Category Archives: FOBOS Position

Position on West TSA CCG Recommendations

Open Space Board of Trustees
January 17, 2011
Dear Board Members:

Friends of Boulder Open Space has followed the West Trail Study Area process from the start. Despite some hiccups along the way, we believe that the Community Collaborative Group process has resulted in the most representative public participation of any of the Trail Study Areas so far. By participating in e-mail communications and in-person meetings, the Conservation Caucus has gained input and garnered support from the conservation community. The outcome is a set of compromise recommendations that balance the interests of the entire Boulder community, while fulfilling our responsibilities for stewardship of the unique landscape and ecosystems in a way that is sustainable over time.

FOBOS supports the consensus recommendations of the CCG, while recognizing compromises made by the CCG in many areas that we see as less than optimal:

  • The consensus recommendations constitute a delicate balance between the many interests that were represented on the CCG. Altering specific items could risk upsetting the community support that has been achieved.
  • The TSA-wide recommendations on Education, Enforcement, and Adaptive Management (p. 6) are particularly critical in our view. Monitoring actual results and making needed adjustments when required will be essential if the Department is to achieve the objectives envisioned in the recommendations.
  • We therefore recommend that the Board adopt the CCG recommendations.

With regard to the non-consensus issue of mountain bikes, we have carefully examined each of the mountain bike routes that has been proposed for the West TSA, and we have concluded, as detailed in the attached position, that biking is not an appropriate use in the WTSA, with the exceptions noted. We would caution the board that only specific proposals can be considered responsibly. The actual environmental consequences and user-conflicts of any proposal are only apparent when examined in detail and on the ground. Planning for the West TSA is now beyond the stage where vague proposals are truly meaningful.

Thanks for your attention,

Mary McQuiston, for the FOBOS Board

 

attachments: FOBOS position on bikes in the West TSA
Tim Hogan analysis of bicycles on Open Space
Sharon Collinge statement on the Precautionary Principle

Friends of Boulder Open Space Position on Mountain Bikes in the West Trail Study Area
Uses of open space have been growing rapidly. Inevitable pressures to expand the existing system of trails and to allow additional uses compete with the importance of these lands as wildlife habitat and with the long-term conservation of natural values and resources.

FOBOS, with a membership of two hundred Boulder citizens, seeks to serve the community’s need for an organized voice representing our interest in the preservation of the health and viability of these lands and ecosystems for future generations.

Natural Resource Issues for the West TSA South of Boulder Canyon
OSMP has the responsibility to provide for passive recreation and to preserve the natural resources of the mountain backdrop in perpetuity. Bicycling is specified in the Charter as an activity that is permitted where designated.

We have investigated each of the proposals made for mountain bike use in the West TSA in detail on the ground. Despite the commendable attempts of the cycling advocates to propose routes that do not have unacceptable adverse impact on natural resources, these attempts have been unsuccessful.

Specifically, several north-south routes have been proposed that parallel the Mesa Trail from Chautauqua to Eldorado Springs Drive. Each has specific insurmountable issues, but they can be summarized in a fairly straightforward way:

  • The West TSA along the mountain front is constrained on the east by the urban boundary and on the west by the steep rocks of the Dakota, Lyons, and Fountain Formations. Existing trails occupy most of the routes around these obstacles and riparian and wildlife corridors are squeezed into the remaining spaces. We already have a dense network of popular and heavily used trails. Coming up with an additional north-south trail corridor that does not fragment already stressed habitat and ecosystems is not feasible.
  • On-the-ground examination of actual routes inevitably finds serious routing problems and conflicts where corridors are constrained by drainages or rock spurs, as at Bear Creek or Skunk Creek.
  • Existing trails are already heavily used, so any routing combination inevitably causes user conflicts, and experience in many locations makes clear that many hikers will be displaced, resulting in additional use on other trails with consequent increased pressure on wildlife and plant communities.

Southern Grassland area—Greenbriar to South Boulder Creek
Some have proposed this area as a suitable location to accommodate mountain bike use in the West TSA. FOBOS considers this to be an unacceptable sacrifice of well-established critical ecosystems for an inappropriate and unnecessary use. The area around Big Bluestem and South Boulder Creek Trails is recognized as extremely valuable and threatened prairie grassland. Much of it is included in the Colorado Tallgrass Prairie State Natural Area for that reason. It is particularly sensitive to excessive off-trail use and braiding.

The terrain is similar to that around the Coal Seam Trail, so the behavior of cyclists can be expected to mirror use there. The Coal Seam Trail had significant braiding, trail widening, and erosion due to off-trail use for passing and dodging around cobbles, and it had to be reconstructed less than a year after it opened. Similar use would cause far more damage in the Big Bluestem-South Boulder Creek area, because of the more sensitive and valuable vegetation and greater seasonal muddiness. This damage is unacceptable. The terrain does not permit construction techniques to prevent such problems—it is too open.

Other Issues
Many trails in the OSMP system are open to mountain biking, as are other public lands in the immediate area. Mountain biking is not an underserved use, and not every use can be accommodated everywhere. A significant number of additional OSMP trails have been opened and constructed for mountain bikes in the last two years at Marshall Mesa and Doudy Draw. OSMP is still dealing with significant user conflicts and perceived hiker displacement on the Springbrook Trail and in the Marshall Mesa area. Major use by commercial outfitters is posing additional pressure that has not been addressed. It would be extremely unwise to create more conflict by opening trails just to the north to mountain bikes, creating more use, more conflict and almost certain displacement of hikers.

The OSMP 2010 Resident Survey shows that the great majority of open space users are hikers. The issue of conflict with mountain bikes is apparent in the survey, and we urge the department and the OSBT to pay attention:

  • In response to the question: “Activities of other users of Open Space and Mtn Parks areas could make your own experience more pleasant or less pleasant. How do the following activities affect your experience?” here are the results for respondents who had visited OSMP areas:
  • Overall/all responses: Mtn Bikers: 11% more pleasant ; 45% no effect; 43% less pleasant [and when you look at just the responses of hikers/walkers who had visited OSMP areas, 48% say “less pleasant”].

These results are bound to understate the reactions that can be expected in the West TSA, where hikers do not currently contend with mountain bikes, which have been excluded since 1987 due to user conflicts in the preceding years.

Finally, we note that there has been considerable discussion about the need for mountain bike trails through the West TSA to allow residents to access the southern trails without having to drive. This argument has little merit. It is easy to ride from anywhere in Boulder to the Marshall Mesa Trailhead today, using city bike paths, and the minimum-traffic frontage road to Marshall. Further access along Community Ditch Trail is already planned to have the road crossing eliminated with an underpass, which will open even more trails without requiring use of the highway shoulder.

In summary, environmental and user-conflict considerations both strongly indicate that trails in the main part of the West TSA should not be designated for mountain bikes.

Friends of Boulder Open Space supports OSMP efforts to find a route for mountain bikes on Chapman Drive, if that should prove feasible. We suggest that safety considerations dictate that if this route becomes possible, bikes should be permitted only uphill on Chapman Drive (downhill travel should be via Flagstaff Road).

Mountain Bikes in the Boulder Mountain Parks Area
by Tim Hogan

One of the more controversial issues to be resolved in the West Trail Study Area planning process concerns the matter of mountain bike access to the Boulder Mountain Parks and surrounding lands. These comments address many of the arguments proffered by the mountain biking community for increased access to this natural area. My primary source for the mountain biking perspective comes from the website of the Boulder Mountain Biking Alliance.

Mountain biking began to emerge as a public lands issue in the early 1980s, and at that time the Boulder Mountain Parks (a separate entity from Open Space at the time) decided not to open up its lands to this new use. Then, as now, the concern was as much about visitor conflict as ecological impacts. In the last 25 years riding has become a huge industry and an activity that many outdoor enthusiasts enjoy. We now find ourselves in a position where a well organized and insistent group of riders are clamoring for access to one of the most treasured and popular natural areas in the Front Range. There is no wonder why they would love to ride through the forests and grasslands in the shadow of the Flatirons. The question is whether the most heavily used area of this relatively small area can support mountain biking without undermining the experience of other visitors and the welfare of plant and animal communities.

Under-served: Riders claim they are under-served in Boulder. This claim is meant to draw attention to their exclusion in the Mountain Parks, but ignores the number of trails available to riders on public lands in Boulder County as a whole. (Surrounding counties provide additional opportunities.) Nearly 200 miles of trails, or 52% of non-motorized trails in the county are open to riders. [USFS numbers are skewed due to the number of trail miles in designated Wilderness Areas from which mechanical conveyance is legislatively excluded.]

The numbers for the three major public land agencies in Boulder County:

  • Agency Mileage [Total/Biking] (Biking %)
  • City OSMP 144/49 (34%)
  • County OS 106/89 (84%)
  • USFS 135/61 (45%)
  • Total 385/199 (52%)

If Boulder mountain bikers are under-served, one might also ask why there are so many riders in the Boulder area? And why have such organizations as the International Mountain Bicycling Association (IMBA) and Bikes Belong chosen to headquarter themselves in Boulder?

Unfair to Exclude: Riders claim it is unfair to exclude them from trails, without seeming to recognize their presence on trails effectively excludes many other users who do not feel comfortable with bikes. The high numbers of riders as the percentage of users on certain trails (Hall and Walker – 56%) reflects this exclusionary effect more than anything else. Calling for “Multi-Use-Trails” leads to trails dominated by bikes.

Ecological Impacts: The BMA website includes a review article that cites numerous studies giving ambivalent results regarding the impacts of riders vs. hikers. The author of the review states: “The two comparative studies discerned minimal differences between bicycling and hiking. These studies may not resolve the continuing debate over who does what to trails. This scientific inquiry needs to be repeated in other geographic locations, on other soils, with more passages by each user group.” For Boulder residents, a visit to Hall Ranch Open Space, and a simple look at the difference between the Bitterbrush (bikes) and Nighthawk (no bikes) trails makes the difference in impacts dramatically clear.

In many places this may be more of an esthetic issue – trail width – than a truly ecological one. Riders are probably correct when they claim that dogs and horses have more of an impact on plants and animals than bikes.

One non-controversial point is that new trails in previously undisturbed habitat do have ecological impacts. If the mountain bike community proposes a new route between the Shannahan Mesa area and Big Bluestem, or the establishment of loop trails proximate to South Boulder Creek, these should be vigorously opposed by conservationists.

Finally, an ecological effect not usually recognized arises from the observation that “the faster you go, the smaller the area.” Ten miles for most walkers is a pretty long day. Everything else being equal, a rider would probably want something twice as far. This dynamic is another reason the demand for trails from mountain bikers is so high, and, to some extent, why the impacts of riders across the landscape is greater than walkers.

Carbon Footprint: It is repeatedly heard that a north-south mountain biking route between Chautauqua and Eldorado Springs would result in fewer miles being driven by cars, and a reduction in CO2 emissions. Again, it is easy to understand why riders would desire such a route, but this particular claim is a bit labored. No doubt, some hardcore Eldorado residents might ride such a route on a regular basis, and many locals would ride it routinely. But the net result would be a dramatic increase in automobile use by out-of-town riders from up and down the Front Range. Such an attraction would not only result in more driving and emissions, but also significantly increase parking demand at the Chautauqua and the South Mesa trailheads – two of the most heavily used trailheads in the system. Of course, this increased demand would have both economic and visitor management impacts as well.

Trail Work: The mountain biking community, like other off-road user groups, has learned the value of being good citizens, and has put in significant time and labor toward the construction and maintenance of trails on which they ride. This is commendable, and in these fiscally troubled times, a real contribution. But their implicit argument that such a contribution gives them a greater right than other users is disingenuous. From the Appalachian Mountain Club on the east coast to the Sierra Club on the west, hikers have been working on trails for over a century. In my experience, this was always viewed as more of a “gift exchange,” freely given out of appreciation, rather than as a bargaining chip. To be frank, the manner in which this chip is being played by BMA and others is a bit unseemly.

Visitor Master Plan (2005) and Charter (1986): The quotes culled from the Visitor Management Plan on the BMA website recognizes “unmet desires” by the biking community, a recommendation to “consider a possible mountain bike (multi-use) trail corridor from the frontside to the backside of Mountain Parks,” and an openness to work with the biking community to explore their requests and reduce visitor conflict. There is no mention of a north-south route between Baseline and Eldorado, nor is there any mention of building new trails to accommodate riders.

The Open Space Charter placed a strong emphasis on the “preservation” of open space lands for their natural values, and made specific provisions for “passive” recreation defined by example as “hiking, photography, or nature studies;” and, if “specifically designated,” bicycling, horseback riding, or fishing.” This categorizing of bikes as a special designation indicates that by the time riding had emerged as a significant land-use issue (1986), the city was doubtful about its inclusion as a passive activity.

Conclusion:

  • A well organized and vocal sector of the mountain biking community is keen to gain access to these parklands.
  • Exploring an east-west connection between Eldorado Canyon State Park and Walker Ranch may be reasonable.
  • It is much harder to see how a north-south trail between Boulder and Eldorado might be routed that would not result in unacceptable visitor conflict.
  • Mixing bikes with families, runners, and unleashed dogs in the passive recreation areas along the east side would be a visitor management debacle.
  • Their impact on trails is indisputable, and proposals to construct new single tracks have significant economic and ecological costs.
  • It is not due to a dearth of mountain biking opportunities that the Boulder area is one of the most renowned places in the country for riders.
  • Many people who enjoy a more quiet experience of the Mountain Park would be genuinely distressed if bikes were permitted.
  • Not every parcel of public land needs to be available to every recreational use.

Why Caution is Needed

by Sharon K. Collinge, Professor, of Ecology and Evolutionary Biology, University of Colorado

“Indications of changes in the earth’s future climate must be treated with the utmost seriousness, and with the precautionary principle uppermost in our minds. Extensive climate changes may alter and threaten the living conditions of much of mankind.”  2007 Nobel Peace Prize Award.

A recent letter to the editor in the Daily Camera criticized the use of the precautionary principle in management of Boulder’s Open Space by stating that “This ‘precaution’ overrides science and data in favor of policies critical of all possible human impacts.”

Put simply, the precautionary principle is an approach that seeks to avoid unintended consequences of particular actions. Rather than ‘overriding’ science and data, this principle explicitly acknowledges the centrality of scientific data to decision-making. Most importantly, it suggests a guiding strategy for managers faced with the uncertainties and knowledge gaps that will always exist in our understanding of a situation.

We will manage Boulder’s Open Space most effectively with a similar approach.

Although we do not know everything there is to know about human impacts on native grasslands, forests, and streams, there is ample scientific evidence showing that increased human activities lead to environmental degradation. This warrants a cautious approach to management of our local public lands.

To avoid unintended consequences we must clearly state our intended consequences by asking, “What do we want Open Space lands to look like in the future—say 5, 10, 20, 50 years from now?” “What condition of the natural environment is acceptable?” “How do we ensure that our actions are sustainable?” If we want the status of our Open Space to be the same as it is or even better 20 years from now, then we must avoid actions that fragment, degrade, and destroy the land and its species. That’s exactly why the precautionary principle is vital in managing our valuable Open Space.

The OSMP Draft Grasslands Plan

Comments by Friends of Boulder Open Space
March 30, 2009

More than half of our city open space lands are grass-dominated ecosystems, remnants of landscapes that once covered much larger areas along the Front Range of the Rockies. They are important in part because they are protected. For the first time, OSMP has taken a close look at their composition and their condition. The draft report reveals the remarkable diversity of life they support.

Plan Overview
The purpose of the report is to “provide a framework of on-the-ground management … priorities to conserve the ecological values ….” Development of this plan follows a six-year process (1999-2005) that produced the Visitor Master Plan and a three-year period (2005-2008) in which two “trail study area” plans were completed. Only now are we developing an understanding of the lands and resources that is essential for their long-term management and that should have preceded any decisions about their long-term uses.

Although driven in part by concern about prairie dog management, the grasslands plan is fundamentally a conservation plan. It is addressed first and foremost to the physical and natural environment of the lands, and its primary objective is to determine their important ecological values and actions needed to maintain and enhance these values. The analysis provides a much needed baseline for these lands and begins the process of putting in place objectives and initiatives to guide future management.

Using a scale that ranges from very good, good, fair, to poor, the plan concludes the overall condition of the grasslands to be fair. The plan divides the grasslands area into seven “targets” for analysis: mixedgrass prairie mosaic, xeric tallgrass prairie, agriculture, black-tailed prairie dogs and associates, wetlands, creeks and riparian areas, and White Rocks. For each target the plan identifies existing condition and objectives for improving conditions.

The report assesses threats to its conservation targets and determines an overall threat ranking of “very high.” Threats identified as “critical” are incompatible trails/recreation, surrounding land uses, incompatible practices by dog guardians, and incompatible water management/use as well as invasive plant species, non-native leopard frog predators, and inappropriate fire management. The analysis also identifies what are termed “best opportunity” areas for achieving conservation objectives. For example, the largest available blocks of habitat types on open space lands provide the best opportunities for conservation of the associated ecosystems.

Finally the report outlines a list of conservation objectives that represent staff determination of priorities for the grassland planning area. These include objectives directed at prairie dog management, bald eagles, weeds, vegetation composition and structure, butterflies, avian habitat, aquatic and riparian resources, leopard frogs, and agriculture.

Our Perspective
The grasslands within the OSMP system are protected because they exist on lands purchased or protected by the city to shape its development boundaries and to provide a buffer from neighboring development. In some cases these lands contain “terrain, geologic formations, flora, or fauna that is unusual, spectacular, historically important, scientifically valuable, or unique, or that represent outstanding rare examples of native species; ….” Much of the land contains areas of agricultural use, including grazing and irrigated meadows for hay. These lands also provide important opportunities for passive recreation.

While it has taken more than 40 years, acquisition of these lands may turn out to have been the easy part. Now we are faced with the challenge of determining as a community how we want to manage them. The Grassland Ecosystem Management Plan is the first step in taking a comprehensive look at our grasslands, determining what we have, assessing their condition, and beginning the work of deciding what our long-term objectives for these lands are.

In our view, the initial task is to determine what habitat these lands provide and the quality of that habitat. We believe our first priority is to protect and enhance this habitat.

What the Plan Tells Us
Of the three primary grassland types, the most common is the mixed prairie mosaic. Such grassland types are found widely in the Great Plains and the Intermontane West. Nevertheless, there are important reasons to manage these lands for their habitat values. Particularly in the large blocks, these lands provide important nesting habitat for many species of grasslands-obligate birds. Among the many vertebrate species identified on these lands are such “uncommon” species as the short-horned lizard, olive-backed pocket mouse, and several rare butterfly species. In addition to the value of periodic fire to renew essential ecological processes, the single most critical management requirement is to maintain existing unfragmented habitat blocks. Unique areas such as the shale barrens located on lands in the northern part of the system require special protection.

Prairie dogs are found most commonly within these mixed prairie mosaic lands. Boulder’s protection of lands with these characteristics has provided protection as well for prairie dogs. Under pre-development conditions, prairie dogs established colonies in such areas while living off the associated vegetation. As food sources diminished, prairie dogs would move to different lands. With rest and moisture the previously colonized lands reestablished their vegetation. With extensive human habitation and use of former prairie lands in Boulder County, prairie dogs have few places to go. Only periodic plague events seem to reduce prairie dog populations, allowing colonized lands some time to recover.

OSMP grasslands also include a relatively large amount of xeric tallgrass prairie, characterized by the presence of big bluestem. This prairie type is predominantly located along the foothills at elevations above the town of Boulder. Xeric tallgrass prairie is much less common in Colorado and globally than the mixedgrass prairie mosaic, and its presence on city open space warrants special management attention. Of special importance is their value as habitat for rare butterflies, including Ottoe skipper, Arogos skipper, crossline skipper, and regal fritillary. Large, unfragmented blocks provide important nesting habitat for a number of grassland birds. Elk graze these grasslands seasonally.

The third grassland type found on OSMP lands is the mesic bluestem prairie. The largest remnants of this type in Colorado are found here in Boulder. Lands containing mesic bluestem prairie are located in about 20 patches from about 5 to 65 acres. One such area was designated the Colorado Tallgrass Prairie State Natural Area in 1984. This prairie type also provides important habitat for rare butterflies, nesting habitat for grassland birds, including bobolinks, and “robust” rodent populations that attract a large number of raptor types. These small but unique areas are clearly deserving of special management attention.

While riparian areas and wetlands are also discussed in this plan we would prefer to see these critical water-dependent habitats treated separately and so defer any additional comments at this point. Separate treatment would allow consideration of ways to improve the in-channel habitat of our perennial and intermittent streams.

What We Would Like to See

1. Respecting prairie dogs

We are fortunate in Boulder County to have protected prairie landscapes in which prairie dogs can still live and thrive. They are an important part of the prairie ecosystem that must be sustained. Yet we see prairie dogs in the larger context of the landscape. Our primary concern is ecosystem health, including all the component parts.

Thus we support staff conclusions that there are carrying capacity considerations that must be taken into account when managing OSMP grasslands for prairie dogs. We cannot independently evaluate recommendations for minimum and maximum occupied acreage and their distribution, but we are concerned that allowing prairie dog populations to cover too much of the suitable habitat at any one time threatens the viability of this habitat. We have observed areas with peak populations that have become virtually denuded of vegetation. During the high wind events in January 2009 we observed dust storms emanating from one such area on open space land near Highways 93 and 128 that made driving unsafe. We do not believe bubonic plague is a good management device for regulating numbers of prairie dogs.

We recognize prairie dog management is one of OSMP’s greatest challenges. The plan provides much better information about the extent of OSMP lands suitable for prairie dog habitation as well as about other ecosystem considerations. We support implementation of the plan’s actions respecting prairie dogs.

2. Respecting fire

Lack of fire appears to be one of the most important missing ecological drivers for our grasslands. We appreciate the complexities of controlled burns but believe fire is essential if the prairie systems are to improve. We encourage OSMP to work on public education about the importance of fire in maintaining healthy grasslands and to continue efforts to utilize controlled burns when possible.

3. Respecting grazing

The report identifies concerns about a homogenization of vegetation communities in both the mixedgrass and mesic bluestem areas and notes the potential adverse effects of livestock grazing in this regard. With this baseline condition respecting vegetation now in place we would encourage a review of livestock grazing practices and some experimentation with altered regimes to test effects on vegetation.

4. Respecting animal species composition, vegetation composition, and habitat effectiveness

The report identifies animal species and vegetation composition as key attributes for the three prairie types. It identifies as indicators for animal species composition the percent occurrence of sensitive butterflies and skipper species, the percent occurrence of grassland dependent butterflies and skipper species, and percent of target with acceptable bird conservation score. As indicators for vegetation composition it identifies native species relative cover, native species richness, percent of target with prevalence of non-native species, and richness of selected conservative plant species.

We wonder about the utility of utilizing such broadly descriptive attributes rather than focusing on attributes that help identify the ecological processes essential to conservation of the target. Thus, for example, in a recent TNC report there is the following explanation of attributes:

To identify what is most important to manage for the conservation of biodiversity in focal areas, we first identify a limited number of biological characteristics, ecological processes, and/or interactions with the physical environment—along with the critical causal links among them—that distinguish the target from others, shape its natural variation over time and space, and typify an exemplary reference occurrence (Maddox et al. 2001). Some of these characteristics are especially important, influencing many other characteristics of the target and its long-term persistence. We label these characteristics of a target its key ecological attributes.

The main premise of The Nature Conservancy’s conservation framework is that key ecological attributes must be managed and conserved to sustain each conservation target (Parish et al. 2003). By explicitly identifying such attributes, land managers can specify what elements of a specific conservation targets are important to manage and monitor in order to assess conservation progress.

The key ecological attributes of a conservation target include not only its biological composition (and crucial patterns of variation in this composition over space) but also the biotic interactions and processes (including disturbance and succession dynamics), environmental regimes and constraints (again including disturbance dynamics), and attributes of landscape structure and architecture that sustain the target’s composition and its natural dynamics (Noss 1990, 1996, Noss et al. 1995, Christensen et al. 1996, Schwartz 1999, Poiani et al. 2000, TNC 2000a, Young and Sanzone 2002). Identifying key attributes that address more than just biotic composition is important for two reasons. First, the abundance and composition of a target may lag in its responses to environmental impairments. Data on biotic interactions, environmental regimes, and landscape structure can help ensure the early detection of threats and changes resulting from human activities. Second, conserving the focal targets is not the ultimate goal but a means for conserving all native biodiversity in an area. Consideration of these additional types of key ecological attributes will further ensure that crucial aspects of ecological integrity are managed for the conservation of all native biodiversity.

Development of a baseline identifying animal and plant composition provides a marker against which to measure change. More important, however, for purposes of management is to identify those factors that shape and sustain this composition. We are not sure the present analysis does this.

5. Respecting locations of rare plants

We agree with the statement that “[f]amiliarity with the location of rare plant populations and the habitats used by these species allows OSMP to avoid or minimize site-specific impacts from trail construction, agricultural management, and other activities. Identification of the ecological drivers that explain the presence of these rare plants also seems important. An example is the kind of analysis that has been done to understand the presence of Ute Ladies –tresses.

6. Respecting management of non-natives

We agree this is both a good indicator of ecosystem health and an on-going management need. We would like to see some analysis of locations with high densities of non-natives to help better understand why they have moved into certain areas and what can be done to prevent such encroachment in other vulnerable areas.

7. Respecting the shale barrens

We would support the closure of these areas to all visitation. They are unique, sensitive, and do not occur widely. With appropriate public education about their values, we believe the public would support such a closure.

8. Respecting White Rocks

This unique area is currently largely within conservation easements. Thus, access is limited. While we would prefer fee ownership of this important area we would only support purchase if it was conditioned on maintaining controlled access through permits.

9. Respecting Implementation

We are pleased to see this initial effort at identifying conservation objectives and strategic actions. We fully support the objectives of improving vegetation composition and structure in Best Opportunity Areas, enhancing avian habitat, maintaining occurrences of rare butterflies and increasing occurrences of grassland-dependent butterflies, and reducing presence of invasive species. These objectives appear to be fully consistent with the preceding analysis respecting the health of the grasslands. For purposes of public education we would encourage some discussion of these objectives to provide an explanation of why they were selected. We would also encourage consideration of organizing the presentation of objectives in Table 25 so that related objectives are connected. At present the list appears somewhat random. We would also encourage consideration of relating the list of strategic actions directly to the conservation objective(s) it would help accomplish. The list in table 26 is tied to a ranking that emphasizes viability but does not connect to purpose. Then the shift to the five initiatives requires still another reorganization of the pieces. The purpose of this last reorganization is unclear and difficult for the general reader to follow.

10. Respecting Consideration of Climate Change

Professor Seastadt, who is a member of the FOBOS Science Advisory Group, provided staff with extensive comments last November respecting the plan that discuss the changes that have been identified related to climate change that are affecting grasslands. Among other things, these changes favor the increased presence of certain vegetative species and disfavor others. He encourages staff to take these changes into account in developing their conservation targets and in determining appropriate management actions. Consequently, we would encourage OSMP to practice natural resource conservation to consider the effects of climatic variability on natural resources and climatic shifts over the next few years to decades.

11. Respecting Sustainable Management

The wisdom in this Ecosystem Management Plan is the fact that the focus is on managing for sustainability of a mosaic of many different grassland eco-types (including the soils, vegetation and non-plant species) in an integrated way – and NOT managing for individual species. In addition, the critical importance of LARGE blocks of land is key.

Our Response to Comments
The February 11 memo to the Board suggests that many of the comments on the draft plan focus on visitor and recreation use concerns. We hope review of the draft plan does not get sidetracked by these concerns. We spent six years developing the Visitor Master Plan. That entire discussion occurred in the absence of the kind of information that is now contained in the grasslands plan. Let’s use this time to concentrate on understanding the lands and their natural resources. Let’s focus on their condition. Let’s identify what is important to us about these lands and natural resources, what natural attributes we want to ensure remain in healthy functioning condition so that they can be enjoyed by not just us but by future generations as well. Once we have achieved this level of comprehension and have put in place a process for achieving and maintaining the desired conditions we can better consider appropriate ways for us to use and enjoy the lands.

Consider the identified concerns. One relates to the recognition that riparian areas are exceptionally important habitat for a wide range of biodiversity; thus we should seek to limit social trails in these areas. The scientific basis for this stated management objective is powerfully documented. Establishing a goal of reducing trails in such areas is entirely consistent with our understanding of the unique importance of riparian areas in places with such limited water. No actions are taken under this plan. It is guidance for consideration in future TSAs.

The concerns suggest that people should never be excluded from riparian areas because they are pleasant places to recreate. Indeed, the entire Boulder Creek bikepath provides the opportunity to recreate within a riparian area. Many of our designated trails provide that experience—more than many of us think are needed and certainly more than would be desirable from a biological perspective. The plan accurately reflects a recognition of the special importance of riparian areas and only proposes the goal of reducing trail densities in such areas. OSMP comments further state the department’s intention only to address undesignated trails. While we agree that removing undesignated trails should be the first priority in each TSA process, we oppose restricting this consideration only to undesignated trails. We believe there may be a few existing trails that currently are located in high value riparian areas that should be considered for either rerouting out of the riparian area or should be closed.

Another concern was that protection of grassland bird nesting areas would interfere with recreational uses of the areas. Again the report accurately acknowledges both the existence of such nesting areas on OSMP lands and the scientific studies documenting the effects of human, equestrian, and dog presence on the success of such nesting use. The conclusion is that we should consider opportunities for seasonal trail closures for trails identified as especially close to the nesting areas, that we should emphasize on-trail use by hikers and equestrians in such areas, and that dogs should be required to be on lease in these areas. In our view these are entirely reasonable proposals that can and should be considered during TSAs.

We note the VMP, in its Resource Protection Initiative, states:

Visitor impacts that degrade or diminish the quality of natural, agricultural, or cultural resources should be minimized. The most significant potential impact from visitor activities is through visitor travel or access. This initiative is intended to: (1) direct visitors away from areas with highly sensitive resources; ….

Had the grasslands plan be in place before the VMP we would have already identified riparian areas and grassland nesting areas as sensitive.

Appendix A – Boulder’s Amazing Grasslands
By maintaining an undeveloped buffer of land around the City of Boulder, we have also protected some very special habitats. The recent draft, Grassland Ecosystem Management Plan, prepared by OSMP staff, documents the remarkable qualities of the grasslands protected as city open space.

Did you know our grasslands support more than 800 species of vascular plants and over 400 species of vertebrates?
Grasslands account for about 24,000 acres of city-owned open space and another several thousand acres of land protected under conservation easements. Other grasslands in the area are protected by the county, by NOAA (Table Mountain), and by the U.S. Fish and Wildlife Service (Rocky Flats National Wildlife Refuge).

The dominant grassland type is the mixedgrass prairie mosaic, accounting for about 40% of the total. Common species include western wheatgrass, needle and thread grass, green needlegrass, New Mexico feathergrass, sideoats grama, little bluestem, and Rocky Mountain bluegrass. Common shortgrass species include blue grama and buffalograss. This mosaic supports numerous grassland nesting birds, badger, and elk as well as the black-tailed prairie dog. More uncommon species include the short-horned lizard, olive-backed pocket mouse, and several rare butterfly species.

Shale Barrens
Located in unique areas in which shales of the Niobara and Pierre formations outcrop, these barrens provide habitat for a large portion of the habitat for Bell’s twinpod, a globally rare and state imperiled endemic species, along the Front Range of Colorado.

Next most widespread is the xeric tallgrass prairie, a vegetation type considered rare and imperiled globally and in Colorado. These tallgrass communities are found in rocky soils at elevations between 5,400 and 7,600 feet where the prairie meets the mountains. This tallgrass habitat is especially important for certain butterflies, including the Ottoe skipper, Arogos skipper, crossline skipper, and regal fritillary. Large, unfragmented patches of xeric tallgrass provide seasonal habitat for a number of grassland nesting birds.

Open space contains about 350 acres of mesic bluestem prairie, the largest remnants of mesic bluestem in the state. This vegetation type is one of the most endangered in the world. In recognition of its importance, the Colorado Natural Area’s Program designated this area of open space as the Colorado Tallgrass Prairie State Natural Area in 1984.

Black-Tailed Prairie Dogs
Black-tailed prairie dogs are considered a “keystone” species in grassland habitats. Populations on open space vary widely. In 2005, 3,500 acres of open space grasslands supported prairie dogs. In 2008, only 1,700 acres contained prairie dogs. Other species associated with prairie dogs include burrowing owls, American badgers, ferruginous hawks, and golden eagles.

Wetlands are found on about 1,500 acres of open space. Wetland types vary widely and include marshes, wet meadows, and riparian wetlands. Such areas contain a disproportionately high level of biodiversity. Rare plant species include the ESA-listed Ute ladies’-tresses orchid and the Colorado butterfly plant. Rare butterfly species found associated with open space wetlands include the prairie Arogos skipper, the prairie regal fritillary, and the two-spotted skipper. Rare birds found in wet meadow habitat include the bobolink and the savannah sparrow. Another species of concern found in these wetlands is the northern leopard frog.

Riparian areas adjacent to perennial and intermittent creeks account for about 1,200 acres. These transitional areas support an unusual concentration of plant and animal life. Of special interest because of their limited presence elsewhere is the Narrowleaf Cottonwood/Bluestem Willow Woodland plant association and the Red Hawthorn plant association. They help protect and enrich the important stream environments of Boulder Creek, South Boulder Creek, and Coal Creek among other drainages. These areas support the highest concentrations of breeding bird populations of any place on open space.

White Rocks
Protected under conservation easement and partially designated as a Colorado Natural Area, the White Rocks cliffs are outcrops of light colored Fox Hills sandstone near Boulder Creek. The unique conditions provide habitat for two rare plant species: the black spleenwort and the American groundnut. Also found here are several species of birds and invertebrates uncommon in Boulder County.

 

Comments on Grassland Ecosystem Management Plan

Comments by Friends of Boulder Open Space
Dec 5th, 2008

General
Friends of Boulder Open Space commends the Open Space and Mountain Parks staff for this excellent document and for its well supported methodology for evaluating the OSMP grassland resources, and for setting targets for achieving and managing healthy ecosystems, based on a solid, scientifically based suite of measurements and practical long-term monitoring.

The Executive Summary states that the “Grassland Ecosystem Management Plan (Grassland Plan) focuses upon the conservation of the 24,000 acres of OSMP lands dominated by mixedgrass and xeric tallgrass prairie.” This is completely appropriate and should not be watered down. Some have advocated that the plan should incorporate methods for balancing recreation needs in the plan. The Executive Summary places the Grassland Plan in the context of the other plans that have been adopted to govern other objectives, including recreation, as does the background material on pages 5-7. Chapter 1, page 5 clearly states its relation to the Visitor Master Plan. This is a Grasslands Ecosystem Management Plan, and it quite properly focuses on managing the grasslands ecosystem.

The right way to deal with conflicting proposed uses of open space lands is with the VMP process, which is intended to do the balancing. The only way OSMP can appropriately balance conflicting demands is to have a clear methodology for managing the resource that carefully identifies the components of the natural systems and defines a healthy state for each, along with ways to determine how various uses would impact that state. This is what allows a land manager to determine whether a particular location is especially important or not, what activities might degrade its health, quality, and value, and, finally, to measure the effects of use over time, in order to practice adaptive management.

Consideration of competing uses has no place in the evaluation of the resources, nor in measuring their health. Good evaluation and measurement are the tools that are needed to determine the potential effects of competing uses and then to evaluate the effects if trails are built, if livestock is grazed, if fires are allowed to burn, etc.

Planning Approach
The use of the CAP approach is an excellent methodology: disciplined, scientifically based, and transparent. As you know, FOBOS has long advocated a clearly defined approach to monitor and manage the system resources. CAP, and the department’s implementation of it in this plan should provide an excellent structure for properly managing the resources, and the 24,000 acres of grassland in the system are urgently in need of such management, as the overall “Fair” state indicates. Moving that state to “Good,” and avoiding degradation will pose a significant challenge over the next few decades, particularly in light of demands for various kinds of use, the continuing effects of past land-use practices. Existing problems with invasive weeds already pose a significant threat, and research indicates that the effects of global warming and excess nitrogen load are likely to exacerbate that threat.

FOBOS has three concerns about the implementation of the CAP approach: Appropriate funding of implementation, particularly for monitoring and mitigation actions, will be particularly difficult in an environment that will become significantly more difficult, rather than remaining relatively static.

  • Appropriate funding of implementation, particularly for monitoring and mitigation actions, will be particularly difficult in an environment that will become significantly more difficult, rather than remaining relatively static.
  • Given the granularity of the approach, there is a significant danger that a set of actions and judgment of their success or failure will be taken in isolation, whereas they will occur in conjunction with a number of other factors operating on the same target. Managing this complexity effectively will require significant discipline.
  • Any tradeoffs that allow uses that may degrade the quality of the resource need to be made without changing target states or ignoring potential effects. On the contrary, when tradeoffs are made, it is critical that potential effects be documented, that planning include potential actions when degradation is greater than anticipated, and that monitoring be done to measure the effects. Note that tradeoffs must take into account all effects on the plan and its implementation.  For example, the criticality of large habitat blocks is well documented in the plan. Hence, a proposed trail’s effect on such a large habitat block would have impacts extending far beyond those immediately along the corridor, and it is vital to take them into account.

Focal Conservation Targets
The selection, definition, and mapping of the focal conservation targets is an admirable synthesis of what we know about the resources and about specific goals for which we need to manage, including ecosystems, specific unique enclaves like White Rocks, and non-ecosystem goals and aggregations of issues, such as the prairie dog associates and agricultural operations.

We hope that there is a continuing long-term effort to refine the nested targets, attributes, and suites of actions in each of the focal conservation targets. The current plan is an excellent first draft, but it is inevitable that it will require constant refinement to achieve its goals.

Strategic Initiatives
The initial list of strategic initiatives is excellent. With respect to Initiative 1 (Large Block Habitat Effectiveness), we would urge you to attempt to increase the number of blocks (Table 21, pages 66-68) of both Mixed Prairie Mosaic and Xeric Tallgrass Prairie that are maintained at good/fair condition, in cooperation with other agencies as appropriate (Strategic Action 26). Because of the importance of blocks of continuous habitat for ecosystem health and species viability, this would be one of the most effective ways to improve our management of the system.

Under Initiative 3, Aquatic Systems Management, Action #17, Evaluating dog restrictions in selective riparian areas to protect sensitive species, should be implemented. Benefits are high and actual impact on dog guardians would be modest. Stating that it has low feasibility because it is “not likely to be appealing to dog guardians” is unpersuasive. Strategic action #21 should aim a little higher in its goal. We should be able to achieve more than three bullfrog-free ponds supporting leopard frogs by 2015.

Monitoring
We note the statement under goal #3 that “Often times maintaining a target in the Good condition is easier and less expensive than trying to improve its condition once it becomes degraded. Monitoring the key attributes of targets that are already within an acceptable range of variability will help ensure targets in Good condition stay that way.” We heartily concur and emphasize that careful monitoring of new trails and appropriate adaptive management are therefore critical. Slow degradation of resources that goes unnoticed causes important ecological losses and is expensive to remedy after the fact.

The strategy of explicitly prioritizing monitoring activities is exactly right. The practical effectiveness of this strategy will, of course, be dependent on budgetary and staffing considerations over time. We hope that the department will place a high priority on these activities, in spite of conflicting demands.

One critical problem in achieving this goal is the neglect in the planning process to budget this necessary monitoring in the cost of new trails or additional access points. Judging the impact of new trails in the system requires the monitoring described, as does doing adaptive management of those trails. But these costs are typically ignored. This results in bad planning, because the additional costs are a “surprise,” and bad management, because the necessary monitoring and adaptive management are not done, resulting in a buildup of needed compensatory maintenance.

The staff ranking of monitoring priority “Very High” to “the indicators associated with grassland vegetation composition and structure, grassland nesting birds…” is an excellent evaluation. Rare plants and individual species monitoring are important, but they are likely to be improved if adequate attention is paid to the vegetation composition and structure, together with a few indicator species, while the reverse is not true.

Our review of the detailed monitoring table of indicators, priority, and methods has been necessarily cursory. In general the list of attributes and their prioritization is excellent.

For both the exotic species assessments using RAM (page L-3), we would suggest that it is critical both that pattern analysis be done, and that particular attention be paid to correlations both with established trails and with new trails. Neither is mentioned in the methods. Control methodology, trail suitability analyses, and best practices for trail building are all dependent on building better understanding of the patterns of establishment of exotic species.

Conclusions
This is a superficial reaction to a monumental plan, but after a one-month review, the superficiality is inescapable. The scope of the plan is (and should be) comprehensive and overwhelming. Its general structure and thrust are focused exactly where they should be—on a careful understanding of the resource and a detailed methodology for its preservation and management.

Once again, FOBOS congratulates the staff on a job well done. Implementation will be challenging, and we encourage OSMP to do the necessary follow-up to actually achieve the goals that the plan sets our so well.

Management for the Eldorado Mountain/Doudy Draw area

Comments by Friends of Boulder Open Space
July 12, 2008

New trails coming to the magnificent Eldorado Mountain/Doudy Draw area
Current concerns and focus for FOBOS are to ensure that appropriate weight is given to conservation of the extraordinary natural resources in the Eldorado Mountain/Doudy Draw (EM/DD) area in the face of the proliferation of new trails there. With the new trails, scheduled for opening in autumn 2008, there will be a total of 13.6 trail-miles for all uses in the Natural Area. The Habitat Conservation Area will have a remote 1.8-mile trail for foot-travel and equestrians and a 0.5-mile climbing access trail. All trails, both old and new, in the Natural Area will be used for mountain biking.

In routing the trails, the OSMP Department has mostly followed routes drawn up by the bike/equestrian/dog user groups, with inadequate consideration for conserving natural resources. The mandate for this conservation priority has been part of the charter for both Boulder Mountain Parks and for the Open Space program from their inceptions to today under the Visitor Master Plan. FOBOS, concerned that the Department was not fulfilling the Community’s responsibility to our children and grandchildren to pass these public lands on to them in a healthy, sustainable state, has been working since last year to influence trail routing and management of these areas.

FOBOS maintains that long segments of the new trails have been very poorly located. We have documented that some trail sections go through extraordinarily diverse native grasslands, one of which includes an unusual, relict plant community, and also through critical wildlife habitat. FOBOS further raised the issue that long segments of trails would traverse potentially unstable hillslopes of shale. Because of the efforts by citizens interested in conservation, planned trail routing through one sensitive area (lower Spring Brook) was avoided, and the Goshawk Ridge trail was slightly modified to avoid a wet meadow, a section close to the upper Spring Brooks drainage, and a mountain lion kill site. Otherwise, no changes to trail routing have resulted from these.

With many more trails in ecologically sensitive areas of the EM/DD area, FOBOS has communicated to OSMP the critical need for a detailed and effective management plan that will focus on conservation of the resources while allowing public access and include: (1) baseline monitoring of the existing plant communities and wildlife populations; (2) expectations for maintenance or restoration of specific, desirable ecosystem conditions; (3) specific descriptions of unacceptable impacts; (4) and ranges of possible management actions in response to observed ecological changes and interactions among users.

Trail Study Area Plan for Eldorado Mountain/Doudy Draw
The EM/DD plan, completed in December 2006, contained some promising commitments:

  • “A detailed long-term monitoring plan with sufficient funding will be developed to guide TSA plan implementation. As part of this monitoring plan, baseline information will be collected where needed and monitoring criteria to measure success in implementing plan goals will be developed.”
  • “To provide and maintain acceptable conditions for natural and cultural resources and for the visitor experience, OSMP will devote sufficient management resources to enforce regulations dealing with seasonal and permanent visitor access closures, use restrictions for specific recreational activities, and on-trail, on-leash, and no-dog requirements. Adjustment of enforcement activities will occur over time, as needs change and levels of visitor compliance evolve.”
  • “Monitoring will be used to determine the effectiveness of management strategies to improve conditions where necessary and maintain acceptable conditions elsewhere. Measuring the effectiveness of strategies involves several steps including identifying the range of acceptable conditions, selecting indicators that will be measured, developing protocols for measuring those indicators, and then implementing the monitoring on the ground. Effectiveness monitoring often requires the collection of baseline data to formally document existing conditions before a strategy is put into action. Monitoring provides the Open Space and Mountain Parks Department with information not only to assess how well the TSA plan strategies are working, but also to refine the nature, location, or extent of implementation.”
  • And many other specific promises on these topics.

Thus the EM/DD TSA plan and Visitor Master Plan call for management that will meaningfully conserve natural resources and will determine when recreational use is causing significant impacts. Reasonable implementation of the TSA plan requires that certain critical management actions be completed before the trails are opened.

Why the current concern? Shortcomings in TSA implementation

The flurry of planning for new trail construction this year has appropriately included detailed plans, contracting documents, and clear schedules for both trail building and physical trail specifications.

Unfortunately, the same attention to detail has not emerged in connection with much of the planning on monitoring, adaptive management, staffing, standards, or staff responsibilities with regard to natural resources, user compliance with expected behavior, possible user conflicts (e.g., bike-hiker-equestrian issues), management alternatives for dealing with problems, etc.

The trails that are planned in the EM/DD area will radically change the recreational use of the area and the impact on resources. This segment of OSMP lands has historically been one of the least used and most pristine in the system, with plant communities that are unique not just in the OSMP system, but in the world, and ecologically important wildlife refugia. The promises in the TSA plan to protect and manage these treasures are critical.

Inexplicably, the promised plans to ensure adequate resource management seem, at present, to be lagging far behind the planning for trail construction.

FOBOS Responses

FOBOS has met several times with OSMP staff to express concerns about planning in these areas, and the lack of transparency in the process.

In May, we presented a set of documents to OSMP staff and the Open Space Board of Trustees that reflected our concerns and that gave a detailed set of examples of how the appropriate monitoring, planning, and management alternatives for action could be organized. We used the Limits of Acceptable Change (LAC) model that has been widely adopted by land management agencies in the U.S. and around the world, and has even been used by OSMP to set forth options for a segment of the new Goshawk trail. This model was originally developed by the U.S. Forest Service in the 1980s, and it is now used by every Federal land-management agency, as well as many local and state ones. The documents FOBOS presented included a score of specific criteria and standards, every one taken directly from either the Visitor Master Plan or the EM/DD TSA Plan. In our examples we included a decision-tree matrix that showed management responses when objectives were not met, or measured changes were not within the specified acceptable limits. The reason for the widespread adoption of the LAC model by land managers is that it provides a method to objectively evaluate the issues, take appropriate action, and manage public expectations.

The answers received from the Department lacked substance. The LAC model was deemed too complex for implementation, but no alternatives were forthcoming.

In mid June, staff created a LAC-type format for dogs in the Spring Brook area. They have put forth a list of 13 things that will be monitored — and have agreed to publicly announce and discuss standards and indicators for assessing (a) compliance with regulations on trails in the Spring Brook area and (b) sustainability of equestrian use of the Goshawk Ridge Trail. They have not yet embraced a LAC-type format or similar process for defining acceptable impacts for wildlife/natural resources, indicating that to do so would be very difficult.

As a result, at the June Board of Trustees meeting, FOBOS presented a different critique of the planning, when we emphasized the lack of documentation or any publicly revealed specifics for land management. We stressed the importance of actual detailed planning, as promised in the TSA plan.

Throughout this process, we have emphasized the need for education, a public process, and the importance of transparency. Users need to know what is expected of them, what circumstances might result in access restrictions, and what will be measured.

Conclusions

Implementation of the EM/DD trails plan requires a detailed adaptive management plan made available to the public before trails are built. To protect the resources, as mandated by the City Charter and the Visitor Master Plan, actions may have to be taken that are based on the data gathered in monitoring and on prior knowledge. A range of possible management actions in response to observed change must be specified for everyone to understand so that later conflict may be avoided.

U.S. 36, Open Space and South Boulder Creek

June 6, 2008
Mayor Ruzzin and members of the Boulder City Council
Frank Bruno, Boulder City Manager

Re: U.S. 36, Open Space, and South Boulder Creek

Dear all:

south_boulder_view
Chris Brown Photography

As we move ahead with the U.S. 36 project, Boulder is faced with choices that bear not only on how we meet our transportation needs now and in the future but also how those transportation needs are integrated with other important community values and interests. Thus the City has chosen to support continuing the BRT lane beyond Cherryvale to Table Mesa and having a flyover connection to the Park and Ride. It has chosen to support having bike lanes along the U.S. 36 corridor between Table Mesa and Cherryvale. These choices were made to accomplish city transportation objectives.

One important effect of these decisions is to substantially increase the land area that will be lost to enable accomplishment of these transportation objectives. The actual number of acres (much of it open space land) that will be converted to transportation use varies according to the alternatives but will likely be in the range of 45, with roughly half of that open space.

Moreover, these lands (open space and other lands) include the South Boulder Creek corridor in an area rich with wetlands (perhaps 15 acres will be lost). They include designated critical habitat for the threatened Preble’s Meadow Jumping Mouse (about 15 acres will be lost) and the threatened Ute Ladies-Tresses (perhaps 40 acres will be lost). They include Burrowing Owl and Prairie Dog habitat. They include lands located within the State’s South Boulder Creek Natural Area and the Colorado Tallgrass Prairie Natural Area. The US 36 crossing already chokes off the South Boulder Creek corridor, directly blocking much of its floodplain and severely narrowing the area through which the creek may pass.

OSMP staff successfully demonstrated to the Federal Highway Administration that City of Boulder open space lands qualify as so-called “4(f)” lands (the first time FHWA has recognized city open space lands as coming within that status). By federal law, 4(f) lands may only be used for a federally-funded transportation project if there is no reasonable alternative and if harm to the lands is minimized.

Friends of Boulder Open Space strongly supports the city’s proposal for a comprehensive mitigation strategy that would actually enhance the South Boulder Creek corridor as it passes through city open space. We propose development of a watershed restoration process with all interested parties involved that would return the creek and its floodplain to a healthier, more functional state. We cannot replace what will be lost by building on these high value, 4(f) open space lands, but we can offset these losses through significant improvements to the creek and its adjacent lands.

We will be following up this letter with discussions with you and with other interested parties.

Sincerely,

Larry MacDonnell

south_boulder_creek_hwy_36
Chris Brown Photography