VOLUME II
PRELIMINARY DRAFT ENVIRONMENTAL ASSESSMENT
1. Decommissioning will serve to limit the harsh impacts of future water restrictions.
2. An inaccurate description of the Project Area is presented.
3. The management plan claims to plan for future use, but has no plans to monitor use, no impacts standards established, and no limits set.
4. Denver Water states "no plans for timber harvest or development exist", but the Forest Service has immediate plans for timber harvest and Gilpin County expects development growth to exceed 1000%.
5. Two dangerous and primary contaminants, cadmium and lead, with known human and aquatic life hazards are not listed nor studied.
6. Mercury, a know human hazard, exceeds the permissible limits by 300X. Denver Water states this as insignificant.
7. The water below the reservoir is significantly more polluted with hazardous heavy metals than the water entering, but no studies of reservoir management and its contributions have been done.
8. Three hazardous heavy metals exceed state and federal limits, but Denver Water has taken no steps toward monitoring.
9. West Slope water is not listed as a source of contamination, but it is one of the primary sources. Agricultural chemicals (herbicides, pesticides, and fertilizers) contribute significantly
to decreasing water quality.
10. This document shows Denver Water's ignorance of local geology and hydrogeology, bringing into question their competence and sincerity.
11. Denver Water and their consultants did not review water quality studies completed by Boulder County in 1976 and 1996.
12. Denver Water claims that their flow regime and modifications affect only a limited section of river, but often no water remains in the river after Denver and other users are done, affecting the entire river along its full length.
13. Imagine breathing just 86 percent as often as you do now. That would amount to one fewer breath every minute. Denver Water is planning to reduce the number of times they meet minimum flow requirements. Aquatic life will be stressed, perhaps beyond the point of recovery.
14. Wildlife records by local groups have not be considered in the resource assessments and consequently inadequate and inaccurate wildlife data is listed.
15. Denver Water claims a "difficulty of enforcement..." but has carried out little enforcement in the past (even after a death at Jumping Rock), and has no plans for monitoring or enforcement.
16. The Winiger Ridge area is easily accessible by foot, horse, or bike, not "only by four wheel drive" as stated in the document.
17. The document fails to note the existence of Lakeshore Subdivision, the closest and possibly largest of the nearby residential areas, certain to be affected by any management decisions at Gross Reservoir.
18. It will be a violation of this document if any agency other than Denver Water implements any component of the management plan.
VOLUME III
VEGETATION AND WETLAND/RIPARIAN RESOURCES REPORT
1.) The document fails to satisfactorily deal with the potential for noxious weed infestation. No plan has been set up to monitor or control the spread of noxious weeds. Increased recreation will increase the potential for the introduction of even more noxious weeds to this relatively pristine area. The workgroup consensus of “no new net increase” in recreation should be adhered to. A weed study and monitoring program should be part of any recreation management plan.
2) Colorado State Park Management would mean the area would become a destination, thereby increasing use (despite the best efforts of the plan) and increasing the spread of noxious weeds.
3) The plan’s own conclusions are often at odds. For example (see our specific comments, on page 9 of PUMA’s Gross Reservoir Comments Section) the plan indicates in one section that, “...proposed action may result in adverse consequences...”, and in another indicates, “no “perceivable cumulative effects...” of the same proposed action! The ambivalence reflected in these two statements leads us to question the validity of the methodology, the studies and the entire document itself.
VOLUME IV
THREATENED, ENDANGERED, AND SENSITIVE SPECIES
1) The following are threatened endangered or sensitive species that occupy habitat in or directly adjacent to the Gross Reservoir project area:
Northern Goshawk - Potentially suitable habitats identified within Gross Reservoir Project area. Surveys did not locate birds, although this species has been observed foraging on the northern portion of the project area. Construction of a power line may cause direct and indirect effects to potential habitats used by the goshawk and provides the potential for electrocution or collision. The creation of additional campsites on the western shores of Gross Reservoir could potentially affect this species.
Flammulated Owl --- Potentially suitable habitat identified. PUMA volunteers had a Flammulated owl respond to a playback on May 31, 1996 in the Winiger Gulch area. Greystone surveys failed to locate this species. Construction of a power line may cause direct and indirect effects to potential habitats used by the flammulated owl and provides the potential for electrocution or collision. The creation of additional campsites on the western shores of Gross Reservoir could potentially affect this species.
Ute Ladies' tresses Orchid -- found in area along South Boulder Creek between the community ditch and the confluence of South Boulder Creek and Boulder Creek (outside of study area boundaries). No suitable habitat (wet meadows, swales, abandoned meanders) found for the orchid in Gross Reservoir Study area #1. Changes in flow through the Gross Reservoir system could potentially effect this species.
Wood Lily - found in Forsythe Canyon. Changes in flow through the Gross Reservoir system would not have any effect on sensitive species in the project area. Increased foot traffic in Forsythe Canyon could put populations of wood lily at risk due to flower picking and digging.
2) The methods section of a scientific paper always documents the amount of time spent in the field conducting surveys. The absence of this information in this report is a glaring omission and suggests that inadequate field efforts might be why certain sensitive species were not detected in the study area. In fact we found that inadequate and, sometime even negligent, studies to be a dubious hallmark of the entire Gross Reservoir relicensing document.
3) Colorado Department of Parks and Outdoor Recreation (CDPR) should be eliminated as a possible management entity. Their stated goals of “relieving the pressure” from Eldorado Canyon State Park by connecting with Gross are diametrically opposed to the Workgroup Consensus of no new net increase in recreation.
4) Because Forsythe Canyon is a riparian corridor containing sensitive species, recreation access should be strictly limited to low density foot traffic only. Horses and bikes should be banned. Rewrite appropriate sections of the plan to reflect this.
5) Eliminate all power line alternatives except the “Northern Alternative” due to the massive habitat disruption and destruction that would result from the other alternatives.
6) The consensus of the summer workgroup meets was there was to be six campsites on Winiger Ridge -- not the ten called for in the map. Remove four of the proposed sites from the plan and from the map -- especially the three that are on steep slopes and in sensitive species habitat.
VOLUME IV
THE RECREATION MANAGEMENT PLAN
1) Remove Colorado Department of Parks and Recreation (CDPR) as a potential management entity because their stated goals are in direct opposition to the “no new net recreation” consensus of the workgroups. CDPR’s involvement in the managing of Gross Reservoir is at best a conflict of interest, and at worst a blatant dismissal of the consensus arrived at by the Recreation Subgroups throughout the entire planning process.
2) Consider a private management entity, paid for by Denver Water Board. The low impact, low intensity recommendations outlined by the Rec Working Groups can be controlled by a single management person three seasons out of the year. Because access roads are closed due to wildlife or weather conditions during the winter, minimal management presence is required.
3) There are many individuals, groups and governmental agencies who are interested in NOT having trail connections, including Boulder County Open Space. Due to potentially severe impacts on the surrounding environment, trail connections were ruled out by the consensus of the workgroups. Eliminate them from consideration in the plan.
4) Include PUMA’s comments in the final draft of the plan. Ninety Five percent of our multi-page commentary was absent from the preliminary draft, nor was it included in the FERC update mailed out at the beginning of the year.
5) Make all improvement plans “no trace efforts”.
6) Reduce the number of campsites on Winiger Ridge from ten to the agreed upon six.
7) We applaud the decision by DWB to ban 4wd vehicles from the Winiger Ridge side of the project area. Gates and vehicle turnarounds must be fortified so they cannot be circumvented.
8.) Traffic on trails in sensitive riparian corridors should be limited to low density foot traffic only. Horses and mountain bikes should be banned. These trails include the Forsythe Canyon, Winiger Gulch and South Boulder Creek Inlet trails.
9) The pollution and noise studies are flawed. Reconsider the impacts increased use will have on pollution, noise and the quality of the wildness experience.
10) Include minutes of the meeting from Cherryvale, Magnolia and Coal Creek in the Appendix. Include letters and supporting documents that reflect the actual diversity of views.
11) Include the notes and documents from the work groups upon which the plan is based -- specifically the August 14 and 21 documents. Documents or minutes from the two follow-up open houses should also be included.
12) Address the fire and safety concerns that will result from the potential for increased recreation. The project area is bordered on all sides by traditionally understaffed volunteer fire departments. Even in the best of weather, access to the project area is slow and difficult.
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