A More Detailed Look at Some of the Key Issues
Alternatives Considered But Not Analyzed in Detail
- In-Fill Alternative: We feel the Forest Service’s interpretation of the language “There will be no expansion of the area outside the boundaries currently specified in the Master Development Plan” is wrong for several reasons. First, those of us that were involved in the update of the ski area and subsequent changes to the Forest Plan in the mid-1990s clearly felt that the language was placed in the Forest Plan to limit the future size of the ski area, since they had just been allowed to expand (Indian Peaks Pod) and Forest Service staff recognized the conflict between the ski area and the local community. The language does not say “current Master Plan” but says currently specified in the Master Plan, implying the Master Plan in affect at the time the Forest Plan was approved. The ARP interpretation in the DEIS is also at fault due to the fact that the Master Development Plan is no longer approved through a public process, only accepted administratively. One administrative process (acceptance of the EMR 2011 Master Plan) should not override two plans approved through a public process (the 1994 Master Plan and the 1997 Revision of the Land and Resource Management Plan for Arapaho and Roosevelt National Forests and Pawnee National Grasslands).
- Upgrade Indian Peaks as a heavier, detachable chairlift and not include Placer Express Chairlift Alternative: The text for this alternative states “For this reason, EMR would not financially commit to a new chairlift in that location.” Why was EMR consulted in development of the DEIS? What happened to the “arms length” relationship?
Comments Pertaining to Section 3H – Fish and Wildlife
The general premise in the DEIS relative to fish and wildlife species of concern is that the impacted areas of most species represent an insignificant proportion of the total potential range on the Forest. In addition, Project Design Criteria is relied on to minimize some of the potential impacts. This approach is a form of reductionism, where each species is looked at individually and only in the context of the Forest. What is missing is a collective look at the impacted species and the context of the locality. In addition, the DEIS concludes that there are impacts to the migration corridor and habitat effectiveness.
Of the one PTES species that could potentially be found in the project area, Canada lynx, the action alternative are “likely to adversely affect” (DEIS at page 3-196).
Of the four Region 2 Sensitive Species found in the project area, the DEIS concluded that three (boreal owl, olive-sided flycatcher and American Marten) will have habitat negatively affected by the proposed actions. Two of these species, boreal owl and American marten, have been found just above Middle Boulder Creek in the project area (Middle Boulder Creek Coalition 2012).
It is not clear what the impacts will be to the Rocky Mountain capshell snail, since no recent data about their presence or absence or population numbers are available since the mid-1990s. There is a connection between placing snow on more National Forest land and where the water comes from (Peterson Lake). Unfortunately, the DEIS chose to only look at the direct impact zones of the Alternatives. Peterson Lake has been taken lower during the winter on a more consistent basis since the mid-1990s. An inadequacy of the DEIS is the lack of current data about the snail, even if just from a presence/absence basis.
Northern goshawks has been observed in and around the ski area over the years, but there are no known nests. However, the DEIS concludes that they would be affected by the removal and thinning of forest cover and that “Alternative 2 would result in the fragmentation of, and habitat losses in, the Middle Boulder Creek pod (a relatively large, intact block of high quality foraging and potential nesting habitat)” (DEIS at page 3-205).
Of the ten Management Indicator Species known to be present in the project area , the DEIS concluded that six (hairy woodpecker, golden-crowned kinglet, warbling vireo, Wilson’s warbler, American elk, and mule deer) will have habitat negatively affected by the proposed actions (with the exception of warbling vireo by Alternative 3). Five of these species (hairy woodpecker, golden-crowned kinglet, warbling vireo, American elk, and mule deer) have been found just above or along Middle Boulder Creek in the project area (Middle Boulder Creek Coalition 2012). The DEIS concludes that the three trout species found in Middle Boulder Creek and Jenny Creek (Greenback cutthroat hybrid, brook and brown) would possibly be negatively impacted by the proposed action. So nine of the ten Management Indicator Species known to be present will be or will possibly be negatively impacted by the proposed actions.
The DEIS conclusions on the loss of elk and mule deer habitat values is of interest. The action alternatives would have minor to moderate negative, permanent effects on elk and mule deer spring through fall habitats. As stated in the DEIS (page 3-216) Habitat effectiveness of these seasonal ranges would be reduced by habitat fragmentation and low levels of human activities (summer maintenance and dispersed recreation) in a larger area surrounding the habitat conversion. Construction activity displacement effects would persist for years (longer for elk than deer) and while full recovery cannot be assumed, it is possible that elk use could largely return to former levels after about seven years, as long as human use remains near current environmental baseline levels. Otherwise, most current elk use would be lost during and after intervals of human activity.” But there is a reasonable likelihood that human activity levels will not remain at current baseline levels during the summer. The “emergency access” bridge will provide a direct link for recreationists on the Fourth of July road. Both the ski area and the Forest Service have demonstrated a poor capability to control unauthorized use of their lands. And the trend for ski areas, supported by Federal legislation, is to provide more summer recreation.
Species of Local Concern
The DEIS predicts some temporary and permanent displacement of moose due to loss of cover and forage opportunities (DEIS at pages 2-65 and 3-222). The DEIS recognized that the floodplain terrace along Middle Boulder Creek is most important.
The DEIS predicts potential effects to a single beaver family in Middle Boulder Creek (DEIS at page 2-65). It should be noted that the beaver located in Middle Boulder Creek is a large colony with several lodges and spans from the Hessie Road/Fourth of July Road fork to the west end of Hessie. The decline of beaver at the ski area is noted. The use of Peterson Lake and Lake Eldora for snowmaking, particularly with a greater drawdown starting in the mid-1990s, has likely had impacts on animals and organisms using these ecosystems. Beaver appear to be having trouble sustaining themselves in the lakes and basins around the ski area. Fluctuating water levels in lakes with beaver lodges make it more difficult for beaver to make it to winter food caches and more vulnerable to predators. Historic beaver lodges on both lakes have not been active for over fifteen years.
The DEIS states “effective habitat would be reduced by the expansion of developed terrain footprints and by fragmentation of some of the larger remaining habitat blocks.” The degree of habitat effectiveness has several variables. One is the species: forest-interior species (hermit thrush, golden-crowned kinglet), often habitat specialists, are more impacted by forest fragmentation, while edge species (American robin, northern flicker, dark-eyed junco), many of which are habitat generalists, may increase. The level of human activity also influences habitat effectiveness. Much of the ski area provides effective habitat during the summer when it is primarily closed, the degree of effectiveness being influenced by special recreation events and staff maintenance projects, which are more common than in past years due to management for the mountain pine beetle.
The DEIS indicates that there are two Forest Plan goals not met by Alternative 2, with respect to effective habitat (DEIS at page 3-218). Guideline 107 states “Avoid disconnecting or severing with new open roads and trails. Favor seasonal use during non-critical times for wildlife when this cannot be avoided.” Both of the action alternatives would fragment and impair effective habitat in the project area with ski trails and lift corridors. The DEIS feels that the negative effects would be less when most wildlife is resident and most human activity is absent. But there is a reasonable likelihood that human activity levels will not remain at current baseline levels during the summer. The “emergency access” bridge will provide a direct link for recreationists on the Fourth of July road. Both the ski area and the Forest Service have demonstrated a poor capability to control unauthorized use of their lands. And the trend for ski areas, supported by Federal legislation, is to provide more summer recreation.
Guideline 108 states “When developing new open roads and trails, do not reduce contiguous areas of effective habitat to less than 250 acres or further reduce effective habitat of 20 to 250 acres in size, except where access is required by law.” The DEIS concludes that Alternative 2 would not be consistent with this guideline, because new conventional ski trails and glades would further reduce designated effective habitat of 20 to 250 acres in size (DEIS at page 3-218). With respect to the effective habitat polygon south of Middle Boulder Creek, the DEIS feels that it will not be reduced below the 250 acres threshold. This polygon extends west around the Special Use Permit area. However, if the Moose Glades Express lift, runs and glades are developed, as contemplated in the 2011 Master Plan for the ski area, then this polygon will not meet the 250 acre criteria.
The DEIS feels that Alternative 2 would be consistent with Guideline 109, which states “Additional open roads and trails should not reduce effective habitat below 50 percent by geographic area, or further reduce effective habitat in geographic areas that are already at or below 50 percent on NFS lands” (DEIS at page 3-219). The DEIS states that the effective habitat for the Boulder Creeks Geographic Area is 52%, which comes from Table 2.2 of the 1997 Revision of the Land and Resource Management Plan, Arapaho and Roosevelt National Forests and Pawnee National Grassland. However, this number is outdated. New user created trails developed since the inventory for the 1997 Forest Plan, as well as older user created trails that were not a part of the inventory, are numerous in the Boulder Creeks Geographic Area and it is likely that the current habitat effectiveness is below 50%. Both Alternatives 2 and 3 will likely further reduce the habitat effectiveness of the area and are not consistent with the Guideline.
There is discussion in the DEIS about wildlife movements along Middle Boulder Creek (DEIS at page 3-220). During Scoping our organization made assertions that the hillside on the south side of Middle Boulder Creek below the ski area functioned as a wildlife movement corridor. The DEIS describes the strip of land on the south side of the creek as “Continuous, largely forested habitat on the south side of the creek is nearly 100 percent effective, mostly buffered from north-side human activities by the high creek flows and lack of bridges (i.e., restricting human access), by the forest cover, and by the noise of the creek. It is likely that most terrestrial and arboreal wildlife movements along Middle Boulder Creek occur on the south side of the creek (i.e., because the habitat is broader and more effective [especially for forest-interior and more reclusive species]).”
The DEIS raises several issues about the corridor in terms of its effectiveness to the east, where it goes through the community of Eldora, as well as the potential impacts of the Proposed Placer ski lift and runs, implying that enough room will be left between most of the runs and the creek for wildlife movement, and there will be effective habitat in this area during the non skiing season as the bridge across the creek to the ski area will be closed and there will be little human presence.
Relative to the community of Eldora, indeed it has a set of impacts to Middle Boulder Creek. The degree of direct impact to the creek varies throughout the community and with the density of development. In order to help mitigate the impacts of the built environment, the community has been working with Boulder County to purchase the mining claims on Spencer Mountain as open space so it is retained as a wildlife movement corridor, as well as a scenic backdrop. This also constricts the footprint of the community. The creek is very close to the undeveloped portion of Spencer Mountain and there are gaps between locations of homes where wildlife can move back and forth.
To understand use of the Middle Boulder Creek/Spencer Mountain wildlife movement corridor, one needs to understand the east and west nodes where animals appear to be moving. The eastern node is the Arapaho Ranch, a montane parkland that is a center of high biodiversity. It functions for Middle Boulder Creek like Tolland Valley does for South Boulder Creek, and Caribou Ranch does for North Boulder Creek. These sites are concentration areas in the spring and fall for elk, year-round concentration areas for moose, and contain large wetlands and grasslands that are grocery stores, providing abundant small mammals and birds as food for carnivorous mammals and birds. The western nodes are several, depending on what type of habitat is desired. There are nodes of beaver enhanced willow carrs, such as the one that the road to Hessie goes through (called the Hessie Willow Carr), as well as up at Woodland Flats. Summer elk concentration areas in the Indian Peaks include Chittenden Mountain area, an area on the ridge between Jasper Creek and Woodland Creek locally called Frog Eyes, and the area southwest of Lost Lake at the top of Revenge Gulch. The animals must cross County Road 130, and then use Middle Boulder Creek, the north-facing flank of Spencer Mountain or the ridge top of Spencer to head west.
We will use two species as surrogates for general animal movement, since we know the most about their movements – moose and elk. Moose cross from the Arapaho Ranch west toward the community of Eldora at the bend in County Road 130. Some will head up Marysville Gulch to the ski area. Others will work their way through the community of Eldora, generally (but not always) staying near the creek or on its south side on the lower slopes of Spencer Mountain. They will feed in the scattered wetlands within the community along the creek. They generally move to the Hessie Willow Carr on the south side of the creek and have been seen at this site in winter. Their movement takes them through the area of the Placer Lift terminal.
Elk conduct a different movement. From 1988 through 1990 members of the herd that use the Arapaho Ranch for transitional range were tracked with the aid of radio-collars (Hallock 1991). Up to 250 elk congregate on the Ranch. Starting at the end of May and running through early July they move to higher elevations. They may calve on the Ranch or at locations as they move west. Some head along the top of Eldorado and Mineral Mountains and move to Chittenden Mountain. Others head up Marysville Gulch and follow the top of Spencer Mountain over to Ute Mountain. Some of these will end up at the upper Revenge Gulch summer concentration area. But others ended up at Chittenden, which means they had to drop and cross Middle Boulder Creek. One of their primary crossing points is the bridge along the trail – it is a wide bridge originally intended for vehicles and is located about 1/2 mile northeast of Lost Lake. Elk tracks are often present in the late lying snow fields on the south side of the bridge. After crossing the bridge they are at the ridge that takes them to the Chittenden Mountain area. While conducting field work to respond to this proposed ski area expansion, on the flanks of lower Bryan Mountain between Middle Boulder Creek and the existing ski runs, a well developed game trail, dominated by elk tracks and droppings, was observed (black bear droppings were also present). The trail is well formed in areas and very braided in others. It is mapped in Attachment 3 of the Scoping Letter from the Middle Boulder Creek Coalition (Middle Boulder Creek Coalition 2012). So it is likely that this is part of the route used by those elk that move across the ridge of Spencer Mountain and then head northwest to Chittenden Mountain Summer Concentration Area.
We feel that the wildlife movement corridor functions through the community of Eldora by being close to the undeveloped slopes of Spencer Mountain. And it is not restricted to just the first bench above the creek as it runs below the ski area, but is much wider. It is likely that other animals use this route. Sighting and signs of mountain lion, bobcat, and black bear have been observed. The old-growth spruce-fir forest below Lost lake, locally called Miner’s Hollow, is a good location to find American marten.
If the Placer lift and ski runs are developed, will the animals still use this area as a movement corridor? And what happens if Moose Glades lift, runs and glades are developed? And again, there is a reasonable likelihood that human activity levels will not remain at current baseline levels during the summer. The “emergency access” bridge will provide a direct link for recreationists on the Fourth of July road. Both the ski area and the Forest Service have demonstrated a poor capability to control unauthorized use of their lands. And the trend for ski areas, supported by Federal legislation, is to provide more summer recreation.
- Plant species of concern highlight the adverse ecological impacts that will occur above Middle Boulder Creek due to the Proposed Action (Alternative 2). Of the nine Plant Species of Local Concern that were documented within the project area, five (Lady Fern, Fairy Slipper Orchid, Oak Fern, Heartleaf Twayblade, and Club Moss) were found in the vicinity of the Placer lift, runs and glades and all would likely be adversely impacted due to the opening of the forest and greater sunlight. All of these species favor shaded, moist forests. Some of the specific impacts stated in the DEIS include:
- Indirect impacts to Lady Fern (Athyrium felix-femina var. californicum) may occur as the result of constructing P-6 trail 20 feet to the east of the only occurrence of this plant. The increased light regime could negatively affect this shade-loving plant (DEIS at page 3-273).
- Eleven occurrences of Fairy Slipper Orchid (Calypso bulbosa) were found on National Forest lands in the proposed ski terrain above Middle Boulder Creek. The proposed Placer Glades could potentially impact five of these locations, either directly through skidding logs or equipment over them, or indirectly by causing an increased light regime. The other six locations occur within 30 feet of the outside edge of P-6 trail. Again, these plants could be either directly or indirectly impacted by trail construction (DEIS at page 3-273).
- Oak fern (Gymnocarpium dryopteris) occurs along a small stream 1 to 2 feet wide on the terrace above Middle Boulder Creek. The proposed Collector trail would bisect this population, resulting in forest overstory removal and indirect impacts to 0.06 acre of this 0.10-acre population (DEIS at page 2-74).
- Heartleaf Twayblade (Listera cordata) was found within the project area and favors cool, moist ravines. Impacts to 0.29 acre of occupied habitat of this species would occur due to various proposed trails in the Placer chairlift area (DEIS at page 3-274).
- Seven populations of Club Moss (Lycopodium annotinum) were found within the project area, all on the backside of the ski area. One population is located 60 feet from the outside edge of a proposed trail associated with the Placer chairlift. Indirect impacts may occur as a result of the Proposed Action (DEIS at page 3-274).
Watershed and Soils
- The collective impacts to soils of developing ski runs lead to an increased reliance on man-made structures and activities to control erosion and handle runoff. Above Middle Boulder Creek, these ecosystem functions are currently being handled by the forested slopes above the creek, about 1,000 linear feet of forest, which should remain as a natural buffer to the creek instead of implementation of the Proposed Action. Some of the changes and impacts of the Proposed Action that will have to be dealt with by Project Design Criteria (PDCs) and Best Management Practices (BMPs) are:
- The Proposed Action will diminish the forested area within the water influence zone (generally within 100′ of a stream or body of water) in the Indian Peaks Watershed of the ski area from 90% to 65% (DEIS at page 2-70).
- Snowmelt in areas influenced by vegetative clearing (such as ski runs and glading) along with the increase in snowpack from snowmaking have higher intensity peak flows that occur earlier in the runoff season (DEIS at page 3-286). The earlier snowmelt is already occurring due to climate change; vegetation clearing and thinning further accelerates the timing of the runoff.
- The peak flow in the Indian Peaks watershed is predicted to increase by 22% due to the Proposed Action (DEIS at page 2-71).
- There will be approximately 55 acres of tree clearing for new ski trails under the proposed action, along with 25 acres of grading (DEIS at page 2-73).
- The Proposed action includes construction of a bridge over Middle Boulder Creek to access the bottom terminal (DEIS at page 2-73).
- Results of the watershed Erosion Prediction Project Model (WEPP) indicate that there would be a high probability of erosion and sediment delivered to waterways from new roads and disturbances along chairlift corridors. But with the proper implementation and maintenance or erosion control Best Management Practices (BMPs), these impacts would be minimized and sedimentation to waterways would be minor and eventually would be similar to natural rates (DEIS at page 3-299).
- Impacts from ground disturbance activities in the Proposed Action would include an increase in soil erosion and sedimentation, changes to soil physical and chemical characteristics reducing soil productivity, permanent loss of soil resources, and a potential increase in landslide and slump hazards. If the Proposed Action is carefully managed with effective erosion control, considering the low to moderate erodibility of soil management units these projects could be implemented without further impacts to the soils resource, and would not affect the soil management unit as a whole (DEIS at page 2-77).
- Approximately 2.7 acres of grading would occur in areas classified as moderate landslide potential (this occurs primarily on the northeast sloping mountainside above Middle Boulder Creek). The slope contains areas of saturated soils and minor, seasonal flowing water, so if water is encountered, surface and subsurface drainage structures may be required to intercept seepage and flow that could affect slope stability. Cut and fill slopes should be immediately stabilized with revegetation measures, mulch, erosion control fabrics, if needed, and other Best Management Practices (DEIS at page 2-77).
- Even though most soil map units have severe limitations for natural-surface roads and trails, this does not imply that the map unit is entirely unsuitable for that use, but can usually be overcome with proper Project Design Controls. However, these ratings indicate that frequent maintenance and costly erosion control measures would be required (DEIS at page 3-300).
- Most soils have severe limitations for re-establishment of vegetation and natural recovery following disturbance, primarily due to low and very low available water holding capacity and high rock content (DEIS at page 3-300).
- Field observation of the Indian Peaks and Corona ski runs after the rains of September 9-13, 2013, indicated active surface runoff, including rilling and sediment deposition along sides of runs where flow is directed into the adjacent forest, as well as at the base. This adds to the impact zone of the ski runs. Severe weather events like that of last September can overcome the design standards of PDCs and BMPs. Additionally, forests are superior than grasslands at intercepting rainfall and controlling runoff.
- In total, approximately 37 acres of wetlands were mapped for the study area, including: 16 acres of forested wetlands, approximately 10 acres of scrub-shrub wetlands, and 11 acres of emergent wetlands. These wetlands mainly occur along Middle Boulder Creek and its stream terrace, on the forested slopes above Middle Boulder Creek, in ski runs, and along Jenny Creek (DEIS at page 3-294).
- The Proposed Action would directly/permanently impact 0.07 acre of wetland. In addition, there would be 0.02 acre of temporary wetland impacts for the installation of utility lines, which would be restored post-construction. The permanently impacted wetland acreage will be mitigated most likely by purchasing compensatory wetland acreage from a wetland mitigation bank (DEIS at page 3-312). The most likely wetland bank for compensation is located near Erie (Phone conservation with Terry McKee, USACOE, on March 13, 2014).
- Indirect impacts to wetlands through forestry overstory removal are expected to impact 1.41 acres of wetlands associated with the proposed Placer chairlift line and associated ski trails on the slope above Middle Boulder Creek. The forested overstory removal would likely cause a change in the species composition of the wetlands away from shade tolerant species to more sun tolerant species. In addition, snow compaction from ski trail grooming and skier use may affect the underlying wetlands by increasing frost depth and delaying plant phenological development (DEIS at page 3-312).
- It should be noted that since the inception of Eldora Mountain Resort, approximately 30 acres of wetland have been filled, most of this in the main parking lot. This is the third largest wetland fill known in Boulder County (Hallock et al. 1986). We are troubled by the fact that the mitigation site will be far from the Middle Boulder Creek basin. We need no net loss of wetlands within this basin.
We feel that the analysis of scenery resources is inadequate and disagree with a number of the conclusions.
- The context of the site, being a major portal for access to the Indian Peaks Wilderness and the Fourth of July Valley, is disregarded in terms of sensitivity of the viewscape. The primary frame of reference of the DEIS is towards the ISO of the ski area, hence the goal is to achieve a low level (moderately altered) of scenic integrity. Somewhere, the fact that this is an entrance to the Indian Peaks, not just in summer but in winter where recreationalists are snowshoeing, walking and skiing, needs to influence the sensitivity of the viewscape. It is probable that the Toll Property should have been given a 4.3 – Dispersed Recreation prescription. And one of the goals of the current effort to manage parking at Hessie is to prohibit parking at Hessie proper, with only trail access.
- The analysis in the DEIS lumps the visual impacts of the new lifts and trails together with the visual impacts of the existing improvements, particularly on the backside. For instance, when discussing the visual impacts from Critical Viewpoints #2, the DEIS states “Existing ski trails and minimal glading are currently visible from this location, so an incremental visual change would be experienced from this critical viewpoint (page 3-77). This same conclusion is voiced for Critical Viewpoint #3 (DEIS at page 3-78). However, the new improvements will place more of the visual impacts in the foreground and much closer to the viewing public. They are less visually subordinate to the landscape character and less compatible or complimentary to the character of the landscape being viewed when placed in the foreground. In addition, the analysis is more geared towards the summer landscape (see the description of colors and contrast, DEIS at page 3-70). During winter there is greater contrast between the white of the ski runs and green of the surrounding forest (after the wind has blown off new snow). For example, see Photo Point 4 in the MBCC Scoping Comments (Middle Boulder Creek Coalition 2012).
- We feel a lot was missed in the selection of the Critical Viewpoints. There are locations between Critical Viewpoints 1 and 3 where there are superior views through the trees along CR 130 of the hillside above Middle Boulder Creek than what was chosen. The “Ground View” of Critical Viewpoint 4 should have been angled up so the runs could be seen. Hessie Townsite should have been chosen as a Critical Viewpoint. The hillside where the ski runs come down toward Middle Boulder Creek is an important part of the foreground to midground backdrop when hiking east through the townsite (see Photo Point 7A in the MBCC Scoping Comments). Another viewshed where the Proposed action would be visible is coming down from Lost Lake (see Photo Point 8A in the MBCC Scoping Comments).
- There appears to be some feeling that relative to whatever scenic impacts exist from the Proposed Action along CR 130, the duration of the view experienced by recreationalists is expected to be relatively short (DEIS at page 3-79). We don’t feel this is an accurate representation of how recreationalists use CR 130 during winter. Recreationalists park at the end of the paved road at the west end of Eldora during the winter. The primary forms of travel are snowshoe, walking (in the snow – it has become very popular, much to the chagrin of cross-country skiers) and cross-country skiing. On a weekend or holiday there can be over 75 cars parked at the west end of Eldora. Many recreationalists don’t go very far, but let’s say that Lost Lake is an average destination. It is 2.6 miles from the west end of Eldora. From the first major bend in the road (where you can start seeing the ski lifts and runs) to the Hessie fork is a half mile; 20% of a round trip to and from Lost Lake would be directly below the Placer lift and runs. From the first major bend to the west end of Hessie is .8 miles; 31% of the round trip to and from Lost Lake would have the sites of the new ski runs as part of the foreground. And if the next phase of ski area expansion on the backside is built, as proposed in the 2011 Master Development Plan (Moose Glade Express chairlift and terrain), the visual presence in the foreground will increase.
We feel that the analysis of noise impacts is deficient. At a meeting in the fall of 2012 between representatives of the Forest Service, SE Group, and MBCC, to a person, we feel there was a promise made by the Forest Service and SE Group to conduct a complete soundscape analysis with noise measurements being taken at several locations starting in the center of Eldora and going up to Hessie. The analysis conducted in the DEIS is qualitative and there is much conjecture. This is a major inadequacy of the DEIS.
- The DEIS provides information about the sound generation of each snowmaking gun and states when there are two guns, the sound level is not additive DIES at page 3-121). But what is the sound level from 20 or more guns lined up on each side of a ski run? That is the scenario witnessed for making snow on a ski run.
- The qualitative analysis throughout this section of the DEIS describes the ridgeline between the community of Eldora and the ski runs on the back side and concludes that this ridgeline dampens the noise originating from the ski area (snowmaking, grooming vehicles, etc.; DEIS at pages 3-121, 3-125, 3-126 and other locations). We feel this assumption is in error. The valley of Middle Boulder Creek is a glaciated U-shaped valley, having walls on both sides. Sounds reverberate in the valley, bouncing off of the opposite valley wall, as well as the wall on the side where it emanates. The valley wall opposite the backside ski runs has several large rock outcrops, which assist in the sound reverberating. Those of us that have lived in valleys understand the phenomena that you often hear a sound better on the opposite side of the valley than on the same side. We feel it is likely that there is no dampening of the noise originating on the backside of the ski area by the ridgeline.
- In the DEIS’ rebuttal of the sound measurements taken during the winter of 1994/95 DEIS at page 3-122), the implication is that the measured sound levels, which were equal to a person talking at 3 feet away or an electric shaver at 1.5 feet. The point was missed. These readings were of snowmaking sounds emanating from where the ski runs are currently located – generally well over 1,000 feet away. What will the sound be like when 20 or more ski guns are located from 160 feet (the approximate distance of the bottom of Placer lift; Paul Alford email communication of March 14, 2014) to 1,000 feet in a valley with walls on both sides? Wouldn’t someone talking to you all day or your shaver running all day be annoying?
- We strongly feel that the acoustic experience of winter recreationalists using the trail (CR 130) west of the community of Eldora will be degraded by the presence of the ski lift and runs coming down to Middle Boulder Creek. The ambient soundscape includes all the sound emanating from the ski area, including snowmaking, lifts, the occasional snowmobile, and the sounds of skiers coming downhill. Many of us enjoy snowshoeing and cross-country-skiing and this is not the experience we desire when heading out on the trial. These sounds could be a significant portion of a daily outing. Many recreationalists don’t go very far, but let’s say that Lost Lake is an average destination. It is 2.6 miles from the west end of Eldora. From the west end of the community of Eldora (where you can begin hearing snowmaking) to the Hessie fork is .75 mile; 29% of a round trip to and from Lost Lake would be directly below the Placer lift and runs and be directly within the soundscape of the ski area. From the west end of the community of Eldora to the west end of Hessie is 1.05 miles; 40% of the round trip to and from Lost Lake would be within the ski area’s soundscape. And under the right conditions, the sound will likely be heard on the switchback on the trail heading to Lost Lake but before the cascades, which is 1.75 miles from the west end of Eldora; 67% of the trip would be within the ski area’s soundscape. And if the next phase of ski area expansion on the backside is built, as proposed in the 2011 Master Development Plan (Moose Glade Express chairlift and terrain), the acoustic presence of the ski area will increase.
Vegetation Management Projects
- Several points regarding vegetation management.
- It should be noted that the thinning and tree removal for Forest Health will decrease wind resistance.
- One of the reasons we are against coming down to Middle Boulder Creek with lifts and runs is it could lead to the spraying of carbaryl closer to the creek. It should be noted that on their private lands, EMR claims to be following Forest Service standards for spraying of carbaryl (100 feet from wetlands and bodies of water), but do not practice that: they have been keeping buffers of 50 feet.
- P6 Sanitation/Salvage with Removal in Lodgepole Pine Stands: If you are increasing regeneration of other species and increasing age class diversity, you are likely increasing ladder fuels.
- The cumulative impacts need to include the following existing conditions:
- Open space lands being purchased by Boulder County and the Eldora Civic Association around the community of Eldora, Hessie, Lost Lake and other sites in the Indian Peaks.
- The Hessie Parking Plan and summer Shuttle.
- The cumulative impacts need to include the following reasonably foreseeable future conditions:
- Summer recreation at EMR.
- The failure of the gated bridge below the Placer lift to keep out hikers and mountain bikers.
- Climate change is inadequately addressed. The following needs to be analyzed in the DEIS:
- The full carbon footprint of each alternative, including, but not limited to, traffic to and from the ski area, energy used for various services, including snowmaking, carbon sinks lost due to the removal of trees.
- How climate change, based on current predictions, may affect the viability of each alternative.
- There is no discussion of local land use plans and how each alternative fits into these plans.
- There is a need for quantifiable wind data. Throughout the DEIS an argument is made that one of the benefits of the Placer Lift is that it will be less impacted by the wind and can stay open during more high wind events. But there are no data to support this line of thinking. At a meeting in the fall of 2012 between representatives of the Forest Service, SE Group, and MBCC, to a person, we feel there was a promise made by the Forest Service and SE Group to measure wind speed at various locations on the back side. The analysis conducted in the DEIS is qualitative and there is much conjecture. This is a major inadequacy of the DEIS.
Hallock, David. 1991. Lake Eldora Ski Area Elk Study. Unpublished report prepared for Eldora Mountain Resort and the Colorado Division of Wildlife.
Hallock, D., N. Lederer, and M. Figgs. 1986. Ecology, Status and Avifauna of Willow Carrs in Boulder County. Boulder County Nature Association Publication No. 4. 38 pp.
Middle Boulder Creek Coalition. 2012. Letter to Sylvia Clark from the Middle Boulder Creek Coalition regarding Eldora Mountain Resort Ski Area EIS Projects. August 31, 2012.