Talking Points for Comments


Middle Boulder Creek Coalition



US Forest Service Scoping Process


  • Buffers make good neighbors.  
  • There will be adverse impacts to ecological, viewshed, watershed, acoustic, and community values.  Individually, cumulatively and collectively, they will be significant.  
  • The lands on the backside of Bryan Mountain below the existing Corona and Indian Peaks ski lifts should be retained as a buffer between Middle Boulder Creek, recreational use in the Hessie area, and the community of Eldora. It is good land use planning and good watershed planning.

In general, we are not against Eldora Mountain Resort, nor many of the proposed improvements.  They provide a recreational service to many area residents, provide jobs, and help the local economy.  Many MBCC members ski there.

Our primary focus is on the expansion of the backside of Bryan Mountain – the area below the existing Indian Peaks and Corona pods down to Middle Boulder Creek.  In the text that follows, the wording “expansion” refers to the expansion of the Special Use Permit Boundary, the proposed Placer Lift and associated ski runs, and the planned Moose Glade Express Lift and associated ski runs as shown in the accepted Master Development Plan.

The following concerns, questions, and issues need to be addressed in the EIS:


Compatibility with Forest Service and Boulder County Plans

  • Forest Plan.  How is the expansion of the Special Use Permit Boundary and proposed ski runs (both in the current proposal and in the accepted Master Development Plan) compatible with the 1997 Revision of the Land and Resource Management Plan for the Arapaho and Roosevelt National Forests, which states there will be no expansion of the ski area outside the boundaries specified in the 1993 Master Development Plan?  Community of Eldora citizens worked hard to get this language in the 1997 Forest Plan in order for there to be a spatial limit on expansion of the ski area toward Middle Boulder Creek.  If the Forest Plan is to be amended, there must be a compelling reason that has changed circumstances.
  • Boulder County Comprehensive Plan.  How is the expansion compatible with the Boulder County Comprehensive Plan, which designates Middle Boulder Creek and Fourth of July Road as Open Corridors, and portions of the backside of Bryan Mountain (including the area planned for future expansion below Corona) as part of the Indian Peaks Environmental Conservation Area?  Policies pertaining to these designations include protecting scenic corridors, preserving valuable scenic vistas in their natural state, keeping areas adjacent to natural water courses free from development, and development and management within Environmental Conservation Areas minimizing human impacts to the flora and fauna.
  • Eldora Environmental Preservation Plan.  How is the expansion compatible with the Eldora Environmental Preservation Plan (EEPP), which is a part of the Boulder County Comprehensive Plan?  Recommendations in EEPP include:
    • Protection of all threatened and endangered and sensitive species, wetlands, riparian areas and old-growth forests.
    • Limiting the eventual size and operations of the ski area, particularly in the Corona Pod.
    • Acquisition of buffers and critical habitat between the resort and the Town of Eldora.
    • Land Conservation Efforts.  How is the expansion compatible with Boulder County and community of Eldora efforts to protect the viewshed for a major gateway to the Indian Peaks by purchasing open space on Spencer Mountain and near Lost Lake?
    • Toll Property.  How is the expansion compatible with the purpose of the Forest Service acquisition of the Toll Property?  It was acquired to solve parking and trail access problems to the Indian Peaks.  Ski area expansion was not discussed at the time of the acquisition.

Environmental Impacts

  • Wildlife.  Forest Service Sensitive Species documented within the area proposed for expansion include American marten, American three-toed woodpecker and boreal owl.  Moose, black bear, mink, mountain lion, and elk also use the area.  The area contains suitable lynx habitat.  How will the expansion impact these and other species and what will be done for mitigation.
  • Wildlife Movement. The lands between the existing runs on the backside of Bryan Mountain and Middle Boulder Creek function as a landscape linkage for wildlife movement through this area, as lands to the south and north already have a high level of human use.  The possibility that this could create a migration bottleneck for animal movement along Middle Boulder Creek needs to be evaluated.
  • Landscape Fragmentation.  The existing ski runs and lifts already fragment the north side of Bryan Mountain from its top to within 980 horizontal feet of the bottom.  The width of the fragmented area is approximately ½ mile.  Dropping the final 980 horizontal feet to Middle Boulder Creek completes a ½ mile swath of fragmented landscape from top to bottom.
    • Not only may this impact movement of animals like American marten, but also smaller animals and organisms such as small mammals and ground dwelling insects.
    • There could also be impacts to the movement of plants and animals necessitated by climate change.

The EIS needs to evaluate the impacts of this fragmentation both on site and within the context of the surroundings.

  • Flora. The vegetation of the lower portion of the north slope of Bryan Mountain is dominated by trees, shrubs and an understory typical of this ecosystem – generally species favoring cool, moist closed-canopy ecosystems.  Ski runs and glades will open the canopy.  How does this impact the native flora?
  • Impacts to Wetlands.  The direct and indirect impacts to wetlands and riparian areas found between the bottom of the Indian Peaks and Corona lifts and Middle Boulder Creek that will be impacted by the proposed expansion, including the proposed bridge, needs to be evaluated.
  • More Snowmaking Means More Water.  Expansion of the ski terrain will require more snowmaking on National Forest lands and the use of more water.  How does this impact the ecology of the water sources, such as the Rocky Mountain capshell snail in Peterson Lake and the riparian habitat along Jenny Creek?
  • Watershed.  Approximately 81% of the north slope of Bryan Mountain has been fragmented by the ski area.  The remaining 19% acts as a buffer to Middle Boulder Creek for proper watershed protection.
    • Runoff and Sedimentation.  Removing a portion of the overstory forest will increase the rate of runoff from precipitation events.  The current buffer along Middle Boulder Creek below the existing Corona and Indian Peaks ski runs is 980 horizontal feet; this will be reduced to less than 50’ in locations by the new ski runs and lifts.  How will this increased runoff be handled without increasing the amount of sediment reaching Middle Boulder Creek.  What maximum level of storm will the sediment control devices be designed for and how does this compare with what currently exists?  Coarse woody debris is an important element of the existing ecosystem: will it remain on the ski slopes and glades?
    • Water Quality.  Snomax is an additive used in the making of snow.  The effects of snomax on water quality, soils, wildlife and vegetation is uncertain and little studied. There is international concern of its use as such snowmaking additives are banned in parts of Austria, Switzerland and Italy.  There is a growing concern about perflourinated compounds (PFCs) found in ski wax.  They have been linked to infertility, thyroid problems and high cholesterol, with most studies focusing on the technicians that apply the wax; again, little is known about the impacts of PFCs on water quality.  This needs to be addressed in the EIS.
  • Presence of Mountain Pine Beetle.  Mountain pine beetle is active on the backside.  What is the spatial extent of lodgepole pine and how does this relate to the location of planned ski runs and the overall opening up of the forest canopy?  Will carbaryl need to be used on the backside to control the mountain pine beetle?  How does the combination of the creation of ski runs combined with mortality from mountain pine beetle change the wind protection of the lower backside?
  • Climate Change. Given the advance of climate change, how will this change the ski area’s need for snowmaking water, how might this changed need be met, and what are the likely impacts to the hydrology and ecology of the water sources? What are the impacts of fragmentation from ski runs on the climate change driven movement of flora and fauna 50 to 100 years from now?
  • Geologic Hazard. Most of the planned expansion below the Indian Peaks and Corona pods is on an area mapped as a glacial moraine.  The west portion of Section 19 (where the future Moose Glade Express lift is located) is shown on the Geologic Hazard and Constraint Areas map of the Boulder County Comprehensive Plan as an area of “Major Geologic Hazard.”  A geotechnical analysis should be done as part of the EIS for the new lifts to determine the suitability of the area for these structures.

Impacts to Hessie/Eldora Access to Indian Peaks Wilderness

  • Scenic Impacts.  The ski lifts and runs proposed for the backside will come down the last slope to the south edge of Middle Boulder Creek and move the visual impacts of the ski runs from the midground to the foreground.  What will be the impact to the scenic backdrop for visitors accessing the Indian Peaks?
  • Noise Impacts.  Cross-country skiers and snowshoers will now experience the sounds of the ski area – lifts, grooming, downhill skiers, snowmaking, and snowmobile – as they head west from the community of Eldora for approximately 1.5 miles.  At its closest, snowmaking will be within 200 feet of recreationists using the Fourth of July road.  What will be the impacts to the acoustic experience of the recreating public that uses this area? 
  • Summer Use of South Side of Middle Boulder Creek.  It will be difficult to stop people from accessing the south side of Middle Boulder Creek and the hillside above by use of the new bridge.  This has the potential of opening up a new area to summer recreation that has had little human use.  In addition, what is the likelihood that summer recreation will become a major component of Eldora Mountain Resort’s activities, as recent Federal legislation has made possible, and how could this impact the backside of Bryan Mountain?

Impacts to Community of Eldora

  • Noise Impacts.  Will snowmaking noise levels increase from expansion on the backside?  Noise from snowmaking on the west side of town and at Hessie already exceeds normal county standards (55 decibels during the day and 50 decibels at night within residential areas 10’ from the property line).  During the 1993 Master Development Plan update statements were made that quieter snowmaking equipment would be installed.  Noise metering in the community of Eldora and at Hessie indicate noise volumes have not changed.
  • National Historic District.  The Eldora townsite has been listed by the National Park Service as a Historic District on the National Register of Historic Places (NRHP; 5BL.758).  Eldora community and Boulder County policy is to review future development proposals, including those outside the townsite, which have potential visual or noise impacts, with significant weight to the compatibility of the proposals with the maintenance of the rural and historic character.  How will the proposed expansion impact the noise and visual impacts for the community?

Ski Area Justification of Need for the Expansion

  • Need for Intermediate Terrain.  The ski area’s case for needing this expansion down to Middle Boulder Creek and Hessie is partially based on a need for more intermediate terrain. However, the deficiency of intermediate terrain can be rectified without any expansion of the backside runs below their current elevation by using other lifts and runs planned in the Master Plan.  One alternative in the EIS needs to look at how the ski area can meet its goals without expanding down to Middle Boulder Creek.
  • Wind Protection.  The ski area’s case for needing this expansion is partially based on believing that the area below the Indian Peaks and Corona pods is better wind protected.  Are there data to support a significant difference?  In addition, the creation of ski runs, glades and the ongoing mountain pine beetle epidemic may largely eliminate that protection.
  • Past Mistakes.  The ski runs of Corona were cut too wide and have led to excessive wind exposure.  The Indian Peaks lift was highly touted when created but the lift does not run during the week.  Why is the expansion on the backside going to meet any further success?
  • Risk.  Judging by the ski industry’s own research, the demand for skiing is, at best, stagnant.  Its primary demographic, the Baby Boomers, is aging and will eventually drop out of the skiing market and it is not clear that there will be a replacement demographic.  The proposed improvements to Eldora Mountain Resort are a substantial investment.  What is the likelihood of financial success?  Should public lands be a part of this risky capital venture?
  • Jobs. The ski area has been touting the number of jobs being created by the expansion.  There needs to be a complete breakdown of these jobs, including construction vs. ongoing ski operations; jobs related to each portion of the expansion (Placer, Jolly Jug, facilities); and further broken down by kinds of jobs, their pay, and their benefits.
  • Emergency Access. The ski area has been stating the need for a bridge across Middle Boulder Creek for emergency access.  The ski area has been operating for 50 years without such an emergency access.  MBCC members that have worked as emergency staff indicate that helicopter is the main means of transport.  The big snow event of 2003 caused some problems, but it was a one in 100+ year event.  Emergency personal that have looked at various options have stated other preferable routes.  This needs a thorough analysis in the EIS.
  • Climate Change. Given the advance of climate change, how will this impact the potential success of the ski area 50 to 100 years from now?

Potential Growth Inducement

  • Expansion Potential.  What is the likelihood that expansion of the ski area on its backside increases the potential for further expansion?  If the Placer lift and associated runs are approved, then the next expansion phase on the backside (Moose Glade) will more likely occur.  Ski area proponents have already expressed a desire for ski runs toward Lost Lake.  Hessie was once considered for base facilities and might be again by a future ski area owner.  What are the cumulative impacts of these potential projects?
  • Sustainability.  Ski areas are growth-based industries, as shown by the proposed expansion of Eldora Mountain Resort.  This goes against the concepts of sustainability and limiting spatial footprints, an emphasis of land use regulations in Boulder County.  There needs to be a spatial limit placed on the ski area.  That was the intention of the current wording in the Forest Plan, which states there will be no expansion of the ski area outside the boundaries specified in the 1993 Master Development Plan.
  • Jolly Jug. It is noted that the Jolly Jug lift and runs, as shown on the scoping map proposal, are significantly different than what is shown in the Master Development Plan.  This expansion, coming down near Jenny Creek, will have similar impacts and need a full evaluation.


  • Need for Joint Forest Service/Boulder County Process.  There is an indisputable connection between ski area facilities found on National Forest lands, governed by the Forest Service, and private lands, governed by Boulder County.  Expanding skier capacity means a need for more parking.  Expanding terrain requiring snow making puts greater demand on water sources.  There needs to be a joint process so all impacts can be reviewed at the same time.
  • Need for a Comprehensive Planning Process for Middle Boulder Creek. The ski area expansion is just one of several changes occurring in the area.  Parking at Hessie is an issue.  The carrying capacity of the Indian Peaks is discussed in the Forest Plan, but no action has been taken.  Traffic is a problem in Eldora and up the North Fork.  All planning is occurring in a piecemeal fashion, only looking at each individual project as if in a vacuum.  They are all interrelated.  A comprehensive planning process needs to be undertaken with all stakeholders at the table and all the issues revolving around the Indian Peaks, Hessie and the ski area on the table.