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This document summarizes the key environmental issues associated with the rezoning in Clear Creek County, case # RZ2006-0004, resolution #07-50 (signed January 31, 2007) which is needed to allow Mr. Michael Coors to construct, open, and operate his proposed Eclipse Snow Park (Eclipse) in the Saint Mary's area, Idaho Springs, Clear Creek County (the County), CO.

This document has been prepared by Heather Ulrich on behalf of concerned citizens of the County for review by the Sierra Club to assist the club in deciding if, and in what manner, they can and will be involved in this issue. The environmental issues are those identified by the citizens as relevant, and may not be a complete list of all concerns. As the Sierra Club reviews this information, we would ask the following.

 

•  Has the Sierra Club been involved in other cases similar to this one? That is, have you:

•  offered support in the past to stop development of a ski/snowboard park, in particular in the State of Colorado ?

•  been involved at the level of a rezoning decision, in particular, for a ski/snowboard park?

•  In general, does the Sierra Club:

•  have particular interest in the proposed land exchange between the Forest Service and Coors/Eclipse?

•  have particular interest in the (related to the land exchange) promises of a James Peak Wilderness trail head?

•  have a particular interest in the possible environmental effects that the proposed Eclipse operation may have, in particular, on the James Peak Wilderness?

•  have general interest in all of the environmental concerns?

•  If there is an interest in any or all of the above items (or others), what type of support could the Sierra Club offer to the citizens of the Count

The Saint Mary's Glacier area and the James Peak Wilderness Area are treasures that deserve protection – treasures for the County, the State of Colorado , and the nation. We look forward to any and all help that the Sierra Club can provide to the citizens of Clear Creek County to protect this beautiful and environmentally vulnerable area.

 

This document is divided into the following sections.

 

  1. The Players – an introduction to some of the key players in this issue, including County officials, citizens, and the Sierra Club.
  2. Zoning Change Overview – an introduction to the changes needed to allow Eclipse, and basics of their proposed operations

•  Environmental issues – a summary of some of the key issues, including:

•  Proposed Land Exchange with the U.S. Forest Service

•  The James Peak Wilderness

•  Water for Snowmaking

•  Watershed

•  Wildlife (including noise and lights)

•  Alpine Tundra and Bristlecone Pine

 

1. The Players

Here is a summary of relevant “players” at the County, concerned citizens, and the Sierra Club.

 

1.1 Clear Creek County

Relevant staff, etc at Clear Creek County include the following. All have the following mailing address, unless otherwise noted.

 

P. O. Box 2000

Georgetown CO 80444

 

Mr. Frederick Rollenhagen, Planning Director

Clear Creek County Planning Department

303-679-2360

frollenhagen@co.clear-creek.co.us

 

Mr. Robert Loeffler

County Attorney

303-679-2326

attorney@co.clear-creek.co.us

 

Mr. Tim Allen (Road & Bridge)

Division Director, Public Works

3549 County Road 312

PO Box 362

Dumont , CO 80436

303-679-2334

 

Mr. Tim Vogel, Director (I think)
Site Development
303-679-2421

tvogel@co.clear-creek.co.us

 

Board of County Commissioners (BOCC)

Joan Drury - Chairman

Harry Dale

Kevin O'Malley

bocc@co.clear-creek.co.us

 

BOCC Secretary

Beth Luther

303-679-2312

bluther@co.clear-creek.co.us

 

1.2 Citizens

Mark (and Donna) Kline

889 Fall River Road

Idaho Springs Co 80452

303.237.8090 or 303.980.6993

chc@macconnect.com

or

MDK Properties LLC

7999 West 16th Ave

Lakewood Co 80214

 

Heather (and Marshall) Ulrich

515 Brook Drive

Idaho Springs , CO 80452

303-567-0727 or 720-320-2613

heather@marshallulrich.com

 

Jan (and Bart) Ziman

2895 Fall River Road

Idaho Springs , CO 80452

303-567-4477

mtncasa1@att.net

 

Christy Nealon

3792 Fall River Road

Idaho Springs , CO 80452

303-567-1983

pooh@wispertel.net

 

1.3 Sierra Club

 

Bill Ikler

Wilderness Co-Chair, Indian Peaks Group, Sierra Club

P.O Box 873

Nederland , CO 80466

303-258-3858
BI@nednet.net

 

Kirk Cunningham

**Title/Position**

977 7th St .

Boulder CO 80302

303-939-8519

kmcunnin@juno.com

 

Rich Levy, Co-Chair

Sierra Club Rocky Mountain Chapter

**address**

**city, ST zip**

970-871-8799

rich.levy@rmc.sierraclub.org

 

Sus an LeFever, Director

Sierra Club Rocky Mountain Chapter

1536 Wynkoop Street , 4C

Denver , CO 80202

susan.lefever@rmc.sierraclub.org

303-861-8819

 

2. Zoning Change Overview

The requested zoning change is to Commercial – Outdoor/Recreation:

 

“providing for commercial/ recreational activities that are directly associated with outdoor recreation.” The C-OR designation allows for the Permitted Principal Use of “1. Alpine ski/cross-country ski and snowboard area.”

 

The change is for various parcels of various zoning designations, something like this: (there is more than a bit of confusion here). See Figures 1 and 2.

 

MR-5 mountain residential, large lot     3 parcels    (40 acres)

R-1 residential single family units     4 parcels   (4-6 acres)

R-2 residential two family units     9 parcels   (10 acres)

M-1 mining one district       48 parcels   (220 acres)

M-2 mining two district       1 parcel    (lumped with the M-1 lots)

C-1 commercial one district       3 parcels   (12 acres)

 

Because residential development is allowed on M-1 parcels, 275 acres are currently zoned/would allow residential development. Only 12 acres would allow some commercial development.

 

Figures 1 and 2. Current zoning and proposed rezoning – all to C-OR. Note the significant amount of surrounding, and “in holdings,” of Forest Service land, zoned NR-PC.

 

 

 

 

 

Adjacent Zoning/Characteristics of the Area

As shown on Figure 1 the areas adjacent to Mr. Coors' property (mostly the scattered blue areas in the upper left and the small orange commercial section) are zoned as:

 

•  NR-PC   Natural Resource/Preservation   all of the light green areas [Forest Service]

•  R-1   Residential Single Family units   the purple area, known as St. Mary's/Winterland

•  R-2   Residential Two-Family units   the light pink area, known as Alice

 

 

 

 

 

 

Figure 3. Zoning in and adjacent to the proposed ESP – all adjacent, and in-holding, land is zoned NR-PC (the Forest Service land), R-1, and R-2, with no buffer zones.

 

This clearly shows that the intended use of the surrounding area is for preservation and residential uses; NOT to support a commercial snowboard park. This is especially relevant because there is NO buffer zon e between the residential areas and the area proposed for rezoning to allow ESP. There is also NO buffer zone between the NR-PC area (Forest Service land) and the proposed Eclipse operation which would have significant impacts on the environment. This area is also a gateway to the St. James Wilderness Area.

 

2.1 Proposed Eclipse Operations

In general, Eclipse is proposing to develop a ski and snowboard terrain park resort. Winter operations are proposed from mid-November through April from 10 to 10. They are also investigating summer operation (as summarized below), including the possibility of year-round skiing. The park would require snowmaking (initially proposed as 42 acres, but possibly increased to 60 acres requiring snowmaking coverage). They “may host approximately 65,000 guests per season… [and] visitation for summer uses will not exceed the winter use. The target market is 10 to 30 year-olds, with 250 weekday guests, 600 to 1,200 weekend guests, and 1,200 guests on “peak days” projected.

 

Summer Operations – 130,000 Visitors a Year

All of the documents prepared by Eclipse from the start, including their application for rezoning, have clearly stated that summer operations are proposed.

 

“ESP is also investigating the option of a summer ski operation. ESP may host terrain park camps from April through mid-June” and goes on to say:

 

“ESP is developing a variety of concepts for summer recreation opportunities; visitation for summer uses will not exceed winter use.” and later says

 

“As long as ESP has adequate snow and public interest, ESP will remain open into the summer months.” [This is their hope of year-round skiing]

 

With winter use estimated at 65,000 + (possibly as many, but not exceed) 65,000 in the SUMMER = 130,000 visits.

 

The only thing that is *somewhat* new regarding summer is Coors stating on his forum http://www.eclipsesnow.com/forums/eclipse_forum/viewtopic.php?t=5&highlight=mtb

 

"We have been seriously considering MTB for the summertimes [sic]. I agree its popularity has increased significantly and what they are doing at Whistler is a good indication of that."

 

This is the first and only (as far as I know) mention of mountain biking specifically for the summer. But summer OPERATIONS have always been a part of the proposal/business plan for Eclipse.

 

The possibility of year-round skiing and summer operations, including the possibility of mountain bike trails, present serious environmental concerns.

 

Daily Night Operations

Just a quick note here that the original proposal states “Projected Hours of Operation: 10:00 a.m. to 10:00 p.m. (will vary by season)” The Initial traffic analysis says “Eclipse is proposed to operate daily from 10:00 a.m. to 10:00 p.m. with a night skiing session.

 

Now, in some statements, Coors/Eclipse is trying to say that they will “probably” only have night skiing on Thursdays, Fridays, and Saturdays.

 

2.2 Current Rezoning Status

The rezoning resolution #07-50, signed on 01-31-07 is CONTINGENT upon Eclipse combing all of the relevant parcels together to provide “access” to what is proposed as commercial property; and upon Eclipse passing development review. Several “mitigation measures” have been identified, although “mitigation” may not be limited to:

 

•  traffic impacts on Fall River Road

•  Clear Creek EMS reimbursements

•  Clear Creek Fire authority, and possible donation of land for a fire response equipment

•  Sheriff's office – limited to parking only

•  wildlife mitigation

 

See Section 3.5.3 for information regarding problems with the proposed wildlife mitigation measures.

 

In addition to “mitigation measures” that are supposed to be addressed during development review, there is a *possibility* that the rezoning issue may be re-opened for public comment, and the BOCC may have to revote on the rezoning. The specifics of this possibility cannot be discussed at this time, but it should be something that the Sierra Club is aware of.

 

3. Environmental Issues

The proposed Eclipse Snow Park would utilize Anchor Gulch, the little bowl that forms the drainage for Silver Creek just 1/3 mile from St. Mary's Glacier itself. Silver Creek then flows into Fall River and on into Clear Creek. Eclipse also proposes to have the area include the alpine tundra terrain above and to the north of Anchor Gulch, above St. Mary's Lake , as shown in Figure 4. The treeline areas in both locations have ancient stands of bristlecone pine, and both areas serve as key wildlife habitat. The surrounding area, zoned as Natural Resource – Preservation/Conservation District (NR-PC) for good reason, is also the gateway to the James Peak Wilderness Area.

Figure 4. Terrain map for the proposed Eclipse Snow Park, including Anchor Gulch (on the left) and the area above St. Mary's/the Glacier lake (served by the proposed, long chair lift) – adjacent to the James Peak Wilderness Area (figure obtained from the Eclipse Snow Park Web site).

 

If allowed, Eclipse Snow Park would lead to damage to the watershed, displacement wildlife, and the destruction of key wildlife habitats and wilderness areas. There would likely be damage to the fragile alpine tundra and ancient bristlecone pine forests. In addition, there are significant concerns regarding pollution, noise, lights, and water.

 

3.1 Proposed Land Exchange with the U.S. Forest Service

In their proposal for rezoning, Coors/Eclipse stated that they had initiate discussions with the F orest Service:

“related to approximately 93 acres of Nation Forest System land surrounding the ESP private property. ESP and the USFS are presently discussing options that would allow ESP to operate on the adjacent 93 acres. [Through SUP]… Another option being pursued is a land exchange that would trade approximately 93 acres of now National Forest for other private holdings within the basin.”

As is quite obvious from the maps (Figures 1 and 2) due to the in-holdings and surrounding land that is owned by the Forest Service, this land exchange would be absolutely necessary for Eclipse to be able to operate.

 

As a part of this land exchange, Coors/Eclipse states that Eclipse Snow Park (ESP) willing construct a trailhead for the James Peak Wilderness Area. See Section 3.2 for more information.

 

3.1.1 October 25, 2006 Letter

Mr. Daniel A. Lovato, District Ranger, Forest Service, Clear Creek Ranger district, Eclipse is proposing exchanging 97.2 acres of federal lands for 56.6 acres of private lands. Here is a relevant paragraph from the 10-25-06 letter from Coors/Eclipse to the Forest Service:

 

“ Eclipse Snow Park proposes to exchange approximately 97.2 acres of federal lands in the Arapaho / Roosevelt National Forests for approximately 56.6 acres of non-federal (private) lands. The exchange will be completed on the basis of equal values based on current fair market value appraisals, not equal acres, as determined by real estate appraisals. If the lands proposed for exchange are not equal in value, the proponent may make them equal by cash payment not to exceed 25 percent of the federal land value. All federal and private lands proposed for exchange are located within Clear Creek County , Colorado .”

 

We question if this exchange would be in the best interest of the public.

 

The 10/25/06 letter to Lavato, signed by states that they have acquired 293.3 acres (68 parcels) [Note – this is different than the rezoning resolution that was signed] that:

 

“The concept plan for the resort is comprised of two ski lifts, 177 acres of skiing terrain, a new guest services building, and expanded parking lot, a small maintenance building, and all appropriate public service utilities. The proposed land exchange involved lands located in the Yankee Hill Geographic Area, as identified in the Arapaho / Roosevelt Land and Resource Management Plan. More specifically, parcels ESP proposed for exchanges are found in Management Area 8.22 – Ski Based Resorts – Existing and Potential.”

Note that they do not admit to or mention their plans for summer operations.

The letter closes saying

“Please contact me at your earliest convenience to discuss the next steps and strategies necessary for us to formally initiate the land exchange process. Our consultant, SE Group, is also prepared to meet with you at your convenience to clarify any project components. Please contact Kent Sharp with SE Group at 970.668.3398. ESP looks forward to working with you and your staff to improve the recreation experience available on private lands and to improve the management efficiencies on public lands.”

3.1.2 Legislative Approach?

One other thing that was in the file as an e-mail from Tom Tancredo's office about the proposed land exchange. It's dated 06/22/2006 from MacArthur “Mac” Zimmerman, Legislative Director, Representative Tom Tancredo ( Colorado – 6) 202/225/7882. It is addressed to Rice D. Cables, Rs Regional Forester, US Forest Services (303) 275-5451 rcables@fs.fed.us . It reads:

Rick, I wanted to make you aware of a land exchange we are pursuing in Clear Creek county. Not sure if you've been approached about it or not but I wanted to put it on your radar screen. Michael Coors is the one making he proposal. He is seeking the exchange to open a snow park. I've talked briefly (as has Michael I believe) with Lisa Subcasky in the Arapaho Roosevelt. her [sic] number is 970.295.6656.

Michael and CO. will probably be contacting you in the next week or so to talk in more detail about the proposal, but I wanted to give you a heads up on it if you weren't [sic] already aware.

Along the Tancredo lines… there is a 07/06/2006 memo/e-mail from Lisa M Subcasky /R2/USDAFS to Steven Rinella, Daniel Lavato, and Tim Sutton with the USFS re: Eclipse Snow Peak [sic] LEX – Michael Coors. This included:

“On May 30, I received a telephone call from Mack, Congressman Tancredo's Office – DC . He wanted to know what level of contact the forest has had with Coors, et al, because he was contact about doing a legislated land exchange. I told Mack that we had initial discussed with Coors, et all and they did not think they had enough non-Federal land to propose a land exchange. Mack said the Coors, et all, was interested in getting an appraisal done what would I recommend. I told him since the FS does not have formal proposal for a land exchange that would be the first thing and tat we would have to through the process (feasibility, etc).

The 7/6 memo states that there was a meeting on 07/05/06 with Daniel Lavato with Lisa Subcasky conferenced in. Michael Coors, Kent Sharp, Scott McGinnis, and Andy Speilman were present for Eclipse. The FS told them that “the district does not have the lands staff” to work on the exchange, and told them that "this exchange is not in our program of work this year.” They also explained that “The FS likes to start out with 100% propend financing; however, it is a negotiated process (they didn't like that – they want the FS to pay for it all). They wanted time frames. All we said we would do is if we received a proposal we could do ‘an initial' review in four weeks to see if it is an exchange where would [we] would proceed with doing the feasibility…however, the feasibility report would take longer since it required title commitment, LDV's etc. They requested a copy of an ATI and the steps involved in a land exchange. I sent them a copy yesterday.”

Thus, presumably, the 10/25/06 letter to Lovato from Michael Coors.  

3.1.3 Earlier E-Mails to Lavato

In October 2006, Marshall Ulrich exchanged a number of e-mails with Mr. Lavoto regarding Eclipse and the possibility of a land exchange. These e-mails are a part of the Forest Service files on this issue, as obtained through FOIA. See Attachment 2 for a complete copy of this e-mail string.

3.2 James Peak Wilderness Area

In August 2002, the James Peak Wilderness Area was officially dedicated. Congress designated the 14,000-acre area, which straddles the Continental Divide and includes area in Clear Creek County adjacent to the area proposed for rezoning to allow commercial use. The legislation prohibits mining, timber cutting, new road building, and land exchanges in the area.

The James Peak Wilderness Area is an alpine wonderland with sweeping views, several majestic peaks, and numerous sparkling lakes. This high-elevation wildland forms the headwaters for the Fraser River , South Boulder Creek, and North and West Forks of Clear Creek. This area provides habitat for elk, deer, bighorn sheep, mountain goat, black bear, and ptarmigan. The area's mixture of alpine meadows and forests also provides outstanding habitat for several imperiled species including the Canada lynx (a state endangered and federally threatened species), wolverine, northern goshawk, pine marten, and boreal toad.

 

In addition to its ecological values, the James Peak area, located only 1½ hours from Denver , provides excellent opportunities for recreation and solitude for many Coloradans. This spectacular place clearly deserves protection, and the land adjacent to the Wilderness Area is much better left zoned as it is; not rezoned for a commercial operation with its associated noise, lights, and activities.

 

As a part of this land exchange with the Forest Service (see Section 3.1), Coors/Eclipse states that Eclipse Snow Park (ESP) willing construct a trailhead for the James Peak Wilderness Area, as stated in their 10-25-06 letter:

 

“As a portion of our development, ESP, through this land exchange, would be willing to develop and provide the aforementioned required trailhead facilities and service as well as allow access across private property held by ESP to provide public access [sic – “to”] the James Peak Wilderness area. This trailhead would be located on private land currently under ESP ownership, or on land acquired through the proposed land exchange. This would rectify the current problematic situation of the general public parking along Fall River Road and other private lands to access St. Mary's Glacier.”

 

They go on to say that:

 

“ESPC will assist the Forest Service in consulting with Clear Creek County commissioners and with local residents to gather information on the appropriate location of facilities and services, as well as the appropriate measures for emergency and law enforcement access, public health, and concerns of impeded access by local residents.”

 

How this trailhead and parking area would be managed and separated from parking only for Eclipse patrons is not clear. Whether or not Eclipse would provide separate toilet and trash facilities (and maintain them) specifically and only for those entering the Wilderness area is also not clear.

3.3 Water for Snowmaking

The proposed 300-acre proposed Eclipse commercial operation could have a significant negative effect on St. Mary's Lake (also called the Glacier Lake ) and the St. Mary's region in general. Eclipse has said that they are have initiated negotiations to obtain (or lease) water rights from Saint Mary's Lake that are currently held by Coors Brewing. The capacity of the lake is 47.6 acre feet, and Coors Brewing has rights to 44 acre feet. The use is defined as industrial, and the point of diversion is in Golden, at the brewery.

 

Typically, the brewery releases their 44 acre feet of water (largely to meet downstream and augmentation requirements) in small amounts throughout the summer and into September and October. The water released from Saint Mary's Lake flows into Lake Quivara in the Saint Mary's area. Water rights in Lake Quivara , as well as Silver Lake , are owned by the Saint Mary's Glacier Water and Sewer District (the District), which supplies water and sewer services to the communities of Ali ce and Saint Mary's. The District does not use the water in Lake Quivara for drinking water, but rather uses this water to meet downstream and augmentation requirements. For decades the District has relied on water released from Saint Mary's Lake to refill Lake Quivara , and thus allow the District to meet its legal downstream and augmentation requirements. Typically, by the end of October, the ice cap is formed on Saint Mary's Lake , and the head gate is closed, allowing the lake to refill over the winter and spring.

 

There are a number of concerns regarding the possibility of using water from Saint Mary's Lake for snowmaking at the proposed Eclipse Snow Park . Coors Brewing currently has these rights for industrial uses with the point of diversion at Golden.

 

•  Is it appropriate (or even possible) to change this use from industrial to snowmaking?

•  Can the point of diversion be changed (or should it be changed) from Golden to allow artificial snowmaking/blowing of snow on the slopes of the proposed Eclipse site?

•  If 44 acre feet of water is taken out of Saint Mary's lake (capacity 47.6 acre feet) in the middle of the winter and after the ice cap is formed, will this (almost or entirely) drain the lake? What will happen to the fish and other life in the lake?

•  If 44 acre feet of water is diverted/used for snow making at the Eclipse site, what will happen to the downstream watershed when the snow melts in the spring? Will there be flooding, increased sedimentation, and/or damage to the downstream riparian environment, including Fall River and Clear Creek?

•  Snowmaking is considered a (at least somewhat) consumptive use. What is the plan for replacement (augmentation) of this water back into the system? Where will Eclipse get water rights for this required augmentation?

•  If 44 acre feet of water is taken out of Saint Mary's lake (capacity 47.6 acre feet) in the middle of the winter, after the head gate has been closed, what will happen in the spring regarding water available to be released down stream, including into Lake Quivara ? The District has relied on this water to refill Lake Quivara for decades. Without this springtime refilling of Lake Quivara , how will the District be able to meet their legal downstream and augmentation requirements?

3.4 Watershed

In addition, Fall River is a riparian habitat and as a primary watershed, we have the obligation to be good stewards. With the increase in traffic volumes and change in drainage patterns, the watershed would be subject to greater levels of water pollution and other possible effects.

 

The Colorado Department of Wildlife (DOW) expressed concerns that the increase in run-off as a result of this development could potentially have an adverse affect on the water quality of the aquatic resources around the project for the life of the development. Pollutants from additional vehicles as a result of this development will likely be drained into the surrounding aquatic systems. Additional pollutants from fertilizers, chemical and petroleum spills, ice-melt and others, could also be introduced into the environment surrounding the development. The affect of these pollutants could potentially have long-term negative impacts on water quality and vegetation without mitigation.

 

Jan Ziman has additional watershed information – some of which is included in Attachment 3.

3.5 Wildlife

The area proposed for Eclipse is home to many large and small species, including primary habitat for Colorado 's bighorn sheep and habitat for the state endangered and federally threatened lynx. The area's mixture of alpine meadows and forests also provides outstanding habitat for other several imperiled species including wolverine, northern goshawk, pine marten, and boreal toad.

 

If the rezoning is approved, the natural wildlife would pay the price in loss of habitat, significantly increased disturbance, and increased vulnerability to accidents due to traffic volume on Fall River Road . They will suffer with increased air pollution as will our lakes and streams, which will collect these pollutants and send them downstream. The natural vegetation would also suffer damage from airborne pollutants, clearing, and grooming activities, thereby affecting the watershed properties of the area. All of these factors would greatly impact wildlife in the area.

 

Other wildlife populations identified by the DOW as abundant include, but are not limited to; elk, mule deer, black bear, mountain lion, coyote, red fox, and a variety of smaller mammals. Moose may occasionally be found in the area, and the population will likely be increasing with the establishment of a small herd in Clear Creek County as animals migrate from Middle Park and South Park . Additionally, the property is in the overall range for elk, mule deer, black bear and mountain lion. It is in close proximity to overall range for Bighorn Sheep, White-tailed Ptarmigan and an elk production area, and maybe used by these species from time to time.

 

There are a number of avian species that may use the habitat on the property and a sample of those birds include: red-tailed hawk, northern goshawk, white-tailed ptarmigan, dusky grouse, broad-tailed hummingbird, chickadee, downy woodpecker, hairy woodpecker, northern flicker, nuthatch, stellar's jay, mountain bluebird, and red-winged blackbird. Many of these birds are currently or could potentially use this parcel of land for nesting habitat during the spring and summer months

 

In addition to disturbance during the winter months, proposed summer operations, possibly including summer skiing, training camps, and mountain biking, would cause additional disturbance to wildlife species; especially since p0oeople will commonly create informal trails throughout a mountain area, cris-crossing mountain sides, wetlands, and other natural areas, spreading out and increasing the overall disturbance and impact to the land.

 

3.5.1 Noise

Snow making and snow grooming are a concern for noise, both for wildlife and local residents. The St. Mary's area is located in a closed canyon, where sounds easily carry and are echoed within the walls of the surrounding mountains and rock cliffs. With no buffer zone between the proposed Eclipse site and the homes at St. Mary's, additional noise from snow making and grooming as well as snowmobiles used, at a minimum, by area staff, would disrupt everyone in the neighborhood, including wildlife. Add to this the fact that these activities would take place at night, likely well after 10 p.m., and the problem is that much more significant.

 

Eclipse has said that they will not have music played from loudspeakers on the slopes, but what about in the public areas? And, what about the PA system and radios in cars parked in the parking lot? In addition, there are discussions of summer skiing and rumors of summer concerts (which are permitted under the newly rewritten C-OR zoning definition). Many of the citizens moved to Saint Mary's because of the peace and tranquility, and wildlife certainly is not adapted to music (or voices) over loud speakers, or to outdoor concerts.

3.5.2 Lights

With night skiing/boarding proposed to be allowed at Eclipse, either until 9 or 10 p.m., lights would be needed. In addition, lights would be needed for nighttime snowmaking and grooming. This will have a negative effect wildlife as well as the local neighborhood where enjoyment of the night sky is one of the pleasures many residents enjoy.

The County Master Plan states the need to update County regulations regarding sensitivity to environmental conditions or night lighting associated with a site. The County should be proactive in this area, and not allow rezoning which would bring bright lights to this remote mountain area – affecting residents and wildlife.

 

The DOW stated that the impact of a functioning ski resort will be significantly increased by longer operating hours and artificial light and noise. Wildlife populations that are subject to any kind of disturbance (hunting, recreation, traffic, etc.) benefit from resting periods and disturbance-free time. Increasing that disturbance by extended time, light and noise will result in less wildlife usage, in general, in the immediate and adjacent areas around the property.

 

3.5.3 Potential Problems with Proposed Wildlife Mitigation

The *problem* with wildlife mitigation is that the resolution identifies the “Plant Fish, And Wildlife Summary Report” (paid for by Coors) prepared by the Western Ecoystems, Inc dated January 23, 2007 – and this report is based on “winter only” operations, which is NOT what Eclipse is proposing. (Apparently Eclipse mis-informed Western Ecosystems about the proposed year-round operations).

 

Wildlife mitigation also points to measures identified by the Colorado Division of Wildlife in their response dated October 3, 2006 (see Attachment 1 for a draft of this response dated September 15, 2006) from Reid DeWalt, Wildlife Manager. However, they do NOT include additional measures presented (and read into the record) by DOW personnel at the January 31, 2007 meeting, including:

 

•  increased probability of road kills on Fall River Road (in particular Big Horn Sheep and Mule Deer),

•  the possibility of the boreal toad existing on the Eclipse property or adjacent (current) Forest Service property, and

•  the possibility of green back cutthroat trout in affected waterways.

 

 

3.6 Alpine Tundra and Bristlecone Pine

A significant portion of the area proposed for Eclipse is above treeline, in alpine tundra. Because of the small number of plant species and the fragility of the food chains in tundra regions, natural or mechanical damage to any element of the habitat affects the whole ecosystem. What effects would skier/snowboarder and, most significantly, operation of heavy grooming machines, have on this fragile environment?

 

There are also stands of bristlecone pine in the area proposed for rezoning. Bristlecone pines are protected in a number of national parks such as the Ancient Bristlecone Pine Forest in the White Mountains of California. The sheer age and beauty of these trees, which may have been seedlings at the time of the pharaohs, inspires awe and protection. Vandalism is a new threat that these ancients face, especially if the proposed rezoning area is open to large numbers of the target market: people 10 to 30 years of age.

 

4. Conclusion

Thank you for your interest and for any possible help you may be able to provide to the citizens of Clear Creek County to protect this beautiful and environmentally vulnerable area. The Saint Mary's Glacier area and the James Peak Wilderness are treasures that deserve protection. Treasures for the County, the State of Colorado , and the nation.

 

Sincerely,

Heather Ulrich

 

cc:   Kirk Cunningham, Richard Levy Sus an LeFever

  Mark Kline, Jan Ziman, and Christy Nealon

 


Attachment 1
CO DOW Response

 

                15 September 2006

 

Frederick Rollenhagen

Clear Creek County Planning Department

P.O. Box 2000

Georgetown , CO 80444

 

RE: Eclipse Snow Park : St. Mary's

Rezoning Case# RZ2006-004

 

 

Dear Mr. Rollenhagen:

 

I would like to take the opportunity to thank you for the opportunity to comment on the proposal for the Eclipse Snow Park, located just north and west of St. Mary's/Alice on Fall River Road in Clear Creek County. My staff is very familiar with the area and the on-going and potential wildlife conflicts related to the vicinity. We have reviewed the project proposal, and would like to specifically comment on potential negative impacts to local wildlife populations.

 

The property covers high elevation lodgepole, spruce/fir and alpine communities, just south of the Continental Divide and the Clear Creek/Gilpin County line. There are intermittent wetlands in the area and it is in close proximity to St. Mary's Glacier. The gullys and ravines on the property serve as a collector for the Fall River watershed, which will eventually flow into Clear Creek and the South Platte drainage farther down stream.

 

Wildlife populations in the area are abundant. They include, but are not limited to; elk (Cervus elaphus), mule deer (Odocoileus hemionus) , black bear (Ursus americanus) , mountain lion (Felis concolor) , coyote (Canis latrans) , red fox (Vulpes vulpes) , as well as a variety of smaller mammals. Moose ( Alces alces ) may occasionally be found in the area, and the population will likely be increasing with the establishment of a small herd in Clear Creek County as animals migrate from Middle Park and South Park . Occasionally, Lynx ( Lynx canadensis) may be found moving through the area. Additionally, the property is in the overall range for elk, mule deer, black bear and mountain lion. It is in close proximity to overall range for Bighorn Sheep, White-tailed Ptarmigan and an elk production area, and maybe used by these species from time to time.

 

Lynx are a federally threatened and state endangered species. The Division of Wildlife is in the midst of a re-introduction and research study of Lynx, based out of the southwest part of Colorado . Some animals have moved through the area in recent years as they expand their habitat and range. Division personnel are closely monitoring lynx movements of radio collared animals. However, there is no evidence at this point of an established, permanent population in the area. Additionally, the Division is one year into a multi-year study of Bighorn Sheep movements and area usage along the Clear Creek Corridor. There has been sheep use in the area, however, determination of specific use areas and migration patterns have not been solidified. Bighorn sheep will commonly use habitat along the continental divide and have been sighted in areas north and west of the property. While it has yet to be determined whether the specific property is commonly used by bighorn sheep, it is well known that areas surrounding the land are utilized by the species. If there are any pertinent findings related to the study, we will be in contact with the county regarding potential impacts to the population.

There are a number of avian species that may use the habitat on the property and a sample of those birds include: red-tailed hawk (Buteo jamaicensis) , northern goshawk (Accipiter gentiles) , white-tailed ptarmigan (Lagopus leucurus) , dusky grouse (Dendragapus obscurus; formally blue grouse ) , broad-tailed hummingbird (Selasphorus platycercus) , chickadee (Parus spp.) , downy woodpecker (Picoides pubescens) , hairy woodpecker (Picoides villosus) , northern flicker (Colaptes auratus) , nuthatch (Sitta spp.) , stellar's jay (Cyanocitta stelleri) , mountain bluebird (Sialia currucoides), and red-winged blackbird ( Agelaius phoeniceus) . Many of these birds are currently or could potentially use this parcel of land for nesting habitat during the spring and summer months. Removal or disturbance of known nesting areas should be avoided during the nesting period from approximately April 1 through July 31 and be in accordance with the federal Migratory Bird Treaty Act. Removal or disturbance of nests should be authorized through the US Fish and Wildlife Service prior to any action. We strongly recommend a breeding bird survey be conducted in the spring prior to any construction to avoid any potential conflicts.

We would like the developer and businesses to make efforts toward condensing human impact on the property to established or newly constructed trails and ski runs, to minimize additional disturbance to wildlife species in the area during ski seasons. Likewise, summertime use of ski runs for downhill biking and related activities should be strictly managed and contained to established trails. People will commonly create informal trails throughout a mountain area, cris-crossing mountain sides, wetlands, and other natural areas, spreading out and increasing the overall disturbance and impact to the land. We strongly encourage centralizing trails, sidewalks, dog areas, parking lots and other gathering areas to help mitigate these impacts.

Additionally, we recommend that extra lighting for night time skiing and music for terrain parks and runs be kept to a minimum. The naturally occurring impact of a functioning ski resort will be significantly increased by longer operating hours and artificial light and noise. Wildlife populations that are subject to any kind of disturbance (hunting, recreation, traffic, etc.) benefit from resting periods and disturbance-free time. Increasing that disturbance by extended time, light and noise will result in less wildlife usage, in general, in the immediate and adjacent areas around the property.

 

Human/Wildlife conflicts should be expected within any mountain community. These conflicts range from bears getting into garbage and garages, to deer and elk eating planted and manicured vegetation around landscaped homes and buildings. Businesses should know that bears are in the area and that special care should be given to garbage storage and bird feeders to minimize bear conflicts in accordance with Colorado law. CRS 33-6-131 prohibits any person from placing food or other enticements out that could attract bears. Businesses should be encouraged to store garbage inside secured facilities or use bear-resistant containers to minimize these conflicts. Repeated failure to abide by this statute may result in possible criminal action.

 

Businesses should also be advised that mountain communities tend to have local, “urbanized” deer and elk populations that will eat many plants commonly used for home landscape design and gardening. Developers should be encouraged to only use native plant species when planting and should be aware there is a likelihood many plants may be eaten by resident herds. To minimize these conflicts, fencing around trees, shrubs and gardens may help in deterring wildlife. Also, increased usage by local wildlife and the establishment of urbanized herds of deer and elk may attract predators looking for prey. The most common prey item for mountain lions are deer, and localized herds may result in conflicts with lions lingering around development and high-use areas. Businesses should be aware of this potential conflict and may want to clear vegetation and overhanging tree branches around their buildings and gathering areas to minimize hiding cover for lions.

 

Bighorn sheep are extremely susceptible to several diseases commonly carried by domesticated sheep and goats. As a result, we strongly discourage any use or possession of domesticated goats or sheep in the area, either as personal livestock or as a weed management tool, because of the possible interaction between domestic herds and wild populations. The interaction with livestock and transmission of such diseases could potentially have a disastrous impact on the local bighorn sheep herds that are already showing signs of disease, particularly pneumonia.

 

We encourage any fencing that is built to be constructed in a wildlife-friendly manner, which allows for the free movement of local herds. We recommend fencing with a smooth top wire that is no higher than 42 inches, with 16 inches between the ground and bottom wire, and 12 inches between the top and second wire. If you would like additional information for other fencing ideas or recommendations, the Division will gladly provide materials upon request.

 

During the construction phase of the development, there is a strong potential for the introduction of exotic and noxious weeds on disturbed soil. Musk Thistle (Carduus nutans) , Canada Thistle (Cirsium arvense) , Diffuse Knapweed (Centaurea diffusa) , Russian Knapweed (Centaurea repens) , Cheatgrass (Bromus tectorum) , Common Mullein (Verbascum thapsus ) , Field Bindweed (Convulvulus arvensis) , and Leafy Spurge (Euphorbia esula) are just a few of the detrimental plants that often become established with disturbance. These weeds will decrease biological diversity, out-compete native vegetation and receive less use from native wildlife if allowed to establish during or after construction. Their propensity to spread rapidly and take over is extremely detrimental to native habitats. Weed control practices including spraying, using weed-free hay and mulch, planting native species, cleaning earth moving equipment before and after use on the property, and active monitoring are recommended throughout the construction and landscaping process.

 

The increase in run-off as a result of this development could potentially have an adverse affect on the water quality of the aquatic resources around the project for the life of the development. Pollutants from additional vehicles as a result of this development will likely be drained into the surrounding aquatic systems. Additional pollutants from fertilizers, chemical and petroleum spills, ice-melt and others, could also be introduced into the environment surrounding the development. The affect of these pollutants could potentially have long-term negative impacts on water quality and vegetation without mitigation. We recommend that you advise developers and businesses of these potential problems, and to keep ice-melt and fertilizers to a minimum in order to avoid any of the potential aforementioned pollutant problems. It is imperative that the integrity of the watershed be left intact during and after construction of the project as the watershed serves millions of down-stream water users.

 

Wetlands in the area serve as a natural means to filter out pollutants in the watershed and provide vital habitat for local wildlife populations, including season avian migrants. Wetland boundaries in the lower portions of the projects should be identified and protected or enhanced, if possible, to help with the potential of increased pollution problems. The U.S. Army Corps of Engineers manages any change to waterways and wetlands, and should be consulted prior to any disturbance, alteration or destruction of streams and wetlands.

 

Finally, with the increase of human activity and travel during construction and after completion of this project, an increase in wildlife/vehicle collisions should be expected. The proposal estimates that an additional 100 to 480 vehicles will use County Road 275 ( Fall River Road ) depending on the user day. While there is no way to determine the exact impact this additional traffic will have on local populations, the wildlife/vehicle collisions will surely increase. There is a major bighorn sheep crossing at the intersection of Fall River Road and I-70, with heavy use at the junction and north of the intersection for ¼ mile. If possible, wildlife crossings, underpasses, or other similar alternatives should be explored and implemented to minimize vehicle collisions with bighorn sheep in this area. We recommend that the developer consult with CDOT and/or the County Road and Bridge department to consider different mitigation options, including but not limited to additional wildlife crossing signs, widening shoulders and cutting vegetation adjacent to roadways. Per Colorado Statute, the Division of Wildlife is not liable to property damage or personal injury due to wildlife/vehicle impacts.

 

One of the major attractions to Clear Creek County and the St. Mary's /Alice area in particular, are the abundant wildlife populations and natural landscape. Clear Creek County should be advised that the incremental growth and development of the county will, inevitably, result in an overall negative impact to local wildlife populations. Failure to mitigate these impacts will eventually result in a change of habitat quality, wildlife use and local population dynamics.

 

If you have any questions regarding this letter or possible mitigation recommendations, please feel free to contact the local District Wildlife Manager, Ty Petersburg, at 303.679.6184. The opportunity to consider this proposal is greatly appreciated.

 

 

Sincerely,

 

Reid DeWalt

Area Wildlife Manager- Area 1

 

 

Cc: Ty Petersburg- DWM; Idaho Springs

Sherri Huwer- Terrestrial Biologist; Areas1 and 2

 


Attachment 2
Forest Service E-Mail String

 

Re: RZ2006-004 Proposed Rezoning in St. Mary's area for proposed Eclipse Snow Park

 

E-mail string between Marshall Ulrich , resident at 515 Brook Drive and Mr. Dan Lovato, Clear Creek District Ranger, U.S. Forest Service, submitted by Marshall Ulrich

 

Marshall Ulrich marsh@marshallulrich.com

To dalovato@fs.fed.us

10/09/2006 04:30 PM

Subject Eclipse Snow Park

 

Mr. Lovato,

 

My name is Marshall Ulrich .  I live up at St. Mary's Glacier and I am a concerned citizen regarding the rezoning of the proposed Eclipse Snow Park . My understanding is that Mr. Coors has been in contact with the Clear Creek Ranger District Forest Service with regard to a “land swap” between Mr.Coors and The Forest Service.   My understanding is that this land swap would be an attempt to piece together a large block of Mr. Coors private property land, then utilizing the newly granted Forest Service Land, together making up a geographically unified snow park.  Could you tell the status of that proposed “land swap”, or is that even a feasible option for Mr. Coors?  Is the land swap something that the forest service can even do?

 

Is there an alternative for Mr. Coors?

 

Also, I was concerned about the Ancient Bristle Cone Pines in the Anchor Gulch, above the actual St. Mary's lake and the Glacier area, some of which I believe could be affected.  Has there been any thought about preservation directed about them?  Are they protected?

 

I understand if you are not at liberty to disclose any information regarding these matters; however I would appreciate and would be interested in any information that you could provide.

 

Thank you for your time and consideration regarding these matters.

 

Sincerely,

Marshall Ulrich

 

-----Original Message-----
From: Daniel A Lovato [mailto:dalovato@fs.fed.us]
Sent: Tuesday, October 10, 2006 10:50 AM
To: Marshall Ulrich
Subject: Re: Eclipse Snow Park

 

Mr. Ulrich, here is what information I can share with you.  We met with Mr.Coors and his group as they requested and discussed a potential land exchange, back in May.  At that meeting we discussed the parameters for a land exchange and the process for a land exchange. The parameters of a land exchange is it must be in the best interest for the American public and not the proponent's best interest.  The US Forest Service does not actively pursue land exchanges because of the time, and money involved with them but does do land exchanges to consolidate fragment land patterns (private and public land mixed) or to acquire critical habitat for threatened and endangered species of plants and or animals, when opportunities arise. When we met with the group we explained their concerns and options as well as our thoughts as well. All we have had with them is preliminary talks but have not received an official land exchange request/proposal from them.  If and when we receive a proposal from them we will follow a series of guidelines to determine if their proposal meets those guidelines to proceed further.  If it meets the criterial then an environmental analysis will be done as per the National Environmental Policy Act (NEPA), which includes public comments through the scoping process.  If during the environmental analysis phase it is determined that the proposal has an effect on any environmental concerns or has consequences to the environment then the proposed land exchange will not go through. Any land exchange must be a equivalent in terms of value (US Forest Service land acquired through the exchange must be equal or greater value than the US Forest Service Land we exchanged).  We also discussed with Mr. Coors the other option of applying for a special use permit instead of a land exchange to use National Forest System Land.  This option is also subject to an environmental analysis through NEPA.  As stated earlier we have not heard back from them and I attribute that to them focused on clearing the first hurdle of getting the county to approve their zoning change.

 

Daniel A. Lovato

Clear Creek District Ranger

Email address: dalovato@fs.fed.us

(303)567-3001

 

 

 

From: Marshall Ulrich [mailto:marsh@marshallulrich.com]
Sent: 10/10/2006 11:24 AM
To: 'Daniel A Lovato'
Subject: USFS and RE: Eclipse Snow Park

 

Mr. Lovato,

 

Thank you so much for your clear and concise response, I verymuch appreciate your time. 

 

Is this information about the status of the land exchange public knowledge?  More specifically, has the U.S. Forest Service (USFS) submitted a response to the Clear Creek County Planning Commission regarding Mr. Coors' proposal for rezoning for his proposed Eclipse Snow Park (ESP)? Note: I assume the USFS was asked to provide input to the proposed rezoning, since a large portion of the Coors property is surrounded by/is very much intertwined with USFS land.

 

If the USFS has not provided an agency response comment/letter to CC County, may I share this information with the Planning Commission? And/or with the public (at the public hearing on Oct 18)? As this issue is quite important, as you understand, especially since Mr. Coors needs the USFS property (by land exchange or special use permit) to "fill in" his ESP.

 

Mr. Coors has indicated in his proposal to CC County that:

 

“Additionally, ESP has initiated discussions with the United States Forest Service (USFS) related to approximately 93 acres of Nation Forest System land surrounding the ESP private property. ESP and the USFS are presently discussing options that would allow ESP to operate on the adjacent 93 acres. This may be made possible by either securing a ski area special use permit (SUP) that would allow ESP to operate approved resort functions on the National Forest similar to most ski areas in the Rocky Mountain Region. Another option being pursued is a land exchange that would trade approximately 93 acres of now National Forest for other private holdings within the basin. The USFS supports this land trade because it would simplify their boundaries and consolidate their USFS land adjacent to Ali ce and the Saint Mary's Glacier. The land trade would also help the USFS with on-going issues related to public access to Saint Mary's Glacier.

 

The requested rezoning process and discussions with the USFS will be proceeding concurrently. This rezoning request is solely for the currently owned property. The analysis for this rezoning request is based on the overall resort concept plan for the 334 acres that ESP plans to eventually operate. If the land exchange is consummated, ESP will approach the County to discuss what will be needed to appropriately zone the acquired land.”

 

So, Mr. Coors is asking the CC County to approve the rezoning “based on the overall resort concept plan for the 334 acres” – yet, if I understand you correctly, he is not currently working with USFS to make this happen. Further, as you point out, the process (whether land exchange or special use permit) is not a simple one and will require environmental analysis and a review process under NEPA. [One side note: if a land exchange and/or special use permit was attached to a piece of legislation, would the NEPA process still apply?]

 

No matter the method… even when/if this land exchange or special use permit process ever actually happened, Mr. Coors does acknowledge that these 93 acres, currently zoned as Natural Resource-Preservation/Conservation District (NR-PC), would also need to be rezoned before a commercial operation such as ESP could be allowed. LOTS of steps to create the “334 acres that ESP plans to eventually operate” – yet he's asking approval based on this potential, arduous, future possibility.

 

Just another note: Mr. Coors is reporting on his ESP Web site his hope of opening for skiing in December 2006.

 

In closing, please do let me know if I can share this information with the CC County Commissioners and/or the public. Or if the USFS has already submitted an agency comment/letter to Fred Rollenhagen at frollenhagen@co.clear-creek.co.us

 

Thank you again so much for the information and your time! It ISgreatly appreciated.

 

Sincerely,
Marshall Ulrich

 

-----Original Message-----

From: Daniel A Lovato [ mailto:dalovato@fs.fed.us ]

Sent: Tuesday, October 10, 2006 1:36 PM

To: Marshall Ulrich

Cc: Lisa M Subcasky; Tim Sutton

Subject: Re: USFS and RE: Eclipse Snow Park

 

With all the email and phone calls I have received it looks like I need to send in a letter to the county but I have shared this information with the County Commissioners during my monthly meeting in September.  The process for a land exchange and or special use permit take at a minimum of 1 year (all the time lines) and  have already missed the botany  season for plants to field survey as well as other field work necessary.  As mentioned we have not received a proposal from them and have not proceeded with any work towards and exchange or special use permit.  As for your question regarding going through a legislative process it will not circumvent the NEPA process as the NEPA process is law and must be followed.  A legislative process will only provide with a timeline in which we must meet, but not allow the law or process to be disallowed.  If they intend to be open this years they can only operate on their private property (pending County approval)  and not on National Forest System Lands.

 

Daniel A. Lovato

Clear Creek District Ranger

Email address: dalovato@fs.fed.us

(303)567-3001

 

-----Original Message-----

From: Marshall Ulrich [ mailto:marsh@marshallulrich.com ]

Sent: Wednesday, October 11, 2006 9:50 AM

To: 'Daniel A Lovato'

Subject: RE: USFS and RE: Eclipse Snow Park

 

Mr. Lovato,

 

Thank you for your clarifications.  I really do appreciate you taking the time, once again, to respond.  I'm glad to hear that you have shared this information with the County Commissioners and think that a letter to the Commissioners is a great idea.

 

On a different, but related note; I've spent a bit of time just below tree line in the bristlecone forests up above us.  They are extraordinary.  Their beauty is unsurpassed!  We are certainly blessed to be living nearby to them.  What a asset to Clear Creek County they are.

 

Sincerely,

Marshall Ulrich

 

 

 

 


Attachment 3
Watershed Information

 

Flood plains, wetlands and riparian areas:

 

The Fall River Homeowners a while back developed their on Master Plan . In it is a wealth of information on the Fall River Watershed as well as studies on wildlife distribution areas. Statements as follows:

 

The collection basin area of the Fall River watershed is relatively concentrated when compared with the volume of water it collects and distributes. Compared with other drainage basins in the area, the Fall River basin collects a greater volume of water per square mile of collection area that many other drainage areas.

 

The Fall River drainage area is fed by a number of sources and is subject to flooding under certain conditions, such as unusual rainfall patterns like those triggered by the Thompson Flood in 1976. For this reason it is and other reasons, maintenance of the watershed capacity of the valley is imperative.

 

The flow of surface water in Fall River is fairly consistent due to a series of dams and other restraints at the upper end of the valley, as well as the role of the watershed. However, during spring runoff season (about 2-4 weeks) there can be instances of moderate to severe flooding depending on weather conditions. A storm centered over the headwaters can bring about a “Big Thompson” type flood in the valley; a quick change from cool to hot weather can bring about excessive runoff and flooding.

 

Erosion due to surface soil disturbances made by poor or excessive construction of roads, houses and other activities can also exacerbate flooding conditions in the area. During spring run off or heavy rains, pollution of the river results from disturbances created by “new” roads/ driveways in the area (York Gulch) turning Fall River into a flowing “river of mud”.

 

Water in the Fall River area is high in mineral content and during periods of runoff and or heavy rains the river is polluted and muddy. This is the result of soil disturbances during prior mining activity, construction of roads in the area and general construction activities within the watershed area which lead to erosion and rapid runoff, thus removing the thin top soil layer.

 

The Fall River Valley was generally formed by erosion from the watercourse. A thin layer of soil covers much of the flat area surrounding the steep side slopes with the outcroppings of granite and talus slopes of broken rock. The soil contains little organic matter to give it texture and absorption capacity. This combination of limited, thin soil layers and poor soil absorption properties makes it necessary to set aside large areas of undisturbed open space for watershed.

 

Where it exists, the soil surface it very fragile and easily dislocated by any significant disturbances. Dislocation leads to conditions of erosion and subsequent flooding, followed by drought conditions.

 

The delicate nature of the soils demands protection from excessive or unnecessary disturbance in order to protect the vital role of the watershed.

 

Because of the concentrated collection area of Fall River , it demands the county to place greater, stringent controls in this area than any other area in the county.

 

> It will take approximately 11,000,000 (That's million) gallons to make snow per season.

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