South Boulder Creek Flood Mitigation Open Space Land DisposalFrom:Gordon McCurry
To:OSBT-Web
Subject:South Boulder Creek Flood Mitigation Open Space Land Disposal
Date:Thursday, February 22, 2024 3:23:10 PM
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Hello OSBT members,
I am writing in regards to your deliberations to dispose of Open Space lands associated with
the construction of the floodwall that is part of the South Boulder Creek Phase 1 Flood
Mitigation project. I am the Chair of the Water Resources Advisory Committee but these
comments are my own, as a professional hydrologist and interested member of the public.
I strongly encourage the OSBT to abide by your Resolution to City Council, dated June 9,
2021, which stated “OSBT will not officially consider the approval and recommendation of a
disposal of any of the Floodwall Acres for construction of the Floodwall unless and until all
the following conditions have been first fulfilled or addressed to the satisfaction of the
OSBT”. Those recommendations include:
obtaining all necessary permits and approvals,
preparing an Environmental Impact Statement and a Site-Specific Biological
Assessment,
preparing an Environment Mitigation Plan and having it approved by OSMP, OSBT and
Council,
there being sufficient planning to design a groundwater conveyance system through the
proposed floodwall that maintains existing groundwater conditions at the site, and
transferring title of 119 acres of land from CU to the City.
Obtaining reviews and approvals by the regulatory agencies (CDOT, CO-DWR, FEMA, COE,
etc) is especially important since the proposed groundwater conveyance system through the
floodwall appears to be the first of its kind, and therefore untested. The City Utilities
Department has been asked for at least 4 years by members of the public to provide examples
of a similar conveyance system – a conveyance system that would be used for a flood control
structure that is dry except during flood events and has not done so – presumably because no
other such conveyance system exists. As you are probably aware, the lands on either side of
the proposed floodwall are high-value wet meadows that are designated State Natural Area
lands and is the habitat for several threatened and endangered species. The shallow
groundwater level in those wet meadows is critical to sustaining those meadows and the
species living within them, so the groundwater conveyance system must be able to maintain
existing groundwater levels in perpetuity.
The groundwater conveyance system must also be able to withstand the significant water
pressure that will exist during flooding events when the floodwall is full of water. The current
design requires closing down a series of approximately nine connector pipes that go through
the floodwall to reduce flow. Previous flood modeling showed that the peak flow will reach
the floodwall less than 5 hours after the rainstorm that produces the flood. That is very little
time to adjust the valves to reduce flow in the connector pipes, being in the midst of a flood,
and assumes that staff can access the connector system and that all of the valves remain in
good working order so that they can be adjusted. Failure to reduce the flow in each of the
individual conveyance pipes could lead to damage of the system, or localized failure.
The review of this groundwater conveyance system by regulatory experts will provide a
necessary third-party assessment and must be undertaken, as stated in the OSBT’s June 2021
Resolution to Council, before the OSBT agrees to Dispose of the Open Space lands associated
with the project.
Thank you for considering my thoughts on this matter.
Thanks,
Gordon
Gordon McCurry, Ph.D., P.G.
Principal Hydrologist
McCurry Hydrology, LLC
303-520-1349
gmccurry@mccurryhydro.com
www.mccurryhydro.com
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