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 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.
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.