Concerns and questions submitted by Friends of Boulder Open Space (FOBOS) June 6, 2007. (All geographic coordinates in WGS84)
The Visitor Master Plan provided for the creation of “habitat conservation areas” (HCAs) and established as one of the goals for such areas: “Provide public access and passive recreational opportunities that foster appreciation and understanding of ecological systems and have minimal impacts on native plant communities and wildlife habitats or other resources.” Thus, new trails in designated HCAs should be designed and constructed in a manner that minimizes their impact on the area’s natural values.
The proposed Goshawk Trail will bring hikers and equestrians into one of the most biologically rich parts of Boulder open space. An area of relatively high elevation meadows and forests traversed by drainages coming off the foothills, the Eldorado Mountain-Doudy Draw (EMDD) HCA supports substantial populations of bear, elk, deer, and mountain lions and provides important habitat for a wide variety of birds including flammulated owls as well as northern goshawks. Because it has been relatively inaccessible, wildlife populations thrive in this HCA, as do important natural plant communities.
The challenge is to provide for reasonable visitor access in a manner that is as compatible as possible with the area’s especially important natural values. Alignment decisions should be based specifically on choosing the most ecologically favorable alternative. Quality of the visitor experience, while important, should be secondary.
FOBOS regrets OSMP’s decision to build the trail before staff has established baseline information respecting the existing condition of the habitat and the resident plant and animal communities. We hope OSMP will follow through on its promise to establish monitoring programs that will eventually help to develop this information and will describe management actions that will be taken if impacts exceed levels defined as acceptable.
We also hope this monitoring will be used to track impacts of the increased visitation associated with the trail and that management actions will be taken, as needed, based on the definitions of acceptability.
Ecologic and conservation issues:
Impacts on habitats for elk, mountain lion, bear, deer from increased visitations and fragmentation of habitat. Even available information does not appear to be considered in the assessment of trail suitability factors. Surprisingly, critical observations made in the Inventory Report for the EMDD TSA are not mentioned in the current Trail Alignment Suitability Analysis (5/18/07). As one example, the Trail Alignment Suitability Analysis ignores the importance of this HCA as “one of the only corridors for seasonal Elk migration in the County” (Inventory Report, p. 31). More information and better use of existing knowledge are needed to make informed decisions.
Birds. Northern goshawk and flammulated owl are among species that require habitat protection. In the TSA Inventory, flammulated owls are described as, “a species of special concern…[that]…have been observed in the Spring Brook drainage where they probably breed…”. This critical observation is not mentioned in the Trail Alignment Suitability Analysis. Similarly, knowledge about the northern goshawk is available, but such information does not seem to have been digested and applied by the responsible OSMP Managers. The HCA also harbors many other raptors and wild turkey. More information and better use of existing knowledge are needed to make informed decisions.
Rare plants— Assessment by OSMP is needed of the types, locations and extent of Rare and Sensitive plant communities along proposed routes. Critical information is missing in the Trail Suitability Analysis (for example the Big Bluestem communities in the upper meadows are not mentioned).
Biologic soil crust—more observations by OSMP or other experts are needed along proposed routes.
FOBOS recommends that OSMP’s Inventory Report be updated and supplemented with observations of local naturalists, OSMP volunteers, and visitors familiar with the area to identify mountain lion hunting grounds, raptor and bear foraging areas, nest sites, etc., so that these areas can not only be avoided but also accurately used in identifying suitable routes through this HCA.
Trail suitability issues
FOBOS supports trail option 2B as the least environmentally harmful option of the “twos”. The northerly sections of 2B provide outstanding views and a route through two ravines and varied vegetation around ridges. The other options would increase habitat fragmentation and impair unique open meadows. We favor track 2B on the basis of its distance from prime wildlife habitat that would be sliced by track 2C.
If trail 2B is constructed we recommend a short spur (just a few 10s of meters long) from the northernmost switchback to the top of the hogback ridge at N 39.9237 deg., W 105.2749 deg. to afford excellent views of Eldorado Mountain, South Boulder Peak and Bear Mountain to the northwest, and panoramic views eastward.
FOBOS is adamantly opposed to 2C, on the basis of, first, avoidable and unnecessarily long incursions into important habitat; this segment has been promoted by OSMP Management as offering a nice visitor experience with good views, and it “passes through a diverse variety of habitats” (Trail Alignment Suitability Analysis, p. 2). Furthermore, the curving and looping of the route “adds (sic) mystery” (ibid, p. 2). FOBOS believes that “adding mystery” is not adequate justification for creating more ecologic damage by lengthening trails.
Track 2C also maximizes environmental degradation by slicing this varied habitat, including mixed shrub and forest (foothills deciduous shrubland) on unusual and rough boulder-strewn substrate, with excellent water-retention capacity, over much of its length. The Trail Alignment Suitability Analysis fails to mention that “foothills deciduous shrubland is a rare and threatened plant community statewide” because it serves as “habitat for a rich diversity of birds and mammals” (Inventory Report for the EMDD TSA, p. 19). The Trail Alignment Suitability Analysis even fails to mention the presence of foothills deciduous shrubland.
Track 2C also fails on the basis that it is now nearly free of “priority” weeds; new trail construction would greatly increase the likelihood of noxious plant invasion to the area (Trail Alignment Suitability Analysis, p. 6).
FOBOS recognizes the challenge of routing around the “2A meadow” while providing realistic access to Mickey Mouse Wall in a track that would be used by climbers. We are concerned that many climbers will short-cut the long path to segment MM-1B by any access (2B or 2C). FOBOS urges close consideration of another option that would mitigate some of the unjustifiable damage of track 2C and allow more direct access to Mickey Mouse Wall:
Retain the existing social trail MM-1A from the 2A/2B/2C junction to the barbed–wire fence. This route is on a moderately gentle slope close to the ridge crest and is characterized by an easily navigable path on rocks and boulders of a range of sizes. These boulders provide excellent protection from erosion. The trail here has been used as climbing access for at least 30 years and is in excellent condition with little signs of wear. Make a short connector from the barbed-wire fence (N 39.92268 deg., W 105.27916 deg.) to proposed 2C (at approximately N 39.92260 deg., W 105.27947 deg.). Such a connector would require only about 20 meters of trail and is likewise on a gentle slope with well-set boulders and rocks that create a natural and excellent surface to buffer run-off and human traffic.
Please compare the costs of this alternative (20-meters length up gently sloping, stable ground) to the cost for the meandering section of 2C (more than 900-feet or about 280-meters long on mostly heavily vegetated, steep sided slopes) that could be eliminated by this alternative route.
This 2C detour would by-pass the steepest part of track MM-1A where it slices an exquisite stretch of the main meadow. At the point where this 2C detour gains elevation to intersect trail MM-1A, trail MM-1A would continue southward. At this point, trail MM-1A becomes gentler and could then remain the main climbing access route, perhaps with a few water bars, as needed. This continuation of MM-1A should be closed to horse travel to prevent erosion.
Having a suitable climbing access on the westerly side of the meadow (MM-1A) would then completely eliminate the need for trail MM-1B, thus sparing more cost and invasion of forest habitat.
If 2C is built, we propose moving this trail higher in elevation above its current east-west flagged route across the upper part of the “2A meadow”. Such relocation would serve two purposes: (1) avoiding a dense shrub community of snowberry and (2) moving visitors farther from the temptation of heading directly down the axis of the meadow below.
FOBOS is strongly opposed to segments 3A and 3B & 3C, on the basis of needless and preventable incursions into important meadow habitat that includes the presence of big bluestem community.
FOBOS supports route 3D as the least damaging of the “threes” on approach to Spring Brook.
FOBOS recommends close attention to proposals for routes that avoid any crossing of North and South Spring Brooks by making a trail around the southward nose of the prominent Dakota hogback ridge and staying north of Spring Brook. We acknowledge that such a route may parallel North Spring Brook drainage for several tens of meters. We recommend a detailed evaluation of vegetation in this stretch before accepting or rejecting these proposals.
If trails are built across Spring Brook, FOBOS favors the following options to minimize impacts:
- 3D to 3C to 4C.
- At 4C crossing, route the trail across South Spring Brook to go directly up and out from the bottomland, thereby eliminating the long 4C stretch along and near the creek bed.
FOBOS is adamantly opposed to segment from 3B to 4A across South Spring Brook because it would cross flammulated owl (and perhaps goshawk?) habitat and heavily used black bear habitat (based on recent observations of numerous bears in this spot by an OSMP volunteer and based on scats over a long period of time). We also oppose the 3B to 4B route that would require the 4B dogleg. FOBOS is strongly opposed to trail segment from 4B dogleg eastward along South Spring Brook, because this segment would traverse more riparian habitat than the 4C option.
Again, no matter where the trail crosses South Spring Brook (and the 4C crossing appears to be the least damaging), it should go directly up hill perpendicular to the drainage and not funnel visitors close and parallel to the bottomland as currently flagged. The same concerns about trails climbing quickly out of the North Spring Brook crossing at 3B should apply to any South Spring Brook crossing.
FOBOS proposes a new option in the “5” trails, here named 5D. Trail 5C is too close to the drainage area of South Spring Brook, and segment 5A is an ecologically unsound and unnecessarily long route that cuts prime deer and elk habitat as well as well-known lion hunting grounds. FOBOS proposes a route to the east of, and nearly parallel to, 5C to the water board road. This track (5D) should lie at least 50 m east of segment 5C and would approximately bisect tracks 5C and 5B. A route to any bridge from trail 5D (at the water-board canal) could be made by a track parallel to the canal. The presence of water adds value to the visitor experience, and this might be noted in the trail suitability analysis.
For each option adopted by OSMP, FOBOS requests written statements that document the OSMP choices as the ones that minimize impacts.
If OSMP does not choose options that clearly minimize ecologic impacts in this HCA, FOBOS requests written statements explaining why OSMP does not choose these least damaging alternatives. The options recommended by FOBOS are based on sound evidence as the least damaging alternatives (2B; 3D to 3C to 4C; direct in-and-out at the 4C crossing; 5D).
FOBOS has asked that OSMP develop a baseline of land and resource conditions prior to the construction of new trails so that evaluation can be made of the effects of trail uses. OSMP has decided not to do such pre-construction monitoring. We now make the following requests:
- An outline of ecologic impacts that OSMP will monitor and that are based on expected losses (including, but not limited to, loss of communities/occurrences of rare plants, loss of wildlife habitat, alteration of wildlife activity);
- Descriptions of the mechanisms for evaluation of monitoring results;
- Consequent management actions to minimize ecologic losses. Please describe in detail how monitoring results will drive adaptive management decisions. Please indicate what is known now (baseline information) and whether that information is, or is not, adequate for future comparison. For each monitoring topic or target (e.g., bear activity), please list criteria that require management response. Please list specific criteria that would trigger temporary or permanent trail closure.
Please describe enforcement plans to ensure on-trail travel.
FOBOS supports the requirement of on-trail travel by horses at all times, on the basis that horse travel is a major cause of erosion and disturbs the land surface thereby promoting plant invasion.
FOBOS encourages restrictions on the use of this area’s trails at night. We further advocate public education and signage to inform visitors of the risks associated with mountain lion habitat. The safety hazards might also be noted in the trail suitability analysis.
FOBOS recommends that OSMP should give more attention to avoiding and conserving the stone structures in the area.
Costs are obviously an important issue to OSMP and the public. Yet it is essential to ensure that new trails are both sustainable on the basis of human use and in relation to the environment through which they pass.
FOBOS is apprehensive that cost issues may trump environmental values. Particularly in a HCA, the requirement of minimizing harm to the area may necessitate added expenses. Such expenses are fully warranted if they help ensure that human uses of the HCA are as environmentally compatible as possible.
What are the currently estimated or budgeted monetary costs to build and to maintain Goshawk and Mickey Mouse trails? Please complete the OSMP Trail Alignment Suitability Analysis (5/18/07) document by providing the public with costs of each trail segment.
What are the currently estimated or budgeted costs to conduct adequate baseline studies and monitoring of these trails?
Other questions relevant to disturbance and health of the ecosystem.
If trail base material must be imported, it will possibly contain weed seeds. Will all such material be tested for weeds before application? If not, why not?
Regarding trail construction, FOBOS strongly urges extreme care in the construction of trails to eliminate any related possibility of consequent plant invasion, with special attention to (1) timely and thorough treatment for rehabilitation of disturbed areas; (2) disposal of overburden that might be moved or removed in the process of trail construction; and (3) lessons have been learned from recent trail construction on Marshall Mesa that damaged plant communities. FOBOS recommends tight oversight of volunteers to ensure that approved alignments are followed.
Status of crossing of Denver Water canal
At present, OSMP does not have an agreement with Denver Water allowing crossing of the canal. Denver has opposed authorizing crossing at the existing bridge and has not authorized construction of another crossing. We believe it would be irresponsible for OSMP to construct a trail to the canal unless and until it has obtained legal permission from Denver Water for a crossing.
FOBOS believes that there is much room and opportunity for improvements to the trail alignments as currently flagged. FOBOS hopes that OSMP will consider closely our recommendations and alternative routings that would minimize ecologic damage to the HCA.
The current plan could be greatly improved by bringing together existing and new knowledge about valuable wildlife and plant resources to inform decisions. Moreover, a few important and viable options have not been considered.
FOBOS is most concerned about impacts of the proposed trails on wildlife and their habitats. Because of the lack of systematic monitoring of many critical ecologic factors in anticipation of the proposed routes, data are inadequate to assess with accuracy some of the impacts on species such as elk, bear, cougar, turkey, raptors, and owls.
Finally, FOBOS believes that this trail-building plan could be improved in many respects to bring trail alignments into compatibility and consistency with the stated purpose that protection of natural resources is the paramount issue and concern in the HCA. Many of the OSMP options on the table seem to favor the human visitor over the permanent residents of this HCA.