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September 17, 2025
John Leybourne
Garfield County Community Development Department
108 8th Street, Suite 401
Glenwood Springs CO 81601
RE: PUDA 12-24-9048 AND PUDA 07-25-9079 – HARVEST ROARING FORK PUD AND
RIVERS EDGE COLORADO PUD REVOCATION – WATER RIGHTS AND FLOODPLAIN
TECHNICAL REVIEW LETTER
Dear John:
At the request of Garfield County (“GARCO”), Colorado River Engineering, Inc. (“CRE”)
reviewed the land use application of Harvest Roaring Fork, LLC (“Applicant”) for the
proposed Harvest Roaring Fork PUD, GARCO file number PUDA-12-24-9048. The CRE
review is focused only on the water rights, physical water supply, and floodplain items.
CRE’s comments are presented below.
Legal Water Supply
Based on the submittal package, the proposed PUD application has provided
documentation and data that the proposed project has adequate legal water rights to
provide for domestic/commercial and irrigation uses and development of ponds. A portion
of the water rights are proposed to be conveyed to the Roaring Fork Water and Sanitation
District (“RFW&SD”). The RFW&SD will serve the domestic water requirements for the
PUD through development of the wells and diversions decreed for use on the Harvest
Roaring Fork PUD in Water Court Case Nos. 01CW187, 07CW164, and 08CW198. The
irrigation water supply will come from senior irrigation water rights in the Glenwood Ditch
(Thompson Glen Ditch Company shares) which diverts from the Roaring Fork River and
also a headgate on Cattle Creek, and the Staton Ditch which diverts from Cattle Creek.
The water right portfolio also includes storage rights that would provide for development
of ponds on the property.
Physical Water Supply
The submittal does not include evidence supporting the water rights will yield an adequate
physical supply of water for the proposed project. CRE is familiar with the water rights,
the RFW&SD, and the property - the project likely has and can develop an adequate
physical supply. However, it is the Applicant’s burden to provide the analysis and
evidence required in support of the proposed project. For the central water system, the
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requirements for the RFW&SD in Section 4-203.M.1.a. need to be provided. For
irrigation, such evidence may include a quantitative description (reliability, diversions,
season of use, number of acres irrigated, etc) of the historic use of senior irrigation water
rights, comparison to proposed demands, identifying what is committed to augmentation
of project depletions (domestic/commercial, evaporation) and what is remaining, etc. The
Patrick Miller Noto letter contains most of this information, but Applicant should complete
the analysis and demonstrate the comparison of available rights/supply for proposed
demand.
Floodplain
Both the Roaring Fork River and Cattle Creek have detailed FEMA Floodplain
delineations with base flood elevations located on the property. The proposed project
does not appear to be planning on development within the floodplain, but a bridge is
proposed across Cattle Creek and utilities are proposed across both the Roaring Fork
River and Cattle Creek. The Applicant proposes to span the entire Cattle Creek floodplain
and avoid any issues with floodplain impacts. At the time the bridge is designed and
included for approval, a Floodplain Development Permit Application should be submitted
to confirm the design is consistent with the Floodplain Regulation including the limits and
elevations of the floodplain and the freeboard from the 100-year base flood elevation to
the low chord of the bridge. The utility crossings will involve work within the
Floodway/Watercourse and a Floodplain Development Permit should be processed to
confirm no alteration to the watercourse and zero rise in the Base Flood Elevation. CRE
anticipates permitting will be straight forward with no potential floodplain issues that would
prevent the proposed activities.
Please call if you have any questions or need additional information.
Sincerely,
Colorado River Engineering, Inc.
Michael Erion, P.E.
Principal Water Resources Engineer
Job No. 1317.7
MJE/mje