PLAN Boulder County Open Space Actions
Comments on OSMP proposed route alternatives for Trail 13 and Trail 14
in Spring Brook/Doudy Draw Natural Area
July 29, 2007
PLAN-Boulder County commends the OSMP staff for careful preparation of
alternatives for routing these proposed trails in the short time frame
available.
However, proper management of Open Space and Mountain Parks resources requires taking adequate time to ensure:
- sound trail construction at reasonable costs;
- trail sustainability;
- preservation of critical wildlife habitat and sensitive plant communities;
- compliance with Council's instructions that the area should
be managed so that it could still be designated as an HCA, should that
become desirable;
- adherence to the Visitor Master Plan (VMP) provisions for
the goals of managing Natural Areas (p. 48) and for implementation
monitoring (pp. 62-63)-specifically
- "Accommodate low-impact visitor activities where adequate trails exist or can be built, and resource impacts can be minimized."
- "Protect the quality of naturalÉresources (especially where high-value resources exist)."
- Implementation monitoring requirements are specified to
measure change as a result of the actions taken. These can only be met
if baseline data are collected. Otherwise most of the criteria in the
implementation monitoring cannot be satisfied.
It is clear from the public field trip on July 17 that the information
available to date falls far short of meeting these VMP criteria. To
cite one example, thousands of yards of the routes proposed are planned
to cut laterally into relatively steep slopes (20-30¡) of Pierre Shale.
Numerous geotechnical studies [e.g. Squire 2001] have shown this shale
unit to be susceptible to rapid erosion and repeated slumping at such
angles. Indeed, one geologist on the tour observed many slumps already
present along the flagged routes. The reason that the slopes are steep
is because the shale erodes rapidly when the edge of the gravel
protecting cap is removed.
These elementary soil characteristics have not been taken into account
in the initial routing proposal, apparently because of the rush to meet
deadlines. This does not reflect badly on the staff who have worked on
the detailed preliminary routes, but it does demonstrate that the
planning process has been unwisely rushed, and that we need to take the
time to do the job right. Rushing to try to begin construction this
season will result in badly built, unsustainable, and very expensive
trails; serious damage to the resource; an inability to properly
monitor the trails' effects; and a much more costly future set of
consequences to deal with. There is no major cost associated with
taking the time to do the job right. The only problems associated with
some delays are that current social trails will continue to be used for
a time. The degradation caused by this process, and the difficulty of
mitigation, will be trivial compared with that caused by trails built
in the wrong places. Once new trails are built, there is likely to be
greatly increased visitation in this area, which will enormously
compound the problem if this is not done correctly.
Now that a preliminary agreement with the Denver Water Board regarding
the canal crossing finally has been reached, it is time to rethink the
trail alignments that were largely done without knowing where the
crossing would be. Attempts to decide routing in advance of this
milestone disrupted monitoring plans for both the Goshawk Ridge Trail
and Trails 13 & 14. It is hard to route a trail or to plan
monitoring when you don't know where it is going! We congratulate the
OSMP staff who have brought these difficult negotiations to a
preliminary conclusion. However, it is time for another careful look at
the alternatives.
We believe that, in light of the recently negotiated mid-canal crossing
location, trail alternatives need to be seriously reconsidered. For
example, two possible alternative routes for the Trail 13-Stem Trail
have not been considered. These are:
- Following the old railroad grade, which already has a bed
installed, so that little additional disturbance would be caused by
trail construction, unstable Pierre Shale routes would be largely
avoided, and there would be far less potential for providing an
invasion pathway for noxious weeds; one bridge would need to be built;
- Up the west side of the stony ridge to the east of the
drainage. This route would avoid much of the sensitive habitat
disturbance that will result from the currently proposed stem trail,
and it has enough gravel cover that it may well provide a route that
has better soil characteristics, and that gains most of the required
elevation at a moderate angle and follows a direct path that would
discourage shortcutting. By keeping to the west side of the ridge,
views down to Lindsey Pond can probably be avoided.
These alternative routes have obvious potential advantages, as staff
admitted on the public field trip. These routes warrant serious
consideration at the very least.
A third significant problem relates to invasive weeds in the area.
Jointed goat grass (Aegilops cylindrica Host) is a major problem on a
large number of trails in the OSMP system. This invasive species is
difficult to control, and it is easily spread by hikers, animals, and
probably mountain bikes. The seeds fit the grooves in Vibram soles, and
they will probably fit many bicycle tire treads. A. cylindirca is
spread as a seed contaminant in agricultural areas, and thence by
grazing livestock like horses, because the seeds survive passing
through the guts of ruminants.
Jointed goat grass has become a serious problem and has seriously
infested the bottom of the Doudy Draw Trail. The proposed rerouting of
the Doudy Draw Trail before this invasive is controlled will only
ensure that the infestation moves up the slope and becomes much larger
and more difficult to control. Yet the Suitability Analyses do not even
mention this invasive except to say that there is a possible problem
during construction of Trail 13 Stem if construction is done from the
direction of Doudy Draw. There is no mention of it being spread by
users, not only to this trail, but to all the others being proposed.
This issue must be seriously considered and preventative measures must
be taken before trail construction. Otherwise, it is highly likely to
damage the resource and to result in major expenses for weed control.
Recommendations
Our principal recommendations and observations are as follows:
- delay construction until next year;
- do not build a trail in Spring Brook Meadow; there are a
number of alternative routes for the currently mapped Trail 13
alternatives. This meadow provides: exceptional habitat for deer and
elk; possible presence of Preble's Jumping mouse; confirmed lion
hunting grounds; vulnerability to weed invasion, as demonstrated by
presence of high-priority weeds (such as Dalmatian toadflax and Sulfur
cinquefoil) along the existing social trail;
- funneling visitors into Spring Brook meadow will inevitably
promote off-trail travel throughout the area, including the length of
the meadow along the desire-line and the current social trail
northward;
- implement the control of jointed goatgrass in Doudy Draw
this fall and winter, and verify that control has been successful
before attempting to schedule the construction of the rerouted Doudy
Draw Trail or Trails 13 and 14;
- as the next step in the public input process, provide maps
at a scale useful for trail planning that include critical wildlife
habitat areas, critical plant communities; and soils/geology. These are
fundamental tools for planning ecologically sustainable trails;
- complete a monitoring plan for the natural resources,
including evaluation of resource impacts; compliance monitoring;
visitor conflict issues; and plans for management actions when expected
criteria are not achieved;
- as a first step, build a modified route from the Doudy Draw
stem trail-possibly up the west side of the stony ridge, staying far
enough west to avoid tempting views into the Lindsey Pond area;
- this approach should connect with upper Trail 14, which
should be followed around its current route, except that it should be
re-routed onto the terrace, far enough back to avoid the ecotone, but
always less than 100 meters from the edge, avoiding relict grasslands,
and fragmenting the forest habitat as little as possible;
- monitor the impact of this trail in order to provide adequate impact data for consideration of Trail 13 alternatives;
- while the usage of Trail 14 is being monitored, consider the
possible routes for 13, including the possibility of routing the upper
alternative farther south;
- among the criteria for Trail 13 that need to be achieved is
the routing of Trail 13-Stem along a less damaging route, which does
not repeatedly cross the riparian shrubland, does not remain in the
terrace/slope ecotone for long stretches, and does not follow long
traverses of unstable, slumping Pierre Shale; there appear to be
several possibilities for achieving these goals.
- for upper Trail 13, which seems more likely to present a
possible route that minimizes resource impacts than lower 13, utilize
the time while 14 is being monitored to achieve a well-planned route;
- one possibility for routing 13 is to follow the currently
proposed alignment for upper 13 approximately 200 yards above the
intersection with the currently proposed Trail 13-Stem, and then
proceed west and then slightly north to join the current alignment of
Trail 13-Springbrook.
We are supportive of OSMP's serious attempts to build environmentally,
ecologically, and geotechnically sustainable trails in this incredibly
beautiful and sensitive area, and we urge you to agree that some
pragmatic rethinking and tuning of this plan will result in a much
better outcome for the public.
Reference:
Squire, M., 2001, Stability of Cretaceous Pierre Shale slopes, in
Kuehne, M., Einstein, H.H., Krauter, E., Klapperich, H., and Poettler,
R., eds. Essen, Verl. Glueckauf.
Thank you for considering this important request.
Sincerely,
Pat Shanks, Chair
PLAN-Boulder County
The People's League for Action Now
At the Boulder City Council meeting October 19, PLAN-Boulder County's
position regarding Sombrero Marsh, a portion of which the Council was considering
purchasing, was presented as follows:
"Sombrero Marsh is a unique and significant wetland system which supports
both wildlife and plant communities that are uncommon or rare. It is presently
endangered by the long-term use of its easterly segment as a Boulder Valley
School District dumping ground.
"The city's Open Space program has already preserved a substantial portion
of the marsh and now proposes to acquire the 42 acres owned by the BVSD,
clean up the dump and restore the marsh's eastern shoreline.
"A requirement of the BVSD is that an educational element be part of
the 42 acres, which would benefit the community as a whole. The Open
Space Department will comply with this concept, the details of which are
still under study.
"PBC strongly supports this effort on the part of Open Space to preserve
and protect a valuable and unique habitat and the rare wildlife species
and wetland vegetation which depend on its existence. It should be noted
that the first priority in acquiring Sombrero Marsh property is protection
of the resource; education should support this primary focus."
Council voted in favor of the purchase.
Prairie Dog Policy (2000)
PLAN-Boulder County supports adoption of the Prairie Dog Protection
Strategy, with a request for further dialogue around some aspects of
implementation. Specifically:
- We strongly support the addition of policies to the BVCP aimed at
protecting "species of concern" and their habitat. Identifying these
species on an adopted list will add certainty to the process for landowners.
- To further reduce uncertainty and surprise in the regulator process, we
suggest that City staff also create maps showing known habitat areas for
identified species.
- We also strongly support any steps the City can legally take to prevent
poisoning of species of concern, including prairie dogs, within the Boulder
Valley. Prairie dog colonies have been poisoned at an accelerated pace
since the possibility of their "listing" as a threatened species was raised
in public dialogue. Prairie dogs are a keystone species; if left unchecked,
wholesale poisoning will dramatically change prairie ecosystems. Poisons
used on prairie dog colonies are also extremely inhumane, resulting in
needless long term suffering for individual animals.
- We believe that negotiating case-specific preservation plans with
individual landowners is a worthwhile strategy to pursue. However, many
people do not yet understand the role that species of concern play within
their ecosystems, and landowners may still hold views that these species
have no value. Thus, to be effective, negotiations around case-specific
preservation must be backed up by a strong commitment to protect species,
backed - if necessary - by appropriate regulation. The proposed changes to
the site review process appear to be an appropriate way to provide this
"back-up" regulation. We recommend a trial period of one-two years to
determine whether the voluntary agreements/site review strategy is leading
to attainment of our species preservation goals.
- Finally, there is considerable controversy among knowledgeable parties
about the City's proposed protocol for prairie dog relocation. We suggest
that further conversation is necessary around the following areas before the
protocol is adopted:
- How to best open up Habitat Conservation Areas - which have already been
screened for suitability - for relocation of specific colonies
- Whether a minimum number of dogs must be available for relocation to
occur, and - if so - what that minimum should be
- Use of augured holes to create new sites for prairie dog towns (instead
of relying solely on areas with existing burrows)
- Improved vegetation/revegetation management techniques (including weed
control and species interseeding) on existing, proposed and relocated colony
sites.
- The possibility of introducing selected predator species (such as
black-footed ferrets) into some prairie dog towns.
Proposed Open Space/Mountain Parks
Consolidation (2000)
PLAN-Boulder County supports the main elements contained in the City
Manager's analysis of the proposal for restructuring the Division of
Mountain Parks and the Department of Open Space/Real Estate, as outlined in
his memo presented to the
City Council at the meeting of March 21, 2000.
We applaud the Manager and the Council for taking this decisive step in
moving forward to resolve this long-standing and divisive issue. We are
especially pleased that the new proposal firmly places the Open Space
acquisitions function within
the newly defined Department.
We also strongly support the recommendation
that the historical appropriation for Mountain Parks from the General Fund
be transferred along with the properties to be managed. We urge the
adoption of a measure,
by a vote of the people if necessary, ensuring this annual appropriation for
as long a period of time as would be required to guarantee that the present
bonding capacity for the Open Space accelerated acquisition program is not
placed in jeopardy.
Many other issues remain to be explored by the proposed Transition Team. We
wish to flag for their consideration a few of the issues raised in the City
Manager's memo.
- We support naming the restructured department the Department of Open
Space and Mountain Parks, provided this does not require a charter
amendment. We also support expanding the Open Space Board of Trustees, for
the transitional period
only, by the addition of two ex-officio, non-voting members. Neither of
these, however, should be a current member of the City Council.
- The Transition Team should include some representation from the public.
This could be accomplished by the appointment of one member from the Open
Space Board of Trustees and one from the Parks and Recreation Advisory
Board. We believe the Team should be entrusted with the decision, after
seeking broad public input, on which of the Mountain Parks lands should be
included in the transfer.
- We do not believe that the reductions in staff recommended in the recent
management audit report can be accomplished without deleteriously affecting
the excellent work that both staffs have been performing in managing these
lands. The starting point should be the current staff plus the currently
vacant positions minus obviously overlapping administrative positions. In
the absence of a true workload analysis, we recommend no reductions in
current staffing levels unless it can be demonstrated that such cuts will
not harm the program. During the transition period, thought needs to be
given to projecting future staff needs as well (based on increased acreage,
increasing visitor usage and changing demographics).
- We find the proposal for two Co-Directors, one overseeing Visitor and
Maintenance Services and the other, Acquisition and Resource Planning, to be
intriguing and worth exploring. Such a Co-Directorship should not be
permanent, however,
but exist only during the transition period.
We have many specific criticisms of the audit report prepared for the city
by Conservation Impact. It presented a recommendation for restructuring
without examining the alternatives in any detail and without offering clear
and convincing
arguments to support the recommendation. It proposed an unrealistic time
frame for the proposed changes. Most important, it provided no adequate
examination of the present or future workload, and the analysis of cost
savings resulting from staff
reductions was shallow and not persuasive.
However, we recognize that this first effort at a management audit was
unique in many respects, and need not serve as a model for the audits
envisioned by the city for other departments. Future audits should more
carefully examine staffing needs.
What are the current tasks and how many people are needed to accomplish
them? What are projected future needs? What are anticipated revenues?
This is crucial, since the city may face revenue reductions and probable
service cuts in the future.