in §307. Monitoring thresholds and responses matter to the groundwater supply that keeps peat wet.
8 / Evidence
Direct source links appear below. Original code, applicant and ecological exhibits are reproduced in the downloadable PDF dossier; the source register retains document pinpoints.
Evidence: S01 · S36 · S08 · S09 · S12. Full titles and pinpoints in the evidence register.
Whitney, Blodgett and Hornsilver to the Eagle River confluence
Downstream wetlands at risk

The complete map follows Homestake Creek through the Blodgett reach, past Hornsilver Campground and to its Eagle River confluence near Red Cliff. Connected wetlands along the full corridor belong in the downstream impact argument.
The inventory follows whole wetland and pond complexes linked to Homestake Creek. Beaver ponds, side channels and shared shallow groundwater carry the creek’s influence across the valley floor. Lower creek levels can also increase drainage from adjoining wetlands supplied partly by springs or seasonal creeks. Across the Whitney-to-Eagle assessment, 36 linked complexes contain 362.1 unique acres of mapped wetland and potential-fen habitat. One 49.2-acre complex crosses the upstream assessment endpoint and is retained whole. The lower reach from Blodgett to the Eagle River confluence contains 137.0 of those acres. These are mapped habitat acres; drying varies with flow, pond levels and groundwater.
Evidence: S26 · S30 · S34. Full titles and pinpoints in the evidence register.
Downstream wetlands and the case for denial
Downstream water supports connected habitat
Reduced flows can lower shallow water tables and shorten the periods when the creek replenishes connected wetlands and side channels. That can leave wetland soils drier, stress willows and other water-dependent vegetation, and shrink the wet habitat that supports wildlife. The timing matters: capturing spring runoff and reducing water during dry periods can harm different parts of the same system.
Fens depend on sustained groundwater that keeps their peat saturated. Where altered creek levels or construction disrupt that supply, wetland plants can change and exposed peat can decompose, releasing stored carbon. Protecting a fen means protecting the water that keeps it alive, including the connections outside its mapped boundary.
Chapter VI and October 27 protections
Chapter VI §6.04.01(15)–(18) and Appendix A address water quality, aquifer-stream relationships, wetlands and aquatic habitat. October 27 §307 reaches peripheral and downstream surface and subsurface resources. Section 406 applies the watershed, groundwater, wetland and aquatic-habitat standards.
Reduced water and lost willow can constrain beaver shelter, forage, movement and dam maintenance. Less beaver activity can then weaken water retention and connected wetland habitat. This reinforcing risk extends beyond the inundation boundary through actual water connections (HWF:BEAVER-HABITAT; HWF:S12; HWF:BEAVER-FEN).
Evidence: S01 · S36 · S27 · S32 · S33 · S34 · HWF:BEAVER-HABITAT · HWF:S12 · HWF:BEAVER-FEN. Full titles and pinpoints in the evidence register.
CRITERION RECORD · EVIDENCE
Surface water and aquatic habitat
1 / Resource or issue
Surface water and aquatic habitat within the complete construction and operating impact area.
2 / The Chapter VI criterion
§6.04.01(15): “The Project will not significantly degrade surface water quality.” [S01, PDF p.19].
Sections 6.04.01(15) and (18) protect surface-water quality and aquatic life/habitat. Appendix A specifically identifies flushing flows, mine-waste dilution, temperature, sediment, spawning habitat and aquatic food webs.
Standards approved October 27
Section 406(C)(1) protects flows, hydrology and water quality, including a requirement that pollutant concentrations not increase over baseline. Section 406(C)(4) protects aquatic life and habitat, including off-channel habitat, oxygen, flushing flows and spawning/egg-to-fry survival. Section 408 requires consistency with the identified water-quality and stream-management plans.
3 / What the evidence shows
Appendix K of the Community Water Plan models a mean May zinc-load reduction requirement of 140.6 kilograms at baseline versus 434.3 kilograms under New Water Infrastructure with historical hydrology. The corresponding additional dilution volume rises from 495.5 to 1,530.3 acre-feet. These are about 3.1 times baseline, holding historical metal loading fixed.
This combined scenario includes 2050 demand growth, a potential MOU infrastructure/operations pathway and Bolts Lake. The May values measure relative ecological risk and mitigation burden under changed flows; they are not additional zinc discharges, annual totals or a regulatory violation finding. The numerical exhibit gives the exact source rows and method.
Evaluate spring capture and seasonal releases separately. Tie enforceable flow and quality commitments to the affected reaches, dry-year conditions and thresholds. An average annual water balance cannot explain a seasonal water-quality failure.
Evidence: S01 · S36 · S15 · S17 · S18. Full titles and pinpoints in the evidence register.
CRITERION RECORD · ANALYSIS + POSITION
Surface water and aquatic habitat: the decision
4 / What remains to be resolved
Whitney-specific matched hydrographs, temperatures, concentrations, release commitments and aquatic responses.
5 / Why it matters to this approval standard
Flow timing affects dilution, temperature and habitat. A matched project/no-project analysis connects the proposed operation to the surface-water and aquatic-life standards.
6 / Save Homestake’s position
7 / What the Board must determine
Would incremental quality or habitat effects remain significant under the actual operating conditions?
8 / Evidence
Direct source links appear below. Original code, applicant and ecological exhibits are reproduced in the downloadable PDF dossier; the source register retains document pinpoints.
Evidence: S01 · S36 · S15 · S17 · S18. Full titles and pinpoints in the evidence register.
Original appendices checked September 20, 2026
Verified river-impact evidence
Whitewater opportunities • Appendix N §6, p. 22
| Reach | Dry years | Wet years |
|---|---|---|
| Tigiwon to Dowd Junction | 85% fewer days | 48% fewer days |
| Edwards to Eagle | 9% fewer days | 10% fewer days |
Published total whitewater boatable-day reductions: New Water Infrastructure with historical hydrology versus Baseline. The metric combines kayaking and rafting flow preferences. These percentages are the original analysts’ reported results.
Zinc • Appendix K Tables 12-13, pp. 21-22
| Mean May metric | Baseline | NWI-H |
|---|---|---|
| Load reduction to chronic rainbow-trout threshold | 140.6 kg | 434.3 kg |
| Additional discharge dilution gap | 495.5 acre-feet | 1,530.3 acre-feet |
Mean monthly totals for the 2009-2016 assessment, holding historical loading patterns fixed while varying flow. The source narrative p. 9 rounds these to 140→434 kg and 496→1,530 acre-feet. Both comparisons are about 3.1 times baseline. Quantitative climate-change projections were excluded from this metals calculation.
The scenario boundary • Appendix C pp. 9-11
The baseline represents the plan’s 2020 current conditions. NWI-H combines projected 2050 demand growth, one potential MOU infrastructure/operations pathway and Bolts Lake redevelopment under historical hydrology. These estimates describe the combined development scenario; a Whitney-only increment was not isolated.
Evidence: S15 · S16 · S17. Full titles and pinpoints in the evidence register.
CRITERION RECORD · EVIDENCE
Wildlife and habitat connectivity
1 / Resource or issue
Wildlife and habitat connectivity within the complete construction and operating impact area.
2 / The Chapter VI criterion
§6.04.01(18): “The Project will not significantly degrade terrestrial or aquatic animal life or its habitats.” [S01, PDF p.19].
Section 6.04.01(18) prohibits significant degradation of terrestrial or aquatic animal life or habitat. Appendix A names migration routes, seasonal range, calving, mating and nesting areas, threatened/endangered species, habitat features and food webs.
Standards approved October 27
October 27 §411 protects against significant deterioration of wildlife or habitat in the impact area and requires documentation of consultation with Colorado Parks and Wildlife. Section 310 covers baseline, impacts, mitigation and monitoring, including corridors and seasonal habitat. Section 406(C)(4) protects aquatic habitat.
3 / What the evidence shows
The 2019 applicant report identifies deer/elk winter range and potential sensitive-species habitat (Technical Report pp. 17-19). The campaign’s Valley Floor 1 archive documents repeated moose use of a creek-parallel route across seasons. Public photographs and films record wildlife in the wetland/forest mosaic at risk. Locations are generalized.
Save Homestake reports firsthand encounters with as many as four boreal toads in a single viewing. The assessment that this is uncommon comes from personal experience and Team Toad volunteering. These observations add a human field record of the wetland habitat at risk.
Reservoir inundation removes the existing terrestrial/wetland habitat. Roads, clearing, traffic, lighting and operation can add barriers and disturbance beyond the waterline. Habitat connectivity is itself a protected function.
Evidence: S01 · S36 · S10 · S11 · S09. Full titles and pinpoints in the evidence register.
LIDAR ADDENDUM 2.0 · SEPTEMBER 24, 2026
The modeled route climbs onto valley sides
For matched down-valley gates, native cumulative ascent rises from 73.2 m in current terrain to 191.6 m in A-C and 191.3 m in D. Primary overall terrain cost rises 1.205% for A-C and 4.422% for D.

The same gates define current and reservoir comparisons. Native cumulative ascent sums uphill travel; relative terrain cost combines distance and grade. All 200 tested paths connect.
The +5% common-budget route-opportunity losses for A-D are 47.66%, 44.83%, 44.34% and 73.42%. At +10% they are 23.76%, 14.06%, 15.67% and 26.92%; at +20%, 12.21%, 7.19%, 7.95% and 14.92%. This is computational routing area, not measured habitat acreage.
Evidence: MODEL:LIDAR-2026-09-24 · S01. Full titles and pinpoints in the evidence register.
CRITERION RECORD · ANALYSIS + POSITION
Wildlife and habitat connectivity: the decision
4 / The supported habitat record
The dated local observations, historical breeding records, habitat context and modeled passage conditions support protection of the valley’s living network.
5 / Why it matters to this approval standard
A connected habitat supplies breeding sites, movement routes and seasonal resources. The criterion reaches those functions as well as observed animals.
6 / Save Homestake’s position
7 / What the Board must determine
Which protected habitat functions would be lost, fragmented or significantly degraded, and what remains after mitigation?
The Board’s substantive compliance finding concerns protected wildlife and habitat. CPW consultation contributes agency expertise. Public records generalize sensitive species locations.
8 / Evidence
Direct source links appear below. Original code, applicant and ecological exhibits are reproduced in the downloadable PDF dossier; the source register retains document pinpoints.
Evidence: S01 · S36 · S10 · S11 · S09. Full titles and pinpoints in the evidence register.
FIELD RECORDS + SCREENED OCCURRENCES
A growing local biological record
- Community observations as of September 23, 2026 · OBSERVATIONS
- 1,400
- Within 229 terminal taxonomic concepts · SPECIES-RANK CONCEPTS
- 190
The September 23, 2026 snapshot contains 1,400 observations assigned to 229 terminal taxonomic concepts, including 190 species-rank concepts. Quality grades: 618 Research Grade, 778 Needs ID and four Casual.
Additional historical and locality records
An additional 233 historical and locality records include 129 eBird-derived observations and 103 specimen records. Each record includes its source, date and reported location.
Historical upper-Homestake evidence
CNHP’s 2000 survey documents boreal-toad breeding and Colorado River cutthroat trout in upper Homestake tributaries (printed p.159 / PDF p.162). CPW’s 2006-2007 monitoring adds pond drying and recruitment uncertainty (printed p.36). The records connect seasonal water persistence with the valley’s breeding and cold-water habitat.
Summer moose habitat stays close to water
Abouelezz and Hobbs studied 21 adult moose and 1,672 summer GPS locations in and near Rocky Mountain National Park during 2017-2018. About 90% were within approximately 285 m of mapped flowing or standing water; the mean was approximately 110 m. This is regional ecological evidence from that population, season and method.
Evidence: HWF:REGISTRY · HWF:V3-17 · HWF:V3-24 · HWF:V3-01. Full titles and pinpoints in the evidence register.
GOVERNMENT RECORD + FIELD RECORD
Lynx: status, habitat and local record
The Canada lynx in the contiguous United States is federally threatened and is listed as endangered by Colorado. A final federal critical-habitat revision became effective August 17, 2026. Its Southern Rockies Unit 6 includes designated areas in Colorado, including portions of Eagle County.
Final rule and geography
The rule was published July 16, 2026 at 91 FR 43732, with an August 17 effective date. Unit 6 geography appears at printed p.43771 / PDF p.40; the regional map follows on p.43772 / PDF p.41. The governing boundaries include textual exclusions as well as mapped designation.
The separate local record
The Save Homestake photo archive identifies a Canada lynx photographed down valley near the Blodgett reservoir option on April 2, 2017. The date and locality are supplied by the campaign archive; the photographer is not identified in the archive.
Habitat and exposure
The archive photograph, regional habitat designation and modeled reservoir exposure describe different parts of the case. Forest cover and connected prey habitat give the valley’s wildlife protection practical meaning.
Evidence: HWF:S22 · HWF:S39 · FED-ECFR-17.11-LYNX · S10 · S01. Full titles and pinpoints in the evidence register.
Ecology exhibit · September 23, 2026
The connected wetland mosaic
CNHP's 2000 Eagle County survey documents boreal-toad breeding and a Colorado River cutthroat trout population in the upper Homestake tributaries. These historical records give amphibian breeding habitat and cold-water streams a documented place in the valley's conservation case.
Historical source: CNHP 2000, printed p.159 / PDF p.162 (HWF:V3-C003/004). CPW 2006-2007 monitoring, printed p.36, adds a record of pond drying and recruitment uncertainty. These findings concern the historical upper-tributary sites.
Homestake's fens, wet meadows, willow corridors, beaver ponds and streams sustain different parts of a living valley. The water connecting them matters through spring runoff, summer low flows and drought. Colorado field studies document changes to streamside vegetation below diversions and lasting damage to drained peat. Protecting Homestake means protecting the seasonal water and connected habitats that keep it alive.
Public locations are generalized to protect sensitive habitat.
Beaver-supported ponds, willow and wet ground supply amphibian breeding water, bird cover, aquatic-insect production, fish refuge and wetland forage. Loss of water or vegetation can constrain beavers and then further weaken those functions. Fens retain their groundwater-fed peat character; connected dams can influence their water regime (HWF:S12; HWF:BEAVER-FEN). The species evidence comes from regional studies and agency habitat accounts (HWF:V4-01; HWF:V3-19; HWF:V3-18; HWF:BEAVER-FISH; HWF:S04).
Evidence: HWF:V3-17 · HWF:V3-24 · S01 · S36 · HWF:S12 · HWF:BEAVER-FEN · HWF:V4-01 · HWF:S06 · HWF:V3-19 · HWF:V3-18 · HWF:BEAVER-FISH · HWF:S04. Full titles and pinpoints in the evidence register.
Ecology exhibit · September 24, 2026; beaver update October 5, 2026
Water, peat and the habitat they sustain
Colorado: channels, peat and beaver water
HWF:V3-ST02, Caskey et al.: 37 north-central Colorado reaches, including 16 pairs. Diversion reaches had smaller channel dimensions and vegetation shifts toward drier-site species (Methods; Table IV; pp.592-594).
HWF:V3-ST04, Schimelpfenig et al.: four restored Colorado fens. Summer water tables rose after ditch blocking, while disturbed surface peat still differed from reference peat at the site restored 20 years earlier (abstract, Table 1 and Results).
HWF:V3-ST03, Westbrook et al.: monitoring two dams in Rocky Mountain National Park found slower seasonal groundwater decline over 9 and 12 hectares, respectively. These measured areas describe the groundwater response at the two study dams (USGS abstract).
North Saint Vrain Creek: water-level and temperature records indicated a side-channel connection during June-July 2015 while an off-channel pond stayed relatively stable through October (Wegener et al. 2017, HWF:BEAVER-SAINTVRAIN). East River: a main-channel dam was built in exceptionally low-water summer 2018 (Dewey et al. 2022, HWF:BEAVER-EASTRIVER).
Wildlife and food
HWF:V3-ST01, Abouelezz and Hobbs: 21 adults, 1,672 summer GPS locations in and near Rocky Mountain National Park, 2017-2018. About 90% were within 285 metres of mapped flowing or standing water (Methods; Table 1).
HWF:V3-ST11, Rhoades et al.: upper Shasta River, California, wet 2019. Late-season drifting prey approached zero below one diversion while streambed biomass could be higher.
Evidence: HWF:S31 · HWF:V3-07 · HWF:S12 · HWF:V3-01 · HWF:V3-21 · HWF:BEAVER-SAINTVRAIN · HWF:BEAVER-EASTRIVER · HWF:BEAVER-GUIDE · HWF:BEAVER-HABITAT. Full titles and pinpoints in the evidence register.
Ecology evidence · November 2 legal comparison
Water and wetland criteria
Chapter VI §6.04.01 and Appendix A, pp. iv–vi. Appendix A helps interpret the approval criteria.
§6.04.01(15) · Surface water
Decision relevance: Magnitude, timing and duration of additional water-quality and channel change. Evidence: HWF:V3-ST02, HWF:V3-ST11, HWF:V3-C011.
§6.04.01(16) · Groundwater
Decision relevance: Which sites depend on the changed source, with the size and duration of water-level changes. Evidence: HWF:V3-ST03, HWF:V3-ST04, HWF:V3-PW01, HWF:V3-PW05.
§6.04.01(17) · Wetlands and riparian areas
Decision relevance: Direct and indirect functional loss, avoidance and duration of any replacement deficit. Evidence: HWF:V3-ST02, HWF:V3-ST03, HWF:V3-ST04, HWF:V3-ST05.
October 27 §§307(C)–(G) and 406(C)(1)–(4) connect flow, water quality, groundwater, wetlands and aquatic habitat. Section 307(E) addresses groundwater and §307(F) addresses fens and riparian areas. The revised §109 definition expressly names fens.
Evidence: S01 · S36 · HWF:S31 · HWF:V3-21 · HWF:V3-42 · HWF:S12 · HWF:V3-07 · HWF:S28 · HWF:S03 · HWF:V3-02 · HWF:V3-06 · S37. Full titles and pinpoints in the evidence register.
Ecology evidence · November 2 legal comparison
Habitat, plants and soils criteria
Chapter VI §6.04.01 and Appendix A, pp. iv–vi. Appendix A helps interpret the approval criteria.
§6.04.01(18) · Animals and habitat
Decision relevance: Exposure and effects on the documented habitat, breeding, connectivity and food-web functions. Evidence: HWF:V3-C003, HWF:V3-C004, HWF:V3-ST06, HWF:V3-ST08, HWF:V3-ST11.
§6.04.01(19) · Plants and habitat
Decision relevance: Affected communities and expected composition, structure and productivity changes. Evidence: HWF:V3-C007, HWF:V3-ST02, HWF:V3-ST05.
§6.04.01(20) · Soils and geology
Decision relevance: Residual peat/soil loss and the credibility of replacement performance. Evidence: HWF:V3-ST04, HWF:V3-PW01.
In the October 27 package, §§307(G), 310, 406(C)(4) and 411 address animals and habitat. Sections 311 and 412 cover terrestrial plant communities, and §413 addresses soils and geology.
Evidence: S01 · S36 · HWF:V3-17 · HWF:V3-24 · HWF:V3-04 · HWF:V3-05 · HWF:S11 · HWF:S34 · HWF:V3-18 · HWF:V3-21 · HWF:V3-34 · HWF:S31 · HWF:V3-06 · HWF:V3-07 · HWF:S28 · HWF:S03. Full titles and pinpoints in the evidence register.
CRITERION RECORD · EVIDENCE
Plants, peat and soils
1 / Resource or issue
Plants, peat and soils within the complete construction and operating impact area.
2 / The Chapter VI criterion
§6.04.01(19): “The Project will not significantly deteriorate terrestrial plant life or plant habitat.” [S01, PDF p.19]. Read (19) with (20): “The Project will not significantly deteriorate soils and geologic conditions.”
Section 6.04.01(19) protects terrestrial plant life and habitat from significant deterioration. Appendix A includes vegetation structure, function, species composition, diversity, biomass and productivity. Section (20) separately protects soils and geologic conditions.
Standards approved October 27
Section 412 protects terrestrial plant communities. Sections 311 and 413 address vegetation evidence and soil/geologic protection; §432 governs revegetation and invasive species. Fen vegetation also falls within the watershed and wetland analysis.
3 / What the evidence shows
The applicant’s 2019 report describes forest, meadows and wetlands (p. 21). Campaign photographs and modeling show conversion of living fen vegetation to open water and reservoir shore. Its peat-forming plants, substrate and groundwater regime function together; flooding changes that system even if plants grow elsewhere.
The 1994 Homestake II decision records competent evidence of predicted wetland degradation and ineffective mitigation threatening rare moss in that earlier project. It demonstrates the legal importance of specific botanical evidence. Whitney’s findings should identify the plant communities and functions documented within its own impact area.
Evidence: S01 · S36 · S07 · S10 · S11 · S12 · S09. Full titles and pinpoints in the evidence register.
CRITERION RECORD · ANALYSIS + POSITION
Plants, peat and soils: the decision
4 / What remains to be resolved
Botanical community plots, peat and soil profiles, complete impact footprint and demonstrated recovery functions.
5 / Why it matters to this approval standard
Plant composition, peat structure and hydrologic support operate together. The protected resource includes the existing community and the time needed to recover its function.
6 / Save Homestake’s position
7 / What the Board must determine
Would plant habitat or peat/soil condition significantly deteriorate after enforceable conditions?
A revegetation plan for temporarily disturbed ground addresses a different impact from permanent conversion beneath a reservoir.
8 / Evidence
Direct source links appear below. Original code, applicant and ecological exhibits are reproduced in the downloadable PDF dossier; the source register retains document pinpoints.
Evidence: S01 · S36 · S07 · S10 · S11 · S12 · S09. Full titles and pinpoints in the evidence register.
CRITERION RECORD · EVIDENCE
Recreation and public experience
1 / Resource or issue
Recreation and public experience within the complete construction and operating impact area.
2 / The Chapter VI criterion
§6.04.01(11): “The Project will not have a significant adverse effect on the quality or quantity of recreational opportunities and experience.” [S01, PDF p.19].
Section 6.04.01(11) protects the quality and quantity of recreational opportunities and experience. Appendix A names visitor days, rafting/kayaking seasons, fisheries, flows and reservoir levels, access, trails, wilderness experience and solitude.
Standards approved October 27
Section 423 retains a significant-degradation standard for opportunities and experience in the Impact Area. Section 321 requires recreation assessment, including access, boating, fishing seasons and heat closures, trails and wilderness experience.
3 / What the evidence shows
The applicant’s 2019 report identifies FR703 access to Gold Park Campground, Holy Cross Wilderness trailheads and Homestake Reservoir, and camping, hiking, fishing, boating and wildlife viewing (p. 22). Campaign photographs and modeling depict the existing landscape and its conversion. Road access connects visitors with these public places; construction and reservoir operations can change how they are reached and enjoyed.
Appendix N reports 85% fewer whitewater boatable days in dry years and 48% fewer in wet years on the Tigiwon-to-Dowd reach in the combined New Water Infrastructure historical-hydrology scenario. Edwards-to-Eagle losses are 9% and 10%. These are modeled flow opportunities for kayaking and rafting, not measured Whitney-only losses.
Loss of an existing river or trail experience matters under Chapter VI §6.04.01(11) and October 27 §423. Access, safety, season and reservoir operations determine what recreation the project would actually offer.
Evidence: S01 · S36 · S10 · S11 · S15 · S16 · S09. Full titles and pinpoints in the evidence register.
CRITERION RECORD · ANALYSIS + POSITION
Recreation and public experience: the decision
4 / What remains to be resolved
Applicant’s access and closure schedule, operational water levels, existing-use record and recreational effects.
5 / Why it matters to this approval standard
The code protects the experience people already have here, including access, season, scenery and quiet. The Board must evaluate changes to that existing experience.
6 / Save Homestake’s position
7 / What the Board must determine
Would the quality or quantity of existing recreation significantly decline after proposed measures?
8 / Evidence
Direct source links appear below. Original code, applicant and ecological exhibits are reproduced in the downloadable PDF dossier; the source register retains document pinpoints.
Evidence: S01 · S36 · S10 · S11 · S15 · S16 · S09. Full titles and pinpoints in the evidence register.
CRITERION RECORD · EVIDENCE
Noise, roads, power and maintenance
1 / Resource or issue
Whitney would bring an operating system into a landscape valued for quiet, wildlife and public recreation. Pumps, electrical equipment, access roads and conveyance facilities need recurring service. Noise, traffic, light and repair activity belong in the permit decision throughout the project’s life.
2 / The Chapter VI criterion
§6.04.01(21): “The Project will not cause a nuisance.” [S01, PDF p.19].
Section 6.04.01(21) prohibits a nuisance. Appendix A identifies dust, fumes, glare, heat, noise, vibration, artificial light and traffic. Recreation and visual criteria, (11) and (14), separately protect public experience and scenery.
Standards approved October 27
Section 429 protects use and enjoyment of property in the Impact Area and existing owners from nuisance. Sections 425-426 address traffic and road costs; §§430, 410, 423 and 431 address dust, air, recreation and scenery. Section 327 requires construction and operation nuisance assessment.
3 / What the evidence shows
CSU describes pumping and conveyance (S08, p. 1; S29). Construction introduces equipment, haul traffic, excavation and work areas. During operation, pumps and associated equipment can produce recurring noise and vibration; inspections and repairs add service traffic and renewed work. The field archive documents the present landscape and use (S10).
The Homestake II decision records evidence of noise, dust and tunnel-work effects on recreation and scenery that supported denial of that earlier design (S07). For Whitney, the component tables identify the sources and phases to evaluate against the valley’s existing quiet and uses.
Evidence: S01 · S36 · S07 · S08 · S10 · S29. Full titles and pinpoints in the evidence register.
CRITERION RECORD · ANALYSIS + POSITION
Noise, roads, power and maintenance: the decision
4 / What remains to be resolved
Applicant’s equipment, receptor, noise, vibration, traffic, lighting and maintenance assessments for construction and operation.
5 / Why it matters to this approval standard
Recurring operation and maintenance can affect the same quiet, access and enjoyment exposed during construction. The nuisance test applies to the actual disturbance left after controls.
6 / Save Homestake’s position
7 / What the Board must determine
Will construction or continued operation cause a nuisance after the proposed controls?
The finding should identify the affected uses, sound and vibration characteristics, timing, lighting, haul/service traffic, closures and maintenance schedule. Assess equipment enclosures, hours and other controls against the actual disturbance that remains.
8 / Evidence
Direct source links appear below. Original code, applicant and ecological exhibits are reproduced in the downloadable PDF dossier; the source register retains document pinpoints.
Evidence: S01 · S36 · S07 · S08 · S10 · S29. Full titles and pinpoints in the evidence register.
CRITERION RECORD · EVIDENCE
Landscape, cultural and historic resources
1 / Resource or issue
Landscape, cultural and historic resources within the complete construction and operating impact area.
2 / The Chapter VI criterion
§6.04.01(14); §6.04.01(22): “The Project will not significantly degrade existing visual quality. / The Project will not significantly degrade areas of paleontological, historic, or archaeological importance.” [S01, PDF p.19].
Chapter VI §6.04.01(14) addresses existing visual quality and (22) protects places of paleontological, historic or archaeological importance. October 27 §§431 and 424 respectively cover these resources within the impact area. Sections 329 and 322 specify the associated materials.
3 / What the evidence shows
The field views and reservoir model show conversion of the creek, wetland and forest setting. Dam works, pump buildings, cleared access, portals and electricity supply would add to the visual change. Their selected locations and the final operating range remain unresolved.
The Camp Hale-Continental Divide proclamation recognizes Ute relationships and military history in this mountain landscape. These connections give the cultural review its human importance. Section 106 review addresses effects on historic properties and includes consultation with affected Tribes; confidential cultural-resource locations retain their protection.
Flooding, excavation, blasting or road relocation can destroy physical evidence and alter a resource’s setting.
Evidence: S01 · S36 · S08 · S10 · S11 · S21. Full titles and pinpoints in the evidence register.
CRITERION RECORD · ANALYSIS + POSITION
Landscape, cultural and historic resources: the decision
4 / What remains to be resolved
All-facility viewsheds and operating levels; professional inventories, significance findings and meaningful Tribal participation.
5 / Why it matters to this approval standard
Scenic character and documented historic or archaeological importance are separate protected interests. Each finding should identify the affected resource, project effect and remaining harm.
6 / Save Homestake’s position
7 / What the Board must determine
Will documented scenery or important historic/archaeological areas suffer significant degradation after treatment?
8 / Evidence
Direct source links appear below. Original code, applicant and ecological exhibits are reproduced in the downloadable PDF dossier; the source register retains document pinpoints.
Evidence: S01 · S36 · S08 · S10 · S11 · S21. Full titles and pinpoints in the evidence register.
CRITERION RECORD · EVIDENCE
Demonstrated necessity
1 / Resource or issue
Demonstrated necessity within the complete construction and operating impact area.
2 / The Chapter VI criterion
§6.04.02(3): “The Project shall be necessary to meet community development and population demands in the areas to be served by the Project.” [S01, PDF p.20].
Appendix A identifies reasonable growth projections, local land-use plans and relationships to other providers’ service areas.
Standards approved October 27
October 27 §§303(D) and 331(B) require the basis of projected demand in the area to be served. Article 4 omits Chapter VI’s separate necessity test. Sections 403, 409 and 434(D) still address feasibility, dependable operational supply and efficiency. The growth and facilities provisions in §434(A)–(B) are limited to projects serving the county.
3 / What the evidence shows
The March 2022 utility fact sheet presents Whitney as part of a larger supply program and describes a range of potential storage capacities. A program target and a storage volume do not quantify the specific service-area demand Whitney must meet after existing investments, conservation and reuse.
Chapter VI’s necessity criterion requires a documented link between the proposed project and the demands of its service area. Under either framework, the burden a new diversion would place on Homestake remains central to the campaign’s opposition.
Evidence: S01 · S36 · S08. Full titles and pinpoints in the evidence register.
CRITERION RECORD · ANALYSIS + POSITION
Demonstrated necessity: the decision
4 / What remains to be resolved
Current service-area demand, reasonable growth, existing/committed supplies, Whitney-only dependable yield and alternatives.
5 / Why it matters to this approval standard
Necessity depends on actual demand, committed supplies and dependable additional delivery. A common reliability basis makes the comparison with demand management and alternatives useful.
6 / Save Homestake’s position
7 / What the Board must determine
Has the applicant demonstrated necessity under a defensible service-area demand and supply record?
Chapter VI’s application materials address alternatives. A no-Whitney portfolio offers a comparison using the same assumptions for drought reliability, cost and water delivered.
The October 27 package omits a standalone necessity finding. Even a demonstrated municipal need would not erase the ecological cost of further depletion or give either city an entitlement to flood this valley.
8 / Evidence
Direct source links appear below. Original code, applicant and ecological exhibits are reproduced in the downloadable PDF dossier; the source register retains document pinpoints.
Evidence: S01 · S36 · S08. Full titles and pinpoints in the evidence register.
CRITERION RECORD · EVIDENCE
Efficient use, conservation and reuse
1 / Resource or issue
Efficient use, conservation and reuse within the complete construction and operating impact area.
2 / The Chapter VI criterion
§6.04.02(1): “The Project shall emphasize the most efficient use of water, including the recycling, reuse and conservation of water.” [S01, PDF p.20].
Chapter VI §6.04.01(12) also addresses resource conservation, energy efficiency and recycling or reuse. Appendix A considers readily available conservation and recycling to the greatest extent allowed by law.
Standards approved October 27
October 27 §434(D) requires efficient planning, design and operation, including recycling and reuse. Unlike Chapter VI §6.04.02(1), it does not expressly name conservation in that standard. Sections 331(A)(3) and 331(E) require application information about conservation techniques.
3 / What the evidence shows
The proposed system collects and pumps headwater water for additional supply. Demand reduction, lawful reuse and existing-system improvements should be evaluated in dependable acre-feet, timing, cost and environmental effect. The code’s efficiency requirement concerns how the project is actually planned and operated.
The reviewed public sources do not quantify additional savings beyond measures already assumed in the baseline.
Evidence: S01 · S36 · S05 · S08. Full titles and pinpoints in the evidence register.
CRITERION RECORD · ANALYSIS + POSITION
Efficient use, conservation and reuse: the decision
4 / What remains to be resolved
Measured progress and remaining practicable savings, with implementation dates and independently reviewable assumptions.
5 / Why it matters to this approval standard
Measured conservation and reuse affect how much additional source water is needed and how efficiently the project operates. Crediting existing progress establishes the correct baseline for additional potential.
6 / Save Homestake’s position
7 / What the Board must determine
Does the proposed project emphasize the most efficient use of water under the actual planning and operating record?
An enforceable efficiency condition identifies the measure, implementation date, expected savings, monitoring, funding and response if it fails. An unfunded promise leaves the water and habitat losses with Homestake.
8 / Evidence
Direct source links appear below. Original code, applicant and ecological exhibits are reproduced in the downloadable PDF dossier; the source register retains document pinpoints.
Evidence: S01 · S36 · S05 · S08. Full titles and pinpoints in the evidence register.
UTILITY REPORTS + PLANNING RECORD
Conservation is already reducing demand.
Documented conservation and reuse have reduced demand in Aurora and Colorado Springs. Those gains establish the baseline for evaluating further savings and alternatives to Whitney.
| Progress already reported | Additional practicable potential / interpretation |
|---|---|
| Aurora reports a 36% reduction in water use since the early 2000s and a use rate of 115 gallons per person per day. [MUN-S01] | Its stated goal is a further 10% consumption reduction by 2040. The published goal does not specify an independently reconciled annual AF saving in this record. |
| Aurora’s 2022 ordinance restricts ornamental turf in new development. Prairie Waters supplies up to 10 million gallons daily, according to the mayor. [MUN-S02] | Capacity is distinct from actual annual production. |
| CSU reports per-capita consumption down 40% since 2001 and 71,960 AF delivered to its potable distribution system in 2024. [MUN-S04] | Its 2025 update cites 7,900 AF of achievable conservation savings through 2070. The cited public summary does not state an annual schedule or baseline for that total. [MUN-S05] |
| CSU reports 276 AF/year of savings from 2024 conservation work. [MUN-S05] | The 276 AF/year completed-program figure and any Whitney-only dependable annual yield use different scopes unless they are placed on the same reliability, timing and legal-availability basis. |
Outdoor demand is a useful planning category
Aurora’s mayor describes outdoor irrigation as historically about 50% of total annual use; CSU’s 2022 plan estimates irrigation at about 40% of annual potable demand. Those dated scopes identify a demand-management opportunity. Current additional annual savings remain unquantified by those dated percentages. [MUN-S02; MUN-S06]
Compare annual savings with annual dependable supply. The 6,850-20,000 AF Whitney storage concepts are a capacity measure, not an annual-yield denominator.
Evidence: MUN-S01 · MUN-S02 · MUN-S04 · MUN-S05 · MUN-S06 · S08. Full titles and pinpoints in the evidence register.
CRITERION RECORD · EVIDENCE
Dependable supply and feasible operation
1 / Resource or issue
Dependable supply and feasible operation within the complete construction and operating impact area.
2 / The Chapter VI criterion
§6.04.01(5): “The Project is technically and financially feasible.” [S01, PDF p.19].
Chapter VI §6.04.01(5) addresses technical and financial feasibility, §6.04.02(3) addresses necessity and §6.04.01(8) protects local service capacity. Appendix A includes reductions in water available for future county supply.
Standards approved October 27
Section 409 expressly requires adequate supplies for current and future operational needs in quantity, quality and dependability. Section 403 requires technical and financial feasibility, including operation, mitigation and monitoring costs. Section 308 requires sources, legal rights, amounts, diversion changes, existing uses and alternative supplies.
3 / What the evidence shows
The utility’s March 2022 sheet gives Whitney storage concepts ranging from 6,850 to 20,000 acre-feet and describes uphill pumping to existing Homestake Reservoir. Storage capacity, annual deliveries and drought reliability measure different things. The key question is what additional useful water the proposed operation can reliably provide.
Senior rights, governing agreements, refill opportunities, consecutive dry years, evaporation, release commitments, conveyance capacity and power-dependent pumping affect dependable delivery. Reservoir drawdown also changes scenery, exposed bed, habitat, dust and recreation.
Evidence: S01 · S36 · S08 · S22. Full titles and pinpoints in the evidence register.
CRITERION RECORD · ANALYSIS + POSITION
Dependable supply and feasible operation: the decision
4 / What remains to be resolved
Whitney-only annual/dry-year yield, refill, senior-right constraints, environmental releases, pumping limits and life-cycle costs.
5 / Why it matters to this approval standard
Reliable delivery depends on physical capacity, legal availability, refill and dry-year operation. These conditions connect the supply promise to feasibility and necessity.
6 / Save Homestake’s position
7 / What the Board must determine
Are the proposed system and promised deliveries technically and financially feasible under the governing record?
Explain which promised deliveries remain dependable and which rely on conditions that are not secured.
8 / Evidence
Direct source links appear below. Original code, applicant and ecological exhibits are reproduced in the downloadable PDF dossier; the source register retains document pinpoints.
Evidence: S01 · S36 · S08 · S22. Full titles and pinpoints in the evidence register.
CRITERION RECORD · EVIDENCE
County benefits and resource losses
1 / Resource or issue
County benefits and resource losses within the complete construction and operating impact area.
2 / The Chapter VI criterion
§6.04.01(24): “The benefits accruing to the County and its citizens from the Project outweigh the losses of any natural, agricultural, recreational, grazing, commercial or industrial resources within the County, or the losses of opportunities to develop such resources.” [S01, PDF p.20].
Section 6.04.01(24) requires benefits accruing to Eagle County and its citizens to outweigh losses of natural, agricultural, recreational, grazing, commercial or industrial resources, or opportunities to develop them. Section (10) separately protects current and foreseeable local economic sectors; (9) prohibits an undue financial burden on County residents.
Standards approved October 27
Article 4 of the October 27 package omits a standalone test weighing county benefits against resource losses. Section 422 addresses significant degradation of any segment of the county economy. Sections 419 and 420 address local government services and undue tax burden. Environmental standards protect individual resources.
3 / What the evidence shows
The utility fact sheet identifies a broader MOU goal of 20,000 acre-feet of average annual East Slope supply and 10,000 acre-feet of firm dry-year West Slope supply. Those are program goals. The Board needs binding, incremental benefits attributable to Whitney, compared with permanent losses in Homestake.
CROA estimates 2024 Upper and Lower Eagle commercial rafting direct expenditures at a combined $1,513,348 across 9,200 user days. Appendix N documents modeled boating-day reductions under the combined development scenario. Together they identify an existing livelihood pathway exposed to flow changes.
Evidence: S01 · S36 · S08 · S16 · S19. Full titles and pinpoints in the evidence register.
CRITERION RECORD · ANALYSIS + POSITION
County benefits and resource losses: the decision
4 / What remains to be resolved
Binding County deliveries and other benefits, recipients, timing and reliability; permanent losses and future opportunities.
5 / Why it matters to this approval standard
Chapter VI weighs county benefits against losses of local resources and opportunities. The permanence of the losses, the location of benefits and the reliability of commitments all matter to that comparison.
6 / Save Homestake’s position
7 / What the Board must determine
Do benefits accruing to Eagle County and its citizens outweigh County resource and opportunity losses?
Compare enforceable local deliveries, reliability and fiscal benefits against lost habitat, recreation, access, economic opportunity and ongoing management costs. Account for permanence and who receives the benefits and bears the costs.
8 / Evidence
Direct source links appear below. Original code, applicant and ecological exhibits are reproduced in the downloadable PDF dossier; the source register retains document pinpoints.
Evidence: S01 · S36 · S08 · S16 · S19. Full titles and pinpoints in the evidence register.
Rights, boundaries and jurisdiction
Protect the public-land setting
Save Homestake opposes any change to the Holy Cross Wilderness boundary. The valley’s protected setting and public access must be considered across all facilities and routes, including the conveyance system and recurring maintenance.
Property rights and approvals
Chapter VI §6.04.01(1) and October 27 §404 require the necessary property rights, permits and approvals before site disturbance. They allow the Board to defer a final decision until outstanding approvals are secured. The location of facilities and access routes determines which ownership and protected-land requirements apply.
A water right authorizes what its decrees provide; the County’s land-use criteria remain an independent approval requirement. Homestake II upheld denial of a particular noncompliant design while recognizing the cities’ underlying water rights (S07).
Connected effects and geographic authority
October 27 §109 defines the impact area by the project’s likely effects. Including territory within another political subdivision depends on a Board agreement for cooperative regulation across both jurisdictions. Water and wildlife can carry a project’s effects well beyond the shoreline.
Evidence: S01 · S36 · S07 · S09 · S21 · S29. Full titles and pinpoints in the evidence register.
Ecology exhibit · September 23, 2026
The ecological case for protection
The mapped wetland mosaic supplies the resource record. Colorado studies explain why water timing, peat and connected ponds matter. Our modeled reservoir flood zones place a shared part of that landscape under water.
The lidar analysis adds a physical consequence: the easiest modeled passage climbs onto valley sides, with fewer routes available within modest terrain-cost budgets.
Evidence: S01 · S36 · HWF:V3-07 · HWF:S31. Full titles and pinpoints in the evidence register.
ATTRIBUTED POSITION · FOR THE BOARD’S EVALUATION
Save Homestake’s requested findings
The finding must connect harm to the rule
A defensible finding connects the effective rule to a documented project effect, the applicable threshold, the mitigation record and the resulting compliance conclusion. One unmet applicable criterion can support denial, while independent supported grounds remain separate.
A proposed fen finding
The modeled consequences correspond to the displayed alternative and elevation.
Scope of the conditional finding
The conditional language depends on a selected project footprint, project-specific hydrology and functions, and a mitigation record using comparable functions and time periods. Our models identify potential flooding at the studied dam sites; the final project design has not been selected.
The Board should state which offered conditions it considered and why they do or do not ensure compliance. Unrelated supply benefits do not erase a failed individual environmental standard in either version.
Evidence: S01 · S36 · S06 · S07 · S10 · S11. Full titles and pinpoints in the evidence register.
THE OCTOBER 27 PACKAGE
Watershed protection and the route to review
Fens, groundwater and downstream habitat
Fens are expressly included in “Waterbody” under revised §109. Sections 307 and 406 connect flow, groundwater, wetland function and aquatic habitat, including downstream resources. Sections 307 and 310 require documentation of consultation with Colorado Parks and Wildlife and describe monitoring. Those protections matter to the wetlands and streams draining to the Eagle River.
When a designated activity can qualify for an exception
Revised §§105(C) and 201 require two things. The activity was or will be reviewed and approved through a county subdivision, planned unit development or special-use process. The Director must also determine that adverse impacts will be or have been adequately mitigated through county land-use regulations and other state or federal permits. This exception begins when the 2026 general land-use regulations take effect or July 1, 2027, whichever comes first.
Public notice of a finding of no significant impact
Under §204, the Director may issue a FONSI if Article 4 standards are met without mitigation or impacts will be adequately mitigated through county, state or federal permitting. The Director must publish notice and reasons in the county legal newspaper within 21 days after the determination. Within 28 days after publication, the Board may decide to reconsider at its next properly noticed meeting. Section 601 separately requires publication of the activity order and a site sign at least 21 days before construction.
Under §301(B), the Director may waive irrelevant application materials. Applicable Article 4 standards still govern a permit decision.
Evidence: S01 · S05 · S35 · S36 · S37. Full titles and pinpoints in the evidence register.
INSPECT THE ORIGINAL RECORD
Source register
GOVERNMENT RECORD
S01 · Eagle County, published Chapter VI before the 2026 rewrite
Chapter VI comparison text. EnCode PDF pp. 16–17, decision rule; pp. 19–20, criteria; pp. 24–29, Appendix A considerations. The County-linked legacy layout uses different pagination.
GOVERNMENT RECORD
S02 · Eagle County, September 15, 2026 proposed 1041 regulations
September 15 draft retained for the history of the rulemaking. The October 27 vote approved the hearing texts S36 and S37.
GOVERNMENT RECORD
S03 · Eagle County, active application LUR-009633-2026
County project entry for LUR-009633-2026. The hearing was held October 27. Its decisions and timing provisions are in S35 and S42.
GOVERNMENT RECORD
S04 · Eagle County, September 23 staff report
September 23 staff recommendation, pp. 1 and 8, on coordinated effectiveness with the general rewrite. The Board subsequently made the 1041 rules effective on passage of a separate resolution.
GOVERNMENT RECORD
S05 · Eagle County, July 10 comparison draft
§331 alternatives analysis and §434 least-adverse alternative; compare September replacement. July printed pages are nine less than PDF page numbers.
Source register, continued 2 of 14
GOVERNMENT RECORD
S06 · Colorado Revised Statutes 2026, Title 24
§24-65.1-501(4): compliance and denial. Read with County conditional-approval provisions.
COURT DECISION
S07 · City of Colorado Springs v. Board of County Commissioners, 895 P.2d 1105
Colo. App. 1994. Homestake II wetlands and nuisance findings, competent evidence, county authority, and retained water rights.
UTILITY STATEMENT
S08 · Colorado Springs Utilities, Eagle River Joint Use Water Project
March 2022, pp. 1-2. Broader MOU goals, Whitney storage concepts, tributary collection and pumping to existing Homestake Reservoir.
GOVERNMENT RECORD
S09 · Homestake Partners, Whitney Reservoir geotechnical investigation application
June 25, 2019. Proposed investigation; alternative dam alignments and exploration/access maps: Technical Report Figure 1 p. 3 / PDF p. 11; Figures 3-5 pp. 6-8 / PDF pp. 14-16.
FIELD RECORD
S10 · Save Homestake, public field archive and modeled reservoir comparison
Campaign photographs, films, generalized wildlife locations and testimony. Compare the four modeled reservoir alternatives in the valley explorer; field record updated September 12, 2026.
Source register, continued 3 of 14
SAVE HOMESTAKE MODEL
S11 · Save Homestake, the case and valley explorer
Campaign interpretation of the mapped fen complex and modeled reservoir alternatives. Model-based conclusions concern the displayed alternatives and water elevations.
GOVERNMENT RECORD
S12 · U.S. EPA, Classification and Types of Wetlands: Fens
Groundwater-fed peat systems, characteristic hydrology and vegetation; natural formation can take up to 10,000 years.
GOVERNMENT RECORD
S13 · 33 C.F.R. §332.3(e)(3), compensatory mitigation
Federal rule expressly identifies fens among difficult-to-replace resources and addresses suitable compensation. Corroborates replacement difficulty; County standards provide the local decision rule.
RESEARCH / SOURCE RECORD
S14 · Chimner and Cooper, Mountain Fen Restoration in Colorado: An Overview
2012, International Peat Congress. Restoration evidence and long recovery of peat physical properties. Full paper linked from the publisher record.
RESEARCH / SOURCE RECORD
S15 · Eagle River Community Water Plan, Appendix C
§2.1.2 p. 9: 2020 current-conditions baseline; §2.1.5 p. 11: combined New Water Infrastructure scenario.
Source register, continued 4 of 14
RESEARCH / SOURCE RECORD
S16 · Eagle River Community Water Plan, Appendix N: Recreational Water Uses
Table 1 p. 7; methods pp. 9-11; Table 2 p. 16; §6 p. 22. Published whitewater boatable-day results from the original appendix.
RESEARCH / SOURCE RECORD
S17 · Eagle River Community Water Plan, Appendix K: Eagle Mine water quality
Methods pp. 4-6; narrative p. 9; Table 12 p. 21; Table 13 p. 22. Mean monthly zinc metrics for 2009-2016.
RESEARCH / SOURCE RECORD
S18 · Eagle River Community Water Plan, main report
Revised October 2024, pp. 22-25 and 68-69. MOU scenario, seasonal effects and additional upper-basin assessment needs. Portal: lotic.quarto.pub/community_water_plan/.
RESEARCH / SOURCE RECORD
S19 · CROA, 2024 Commercial Rafting Use Report
Revised August 13, 2025, PDF p. 8. Upper and Lower Eagle user days and expenditure estimates.
GOVERNMENT RECORD
S20 · Colorado Parks and Wildlife, July 16, 2026 fishing-closure announcement
Dated notice of full-day voluntary Eagle fishing closure beginning July 17, from Lake Creek to the Colorado confluence; low flows and high temperatures.
Source register, continued 5 of 14
GOVERNMENT RECORD
S21 · Proclamation 10476, Camp Hale-Continental Divide National Monument
October 12, 2022; 87 FR 63381-63392. Documents Ute connections, the military landscape and monument protections.
RESEARCH / SOURCE RECORD
S22 · Colorado River District, Shoshone water-rights FAQ
Senior rights and river administration context. The decrees and applicable operating agreements govern the water-right context.
GOVERNMENT RECORD
S23 · Eagle County, broader land-use-code adoption schedule
Historical schedule for the separate November 3 general land-use code and map proceeding. See the meeting agenda, S39.
GOVERNMENT RECORD
S26 · CNHP, Fen Mapping inventory
Complete September 18 export: 600 features across the query area covering the model. Potential Fen IDs 3033, 3045, 5490 and 5491 intersect one or more modeled alternatives; 3045 and 5491 intersect all four. See the map methods and per-feature overlap register. This is the archived older service. A September 23 query of a separate downstream envelope returned 18 older-service features and six Fens 2025 features with different geometries. Authoritative version and individual polygon correspondence between the two services remain unresolved.
GOVERNMENT RECORD
S27 · Chadde et al., Peatlands on National Forests of the Northern Rocky Mountains
USDA Forest Service RMRS-GTR-11, 1998. Printed p. 16 / PDF p. 20: flooded sedge fen converted to aquatic vegetation; printed p. 32 / PDF p. 36: hydrology, water-level regulation and off-site disturbance. Pertinent original pages appear in the Eagle County 1041 Evidence Dossier.
Source register, continued 6 of 14
GOVERNMENT RECORD
S28 · 40 C.F.R. §230.41, wetlands effects
§230.41(b) recognizes permanent flooding as a mechanism damaging or destroying wetland habitat and productivity. General technical support for the modeled impact mechanism.
UTILITY STATEMENT
S29 · Colorado Springs Utilities, draft full ERMOU development conveyance map
CSU draft map published by Aspen Journalism, July 17, 2019, linked externally. The map section uses original Save Homestake geography from USGS and a schematic of CSU’s 2022 description (S08, p. 1).
GOVERNMENT RECORD
S30 · CNHP, Colorado Wetlands inventory and complete overlap register
Complete September 18 export: 2,979 features, including Colorado Heritage Program and National Wetlands Inventory sources. Source classes retained; ponds/rivers/lakes separated from mapped wetlands. The complete per-feature overlap register is linked in the web map section.
SAVE HOMESTAKE CALCULATION
S31 · Save Homestake, complete per-feature flood-zone overlap register
CSV lists every positive-area inventory intersection by alternative, source, feature ID, source classification and modeled area. Companion methods preserve input hashes, dissolved totals and complete-export checks. September 20, 2026 model.
RESEARCH / SOURCE RECORD
S32 · National Research Council, Riparian Areas: Functions and Strategies for Management
2002, chapter 3, printed pp. 149-150. Reduced flows and diversions alter riparian water supply; reduced overall flows can lower water tables and stress vegetation. Supports the downstream harm mechanism.
Source register, continued 7 of 14
GOVERNMENT RECORD
S33 · CNHP / USFS, Inventory of Fens in White River National Forest
July 2025. Executive summary and printed p. 1: sustained saturation, groundwater supply and protection of contributing watersheds. Printed p. 36: disturbed hydrology, peat decomposition and carbon release.
SAVE HOMESTAKE CALCULATION
S34 · Save Homestake, connected downstream wetlands and source record
October 6, 2026 mapping uses the September 18 and October 5 CNHP and USGS inventories. Complete wetland and pond polygons, channel connections and valley-floor terrain identify connected habitat. Potential-fen classifications and reservoir overlaps are identified separately.
RESEARCH / SOURCE RECORD
HWF:V3-17 · Biological Survey of Eagle County, Colorado
Printed p. 159, PDF p. 162; Holy Cross City PCA; cottongrass account;
RESEARCH / SOURCE RECORD
HWF:V3-24 · Status and Conservation of Boreal Toad 2006-2007
Printed pp. 36 and 76; site monitoring tables; Historical agency
PEER-REVIEWED
HWF:S31 · Downstream effects of stream flow diversion on channel characteristics and riparian vegetation in the Colorado Rocky Mountains
Abstract; Methods; Table IV; pp. 586-598;
Source register, continued 8 of 14
PEER-REVIEWED
HWF:V3-07 · Effectiveness of Ditch Blockage for Restoring Hydrologic and Soil Processes in Mountain Peatlands
Abstract; Table 1; Results;
PEER-REVIEWED
HWF:S12 · Beaver dams and overbank floods influence groundwater-surface water interactions of a Rocky Mountain riparian area
Abstract and citation metadata;
PEER-REVIEWED
HWF:V3-01 · A high-altitude thermal infrared method for estimating moose abundance and demography in Rocky Mountain National Park, USA
Methods habitat-suitability model; Table 1;
PEER-REVIEWED
HWF:V3-21 · Reduced Streamflow From Water Diversion Alters Stream Ecology and Fish Behavior
Methods and Results;
RESEARCH / SOURCE RECORD
HWF:V3-42 · Homestake water findings
September 24, 2026 public edition; recorded exports and Gold Park flow, WY2007–2024; linked annual records and methods.
Source register, continued 9 of 14
RESEARCH / SOURCE RECORD
HWF:S28 · Rocky Mountain Subalpine-Montane Fen ecological system
Diagnostics; hydrology; vegetation; associations; CNHP system
RESEARCH / SOURCE RECORD
HWF:S03 · Inventory of Fens in White River National Forest
Section 4.2; Tables 10-12; Appendix A;
RESEARCH / SOURCE RECORD
HWF:V3-02 · Eagle County Chapter VI
6.03.10; 6.04.01(15)-(20); Appendix A pp. iv-vi;
PEER-REVIEWED
HWF:V3-06 · Rapid riparian ecosystem decline in Rocky Mountain National Park
Abstract; Methods; figures;
RESEARCH / SOURCE RECORD
HWF:V3-04 · CPW Fish Distribution Schedule 2023
PDF p. 34, water 20622 and 67365; species-code legend;
Source register, continued 10 of 14
RESEARCH / SOURCE RECORD
HWF:V3-05 · CPW Fish Distribution Schedule 2024
PDF p. 35, water 20622 and 67365; species-code legend;
RESEARCH / SOURCE RECORD
HWF:S11 · Colorado River cutthroat trout species profile
About; Cutthroat Trout Taxonomy Research;
PEER-REVIEWED
HWF:S34 · Informed breeding dispersal following stochastic changes to patch quality
Abstract; DOI metadata;
PEER-REVIEWED
HWF:V3-18 · Beaver recolonization explains aquatic insect emergence patterns
Abstract; DOI 10.1086/734565;
RESEARCH / SOURCE RECORD
HWF:V3-34 · CNHP current tracking list, public read-only data response
2,214 returned rows; exact-name rank/status fields; accessed 2026-09-23;
FIELD SURVEY / TECHNICAL REPORT
HWF:FEN-2011-S01 · Malone, Carlson, Smith, Culver and Lemly (2011), Wetland Mapping and Fen Survey in the White River National Forest
CNHP report prepared for White River National Forest, November 2011. Gold Park sites 6982 and 6969; surveys September 12, 2011. Table 1, printed p.5; site accounts printed pp.92–99 (PDF pp.96–103), especially pp.92,94,97–98.
Source register, continued 11 of 14
SAVE HOMESTAKE CALCULATION
HWA:S-GP-ANNUAL · Matched Gold Park annual inputs, WY2007-2024
18 annual rows; tunnel_export_13704614_af and flow_af_observed_days; verified September 23, 2026.
SAVE HOMESTAKE CALCULATION
HWA:S-REPORT · Homestake flow, basin and closure findings, September 24 evidence edition
Public findings integrating the matched WY2007-2020 800-m PRISM water balance, signed storage, estimated water returned to the air and the amount still unexplained.
SAVE HOMESTAKE CALCULATION
HWA:S-RAW · Homestake Gold Park evidence, calculations and water-accounting archive
September 24 reproducible bundle containing raw PRISM, DWR and USGS records; scripts; signed annual and storage ledgers; component-status table; workbook; SQLite database; figures; report; and SHA-256 manifests.
RESEARCH / SOURCE RECORD
HWF:REGISTRY · Homestake wildlife and flora occurrence record, v0.3
September 23 v0.3 evidence package and SQLite/CSV records. 1,400 BioBlitz observations; 229 terminal concepts, including 190 species-rank concepts; 618 Research Grade, 778 Needs ID and four Casual. Additional screened GBIF/locality records: 233, including 129 eBird-derived and 103 specimen records.
RESEARCH / SOURCE RECORD
HWF:FEN-2025 · CNHP fen service comparison, September 23, 2026
Identical downstream query envelope returned 18 Potential Fen features from the older service and six Fens 2025 features; geometries differ. The dated older-service overlay remains reproducible, but the services do not establish authoritative version or polygon correspondence.
Source register, continued 12 of 14
AGENCY DATA
HWA:S-USGS-GP · USGS 09064000 Homestake Creek at Gold Park
Daily mean discharge 00060/00003, October 1, 2006 through September 30, 2024; 6,575 approved daily values, including 2,876 estimated-day qualifiers; verified September 23, 2026.
AGENCY DATA
HWA:S-TUNNEL · DWR Homestake Tunnel monthly diversion records
Water class 13704614; Approved 216 monthly records for WY2007-2024; verified September 23, 2026.
AGENCY DATA
HWA:S-RESERVOIR · DWR Homestake Reservoir storage and evaporation accounts
Evaporation classes 36604, 36796, 178123; reservoir-stage-volume.json endpoints 2006-09-30 and 2024-09-30; verified September 23, 2026.
AGENCY DATA
HWA:S-REDCLIFF · DWR-published USGS 09064500 Red Cliff water-year flow
WY2007-2011, totalQAf; record dataSource=USGS; preserved September 20 vintage, daily-USGS cross-check September 23; verified September 23, 2026.
AGENCY DATA
HWA:S-COLLECTORS · DWR five Homestake collector monthly records
WDIDs 3701253, 3701254, 3701255, 3701256, 3704644; total-capture water class 10000000 + WDID; 660 Approved monthly records in WY2014-2024; verified September 23, 2026.
Source register, continued 13 of 14
SAVE HOMESTAKE CALCULATION
HWA:S-TOPOLOGY · Gold Park basin: existing intakes and reservoir
The five existing tributary intakes and Homestake Reservoir lie upstream of the Gold Park gauge.
SAVE HOMESTAKE ANALYSIS
HWA:S-WHITNEY-GAP · Whitney storage and dependable-yield evidence record
Public sources identify Whitney storage concepts and a broader project objective, but do not establish Whitney-only dependable annual or dry-year yield. Evidence reviewed through September 23, 2026.
GOVERNMENT RECORD
HWF:S22 · U.S. Fish and Wildlife Service, final Canada lynx critical-habitat rule
43732/PDF1 effective date; 43771/PDF40 Unit6 geography; 43772/PDF41 Unit6 map; 43768-43769/PDF37-38 boundary rule. Official source checked September 23, 2026.
GOVERNMENT RECORD
HWF:S39 · Colorado Parks and Wildlife, lynx species profile
Protection Status; Threatened and Endangered. Official source checked September 23, 2026.
GOVERNMENT RECORD
FED-ECFR-17.11-LYNX · 50 CFR 17.11(h), federal Canada lynx listing
17.11(h), Lynx, Canada [Contiguous U.S. DPS] row; eCFR displayed current to September 21, 2026. Official source checked September 23, 2026.
Source register, continued 14 of 14
UTILITY STATEMENT
MUN-S01 · Aurora Water: Innovation & Sustainability
By the numbers; Future Goals. Checked September 23, 2026.
UTILITY STATEMENT
MUN-S02 · Here's how Aurora's leading water conservation
Outdoor irrigation paragraph; 2022 ordinance paragraph; Prairie Waters paragraph. Checked September 23, 2026.
UTILITY STATEMENT
MUN-S04 · 2025 Official Statement, City of Colorado Springs Utilities revenue bonds
Printed pp6,47,52-53; PDF pp12,53,58-59. Checked September 23, 2026.
UTILITY STATEMENT
MUN-S05 · Utilities Board Working Committee packet
PDF pp36,41-43 of 83; slides12,17-19. Checked September 23, 2026.
UTILITY STATEMENT
MUN-S06 · 2022 Water Efficiency Plan
pp13,18,20 and Table5 pp21-23. Checked September 23, 2026.
INSPECT THE ORIGINAL RECORD
Water-accounting sources
MODELED AGENCY DATA
HWA:S-PRISM-800M · PRISM 800-m monthly precipitation and methods
AN81m/M3 800-m monthly precipitation clipped to the 35.9029-square-mile Gold Park StreamStats polygon for WY2007-2020. Total precipitation is rain plus snow water equivalent, not snowfall or peak SWE.
AGENCY DATA
HWA:S-STAGEVOLUME · DWR Homestake Reservoir stage-volume endpoints
Approved storage endpoints. Exact annual changes are available for most years; only the combined September 2013 to September 2016 repair-period change is supported for that gap.
PEER-REVIEWED
HWA:S-SNOW-SUB · Sexstone et al. 2018, Snow Sublimation in Mountain Environments
Regional process model including surface, canopy and blowing-snow sublimation. The reported 22-36% range, mean 28%, is a regional sensitivity benchmark, not a calibrated Gold Park estimate.
PEER-REVIEWED
HWA:S-SNOW-FIELD · Schwat et al. 2025, Estimating Snow Sublimation in Complex Terrain
Direct East River opening estimate of 33-42 mm, approximately 8-10% of peak SWE, for one winter and one opening. Denominator and spatial scale are retained.
PEER-REVIEWED
HWA:S-SNOW-SURFACE · Sexstone et al. 2016, Colorado surface-sublimation methods comparison
Colorado forest-opening surface-only losses equaled 13% and 17% of winter precipitation. Canopy and blowing-snow terms are outside that surface-only result.
Water-accounting sources, continued 2 of 3
PEER-REVIEWED
HWA:S-FEN-ET · Blanken 2014, high-elevation wetland evaporation
High Creek Fen eddy-covariance study. Table 5 reports 101-353 mm of partial-season ecosystem evaporation, including the drought year. It combines vegetation, soil and wet-surface vapor flux; the mapped-fen calculation applies this analogue to 165.324 acres.
GOVERNMENT GIS DATA
HWA:S-FEN-MAP · Colorado Natural Heritage Program 2025 fen mapping
Exact basin clip: 11.593 confirmed fen acres and 153.731 potential fen acres, 165.324 acres combined. Potential fen is a mapping category, not field confirmation.
GOVERNMENT GIS DATA
HWA:S-WETLAND-MAP · CNHP and U.S. Fish and Wildlife Service wetland inventory
Exact basin clip: 332.104 acres of vegetated and other mapped wetlands. The NWI layer overlaps mapped fens and is not added to fen acreage.
PEER-REVIEWED
HWA:S-GROUNDWATER · Carroll et al. 2020, groundwater controls on headwater streamflow
Colorado headwater process analogue showing interflow, groundwater contribution and groundwater-supported ET. Recharge and baseflow are internal pathways unless water crosses the accounting boundary or changes storage.
GOVERNMENT RECORD
HWA:S-BYPASS · 2008 environmental assessment, Gold Park bypass condition
Printed p. 3-25 states the operating condition of 24 cfs or natural inflow, whichever is less, at Gold Park during diversion. It is an operating rule, not a biological-sufficiency finding.
Water-accounting sources, continued 3 of 3
GOVERNMENT METHOD
HWA:S-R2CROSS · Colorado Water Conservation Board R2Cross program
Reach-specific instream-flow method based on hydraulic criteria including depth, velocity and wetted perimeter. It does not supply one transferable Gold Park minimum for all species, seasons or wetland systems.
SAVE HOMESTAKE CALCULATION
HWA:S-CLOSURE-LEDGER · Gold Park water-accounting closure ledger, September 24, 2026
Machine-readable WY2007-2020 annual ledger, signed storage correction, estimated natural-process ranges, mapped-area quantities, treatment of unmeasured quantities and no-double-count rules. Companion CSVs and workbook are in the same public evidence directory.
AGENCY GIS INVENTORY
HWF:FEN-MAP-V2-S01 · Colorado Natural Heritage Program, Fens (CNHP 2025), Fens_2025_V2 map service
Official CNHP polygon inventory, retrieved October 10, 2026. FEN_STATUS preserves the agency classification; Source identifies the contributing survey or project.
SAVE HOMESTAKE ANALYSIS
HWF:FEN-MAP-ANALYSIS-S01 · Save Homestake, CNHP Fens2025V2 watershed classification and modeled-pool comparison, October 10, 2026
Official CNHP polygon geometry, complete USGS NLDI watershed boundary, class counts and A–D modeled-pool intersections. Retains source query URLs, coordinate system and hashes.
Source register
Lidar corridor source and reproducible results
SAVE HOMESTAKE MODEL
MODEL:LIDAR-2026-09-24 · Whitney lidar corridor analysis, addendum 2.0
2016 lidar; native 2 m directed routes, matched central gates, 200 routes and 15 cost envelopes; September 24, 2026.
The linked methods page includes the baseline and A-D route maps, route metrics, corridor-envelope comparison and gate-height sensitivity results.
Routes use native 2 m terrain derived from 2016 lidar. The reservoir barriers come from the separate 10 m visualizer. The +5%, +10% and +20% common-cost envelopes describe computational route opportunity; all 200 tested paths connect.
Sources added October 5, 2026
Beaver ecology source register
GOVERNMENT RECORD
HWF:BEAVER-GUIDE · The Beaver Restoration Guidebook, version 2.02
2023, version 2.02, printed p.3 (PDF p.13): off-channel habitat along larger rivers and seasonal main-channel dams during low flow.
PUBLISHED RESEARCH
HWF:BEAVER-SAINTVRAIN · Beaver-mediated lateral hydrologic connectivity, fluvial carbon and nutrient flux, and aquatic ecosystem metabolism
Wegener et al. 2017, North Saint Vrain Creek, Colorado, May-October 2015; sections 2.1 and 3.1, Figure 5: inferred June-July side-channel surface connection and relatively stable off-channel pond levels through October.
PUBLISHED RESEARCH
HWF:BEAVER-EASTRIVER · Beaver dams overshadow climate extremes in controlling riparian hydrology and water quality
Dewey et al. 2022, East River, Colorado: main-channel dam construction during exceptionally low-water summer 2018; seasonal hydrology and figure captions.
Sources added October 5, 2026
Beaver ecology source register
PUBLISHED RESEARCH
HWF:BEAVER-FEN · Beaver-mediated water table dynamics in a Rocky Mountain fen
Karran, Westbrook and Bedard-Haughn 2018, Rocky Mountain fen: four intact-dam years and two post-breach years. Abstract reports raised, stabilized water tables and greater storage within a study-specific 150 m radius.
GOVERNMENT RECORD
HWF:BEAVER-HABITAT · Castor canadensis: American beaver
Tesky 1993, U.S. Forest Service species review, habitat, food and cover sections; stable aquatic habitat, forage, underwater shelter access and fluctuating water levels. Accessed October 5, 2026.
Ecology sources used October 5, 2026
Beaver habitat and wildlife sources
SOURCE RECORD
HWF:V4-01 · Trends in Rocky Mountain amphibians and the role of beaver as a keystone species
Rocky Mountain amphibian trends, 2002–2011; RMNP species were too rare for most trend models.
SOURCE RECORD
HWF:V3-19 · Influence of beaver dam density on riparian areas and riparian birds in shrubsteppe of Wyoming
Abstract
Ecology sources used October 5, 2026
Beaver habitat and wildlife sources
PUBLISHED RESEARCH
HWF:BEAVER-FISH · Relocated beaver can increase water storage and decrease stream temperature in headwater streams
Dittbrenner et al. 2022, Washington headwater streams; abstract: increased storage and cooler downstream summer water at established relocation sites.
COUNTY RULEMAKING RECORD
October 27 vote and rule text
GOVERNMENT RECORD
S35 · Eagle County, October 27 Board hearing replay
Motions at 50:23–53:45. Corrected attachment identities at 53:01; conditional effectiveness at 53:25; counsel on a later resolution at 54:34.
GOVERNMENT RECORD
S36 · October 27 Attachment 1.2, standalone 1041 rules
Board-approved base text, read with S37. Definitions and FONSI, PDF pp. 5–16; permit decisions, p. 19; watershed and wildlife, pp. 23–29 and 43–45; water-project standards, pp. 49–50.
GOVERNMENT RECORD
S37 · October 27 Attachment 1.1, revisions approved with Attachment 1.2
PDF pp. 1–2 amend §§105, 109 and 201. The redline adds fens to Waterbody and sets separate conditions and timing for the §105(C) exception.
GOVERNMENT RECORD
S38 · Eagle County, November 2 Board working-session agenda
Subsequent meeting record. No separate 1041 enacting resolution is identified in the agenda or the November 2 meetings reviewed.
COUNTY RULEMAKING RECORD
Meeting records and transcript
GOVERNMENT RECORD
S39 · Eagle County, November 3 general land-use hearing agenda
File LUR-009660-2026 concerns the general Eagle County Land Use Regulations. It has a separate timetable from the October 27 standalone 1041 package.
GOVERNMENT RECORD
S40 · Eagle County, October 27 hearing staff report
PDF pp. 5–6. The recommended motions address designation, approval of standalone regulations and effectiveness upon a separate enacting resolution. The actual votes appear in S35 and S42.
GOVERNMENT RECORD
S41 · Eagle County, October 27 Board hearing agenda
Agenda item M.1, LUR-009633-2026. Links the staff report, rule attachments and hearing materials.
GOVERNMENT RECORD
S42 · Eagle County, October 27 hearing transcript
Motion 4 as corrected at 53:01, votes and motion 5 at 53:25, and counsel’s explanation at 54:34. The vote concerned countywide rules.
Original legal exhibits
The original evidence and rulemaking exhibits
The linked PDF dossier includes the original map, legal excerpts, Forest Service evidence and both complete October 27 attachments. Bookmarks open each exhibit.
Open the evidence PDF and its original exhibits
Project map: the 2019 application’s Figure 1 (technical p. 3 / PDF p. 11) locates the four alternative axes, Homestake Creek and road. It supplies geographic context for the campaign model and downstream construction callouts. Save Homestake’s original water-system map appears earlier in this dossier; the utility draft remains linked as a source.
Chapter VI before the rewrite
The Chapter VI excerpts in the PDF show the decision rule, approval criteria and the considerations in Appendix A.
September 15 historical draft
The historical September excerpts show the evolution of the decision rule and water-project standards. The October 27 vote adopted S36 with the changes in S37.
September staff recommendation
The September 23 staff report recommended coordinating effective dates with the general land-use rewrite (p. 8). On October 27, the Board instead tied 1041 effectiveness to the passage of a separate enacting resolution.
Ecological evidence
The Forest Service pages in the dossier PDF document vegetation change following sustained fen flooding and explain hydrologic and off-site threats to peatland function. They support the mechanism evaluated in the modeled Whitney impact case.
Evidence: S09 · S01 · S02 · S04 · S27 · S35 · S36 · S37 · S42. Full titles and pinpoints in the evidence register.
