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Open Space - Study Session - Grassland Ecosystem Management Plan Responses to Community Comment on the Public Review Draft MEMORANDUM TO: Open Space Board of Trustees FROM: Michael D. Patton, Director Open Space and Mountain Parks Eric Stone, Resource Systems Division Manager Mark Gershman, Environmental Planning Supervisor DATE: February 11, 2449 SUBJECT: Study Session: Grassland Ecosystem Management Plan Responses to Community Comment on the Public Review Draft I. PURPOSE The purposes of the study session are to: 1. Summarize the community feedback on the Public Review Draft of the Grassland Ecosystem Management Plan (Grassland Plan); 2. Discuss staff's proposed responses and plan revisions to address the following key topic areas: a. Coordination of Open Space and Mountain Parks (OSMP) Planning Efforts b. Grassland Plan conservation strategies and Visitor Access c. Addressing community concerns about prairie dog conservation 3. Receive recommendations from the Board members about their preferred responses to community concerns. II. EYECUTIVE SUMMARY Staff began work on Open Space and Mountain Parks' (OSMP) Grassland Plan in the fall of 2446 following the acceptance by City Council of the city's Urban Wildlife Management Plan (UWMP). The council-accepted Black-tailed Prairie Dog Component of the L1WMP identified the completion of the OSMP Grassland Ecosystem Management Plan as a priority action. The UWMP described opportunities for prairie dog conservation in the "urban core", and identified the need for anecosystem-based grassland plan as the vehicle to describe how the city's natural lands would contribute to prairie dog conservation. This council priority matched well with OSMP's intent to develop the grassland plan as a complement to Forest Ecosystem Management Plan (FEMP) and the recently completed Visitor Master Plan (VMP). By the end of 2446, staff had developed a draft project purpose, a proposed geographic scope, and preliminary ideas about conservation targets those elements of the grassland that would become the focus of the plan. OSMP discussed the draft conservation targets with a group of grassland ecologists and conservation professionals during a daylong workshop on December 15, 2446. The ideas generated during this meeting were used to adjust and further define the plan's proposed conservation targets. 1 The draft project purpose, and proposed geographic scope were discussed by the OSBT on February 27, 2007. Staff held two community meetings to gather feedback on the draft purpose, scope and targets on November 28 and December 12, 2007, The OSBT discussed the purpose, scope, and conservation targets in a study session in January 9, 2008. A public review draft of the Grassland Plan was made available at the end of October 2008 for a six-week public comment period. OSMP hosted a community meeting during the review period to provide community members an opportunity to learn more about the plan and share their comments. Comments from the meeting are included in Attachment A. OSMP received 74 written comments on the public review draft of the Grassland Plan (Attachment B). OSMP received many comments supporting the plan and the development of conservation strategies for environmental and agricultural resources. Community members provided feedback raising concerns and providing suggestions about a broad range of topics. These comments focused on the following topics: • Coordination among the Grassland Plan, the Visitor Master Plan and Trail Study Area Plans o General Plan Coordination Concerns o Documenting and Measuring Tradeoffs Between VIVIP and Grassland Plan Goals o Recognizing of the Importance of Visitor Services in the Grassland Planning Area o Need for Analysis and Assessment of Recreation in the Grassland Planning Area • Grassland Plan Conservation Strategies Affecting Visitor Access o Trail Closures in Wetland/Riparian Buffers o Proposed Grassland Bird Protection Areas o Trail Placement along the Edge of Large Blocks of Open Space and Mountain Parks • Prairie Dag Conservation and Management o Insufficient Areas Designated for Prairie Dog Conservation o Threat of Plague to Prairie Dogs o Preventative Application of Insecticides to Reduce Threat of Plague o Agricultural Lease Modification to Promote Prairie Dog Conservation o Relocation Elsewhere in Colorado o Prairie Dogs Lead to Vegetation and Soil Loss o Prairie Dogs' Negative Effects on Agricultural Sustainability o Impact of prairie dogs on neighboring private landowners o Plague and Liability Potential Staff summarized and responded to a number of other comments that were not selected for discussion at this study session. They are included in Attachment C. 2 III. QUESTIONS FOR THE BOARD'S CONSIDERATION The Board has sometimes found it helpful to have a few questions to focus its study session discussions. The following are suggested as possibilities: Does the Board agree with the responses to public comment outlined below? If not, what responses/plan revisions would more closely reflect the Board's thinking? Are there other key topics that the Board would like staff to address? (See Attachment C for staff's summary of other public comments). IV. ISSUE DESCRIPTION AND ANALYSIS ~ ' General Plan Coordination Concerns Comment Summary 117any comments focused upon the relationship of the Grassland Plan with the VMP and Trail Study Area (TSA) planning process. These comments ranged from questions about how the plans are related, to recommendations that the Grassland Plan be viewed as a resource inventory to inform TSA plans. Some comments suggested that trails and recreation should not be mentioned at all in the Grassland Plan because they are the purview of the VMP and TSA plans. Others suggested that since the Grassland Plan identified and analyzed only ecological and agricultural targets, it should not make recommendations that could affect visitor's access or experience on OS11'IP lands. OSMP staff attempted to address this issue in the introductory section of the Grassland Plan. The following was excerpted fi•om the plan under the heading "Relationship to Other Planning Documents" OSMP's Visitor Master Plan (VMP) (City of Boulder 2005) developed a framework to deliver recreational facilities and services in a manner consistent with the conservation of natural and cultural resources. The Grassland Plan used the policies and management area designations in the VMP as a starting point for examining the relationship among recreational activities and grassland/agricultural conservation. The Grassland Plan provides information about areas of ecological importance that was unavailable when the VMP was developed. One of the ways that the objectives of the Grassland Plan will be acted upon is through on-going integration of new grassland information in the Trail Study Area (TSA) planning and TSA plan revision process. The availability of specific information about the current status and desired condition of natural resources will improve OSMP's ability to balance resource protection and visitor access. (Public Review Draft Grassland Plan p. 5 emphasis added) The Open Space and Mountain Parks Department (OSMP) delivers several community services. Among these are land acquisition, and land management for passive recreation, biodiversity 3 conservation, and agriculture. Like other city departments, OSMP in partnership with the community has developed master plans to guide sen~ice delivery. These master plans describe: • The priority services that OSIvIP is committed to provide, • The acceptable levels of service delivery, and • The specific actions that OSNIP will use to deliver these services . City Council has approved three OSMP master plans to date. • The Accelerated Acquisitions and Management Plan provides guidance for the department's acquisition of land, water and mineral rights. • The Visitor Master Plan (VMP) describes the priorities, levels of service, and strategies for providing recreational services. • The Forest Ecosystem Management Plan (FEMP) addresses the ecological management of the forested foothills. The CTrassland Plan was intended to complement these plans by providing a framework for strategic action to conserve the ecological values of Boulder's grasslands and to ensure on-going agricultural production. Taken together, the VMP, FEMP and Grassland Plan provide guidance and strategies to provide the community with recreational access, agricultural and biodiversity conservation services. These plans were designed to be compatible. For example, where the FEMP and Grassland plan overlap geographically forest management practices such as tree-cutting and prescribed fire are being used to restore grassland ecosystems. The V MP and Grassland Plan address different aspects or values associated with OSMP management. Many of the strategic actions in the Grassland Plan are unlikely to affect visitors significantly if at all. For example, the Grassland Plan anticipates some changes to timing or frequency of livestock grazing. Such changes would be accomplished outside of TSA planning or implementation and are unlikely to be noticed by or affect visitors to OSMP. From time to time, there will be the need to address competing objectives of the Grassland Plan and the VMP. Consider the placement of a new trail. From the perspective of the visitor's experience, the VIvIP Establishing the Vision by recommends providing Setting Priorities an aesthetically pleasing setting for Boulder City Charter trails. In order to Boulder Valley Comprehensive Plan conserve high-quality OS Long Range Management Policies wildlife habitat, the Grassland Plan recommends placing FoGUStng the Vision by trails along the edges Developing Strategies of large habitat blocks. Forest Plan The edges of habitat Visitor Master Plan Grassland Plan blocks are often along roads-a less pleasing Trail Study Area Plans Making the Vision Reality by ¢ Taking Action OSMP Strategic Operating Plan location for most visitors. The TSA process provides an opportunity to develop recommendations for a route that takes into consideration both trail aesthetics and habitat effectiveness. The figure above depicts the relationship among the various plans and policies that guide OSMP's land management. Documenting and l~~Ieasuring Tradeoffs BetFVeen Vl~~TP and Grassland Plan Goals Ca,~,~enr su~,~a~y Some commnents reflected a desire that OSMP nnprove the way the TSA process describes and measures the tradeoffs between conservation and visitor access when these objectives compete in the same geographic area. When OSMP commits the resources and makes significant changes to the land (e. g. trail or trailhead construction) trade offs among OSMP purposes are considered "up-front" and predicted during the TSA planning process. The TSA planning process combines community input, existing scientific or inventory information, guidance from management plans, and OSMP's best professional judgment to arrive at a decision about the relative costs and benefits of an action or actions. Staff places a great deal of emphasis on pre-planning, because it is very unlikely that a trail or trailhead would be removed once it is in place. The development of the Cn•assland Plan will provide an important system-wide context for informing decisions about the relative value of a particular resource. For example, there is likely to be a greater imperative to protect the only occurrence or one of a very few occurrences of a particular rare resource. Without a system- wide understanding of the relative importance of a population of rare plants, or a large habitat block, it would be possible to assume incorrectly that there were other occurrences that could be protected in future TSA plans. However, it is unrealistic to expect all up front predictions to be completely accurate. Therefore OSMP staff folio«~s up by collecting information after a strategy is implemented (e.g. after a trail is built). OSI~IP relies upon formal and informal information gathering including visual inspections, rapid assessments, or tracking anecdotal information from staff and visitors. Where there are significant unanswered questions about the effect of an OSMP action, staff may initiate a formal monitoring project to collect quantitative data. This sort of monitoring is expensive and requires pre-planning for baseline information collection and to prepare protocols and train staff. Whether collected formally or informally, new information is used to adapt management strategies and improve future decisions. Recognizing of the Importance of Visitor Services in the Grassland Planning Area COJ?2J't2EtZt .STLLPt2l1Z[LYy Several comments expressed a concern that the Grassland Plan does not adequately describe or acknowledge how people enjoy the Grassland Planning Area. Some described an anti-recreation tone to the plan and suggested that OSMP distinguish and highlight compatible and positive human activities in the Grassland Planning Area. 5 Visitor access to the Grassland Planning Area is a highly valued, popular and integral part of OSMP's community service delivery. The Grassland Plan should reflect the strong community interest in enjoying and learning about OSMP grasslands and that providing access, enjoyment and education are important visitor services. OSMP staff has prepared an addition to the plan describing the ways in which OSMP supports visitor access, visitor enjoyment, educational programming, outreach activities and volunteerism in the Grassland Planning Area (Attachment D). Staff has also reviewed the draft document to identify and proposes to modify the tone where appropriate. OSMP received many specific comments that will allow for improvements to the draft. For example, the target descriptions will be modified to include more information about the many compatible ways that people enjoy the planning area. It is important to note however, that there are types of recreational activities and visitor behaviors that can and do damage the conservation targets; even though they do not represent all, or even most, of the visitor activities enjoyed in the Grassland Planning Area,. In an attempt to address all necessary aspects of grassland management, the Grassland Plan will continue to identify and address these incompatible practices. Need for Analysis and Assessment of Recreation in the Grassland Planning Area Comment ,Summat~y OS11~1P received comments from community members who felt that without a recreational inventory, analysis, or needs assessment, the Grassland Plan should not recommend strategies that could affect recreation in the planning area. Open Space and Mountain Parks completed asystem-wide analysis of the visitor experience and visitor facilities in the VMP (completed in 2445) and has been completing detailed recreational analysis and planning through the TSA process across the OSIVIP system. Although part of a separate plan, the guiding principles, objectives and strategies of the VMP were part of the Grassland Plan staff's thinking when evaluating strategies affecting recreation. The draft Grassland Plan identifies some recreational activities which reduce the viability of Grassland Plan targets. These activities include, but are not limited to, the presence of people and pets in sensitive raptor and grassland bird nesting areas during breeding season, dogs chasing prairie dogs and other ti~-~ildlife, and trampling of creek banks by people and dogs. Strategies developed to address incompatible recreation were repeatedly modif°ied in an attempt to avoid or minimize consequences to OSMP's visitor service delivery. Stafftook seriously the VMP guidance to use the least restrictive approach. However, the VMP also guides OSIVIP to be careful to protect resources when there are reasonable grounds for concern about significant damage. Staff also considered the strategies included in the recently completed TSA plans as examples of approaches that were likely to appeal to the community. All strategies were evaluated according to their benefit, feasibility and cost. A component of feasibility ranking was a consideration of how stakeholders, including visitors, would be affected by the strategy, and to what degree the strategy would appeal to their motivations. The latter is 6 especially important because OSIti~IP relies strongly upon voluntary compliance with its policies and regulations. • • Trail Closures in Wetland/Riuarian Buffers eQnanxent Summary The closures of designated trails in wetland and riparian areas negatively affect visitors' enjoyment of OMSP. These areas provide some of the best scenery, excellent opportunities for nature observation, are shady and cool, and are among the most popular destinations for visitors. The draft Grassland Plan does not propose closures of designated trails to achieve the objective of reducing trail density in wetland and riparian areas and their buffers. In fact, this strategy was ranked highly because it could be carried out by closing only undesignated trails. The plan will be modified to clarify this point. Staff has prepared language to explain the reasons for wetland and buffer protection, and how the proposed standards were developed (Attachment E). The VMP directs staff to evaluate undesignated trails and to close trails that are not identified for designation. Staff conducts an undesignated trail evaluation routinely as part of each TSA plan. Grassland plan staff conducted an analysis of trails in the buffers to see if it would be possible to meet the wetland buffer road/trail density objective by focusing on undesignated trails. After analyzing the relative contribution of designated and undesignated trails to trail/road density in the buffer areas, OSMP found that the objective could be achieved by addressing impacts from undesignated trails alone. Achieving the Grassland Plan's wetland/riparian buffer trail density standard does not mean that OSMP will not construct new trails in these areas. The draft grassland plan states that acceptable conditions are met when most (at least 75%) of the wetland and riparian buffers will have a trail density lower than 46 meters/hectare (61 ft/acre). Given the size of the 200m buffer (see the map on page four of Attachment E), it is inevitable that trails will enter the buffers. OSMP staff recognizes the importance of providing access to the diverse ecological types found in the Grassland Planning Area including wetlands, creeks, ponds and riparian areas. In fact, several trails have been built in wetland/riparian buffers as part of the implementation of TSA plans for Eldorado Mountain/Doudy Draw, and Marshall Mesa/Southern Grasslands. • OSl1'IP should provide specific information about which trails would be moved or closed. OSMP anticipates that closing undesignated trails, or re-routing designated trails in wetland/riparian buffers would be incorporated into TSA planning and implementation. This approach ensures that an undesignated trail will first be considered for designation. It also gives OSMP one way to prioritize the large number of possible undesignated trail closures across the OSMP land system and answer questions about exactly which trails OSMP would close. Staff would begin addressing the undesignated trails remaining after the TS A plan's undesignated trail evaluation While there are likely to be numerous criteria for prioritization of undesignated trail 7 closures (safety, location, aesthetics, other resource impacts), it is likely that undesignated trails actually entering wetlands or riparian areas would be among the highest priorities. Closing trails within the buffer, area beginning with those closest to the wetland or riparian area or creating the most habitat damage within the wetland buffer would be lower priorities. OSMP has been relocating trails from riparian areas and wetlands to reduce ecological impacts for many years. OSMP has moved, or proposed relocation of the Towhee, Bear Canyon, Greenman, and Doudy Draw trails to protect creeks and wetlands. Designated trails are not typically moved outside of the 200m buffer, but rather rerouted from the creek bottom or away from creek banks or the edge of the wetlands. The community has been generally supportive of these trail re-routes because the old trail is typically replaced by abetter-designed substitute serving the same general destinations. It is likely that such designated trail re-routes would continue. In some cases, OSMP may take action outside the context of TSA planning to protect sensitive resources from severe impacts. Proposed Grassland Bird Protection Areas The plan proposes ntcieasing the area of seasonal closures by a factor of six to protect ground nesting birds. This would significantly recluse recreation opportunities for visitors (such as long runs with unleashed dogs and off trail travel by equestrians). The Grassland Plan recommends consideration of additional seasonal ground nesting bird protection areas (Attachment F) as a way to reduce stresses upon grassland birds during the sensitive breeding time (May 1-July 31). The focus on grassland birds is a reflection of continental scale population declines affecting this group and the opportunity to make a local contribution to regional conservation efforts. Staff considered that establishing these seasonal protection areas over less than half of the grassland bird habitat on OSMP as a reasonable balance. During the grassland bird nesting season, these protection areas allow visitor access on designated trails. Visitors are also welcome to bring their dogs where regulations allow; however, leash requirements are in place. Staff does recognize that leash and on-trail requirements reduce the range of activities that visitors can enjoy in these places. The protections extended to grassland nesting birds are not simply visitor access restrictions. OSMP staff minimizes visits to these areas, altering management and maintenance schedules. Staff also works with agricultural lessees to adjust livestock grazing. Changes in seasonal use and stocking rates can help optimize habitat conditions and improve the chances of breeding success by ground nesting birds. The Grassland Plan does not recommend establishment of these protection areas, but rather conside~crtion of some specific areas as part of current and future TSA planning. Staff and community members voiced a concern over the lack of system wide information about the relative value of environmental resources during the developrnent of the Marshall Mesa/Southern Grasslands and Eldorado Mountain/Doudy Draw TSA's. Now the Grassland Plan can provide some of this information to inform TSA planning. The areas proposed for consideration were identified mostly based on block size and general habitat characteristics, but also with historic grassland bird data collected by OSMP staff and researchers outside the Department. If funding is available, OSMP will be surveying bird populations starting in 2009 in the proposed seasonal 8 closure areas to build a better understanding of the relative value of these areas for bird conservation. As with other resource protection strategies, OSIVIP cannot always wait for TSA plan development to take action to protect sensitive resources. Some grassland bird closures may be instituted outside the TSA fiamework when sensitive species are at risk of significant impacts. OSMP routinely institutes seasonal protected areas (which include access restrictions) to protect grassland nesting raptors such as Osprey, Bald Eagles and Burrowing Owls. In the case of Bald Eagles, OS11~IP has a legal obligation to protect nest sites. The community has been generally supportive of these protection measures. Trail Placement along the Edge of Large Blocks of Open Space and Mountain Parks Comment Summary The Grassland Plan recommends limiting new trails development in large habitat blocks to the edges. This will degrade the visitor experience and should not be vnplemented until the recreational resources ui an area are inventoried and evaluated. OSMP agrees that trail placement decisions need to be made after evaluating the local recreational and ecological resources. This strategy will be restated to indicate that such determinations will be made after evaluation of both natural and recreational resources during the TSA processes. Insufficient Areas Designated far Prairie Doi Conservation Comment Summary The extent of land designated as prairie dog conservation is insufficient • There should be at least 1,673 acres of prairie dog conservation areas, to equal the maximum extent of prairie dogs occupying the Habitat Conservation Areas designated in the 1996 Black-Tailed Prairie Dog Habitat Conservation Plan. • The maximum acreage of prairie dogs should be increased to at least 3,500 to match the maxnn~.un extent of prairie dog occupation across OSl~IP lands from 1996-2007. • Removal should not be included as a management option for Grassland Preserves • The occupation threshold of 26% should be increased Currently in the plan, minimum acreage conserved for prairie dogs (Prairie Dog Conservation Areas + Multiple Objective Areas + 10% of Grassland Preserves) is equal to 1,545 acres. The maximum occupancy of 2,842 acres is based on acreage from Prairie Dog Conservation Areas + Multiple Objective Areas + 26% of Grassland Preserves. This number actually represents a 59% increase in acres of prairie dog occupation protected over the designations developed in the 1996 plan. Although the plan includes language to allow consideration of removing prairie dogs from Grassland Preserves if occupation exceeds 26%, this is based on the co-occurrence of poor vegetative conditions resulting from prairie dog occupation. As a result, the plan does not 9 preclude the possibility of prairie dogs occupying in excess of 2,842 acres in protected areas if vegetative conditions remain suitable. The inclusion of "possible relocation /removal" as a strategy in Grassland Preserves if occupation reaches a threshold and vegetative conditions are poor is intended to protect other Grassland Plan conservation targets within the Grassland Preserves. IVlost of the large, best opportunity blocks of Mixed Grass Prairie Mosaic exist within the Grassland Preserves. While prairie dogs constitute a portion of this mosaic, long-term occupation can degrade vegetative conditions beyond viability thresholds set up in the plan. As a result, unlimited prairie dog occupation in Grassland Preserves could lead to a situation in which viability of the mixed grass prairie mosaic could not be maintained at suitable levels. Since the Grassland Plan strives to conserve all conservation targets simultaneously, the plan includes limits to ensure that black- tailed prairie dogs do not become a source of stress to other targets. However, occupation of prairie dogs beyond 26% would not necessarily create a problem, or elicit a response unless vegetative conditions had fallen below the designated viability thresholds. Therefore, prairie dog populations could expand as long as co-occurring conservation targets were not threatened. Staff considers 2,842 acres (or more under conditions described above) sufficient to ensure conservation of a significant acreage of Black-tailed Prairie Dogs and Associates while simultaneously ensuring the conservation of other GMAP conservation targets. Threat of Plague to Prairie Dohs Comment Summary The level of threat posed by plague should be higher than "117edium" for the prairie dog target and "Low" for the planning area. Plague is unpredictable and has been shown elsewhere to lead to 100% loss of prairie dog towns and an overall downward population trend in prairie dogs. OSMP staff recognizes that sylvatic plague poses a threat to Black-tailed Prairie Dog populations across the species' range. In Boulder, detailed mapping following the 1994-1996 plague epizootic and experience with previous epizootics have shown a recovery over time of acres occupied by prairie dogs up to and exceeding pre-plague levels. Following the mid-90s epizootic, prairie dogs occupied only 182 acres on OSMP lands, but expanded to over 3,500 acres in 2005 prior to the current plague epizootic. While some increases in prairie dog occupancy were due to new property acquisitions and relocations onto OSMP property, many colonies affected by plague recovered without human intervention. Several colonies also survived plague due to their relative isolation in the landscape (colonies in more urban areas appeared not to get affected by plague). In addition, OSIVIP staff has seen no evidence that plague is evolving to be more virulent. In fact, evidence exists that some animals may be able to develop immunity. This may provide a possible mechanism by which future plague outbreaks may be less devastating to populations in the short and long term. Based upon local experience, staff has no reason to believe that future plague epizootics will differ in severity or scope. However, staff also recognizes that prairie dog populations elsewhere have experienced significant long-term impacts from plague and that future epizootics in Boulder may not behave 10 in the same way that we have experienced in the past. To address this, staff proposes to modifu language in the plan to explain the patterns of past plague epizootics in Boulder, and to explicitly recognize the uncertainty and potential for more significant impacts in the future. Consequently, the threat ranking of sylvatic plague will be increased to "High" in an effort to capture this uncertainty. Preventative Application of Insecticides to Reduce Threat of Plague Comment Summary Given the significant threat posed by plague to prairie dogs and the environment they support, the plan should better pose strategies to address the unpacts of this disease. OSMP should consider the preventative application of insecticidal dust. OSMP agrees that effective strategies to address the threat posed by plague could be useful for the conservation of the "Black-tailed Prairie Dog and Associates" target. Staff will add preventative insecticide dusting as a potential strategy. However, as described below, this strategy offers limited benef°it, and faces several feasibility issues. Plague moves quickly through prairie dog colonies without forewarning. OSMP staff typically becomes aware of plague epizootics only after there has been a significant die off- and dusting would have limited, if any benefit. Confirming the presence of plague typically takes at least an additional two weeks. Beginning a program of burrow dusting to slow or stop the spread of plague would require the application of large amounts of insecticides. Such a practice would require approval through the city's pesticide guidelines. These guidelines were established to ensure that the City minimizes the use of pesticides in response to community concerns associated with the direct and indirect effects of pesticides upon people in general and more specif°ically upon those with chemical sensitivity and other non-target native species. While chemically sensitive people can avoid prairie dog colonies during and after dusting, there are a number of non-target species, particularly invertebrates, that use and rely upon both active and inactive prairie dog burrows. Invertebrates would be killed by burrow dusting, and widespread treatment could have significant effects upon the invertebrate populations of prairie dog colonies. In addition to addressing the non-target effects, the feasibility of burrow dusting can be challenging in the fragmented landscape of the Boulder Valley. It is difficult to predict how plague epizootics move across the landscape. This would require preventative dusting in all "next nearest" colonies around the place where plague is first detected. C)SMP agrees with the conclusions of Cully et al. (200b: I67) i that the use of insecticide dusts should be limited to specific areas v~~here prairie dog conservation is especially critical (such as study colonies orblack-footed ferret relocation sites). OSMP will continue to use burrow dusting in situations where required as a condition of a relocation permit by the Colorado Division of i i Cully, J.F., D.E. Biggins, and D.B. Seery. 2006. Conservation of Prairie Dogs in Areas with Plague. In Hoogland, J.L. ed. Conservation of the Black-tailed Prairie Doi .Island Press. Covelo, CA. 350 pp. 11 Wildlife or where Boulder County Health identifies a public health issue. These applications tend to be localized and have less widespread non-target impacts. Agricultural Lease Modification to Promote Prairie Doh Conservation Comment Summary Has OSMP considered modifying agricultural leases to allow prairie dog occupation of leased areas? Prairie dog occupation is already widespread in OSMP properties leased for agricultural production. In fact, many of the prairie dog conse7vation areas fall within areas leased to local ranchers for livestock grazing. OSMP's leases provide no guarantees that prairie dogs (or any wildlife) will be managed to address impacts to agricultural production. OSMP does not allow agricultural lessees to control prairie dogs. While OSMP considers livestock grazing and prairie dog occupation to be compatible uses in native rangeland, irrigated pastures and croplands are not considered compatible with prairie dog occupation. The Grassland Plan recommends removal of prairie dogs from these areas, v~~hich are the highest quality agricultural lands on the OSMP system. Relocation Elsewhere in Colorado Comment Summary Why doesn't the plan consider relocation of prairie dogs from OSMP lands to other places in Colorado? The demand for prairie dog receiving sites in Colorado far outweighs the supply. This is partly due to a state law requiring approval from the board of county commissioners in the "receiving" county for relocation of prairie dogs from another county. While there have been some cross- county relocations in Colorado, most county commissioners have repeatedly expressed no interest in receiving prairie dogs from outside their borders. Most agencies that manage prairie dogs reserve available receiving sites for their own needs. Addressing the limitation of the state law requiring county commissioner approval is among the implementation tasks outlined in the UWMP. OSMP staff will work closely with the Urban Wildlife Coordinator, city Policy Advisor and interested community groups when appropriate. ~SMP received extensive crud detailed comments from Keep Boulder Wild about prairie dog- related concerns. Those comments and staff's responses are included as Attachment G. Prairie Dogs Lead to ti e~etation and Soil Loss Comment Summary Prairie dogs when confined to relatively small habitat blacks appear to increase in density, stressing vegetation, resulting in less protection of soil from wincl and water erosion. Where not confined, their populations spread to occupy all available habitat. 12 • OSNIP should not allow the conversion of a vegetated grassland to an area of bare soil or an area where soil has been lost and the substrate is subsoil. • V4~ind erosion from prairie dog colonies results in low visibility conditions on nearby roadways adjacent to colonies. There appears to be not only an ecological issue of soil loss, but also a potential safety(liability issue that the city should address. This effect was especially notable during recent high winds in January, 2009. • What natural processes or human actions will stop prairie clogs from spreading to occupy all of the mixed grass prairie mosaic in the planning area? • Recent (winter 2408-9) high winds have lifted soil from areas where the activities of prairie dogs have removed vegetation and exposed soil. Wind erosion and soil loss have been particularly severe. Large dust plumes blowing across the highway have slowed and even stopped traffic. Wind blown soil from the prairie dog towns creates a serious hazard. The conservation strategies in the Grassland Plan indicate a range of prairie dog occupancy with upper and lower limits. This is done in acknowledgement that prairie dogs are a natural component of some prairie communities and that their populations nation-~~~ide have declined severely. Areas unaffected by prairie dogs also contribute to grassland biodiversity. Therefore, some areas are designated to support prairie dog colonies while others support the plants and animals that do not co-exist with prairie dogs or with prairie dog occupancy above certain levels. For example, when prairie dog populations within Grassland Preserves exceed 26% and there is indication that vegetation is being affected, OSMP can assess the need for relocation or removal of prairie dogs to protect the overall biological integrity of these preserves. Prairie Dogs' Negative Effects on Agricultural Sustainability Comment Summary The protection of prairie dogs has significant negative effects on agricultural land management that go unresolved in this plan. • OSMP does not address the threat posed by animals dispersing from prairie dog colonies onto adjacent public and private agricultural lands; • One of the best examples of how the city could promote agriculture would be by controlling prairie dogs on city-owned lands leased for agricultural production. OSMP values the contributions many private landowners and other public land agencies make toward continuing farming and ranching in Boulder County. As an agency with agricultural land management responsibilities, OSMP is air-are of the challenges facing landowners who consider prairie dog occupation incompatible with their land management goals. The management framework included for prairie dogs on OSMP lands recognizes the importance of agricultural resources. Of the 1,129 acres of prairie dog colonies that occur on irrigated agricultural lands on OMSP, 753 are included in transition or removal areas that would allow relocation or removal of prairie dogs for the protection of the irrigated agriculture on the properties. In addition, for the remaining 376 acres, removal is allowed if prairie dog occupation is threatening irrigation of the property. Whenever possible, OSIVIP seeks to coordinate 13 relocation and removal of prairie dogs with adjacent neighbors to reduce the likelihood of recolonization. OSMP feels that prairie dog occupation and livestock grazing can be compatible. Grazing practices are adjusted in areas with prairie dog occupancy to reduce the likelihood of overgrazing by the combination of prairie dogs and livestock. OSMP has experimented with a variety of visual barriers both natural and artificial. Our experience is that they are costly to construct and maintain and not particularly effective. The most effective approach we have found to date is to identify and designate prairie dog conservation areas where there are the fewest surrounding land uses incompatible with colony expansion and dispersal. The best example of this situation is the Southern Grassland Preserve. However, even there, where large blocks of habitat OSMP grasslands are surrounded by some compatible management other neighbors consider prairie dogs incompatible. The prairie dog relocation process administered by the Colorado Division of Wildlife requires consideration of and notification of adjacent landowners prior to the approval of a relocation permit. OSMP is required to obtain a CDOW permit and ~~-ill meet those permit requirements. In addition, OSMP «~ill work with others to develop cost effective strategies to minimize conflict arising from management of prairie dogs on OSI~IP properties. Plague and Liability Potential cQ,~,~e,~r .sr~~,~a~y Open Space and Mountain Parks should be aware of the potential liability posed by managing for prairie dogs because they are carriers of plague, which can be transmitted to humans. The city takes the following actions to address potential liability concerns: • Coordinates plague response with Boulder County Health. • Posts areas when plague is suspected, warning visitors of the potential dangers, and suggesting that they leash their dogs. • Responds to confirmed plague outbreaks in consultation with Boulder County Health. Responses include, but are not limited to, area closures and dusting of burrows with insecticides. V. Next Steps After receiving feedback from the Board on the proposed responses to public comment, staff will make modifications to the Grassland Plan. Staff will present a final draft Cnassland Plan to the Board at a future public hearing. Staff will request the Boards' approval of the Grassland Plan at that time. ATTACHMENTS: A. November 24, 2048 Community Meeting Notes 14 B. Comments on Public Review Draft C. Grassland Plan Comments Not Highlighted for Discussion with Proposed Staff Responses D. ~SMP's Community Services Provided in the Grassland Planning Area E. Wetland and Riparian Buffers and Trail Density F. Seasonal Groundnesting Bird Protection Areas G. Comments from Keep Boulder Wild with OSMP Staff Responses 15 ATTACHMENT A: November 2i~ Community Meeting Comments Open Space and Mountain Parks Grassland Ecosystem Management Plan Public Review Draft Community Meeting Comments - - 1 1 J20/2008 ~ ~li~~~ii i~~l'~~~. Summary and addition general information requests: i~, ~ ~ ~ -r-- ~y~>~,~, Layperson's analysis of plan, re: biological goals effects Suggests brief summary in plan of how this plan works with other management plans Clarify the process for decision making regarding providing visitor services and conservation actions. Prairie Dags -request for public involvement concerning: Need to agree with prairie dogs designations as next step before creating prioritized lists of "transition areas" Prairie dogs -requests far actions on our part: Resident lives near 61St Street and Andrus Rd, near city prairie dogs, concerned about accidents on road, prairie dogs are burrowing under the road causing road damage and dangers as cars try to avoid hitting them. This is dangerous, prairie dogs need to be controlled Are we looking at options to relocate prairie dogs in other counties? 75t" Street resident, lives next to prairie dogs, can no longer use land for agricultural purposes due to impacts of prairie dogs. Therefore, OSMP does not support private Agricultural practices due to prairie dogs presence it allows. The plan has no mention of controlling migrating prairie dogs onto private land. Resident lives on Valmont near Teller Farms in an island of prairie dogs prairie dogs that were relocated into this area. Subsequently there has been a loss of agricultural land to weeds and dust. • OSMP does not share responsibility for prairie dog management appropriately with private landowners. • There are more acceptable, natural ways to manage colonies. OSMP has a responsibility to private landowners. • Need to experiment with different management options. Keep including neighbors in conversations and decisions. Modify agricultural leases to allow prairie dog occupation - or to remove livestock, modify stocking rates. Prairie dogs-- Neighbor's concerns regarding prairie dogs: Prairie dogs will always be a "double-edged" sword -lack of predators is the problem. S:~OSMP~PLAN~GEMAP~Public Process~l 1.20.2008.OpenHouse~Community Meeting Comments.doc 1 November 2~ Community Meeting Comments Valmont prairie dog transition site question: Will people be notified if prairie dogs will be moved near them? Answer -Yes How will OSMP prioritize transition sites? High priority, agricultural fields and adjacent land issues What are the relocation sites criteria? Vegetative quality standard (native species cover, native species richness, etc) must be met There need to be existing burrows Absence of plague for at least 1 year in the potential relocation site Grassland Plan allows for habitat recovery before putting prairie dogs back onto a property after a plague event How will we manage prairie dogs once they are relocated? Prairie dog protection concerns: Current acres of prairie dog colonies? Answer in Jan 2007 1,734 acres Potential acres of prairie dog colonies? Answer: $00-2,100 [incorrect?] Concern: There is a 43% reduction in the areas for prairie dogs in designated HCA's. Transitional areas have increased. The idea that colonies need room for expansion and setting limits of occupation are contradictory. Has the city considered the potential for plague liability? Are there opportunities to move prairie dogs out of Boulder County -including cooperating with other open space programs? Recreational Opportunities Plan doesn't balance all of OSMP's charter goals. Needs more consideration of objectives besides managing grassland ecosystem. It doesn't include things like preservation of recreation options in a balanced way. Concern visitor experience objective isn't represented as strongly as would be preferred Need assessment of visitor access resources include BVCP trail recommendations Grassland areas are underserved by trails compared to measures of trail density in the mountain parks. S:~OSMP~PLAN~GEMAP~Public Process~l 1.20.2008.OpenHouse~Community Meeting Comments.doc 2 November 2~ Community Meeting Comments Concerned about of amount trails proposed for closing in wetlands and riparian areas, thinks these provide important educational opportunities and would like to see an expansion of education opportunities. There's a tone of "we (OSMP) know what's best", Concerned public doesn't have enough input. Needs to be a larger education piece. Creatively address what seem like "either/or" situations. Example: move trail away from riparian area; more birds stay in area, have one-way, out and back (look out trails), that take people to water to see birds at a lookout point. OSMP needs to collect better baseline information prior to making changes such as building trails. The adaptive management response to monitoring information needs to be explicit. Example dramatic changes on Marshall Mesa resulting from new trail construction. No up front monitoring, no adaptive response. Add a "positive human potential" as a counterpoint to negative view of human activity. Improve understanding and experience. Provide more detail - e.g. specifics about which trails would be moved/closed near wetlands and riparian areas. Conflicts between VMP and Grassland Plan -How will you coordinate TSA plans or planning with the Grassland Plan? More information about identification of undesignated trails, what kind, whether it can be determined how to prioritize them including: use, negative or positive qualities, etc. Conservation objectives impact visitor access objectives and vice versa, examples include: Reduce trails in wetlands Seasonal closures for birds New trails around edges of habitat Concerned that there is a lack of balance between visitor access to environments that increase our quality of life (compared to protective measures proposed). We need both. OSMP staff is out of touch with science In moving trails away from water sources birders won't be able to see as many birds. This would encourage birders to go off trail. Absence of recreational and agricultural inventory or analysis -yet plan proposes taking actions on recreation -and agriculture. Ecological comments: Likes emphasis on ecological integrity, even if it means trails might be closed, or access restricted. S:~OSMP~PLAN~GEMAP~Public Process~l 1.20.2008.OpenHouse~Community Meeting Comments.doc 3 November 21~ Community Meeting Comments The plan mentions weeds in the context of areas that are "dominated" by weeds or where weeds are "prevalent". Suggestion was fora 3rd target for hotspots that should be considered which would be parking lots, trailheads, to ID new weed arrivals. ASAP [Mark also recorded this weed comment as] -Add "hot spots" for new species of weeds. Institutionalize in monitoring. Concern that the list of conservation elements is too narrow. -Need more comprehensive consideration. Agriculturally oriented suggestions: There is a need to consider the impacts of need for locally produced food -more agricultural land use -Organic Farms. Absence of agricultural inventory or analysis -yet plan proposes taking actions on agriculture. S:~OSMP~PLAN~GEMAP~Public Process~l 1.20.2008.OpenHouse~Community Meeting Comments.doc ~ ATTACHMENT B Comments on Public Review Draft OSMP Grassland Plan Open Space and Mountain Parks Grassland Ecos stem Management ~~~~7 . Comments on Public Review Draft ~is 4~,+~ lli~, ~ ~ " ? 2f8f2009 1Ui~ , ~ ~ ~,,a i~~~,~: r;~ Open Space and Mountain Parks received 74 comments on the Grassland Plan. Section I The first section (pages 2 to 28} includes the comments received via email or over the web-based comment form. Each comment received, at a minimum the standard response reproduced below, and the person was added to the mailing list for the Grassland Plan. OSMP staff also responded directly to many of the people providing comments. Section II This section (pages 29 to 122} includes letters sent by the following organizations, responses to a survey sent to agricultural lessees and comment letters from several individuals. • Anadarko Land Corp (Oil and Gas} Prairie Ecosystems • Boulder Area Trail Coalition (BATCO} Agricultural Lessee survey response (4} • Boulder County Horse Association (BCHA} Letters from Individuals • Boulder County Audubon Society (BCAS} Chris Morrison • Boulder County Parks and Open Space Jennifer Kwasniewski • Boulder Mountainbike Alliance {BMA} Karen Hallweg • Boulder Outdoor Coalition {BOC} Michael Katz • Friends Interested in Dogs on Open Tim Seastedt {CU Ecology professor} Space (FIDOS} (letter created from email) Sharon Collinge (CU Ecology Professor} • Friends of Boulder Open Space {FOBOS} • Keep Boulder Wild (Prairie Dag Coalition and Sierra Club} Extended Response Thank you for your feedback about the Grassland Plan. Open Space and Mountain Parks (OSMP} will be taking comments on the public review draft through December 5. OSMP staff will consider all comments to inform the revision of the plan. Members of the Grassland Plan team will be reviewing your input and providing an individual response when requested, or in instances when we believe a response would answer a specific question, clear up a misunderstanding, or be helpful in some other way. Otherwise, the comments will be used to identify needed corrections, improvements and potential changes to the draft Grassland Plan. If you have a specific question that has gone unanswered (please give us five days from the date you submitted your comment}, or would like to speak to someone directly about the Grassland Plan, please contact Mark Gershman at gershmanm@bouldercolorado.gov. Thanks again for taking the time to provide OSMP with your ideas about how to improve the draft Grassland Plan. Mark Gershman, Project Manager Open Space and Mountain Parks 1 Greg Hayes 11/412008 Boulder CO I would like to propose we at least consider bringing back the plains sharptail grouse and pronghorn to the southern portion of the Boulder openspace as with the Rocky Flats addition there would be enough land to justify the effort. I would also like to propose this now before all of the southern areas are taken by prairie dogs which fill a niche but should not be a singular grazing species consuming all of the available habitat. Larry Quilling 11 /10!200$ From: the5quills@comcast.net [mailto:the5quills@comcast.net] Sent: Monday, November 10, 2008 8:22 PM To: OsmpCarrespondence Subject: Questions ar comments about the Grassland Plan email_from: the5quills@comcast.net comment: Please explain why this comprehensive plan makes no provisions for hunting. There certainly is plenty of information placating the special interests for prarrie dogs so why not at least make an attempt to explain why the impact study does not address the benefits hunting could bring to the prarrie grasslands for pedatar and migratory bird control? How about controlling the deer population? Frankly I am not surprised the plan makes no provision to protect my rights to hunt. Maybe if I ran around nude with a pumpkin on my head or streaked through a football game my fringe hunting opinion could be recognized for the real science solutions it could bring to your grassland management plan. Carl Bock 11/1612008 Loveland CO Hi Mark, Jane and I are now living full-time in Loveland, having sold our home in Arizona last year. Unfortunately, we are under a large and looming writing deadline at the moment that is likely to take us well into December. We just cannot take on another task as the moment, so we'll have to pass on reviewing your grassland plan. From the exec summary, it looks thoughtful and thorough. Best, Carl Carl E. Bock, Professor Emeritus Ecology and Evolutionary Biology University of Colorado Boulder, CO 80309-0334 a-mail: carl.bock@colorado.edu office phone: 303-492-7184 Home address: 5224 Lighthouse Point Court Loveland, Colorado 80537 Phone: 970-593-0343 e-mail: as above Holly Cerretani 11/16/2008 Boulder CO Our lot borders the grasslands open space in north Boulder just south of Lee Hill Rd. I use the trail systems around Boulder almost daily mostly for hiking ar walking my dog. I have lived in Boulder County for 40 years mostly in Boulder itself. My main concern is for the preservation of the wildlife and indigenous plant life. The prairie dog population has plummeted in my lifetime in the Boulder area. The open space just north of the intersection of Broadway and 28th St (by the plant that makes septic tanks on the east side of highway 36) used to have a thriving population of prairie dogs and over the past 4 years it has been literally wiped out. There are a very few of the animals in the south end now but I have been wondering what happened. In that same open space there is a small wetlands area Mesa Reservoir I believe and I was appalled to see cattle allowed in there last May polluting the water and trampeling the bird's nests. There are signs that prohibit dogs and horses because of the fragile ecology and yet cattle were allowed to destroy it at probably the worst time of year. Who makes these awful decisions? I believe we need to do whatever we can to protect and promote a healthy diversity in the local animal population including the predators (all of them) and be sure to make the humans clean up after their pets keep their animals under control and educate them about the possibility of interaction with wildlife if they choose to live here. People should be taught that if they feed the deer and they attract a mountain lion who eats their dog it's their fault not the mountain lion's. I love Boulder I appreciate the open space and my ability to use it. I don't think we need more human access. I think we need to protect what we have from damage and overuse.Thanks Holly Cerretani 4753 6th St, Boulder 2 Larry Quilling 11/17/2608 Hello Mark, I responded to your request for information last week and I just wanted to confirm that you had received my response. I will plan on attending the meeting and wanted to make sure not to surprise you with my inquiries regarding hunting as a viable component of the Grassland Ecosystem Management Plan. I understand this will not be a popular discussion and I want to assure you I am not a zealot who will demand unreasonable actions. I am chiefly concerned with open dialogue concerning the impact of migratory birds, and over population some game species that could be controlled with hunting as part of the plan. At the very least, the pros and cons should be studied and discussed before new policies are enacted. I have forwarded this e-mail to the members of the CU Ducks Unlimited Chapter for their participation as well. Best Regards, Larry V. Quilling 720-684-3277 11/17t2008 Boulder CO I live in the North Rim subdivision immediately adjacent to open space. 2 years ago you had a big bubonic plague problem in this open space area. I for one do not think we should put the children adults and pets at substantial risk of contracting the plague again. Also it took its toll on property values and with values declining today I don't want to see them totally evaporate due to the plague. Prairie dogs are fine but they need to reside in areas which present minimal risk to humans. Last time the City told us what precautions to take when going into the open space. You neglected to look at the reverse; the effect of coyotes prairie dogs foxes mice squirrels etc. that reside in the open space leaving your open space and coming onto our property with the plague. You have to look at all aspects; not a very narrow interest. 11 /17/2008 My property borders on open space. We have had problems with the black-tailed prairie dogs coming onto our property. Additionally they carried bubonic plague and had to be eradicated 2 years ago. Introducing them would create the same situation. Therefore I am opposed to introducing the prairie dogs. Shari Leyshon 11 /18/2008 Hi Mark, Thank you so much for the notice. I"ve just agreed to another meeting at that time... however I would love to attend..so I will try. Thank you for your great, great work an this. I attended an Open House last winter at the Offices. I was so impressed with your Open House.!!!!.. We met then....a long time ago now! I am a native of Illinois and was a co-steward of a tall grass restoration site and worked with TNC's volunteer stewardship network for ten years. I remember you worked with TNC I am working on an agricultural project here in Boulder. I'm very interested in the integration of perennial agriculture {particularly na-till grains i.e. The Land Institute in Kansas), biodiversity, riparian corridors and open space. Hope to say hello on Thursday) all the best for a great meeting, your plan seems so very great. With Kind Regards, Shari Shari Leyshon Founding Director The Boulder Fruit Tree Project www.boulderfruittreeproject.com 720.425.4454 Robert Kiser 11/19/2008 Boulder CO I live in Heatherwood 75th & Jay. the area open space has prairie dogs their population is increasing faster than their natural predators can consume. The rodents are beginning to exit the open space area and cross Heatherwood drive. There is a city park and BVSD elementary school they are exploring for colonization. Question; is this a concern for you? if not you is there another department that should be informed ? Should anyone be in charge of containment ? are the dogs protected when on county roads public school grounds city parks or in my yard? Concern... twisted ankles an school ground and park areas. Comment many area residents including myself would prefer not to have prairie dogs in our yards. Thank you for your time in response regards Robert kiser 7681 Canterbury ct 3 Larry Quilling 11/19/2608 Hello Mark, Thanks for chasing down my e-mail. I did not realize I had not signed the message or identified myself. I agree with many of the comments you make below. I too am a conservationist but I do not limit my vision of our ecosystem to non-lethal solutions. Your statement: "Lethal control in general and hunting in particular have not been the community's preferred option as the first choice for wildlife management in the city of Boulder or for city-owned open space lands." does not account for important benefits that can be achieved using hunting as a wildlife management tool. The health of our big game and migratory bird populations would benefit from regulated hunting practices. Dismissing hunting from your report without any consideration is not good stewardship. It is however the best way to skirt public attention. I have no allusions that hunting will be added as a recreational or OSMP management solution but I do request that studies such as the OSMP Grassland Plan include the viable alternatives such as hunting as part of their analysis. Otherwise, our city's policy making decisions are vetted and biased towards established norms without consideration for other viable points of view. Thank you for listening, Larry V. Quilling 720-684-3277 Jason Vogel 11 /201200$ This document makes sweeping recommendations to restrict recreation in the grasslands areas without surveying analyzing or evaluating the recreational opportunities and attributes of our grasslands. This is ideology clothed as bad science. If you want to make the case that trails pose *very high threats* to the ecosystem then you need some empirical and dispassionate analysis to support your case. That analysis needs to look at both the positive and negative effects of trails as well as the relative effect of trails given all of the stressors to our grasslands. Furthermore the recommendations about trails would impact our recreational opportunities to a very high degree. If it truly is important to *reduce road and trail density within 200 M buffers of wetland and riparian areas by 50°lo by 2018* then there should be some analysis of where new trails can be built to serve the well documented demand for recreation among the general Boulder populace. Without such an analysis these recommendations look like an ideologically-based attempt to restrict recreational opportunities. While I do respect our natural ecosystems and hope to see them function in a healthy manner in perpetuity I do not believe that just getting humans out of the picture is a reasonable proposition (politically or practically) nor should it have been recommended in this report. Those decisions are being made through a public input process defined by the Visitor Master Plan. This report reads as if it is trying to do an end run around that process. OSMP needs to be more careful in its use of analysis of natural resources. While the impact of recreation on ecosystems is a valid and important area of study. If it appears to be done with a predetermined result of restricting recreational access then you have failed to fairly serve the public that funds your department and you will be perceived as unfairly biased against recreation. Jason Vogel Ph.D. 3300 Bridger Trail #111 Boulder CO 80301 303-525- 0832 4 Julie McCabe 11/20/2608 Boulder CO I am very disappointed in the plan. Its science is biased against user/recreation values. It will create more closed space rather than open space. I do not know when or understand why the current powers in OS decided that conservation and recreational values are not compatible uses but this is exactly what this document says. It is more of the Bruce Bland extreme eco-only logic that views a perfect natural world as being possible only if humans aren't there. I am well travelled and I have seen parks departments federal state and local strive to include humans in natural environment without harming it. I've walked along elevated walkways in the Everglades. I've visited viewing blinds in the Tongass that allow people to watch bear and eagle salmon fishing. It is only with the City of Boulder's OS department that tax dollars are desired but stringent steps are taken to limit ALL visitor access except to highly used trails contiguous to the city limits. My prediction is if this process is allowed to continue these OS policies today will break the psychological bond between citizens and OS. People will not be able to appreciate all this wonderful ecosystem it will be out of sight and out of mind. If the future world is one where health care jobs cost of living etc. are all making great demands upon the tax payer and OS needs millions to manage land that no one can access to appreciate it will not be surprising to see the OS system fail. It will be seen as an expensive folly of a boomer rich time when people with too much money adopted extreme policies that do not serve public interest. {Public interest includes support of ecosystems.) People can make and should be allowed reasonable {will not cause meaningful harm) access to public lands. Excluding people in the name of pristine conservation is extreme politics not good science {no matter how you dress it up). If this kind of thinking is adopted in the Grassland Management Plan you will be putting more nails in the coffin called Closed Space. Mike Obrien 11 /2512008 The study simply emphesises the OSMP missconception that its mandate is to protect the natural enviroment from certain distruction at the hands of an ever expanding human popultion. Beyond that it is of little value since it ignores the very visable damage done by grazing and ignores the lack of actual human impacts. If implemented it will violate the Open Space Charter and will reopen the whole visitor master plan. The open space department ovbiously has too much money. Anonymous Lessess 11 /25/2008 One of four (4) written responses received in response to a survey. Randy Kryszak 11/25/2008 Longmont CO I live on Mount Sherman Road and my backyard is next to the cottontail trail that was damaged because the trail was put in a drainage ditch. Are there any plans to repair the trail or perhaps move the trail out of the ditch? Perhaps have a trail next to the ditch instead of a ditch/trail. 5 Jeffrey Brown 11 /26/2608 Prairie dogs are denuding and ruining a valuable non-renewal resource the topsoil. Where is this addressed in the plan? Your well meaning but misguided policy towards prairie dogs is ruining our open space properties and when topsail is lost it is gone forever. The short sided feel good nations that the prairie dog management strategies are based must be reevaluated. Apex. #7 sites lots of science but very little common sense. Anybody can see that by allowing prairie dogs to denude the land leads to sail exposure drying fracturing of soil structure and loss of soil due to wind and rain. To refer to some of these small plots as ecosystems is an insult to the concept of the word. These small plots are effectively cages. By allowing an unchecked population of prairie dogs on a plot that is limited in range by roads ditches rivers and structures limits the poor prairie dog the opportunity to move and relocate as the pressure of increasing numbers requires. It is like putting a population into a caged zoo habitat then leaving them to fend for themselves. Not feeding a caged animal is a cruel illegal and unacceptable practice. Every small plot of open space is a priceless resource to be preserved for the future. It is in my mind criminal to see so much land destroyed in the name of prairie dog protection. Please tell to me haw I am to explain to my grandchildren why so much of our open space land has been converted from potentially beautiful grasslands capable of sustaining a great biodiversity to gravelly subsoil wasteland with only noxious weeds as sparse vegetative cover. Culling prairie dog numbers is the best solution. An unpopular option to well- meaning but misguided protectionists but culling is essential to the wellbeing of our grasslands and to their animal inhabitants. Sincerely Jeffrey W. Brown Jessica Post 11/29!2008 Eldorada Sprin CO I am deeply upset about the new proposal to close off more open space to the public. I have lived in Eldorada Springs my entire life and can remember several walks and adventures behind my parent's property in the open space. There used to be plenty of wild flowers trees plants and animals. Recently when I walked back in this same area it was overrun with prairie dogs and cow dung. I think that it is preposterous to assert that humans are doing damage to these areas and the wild nesting birds that inhabit these lands when farmer's cows are allowed to run free. It used to be enjoyable to ride horses on these trails but now it is merely impossible because of all the holes from prairie dogs. It is passible for humans to use this land responsibly with little or no damage to the environment and wildlife in open space parks. I have always been so proud to take my friends and in-laws to the numerous parks trails and open space in Boulder. Many of these spaces including the one from my childhood have already been closed and cut off to the people who have enjoyed them for decades. I refuse to allow anymore open space to be closed off. I believe that the data used to prove the need for these closers is faulty the Open Space and Mountain Parks are over stepping their responsibilities and the time and energy put into shutting these spaces down could be better spent on public education and awareness. It is deeply upsetting to me that farmers have not had to suffer from the loss of public land especially since their cows are a major part of the problem. Madison Post 11/29/2008 Eldorado Sprin CO I am totally against the tone and recomendations in the grassland plans. There is no need to shutdown vast portions of our open space lands. OSMP apparently perceives that visits by the public can only be detrimental when just the opposite is true in >90% of the cases. The bird studies you cite are self-serving and even then misinterpretted. Do you really believe that birds will not build nests if the habitat is provided? Do you truly believe a hiker on a trail will exterminate fledglings if he walks within 50 m 100m or 200m of a nest? Is it unreasonable that birds do not build nest near trails (humans avoid highways too!). I have spend many quiet moments on open space sitting with dogs. Meadowlarks and sparrows come visit and investigate -they are curious not terrified! And how can a scientific survey study in good conscience make recommendations against public visits when recreationalists have had no opportunity to provide input to the plan?? You are way off base with this one. Many of my friends and many other people now believe OSMP is far too left wing. 6 Cindy Johnson 11/30/2668 Eldorado Sprin CO Thank you for taking the time to hear our family's response to your plan. First of all we are stunned by the GEMP's display of anti-recreation and anti-trail bias. It does not appear to be consistent With the City Charter or The Visitor Master Plan. Why are you trying to discourage all access? We were not informed of this plan when we paid our hard earned dollars through sales taxes to you. We understood that it would preserve the land and give us the privilege to use the trails. We feel strongly that we can and are compatible users of our Open Space and we have demonstrated it for 25 years. The sales taxes support the bonds that make Open Space acquisition possible. Why are you biting the hand that feeds you by tipping the balance too far towards preservation? If the usage on the trails is too high why don't you implement a plan to charge the people from Denver Golden and Broomfield a fee to use Boulder trails? You have lots of staff personel and vehicles to support this idea. If you would allow the cows to graze on Open Space consistently wouldn't that help your endangered ecosystem? Cows eat noxious weeds. That sounds like good management to us. Your poor management practices have allowed the prairie dogs to destroy the pristine mountain meadows surrounding Boulder. We have used those trails for the past 25 years and have personally witnessed the damage from prairie dogs that hadn't been there for 20 years prior specifically the area south of Eldorado Springs Drive and west of Highway 93. Our children use the trails to exercise and stay out of trouble. It's a wonderful alternative then going to the mall to cause trouble. Our neighborhood came together {aver 20 people) to voice our concerns last summer on the closing of trails due to nesting ground birds on Eldorado Springs Drive and we were not heard. Please listen to us this time. Our youth are counting on you. We feel the plan is incomplete and would like you to consider the recreation resources and the visitor experience far the grassland areas. Sincerely Cindy Johnson Kristen Campbell 11/30/2008 Boulder CO i support the views expressed by the boulder trail runners- please do not reduce the trails on the grasslands of east boulder county. please include increased recreation and visitation in your management plans. being able to run trails in my open space is why i support these lands- reducing the public's ability to enjoy open space would defeat the purpose of having this land. please keep me updated an this issue as it unfolds. thank you Sandra McCoy 11/30/2008 Boulder CO I moved from eastern Kansas in 2006 and was active there in prairie grass preservation. I am happy to know that OSMP has a well developed program regarding the preservation and appropriate use of surrounding grasslands. I love the colorful quiet beauty of the prairie; I also know that a dense prairie is full of complexity and life--both plant and animal. Keep up the good work. George Zack 11/30/2008 Broomfiled CO What exactly is meant by in terms of what is being proposed when the plan says: Reduce trails within 200 m of wetlands and riparian zones by 50% in 10 years? Is that closure? Reroute? 7 Ellen DeMoney 12!1/2008 Boulder CO I am deeply disturbed with your plans to reduce trails by 50%. This is not your job. Your job is to try your best to obtain ALL of your objectives as listed in the Grasslands Ecosystem Management Plan. Limiting trails removing trails limiting visitors ability to explore the open space area without any scientific evidence that people andlar dogs or horses will destroy the area is acting a bit like dictators. You do not have that right to do this. This is not what we pay those open space tax dollars. You have not even taken into account what global warming will do with your restoration. Do you know that plants are migrating 400 miles or more from the South to Colorado? Where is your research? Where is your data? This anti-trail plan has gone too far and I believe you will see the people revolt against you. Trail users are just as concerned with the environment as you and it is insulting to be treated as some sort of scourge to the area. You need to revise this with how and why you are going to limit the trails what your source is for SCIENTIFIC reasons you also need to put people into the equation. My parents had nesting Bald Eagles 50 feet from their house...so much far people causing them hardships with reproduction. As a scientist an environmentalist and avid trail user far over 25 years I am deeply disturbed with how this plan is worded the lack of data supporting or NOT supporting your stances and the total lack of understanding that the people of Boulder and the surrounding area are good stewards of the land and need access to it to be even better stewards. Anonymous Lessess 12!1!2008 One of four (4}written responses received in response to a survey. Brad Schildt 12/1!2008 Boulder CO I believe the GEMP is remarkably unbalanced. I am an environmentalist and am strongly supportive of protecting our environment but removing 50% of trails that are nearby any riparian habitat is absurdly draconian and no scientific justification was given. I suggest a balanced course of action that which is informed by logic and scientific analysis. I fully agree with the comments and suggestions provided by the Boulder Outdoor Coalition and the Boulder Trail Runners. Sincerely Brad Schildt 8 Mike Barrow 12/1/2008 Longmont CO This is not the official BMA input; this is my personal input. I was dismayed while reading through the document. There was so much negativity focued on the impacts of recreation that I thought we had taken a time warp back ten years. It is no longer acceptable to pit recreation against preservation. This community will not tolerate this paradigm anymore. OSMP and the plans and projects it implements on these lands are created by humans. Any 'natural processes' that may be occurring on these lands are doing so because humans want it that way. Any plan to restore natural processes are implicitly unnatural because we humans are making it that way. Any metrics of measuring the quality of the natural resources are meant for the human ego to pat ourselves on the back and make us feel more green than the next guy or community. We humans are creating a grasslands plan that will mimic natural process for our own edification. Is this bad? Heck not I like plenty of what is proposed in this plan. But this plan declares war on the fact that there is a massive human/urban interface among these lands. This plan created by humans is schizophrenic to think they can exclude human impacts... it's humans that are restoring these lands) That's an impact! We can never restore natural processes only mimic them. So when I see these targets of reducing the access to the very humans who want to support OSMP in their efforts to manage these lands it raises my blood pressure. This plan tries to polarize the community. It will not be successful if this tone and approach continues. The people who pay for your salaries want high quality wildlife values AND high quality recreation. If you can't do both then you need to retire or quit and we'll hire someone who will. This plan needs to enrich our lives by creating high quality resources on our public lands. But we need to see and experience those resources we need to be part of it. When I read about how the plan wants to exclude humans from riparian areas I shake my head and ask what were you thinking? Move us 200 to 300 meters away? I hope you enjoyed the Kool-Aid because it didn't work forme. This plan needs to embrace and acknowldege the needs of recreation. Until the plague comes and wipes us all out these are the cards you have been dealt. You can't discard the recreation just because you don't like it or can't get as'natural' as you think it should be. There has to be a balance. This plan is a LONG way from that. 9 Peter Bakwin 12/212008 Boulder CO To: Open Space and Mountain Parks Re: Grasslands Ecosystem Management Plan Thank you for the opportunity to provide our feedback on OSMP's Grasslands Ecosystem Management Plan (GEMP). We appreciate the enormous amount of work that Staff has put into this plan over the last two years. The document provides a remarkably detailed catalog of the ecological resources within the City 's grasslands areas. However, we are very concerned that the plan is incomplete: it addresses ~SMP's habitat and wildlife conservation resources and objectives but does not consider the recreation resources and objectives, or quality of the visitor experience for the grasslands area. As a result, the plan is unbalanced and anti- access. The GEMP far oversteps its mandate in making draconian recommendations regarding recreational access, which should be removed from the plan. Under the Visitor Master Plan, trails and recreation are the purview of the TSA process. We want to be very clear that the GEM P should not be seen as superseding the TSA process, which is the process that City Council passed with community support. The GEM P should represent input to the TSA process, with respect to ecological resources and goals in the grasslands areas. The plan makes three major controversial recommendations with regard to trails and recreation in the grasslands, which we address in detail below. 1. Reduce trails within 200 m of wetlands and riparian zones by 50°to in 10 years. This recommendation has the appearance of being anti-trail. There are two possibilities for "reducing" trails near wetlands: close them or relocate them. The plan should be specific about what is being recommended for particular existing trails. We are especially concerned about same of the gems of the C)SMP system, such as the South Boulder Creek Trail, Dry Creek Trail, East Boulder Trail, Coat Lake trails, Boulder Reservoir, Left Hand Trail, Sawhill Ponds trails, and others. Also, haw does this recommendation impact major future trail connections, such as the Teller Farm to Dry Creek and Dry Creek to South Boulder Creek connections that are included in the Boulder Valley Comprehensive Plan, the Union Pacific RR Boulder-Erie Rail Trail, and the Marshall Reservoir Trail that was approved in the Southern Grasslands TSA? Regardless of whether trails are closed or relocated, this recommendation will reduce visitor access to prairie wetlands by 50% or more at a time when area population and visitor numbers are increasing. This is a stunning effort to take away access to these lush areas that provide a unique visitor experience, without even looking far ways of allowing people and wildlife to coexist. 2. Increase the area of seasonal closures by a factor of six to protect ground-nesting birds. This recommendation is clearly anti-access, and is premature until the full impact on the visitor experience is known. Also, OSMP needs to consider that, while seasonal closures have been generally supported by the public, excessive application of this management tool may reduce public support for and compliance with the regulations. Since GEMP looks only at the conservation goals and resources, these issues are not addressed. 3. Locate new trails in large habitat blocks around the edges of these blocks. This recommendation will certainly result in a lower quality of visitor experience, as the edges of parcels tend to be next to roads or subdivisions. People visit open space to get away from cars, development and noise, and an unsafe or poor quality of visitor experience reflects badly on the City's Open Space program. It is impossible to make a balanced assessment of this issue until the current and potential recreational resources have been thoroughly inventoried. The City Charter lists eight unprioritized purposes for the open Space program, including bath conservation and passive recreation. Clearly, the conservation and recreation goals are highly interconnected, and neither can or should be considered separately. Considering only conservation goals, as was done in the current draft of GEMP, can only lead to the conclusion that trails and recreation have a negative impact on reaching those goals. However, without some level of visitor access there will be no support for the program, so clearly both access and conservation are needed. So, for example, the costlbenefits analysis on p. 96 of the plan does not consider the cast of reduced visitor enjoyment of the land, such as reduced support for the program, reduced understanding of and appreciation for wildlife 10 habitat, reduced mental, physical and spiritual well-being of the citizens who paid to preserve this land, etc. Furthermore, we do not agree that visitor access is necessarily a threat to habitat conservation (e.g., p. 72-73, Table 22). There is a big difference between responsible, sustainable use and rampant use. OSMP needs to consider ways to foster the former while discouraging the latter, rather than simply trying to discourage all access. OSMP's grasslands areas, especially east of Broadway, are currently greatly underserved with visitor amenities, relative to the Mountain Parks. For example, at the end of 2007 there were 4.~ miles of designated trail per square mile of land in the Mountain Parks (West TSA}, while outside of that area there were just 1.2 miles per square mile (similar to the Indian Peaks Wilderness). This means that residents of the eastern part of Boulder, and in the towns to the east that are abutted by OSMP land, have relatively few nearby opportunities for passive recreation on OSMP land. This imbalance should be rectified with the construction of new sustainable trails in the eastern portion of OSMP -specifically, in the vast grassland area under discussion in the GEMP. The GEMP is bath a protection plan and a restoration plan, and these are very different activities. The restoration component is essentially experimental. There is no possibility that the OSMP's grasslands will be restored to their pre-settlement condition, as many species have been permanently extirpated, and conditions have radically changed. In future, climate change will play an increasing role in shaping all ecosystems. Hence, the restoration component of the GEMP is an attempt to engineer the grasslands ecosystems in a way that has unknown consequences. It is obvious that, in order to be successful and sustainable, this experiment in habitat restoration within an urban area needs to include human visitation. In conclusion, this draft of GEMP displays a clear anti-recreation, anti-trail bias which is not consistent with the City Charter or the Visitor Master Plan. As a management plan, this document would be a disaster for the community, leading to even more conflict and acrimony, and a major reduction in support for Open Space. OSMP can fix this problem either by including a detailed inventory of current and potential recreation resources and goals in the GEMP, or by being very clear about the relationship between GEMP and the TSA process. We believe the GEMP should simply inform the TSA process about ecological resources and status within the grasslands area, while all recommendations and decision making should be done within the broader framework of the TSA process, as is consistent with the Visitor Master Plan. Sincerely, Boulder Outdoor Coalition: Boulder Area Trails Coalition (BATCO} Boulder Mountain Bike Alliance (BMA) Flatirons Climbing Council (FCC) Friends Interested in Dogs and Open Space (FIDOS) Boulder Trail Runners (BTR) Boulder County Horse Association (BCHA) Chris Morrison 12/2/208 Boulder CO Comments on the Grasslands Ecosystem Management Plan 11 John Taylor 12/2/2008 Boulder CO To: Boulder Mountain Parks and Open Space Managers & Trustees As a long time resident of Boulder (since 1965} I have continually enjoyed the large areas of undeveloped land surrounding the city. It was most encouraging when Boulder voters decided to aquire and preserve much of this undeveloped land as open space. Ever since then the existence and accessability of the Boulder mountain parks and open spaces is the single factor that in my opinion makes Boulder a unique place to live. In the past 4 or 5 years however I encounter more and more restrictions on access to OUR land. Some of these restrictions I can agree with: we need prarie dog colonies to supply food for the various predator species (foxes coyotes raptors etc.}; the raptors need protected areas for nesting; same (but NOT ALL} stream drainages need protection for the amazing variety of plants and animals that depend on them. The current round of additional closures and restrictions of access to Boulder open spaces goes way too far. This is OUR land not YOUR land. We are the owners you are the caretakers. By closing off large sections of land for very questionable reasons you are bit by bit removing the major factor that makes Boulder such a great place to live. I propose that there be no additional closures and access restrictions. In fact a number of the existing restrictions should be removed. One particular example is the springtime ground-nesting bird closures which are completely unnecessary. If there are individuals who violate long-existing laws then punish the individuals. Your position seems to be that people are guilty until proven innocent or even worse in this case guilty and cannot be proven innocent. Unfortunately you are taking the traditional misguided governmental approach of punishing everybody because of the misdeeds or bad behavior of a few individuals. John Taylor 4277 Eldorado Springs Dr. Boulder CO 80303-9610 Bobbi Snider 12/212008 Denver CO I was wondering if there is a legal description (Section Township Range} of all the acreage involved in the Grassland Ecosystem Management Plan? Thank you! Chole Rackley 12/212008 Boulder CO I believe that the prairie dog population in the Teller LakeslFarm area has been allowed to expand without consideration to the goals specified in your draft. The burrow holes present a significant health risk to horses (broken legs}. The prairie dogs themselves carry fleas which may or may not pass on the bubonic plague to passerby domestic dogs and humans. The value of the land comprising the Teller lake/open space system is exceptionally high from a recreational and ecosystem perspective. If you were to look at aerial maps of the property from a mere decade ago and monitor it yearly you would be horrified to see the destruction wreaked upon this jewel of a parcel by the prairie dog. Wild grasses ornamental wild flowers grasses to hold the soil in place etc. are now gone due to the prairie dog infestation. Please enlist the assistance of adjoining private land owners to manage the population of prairie dogs by offering county tax credits as an incentive to help you with this obviously overwhelming problem. There are so many residents willing and able to help with this issue. Sincerely Chole Rackley Mike Edwards 12/3/2008 Dear Staff and Trustees, In 1966, I came to the University of Colorado in Boulder as a student. My first morning in Boulder, I bushwhacked 2000 feet to the top of Green Mountain with my boy scout canteen. At that time I didn't even know there was a trail system. For many years afterwards I was fortunate enough to awn a house that was right on the approach to the Big Bluestem trail. I took advantage of this location, and over the years I have hiked, literally, tens of thousands of miles on the Boulder Mountain Open Space trail system. I have voted for every single Open Space tax hike (big words from one of Boulder's handful of Republicans}. The increasing trend of more and more Open Space closures, supposedly protecting the land from the very people who paid for it, cannot continue. Responsible stewardship is admirable, and I practice it every time I am out there hiking, but I can't support purchasing the land just to look at it. My intention when I voted for Open Space taxes was to protect and preserve the land for both people and animals. Sincerely, Mike Edwards 12 Steve Jones 12t3t2008 Boulder CO Draft Grassland Management Plan Comments from Boulder County Audubon Society Cindy Johnson 12/3t2008 Eldorado Sprin CO I understand that you are taking comments on the public review draft through December 5. How do I truly know my voice was heard? Is there going to be a meeting or hearing that we can attend to re voice our opinions? Cindy Lindsey Sterling Krank 12/3/2008 Boulder CO Comments from Keep Boulder Wild are attached Hi Mark, Mike and Heather, Thank you for your time yesterday. Here are the comments we submitted yesterday with asterisks and bold identifying the comments we'd like to hear answers by Thursday evening. That will give us Friday to make suggestions on then. We are of course open to you getting us answers later and extending the comment deadline for us too then, but that is up to you. We thought the meeting went pretty well yesterday. I also did want to say that in the South Dakota region CAP, we did not list prairie dogs as a threat at all. Although the area deals with the same grazing pressures and weather patterns as we do here in Boulder, prairie dogs were not managed as a threat, but rather as a strategic action to improve other conservation targets. le: the more prairie dogs we have, the more associated species, such as badgers, horned larks, and burrowing owls we will have. Granted, there are ferrets in the area and it is a larger scale, but there is also MUCH more cattle and ungulate grazing in the system than here. So, I wanted to mention that fundamental difference I see in the plan. Also, the overall feeling the draft GMP currently has is, "What do we do to the prairie dogs once they have exceeded 26% instead of how can we enhance their habitat for the pdogs and their associated species? Thanks so much for your time! Lindsey & Deirdre Lindsey Sterling Krank Director, The Prairie Dog Coalition 2525 Arapahoe #E4-527 Boulder, CO 80302 (720) 938- 0788 lindsey@prairiedogcoalition.org www.prairiedogcoalition.org Jaye Fuller 12/3/2008 Boulder CO I am in agreement and support the enclosed letter regarding the open space trails within Boulder County. Thank you far considering the concerns of the natural habitat as well as the human use of these areas. Jaye Fuller 4990 Valkyrie Dr. Boulder, CO 80301 (Boulder Reservoir area) Comments from Boulder Outdoor Coalition 13 Ryder Johnson 12t3t2008 Eldorado Sprin CO Dear Open Space Board Of Trustees and OSMP Staff, I am a 13 year old bay who was born and raised in the Eldorado Springs Valley. My family has horses and dogs and we love our life here. We have always felt that we were friends of Open Space. When I ride and hike on the trails I stop to visit with the rangers and they are always nice to me. My Border Collie has passed the voice and sight control test and is always well behaved wherever we go. I have many interests. At the age of nine years old I started my own business raising egg laying chickens and selling the eggs to my neighbors. (Coo coo ca choo I am the egg man) I also love to bull ride every Saturday night up in Greeley. My parents think I am crazy. I think it's a better alternative to the drugs and bullying that occur in my everyday life at school. I am speaking as a youth for our future in Boulder. If you shut down the Open Space trails I will not be able to exercise my self and ride our horses with friends. I can't drive a car or a traitor to a trailhead to get access. Right now I can walk out my back door with three or four of my neighborhood buddies and hike the trails, ride horses and get fresh air. If you close our trails I will have no choice but sit home and play stupid video games just so I won't get bored. Please hear my plea. Do not shut down our access to Open space. Thank you, Ryder Johnson Dave Beckwith 12i3t2008 Lafayette CO Gentlemen, I wish to express opposition to the major access restrictions proposed in the GEMP. I have been a supporter of the Boulder area open space acquisitions for many years, but if I will be restricted from access to these areas I am not inclined to vote for further taxpayer support for acquisitions. These are not wilderness areas. They cannot be treated as wilderness. They provide an interface between the human and animal populations. Considering only the needs of the animals and none of the needs of the people is an extreme view that will lead to less support for your policies. Respectfully, Dave Beckwith Dave Beckwith Lafayette, Colorado 720-890- 0775 Jennifer Kronenberg 12/3t2008 Boulder CO The Grassland Plan concerns us on several levels. Please do not lock out people) Please do not put trails along streets subdivisions and homes) And please limit the seasonal closings. Let's find a better balance between nature and people. We gladly pay taxes to support Open Space but want to maintain our rights to enjoy it up close and personal. Thank you. Madison Post 12/3/2008 Eldorado Sprin CO I have written numerous comments to OSMP and the open space trustees recently on the Grasslands Ecosystem management Plan (GEMP) objecting to further (draconian) closures of open space lands to the public. I also have commented on the vetting process for such closure of which council should be aware: In my limited experience with the development of VMP and TSA plans it appears to go this way:mOSMP spends a lot of time putting together a a visiona of management policies. This vision reflects primarily OSMPa s view of the way things should be done. These draft plans are then presented to the public and over the course of several meetings OSMP politely listens to all comments an the issues. However in the end only changes that fall within OSMPa sconservation-oriented philosophy are adapted. The final version is then sent to City Council far approval and council basically rubber-stamps it. After all it has been properly vetted right? This is certainly the way things happened with respect to bird closures near the Eldorado corridor for the few of us that knew the process was underway and who tried to provide input. Our e-mails on the topic were never even acknowledged by OSMP. After the closures were in place OSMP would not budge on altering the closures in a sensible way because by god Big Brother knows best. Reasonable alternatives and scientific controversies again were dismissed summarily with the same mantra of needing to preserve precious resources from the coming hoards of uncaring public. 14 Larissa Read 12/3/208 Boulder CO MEMORANDUM To: Mark Gershman, Environmental Planner From: Larissa Read, Natural Resource Planner Date: December 3, 208 Re: Comments on OSMP Grassland Ecosystem Management Plan Thank you for the opportunity to comment on the City of Boulder Open Space and Mountain Parks Grassland Ecosystem Management Plan (Grassland Plan). Several Boulder County Parks and Open Space staff reviewed the document and attended your November 2a, 20g8 open house. These staff members included planners, a wildlife specialist, a plant ecologist, and a weed specialist. In addition, participated in some of the early interagency scoping meetings for this Grassland Plan. We greatly appreciate these invitations to become involved as a collaborative land manager in the Boulder County region. We have the following comments to share with you regarding the Grassland Plan, which we have grouped by general topic area. 1. We are very supportive of the overall conservation-based approach to grassland management that is the focus of this plan. We believe this approach suits OSMP's vision for their properties, and provides a clear focus for the priorities of the department and the City. We applaud OSM P for taking a strong stance for conservation of these unique and important grassland resources. We also support the concept of protected corridors along riparian areas and wetlands, especially where social trailing has degraded ecosystem values and functions. In addition, we believe your plans for weed management are thorough and will provide solid management on your properties. We also congratulate OSM P for planning to place a considerable effort on monitoring of these resources in the future. As a fellow land management agency, we understand haw difficult it is to uphold commitments to monitoring, and we support OSMP in their efforts to do so. We also applaud OSMP for engaging a wide array of stakeholders and partner agencies throughout the planning process. 2. Although we are supportive of the conservation-based approach to this plan, we have some concerns about the hierarchy and interaction between the Grassland Plan and other OSMP plans including the Visitor Master Plan, the various Trail Study Area plans, and the City's prairie dog management policies. We suggest that clarification of this issue be a priority in future revisions of the draft. We believe such clarification will aid other land management agencies in understanding and partnering towards OSMP's goals. It will also remedy some of the concerns that the public has about how the Grassland Plan implementation relates to other OSMP directives. We understand the reasoning by which OSMP chose an approach similar to that of The Nature Conservancy; however, we have some concerns that it does not fully incorporate the human dynamics that are important aspects of management and use of OSMP grasslands. We suggest that the document be embellished with references to the other plans, especially those that deal with human use, and how they will inter-relate. 3. We understand that the intent of the Grassland Plan process was to develop a detailed, conservation- basedapproach to grasslands under OSMP management. However, we are concerned that the plan is in some regards too detailed, and in others, not detailed enough. For example, Chapter V contains information on Conservation Objectives (Table 25) and Conservation Strategic Actions (Table 26}, which are all highly detailed. In addition, four Initiatives were developed, with several more Conservation Objectives and Strategic Actions for each. This detail is not matched with basic details on casts, schedule, and information about who will carry out these items. We are concerned that Chapter V lays out an overly ambitious set of actions and initiatives that will be difficult for OSMP to successfully meet. We understand the value in setting high goals as a land management agency, but we suggest that Chapter V provides too much detail on strategic actions without much detail on how it will be accomplished. 4. We are concerned that overall grassland conservation efforts will be compromised without proper enforcement of OSMP dog regulations, especially dogs under voice and sight control. We have all experienced or heard reference to numerous situations where dogs are not under control on OSMP grassland properties. In addition, both leashed and unleashed dogs are seen in grassland areas where they are prohibited. We are all aware of the effects of dogs on ecosystem and wildlife values in grasslands. This becomes a greater concern to us on OSMP properties that abut Parks and Open Space properties, where dogs are required to be on-leash at all times. We suggest that a commitment be made by OSMP and the City to better enforce its dog regulations in order to support the conservation efforts so 15 carefully laid out in the Grassland Plan. 5. We are appreciative of OSMP's efforts towards collaboration with us and other land management agencies towards protection of grassland resources on the Front Range. In particular, it is important that we continue communication on management decisions that affect our jointly owned properties. In addition, we request that OSMP consider the impacts of its management decisions on adjacent or nearby Parks and Open Space properties. We mention one topic above, that of dog control on grassland properties near ours. We also paint to examples such as infestations of Eurasian watermilfoil and garlic mustard, where better control by OSMP might have mitigated infestation on our properties. We understand that the City has more limited weed control options than Parks and Open Space. Because weed management is of great concern to the public and partner agencies, we encourage and support OSMP in seeking a broader range of management alternatives for weed control. We also suggest that you state in the Grassland Plan the species or species lists that you intend to monitor or control, and clearly reference your own weed management policies. If you would like to discuss these comments, please contact me at 303-678-6273 or !read@bouldercounty.org. We will continue to support OSMP as it moves this Grassland Plan through its public and approval processes. We look forward to continuing our collaboration for management of these important grassland ecosystems. Suzanne Webel 12/4!2008 Boulder CO BCHA Response are attached Hello Mike and Mark Attached please find BCHA's response to the Draft Grassland Ecosystem Management Plan. While we appreciate much of the effort that went into the document, we are disappointed that the only "ecosystem management" it considers are more closures and restrictions on the humans who have paid for it and love it. Therefore we, along with many other organizations and individuals, consider it to be an unfortunately unbalanced document that was issued at an inopportune time in the VMP-TSA process. We hope you will consider our comments in the constructive spirit they are offered, and we trust that if they are duly honored, respected, and incorporated into the GEMP it will become a product we can all support. Please include our letter, BCHA's Horses & Weeds position paper, and our comments in the OSBT agenda packet with all the other feedback. Thanks Suzanne Webel Ted Waddle 12/4/2008 Eldorado Sprin CO Igo hiking on the Mesa trail almost every day and on other trails near my house. I believe open space land should be open to the public we paid for it with our taxes. We did not pay far it expecting to be shut out of it. People and their access to public lands are more important than nesting birds or any other animals including cows. Cattle wandering all over grasslands do much more damage than hikers anyway. Please don't let extreme environmental ideas limit public access to our public lands. Regards Ted Waddle Anonymous Lessess 12/4/2008 One of four (4}written responses received in response to a survey. Bernd Lutz 12/4/2008 Comments from Boulder Outdoor Coalition are attached 16 Linda Mahnoey 12/5!2008 Boulder CO Very goad plan. It provides protection to same very special plant communities while also allowing visitors the opportunity to enjoy the land. The prairie dog issue will continue to be contentious. The only logical solution is to try and work with other counties particularly on the Eastern plains to find alternative places to maintain colonies. A willingness to compromise and also offer incentives to rural landowners may help solve the pressures put on the prairie dog colonies locally as well as address the concerns of Boulder County landowners who feel like they are being forced to deal with the prairie dogs that leave open space properties. The Eastern plains will continue to face water shortages and they may be receptive to an alternative use of their land in the future. If several Front Range communities worked together and came up with a good plan it might be to the benefit of all concerned. This planning will be more critical if the black- tailed prairie dog is listed under the Endangered Species act. Can't hurt to be a little proactive. Karen Hollweg 12/5!2008 Boulder CO Karen Hollweg Comments Since I'm never quite sure what really gets into an e-system and I've been having trouble with the OSMP website today, I am submitting my comments directly to you (in addition to submitting them online}. See attached. and Thank you! I look forward to reading and learning more from this Plan as my schedule allows. Karen Ed Mills 12/5/2008 Boulder CO FIDOS has been a cooperative and productive partner with OSMP management throughout the VMP and first two TSA studies. We have worked in concert with staff to implement such innovative and creative programs as the Green Tag Program Trail Head Leashing and corridor V&S among others to provide opportunities for a high level of visitor experience for dogs their guardians and other visitors. FIDOS is committed to continue this effort to insure the proper steps are taken in balancing resource protection while making the visitor experience work. While the Grasslands Management Plan (GEMP) does an extraordinary job of inventorying the resources of the Grasslands Ecosystem ita s inherent flaw is the exclusion of critical issues concerning balancing the goals of preservation and recreation. The plan addresses habitat and wildlife conservation resources and objectives but not recreational resources and objectives. The current draft GEMP displays a clear anti-recreation anti-trail bias which is inconsistent with the City Charter Visitor Master Plan and TSA process. Unfortunately the implementation of the current draft as proposed as a management plan outside of the VMP and TSA process theatens the very frame work of public process and cooperation established thus far. The GEMP should be used as it is: a study to be incorporated into the Grasslands TSA's. It should not be the management plan to trump other management plans and agreements outside the bounds of the VMP and the balance of OS purposes envisioned in the open space charter. The elimination or re routing of half the popular hiking and dog walking trails at South Boulder Creek Trail Dry Creek Trail East Boulder Trail Coot Lake trails Boulder Reservoir Left Hand Trail Sawhill Ponds increasing the area of seasonal closures by a factor of six and routing of trails around the exterior of areas of highly desirable interest (all of which are called for in the plan} are particularly troubling. There are acceptable levels of impact associated with insuring a high level of visitor experience which we ignore at or own peril. Direct experience with nature is the most highly cited influence on environmental attitude and conservation activism. Outdoor play and nature experience have proven beneficial for cognitive functioning reduction in symptoms of ADD increase in self- discipline and emotional well being at all developmental stages. Direct experiences of nature tend to be neither particularly hazardous nor momentously spectacular but evidently intrinsically important to both development and conservation. Oliver R.W. Pergams Department of Biological Sciences University of Illinois at Chicago. The GEMP should be used as a valuable tool. It's recommendations and management planning should be done within the broader framework of the process as is consistent with the Visitor Master Plan. Within this framework FIDOS and OSMP staff can continue their cooperative efforts towards expanding V&S opportunities visitor studies educational efforts and compliance with regulations. Anything less threatens to undermine this cooperation and the buy in and support of the public. Strengthening the connection between the public and their open space through both quality access opportunities and conservation can only advance our open space goals. Ed Mills FIDOS President 17 Louise Gorsuch 1215!2008 Boulder CO Prairie dogs ahave made inroads inot the open space off 95th and Lookout Road {SW corner). Their holes are extremely dangerous to jorses and joggers, etc. They need to be kept out of the open space. Thank you for mowing when the grass got long. Plase could you do that wne the grass gets long {approx. once a year). Molly Buchanan 12/5!2008 Denver CO Anadarko Letter are attached Dear Mark Attached is a letter dated December 5, 2008, entitled "Notice of Mineral Interests and Oil and Gas Leasehold Interests Owned by Anadarko Land Carp., Anadarko E&P Company LP and Kerr-McGee Oil & Gas Onshore LP" which are comments for the Anadarko entities regarding the draft Grassland Ecosystem Management Plan. Please provide the letter to the City and the appropriate departments within the City and make it part of the record in the City's deliberations on the proposed Grassland Plan. You will also receive a hard copy of the letter by courier delivery today. If you have any questions, please call. Thanks very much. Molly Molly Sommerville Buchanan MOLLY SOMMERVILLE BUCHANAN, P. C. 1580 Lincoln Street, Suite 700 Denver CO 80203 Phone: 303.825.0416 Fax: 303.825.3202 E-mail: msb@msbuchananlaw.com Eric Vogelsberg 12/5!2008 Boulder CO I am extremely disappointed in the draft Grassland Plan. After claiming a scope limited to just the conservation of ecological values and agricultural production of the grasslands the document makes totally inappropriate recommendations about public access and recreational opportunities. These are items to be addressed in the ongoing TSA processes. The Grasslands document makes note of the TSA process as the appropriate place to deal with these items and then blithely goes on to make sweeping statements about recreational impacts and to propose draconian measures to limit those impacts. The document claims a The Grassland Plan is intended to provide a framework of on-the-ground management public policies and landslwater acquisition priorities to conserve the ecological values of Boulders s grasslands and ensure on-going agricultural production.a It claims to not deal with other Charter objectives and then recommends rerouting or removing 50% of the trails within 200m of wetlands & riparian corridors limiting new trails and trail locations increasing the grasslands subject of seasonal closures from 7% of the total to 45% {an additional 6000 acres) adding additional dog leash restrictions and modifying the VMP to convert a Passive Recreation Area to a Natural Area. The result feels like a deliberate attempt by a set of staff members with only one viewpoint to circumvent a public process with which they disagree. I thought we had gone beyond this kind of behavior. Rewrite the draft to deal with the grassland issues it claims to address excluding the recommendations about access and recreational which it claims not to address. Let the TSA processes which do claim to consider all Charter objectives deal with those issues. 18 Guy Burgess 12/5/2098 Boulder CO Memorandum To: Grasslands Ecosystem Management Team Boulder Open Space and Mountain Parks Department Open Space Board of Trustees Boulder City Council From Boulder Area Trails Coalition Guy Burgess, President burgesshg@gmail.com 303-499-0354 Subject: Comments on Draft Grassland Ecosystem Management Plan Date: December 4, 2008 It seems to us that the Draft Grassland Ecosystems Management Plan has made enormous progress in understanding the current status of OSMP's grassland and riparian ecosystems as well as outlining opportunities for improving the health of those systems. Unfortunately, the Draft Plan's exclusive focus on nan-human aspects of the ecosystem limits its ability to advance larger OSMP policy goals. The goals explicitly stated in the City Charter, the Visitor Master Plan, and the various Trail Study Area processes reflect a broader vision for the management of OSMP properties. These documents {with their clear mandate to balance environmental preservation, passive recreation, and other goals including agriculture} see Boulder's citizens and the many plants and animals which inhabit OSMP lands as part of the same ecosystem. In this context, the principal goal of OSMP is to foster a harmonious balance which allows both human and non-human elements of the ecosystem to flourish. To do this OSMP needs to move beyond what I have called "separation ecology" with its focus on preserving the environment by simply limiting human presence wherever passible. In its place, OSMP needs to pursue a vision of "connection ecology" which recognizes that humans are also part of the ecosystem. This, in turn, suggests that OSMP should supplement the Draft Grassland Ecosystem Management Plan with an ongoing search for the most effective ways of accommodating the continually expanding need for human visitation while simultaneously protecting the non-human environment and fostering a fully functioning ecosystem. To do this OSMP needs to add needs to integrate the following elements into the plan: • An inventory of the kinds of experiences that humans currently find enjoyable and attractive within OSMP grassland and riparian ecosystems, • An inventory of opportunities for promoting environmental understanding through interpretive materials and environmentally instructive visitation opportunities {such as access to birdwatching spats or opportunities to watch farmers actually grow crops over the course of a season}, • An inventory of similar and as yet undeveloped opportunities for expanding visitation to meet the needs of an ever-growing population, • An assessment of how highly people value each experience. (For example, time spent near lush riparian areas is likely to be more of a highly valued than time spent in hot dry grasslands.} • An assessment of the nature and magnitude adverse impacts on non-human species associated with each of the above experiences. • Identification of options for restructuring current (or structuring possible future) experiences in ways which limit environmental costs while maximizing human benefits. This information could then provide a sound basis for the upcoming Trail Study Area processes as well as mare immediate OSMP and OSBT decisions about the management of these properties. We expect that with cleverness and dedication this approach could, at minimal cost of the non-human environment, provide highly enjoyable, highly enjoyable passive recreation opportunities which also allow Boulder residents to appreciate and better understand the nonhuman environment and the city's agricultural and historical heritage. As currently written the Draft Grassland Ecosystem Management Plan doesn't address these critical issues. If it is not corrected, we are concerned that many exciting opportunities for simultaneously 19 advancing OSMP's preservation and recreation goals will be missed. After all, you can't find solutions to challenges if you don't look. Heidi Grimditch 12/5/2008 Eldorado Sprin CO Management of Open Space should be changed to management of closed space. I live in Eldorado Springs and in the last nine months gates have not only been locked but also removed and turned into barbed wire fencing. I train guide dogs for the blind community and took a walk every morning to expose the puppies to traffic. I now have to walk on the side of the Eldorado Springs Rd. putting myself and the puppy at risk to get hit by a car because the gate I used to exit the RR track trail was removed. When Open Space was a concept being sold to the community to support with their hard earned tax money we were all told we would have recreational usage of the lands. Now many years later the balance of recreation and conservation does not exist. Closing people off of the land they purchased is not smart. Taxes are the future of open space and if people see they are being closed out they will no longer support the concept. If the land is being overused find a way to limit it to Boulder residents. Myself and my neighbors spoke with the OSMP about the gate removal and gate locks on open space south of Eldorado Springs Dr. no one listened. We have 22 horses within a one half mile radius of the locked gate and removed gate. With no access it forces riders to drive trailers to already crowded parking lots to ride. We have many young people who ride these open space trails keeping them from mischief. The prairie dogs have decimated part of the area south of Eldorado Springs Rd. this shows poor management of the area. it is probably easier to close people out than prairie dogs. I urge you to all find preservation solutions that do not include closing open space trails to the very people who approved their purchase. Heidi Grimditch 1900 Senda Rocasa Boulder, Co. 80303 McIntyre Mark 1215!2008 Boulder CO Boulder Mountainbike Alliance Comments are attached Hello Dean: On behalf of the BMA I am submitting our comments regarding the Grassland Ecosystem Management Plan. Please ensure that this document becomes part of the official public comment. Regards, Mark McIntyre -Boulder Mountain Bike Alliance Board Member Catherine Whitlach 12/5!2008 Boulder CO To Whom It May Concern, As a frequent trail user in the Boulder area (on foot, bike, and horse} I wanted to express my disappointment and distress about the recent Grasslands Ecosystem Management Plan (GEMP). I strongly agree with the letter from the Boulder Outdoor Coalition (reprinted below this paragraph); I believe the groups of the Boulder Outdoor Coalition have several valid reasons for the ineffectiveness of the GEMP plan. Instead of simply closing off access, please take the time to consider the 3 major points below. It would be wonderful to see the OSMP work with the public, encouraging proper and respectful use of the open spaces; by closing off all access, OSMP is implying to the public that they do not deserve to be a part of their awn wilderness-an implication that has already caused great outrage amongst Boulder County residents. I urge you to consider the views of the Boulder Outdoor Coalition groups, redraft the GEMP plan, and form a productive relationship with trail users. Thank you for your time, Cathy Whitlatch Cathyw44at7gmail.com, Boulder, CO 80302 Ernest Pund 12!5!2008 Eldorado Sprin CO I am writing to protest the proposed closure of open space for preservation. While I am in favor of saving our environment and protecting our natural habitat I believe it is a mistake to so dramatically limit access by people. My family lives adjacent to a neighborhood gate we use it regularly but rarely see anyone else there. Certainly the impact is minimal and I question the 'science' used in deciding that a closure of access is warranted. 20 Ryder Johnson 12/5/2008 Eldorado Sprin CO Dear Mr. Gershman, The areas I access are south of Eldorado Springs Drive between the Doudy Draw and Highway 93 and north between the Mesa Trail and Highway 93. I have copied some pictures of the Open Space meeting I attended this past summer 2008 trying to make sense of the nesting ground bird gate closure. That was the worst time of year to close the gate because it was our summer vacation. I was so sad when I saw the big chain and lock you put on the gate the next day. I thought to myself, "well there goes my summer fun for another year" In the pictures you will see the gate that is located at the end of Senda Rocosa. Hope this helps you to identify the areas I am concerned with. My Mom said our neighbor told her this summer that you removed one of the two gates on Eldorado Springs Drive between Senda Racosa and Highway 93 and replaced it with a barbed wire f ence? If that is true why did you do that? The other side to the north is also an area I like to walk my dog and get exercise. I can even walk home from my school on these trails off of Greenbriar. So what I really want to know is what are your plans for theses areas? Will any of the current trails be changed as to haw they are used in the future? Thank you for your time. I'm happy you like my letters. Happy Trails, Ryder Bruce and Kat Tenenbaum 12/5!2008 Boulder CO We live at 7279 Arapahoe just east of the Merle-Smith open space. We understand that there is talk of regulating the use of that space as well as other open space areas. After living here 25 years and supporting the purchase of these neighborhood properties we would feel cheated to have their use suddenly denied to us. We would appreciate information on how we can become involved and have input in the decisions being made on these properties. Please note our concern and contact us as soon as possible. Thank you. Anonymous Lessess 12/5/2008 One of four (4) written responses received in response to a survey. Erik Kronenberg 12/5/2008 Eldorado Sprin CO Hello: My name is Eric and I'm 14 years old. My mom told me about some of the changes that might happen with Open Space and I'm not too happy about them. We moved to Eldorado Springs last Thanksgiving. I like to go an the trails with my family and friends and dog, Sunshine (she's a golden retriever and I love her and she's really well behaved). Some of my friends hang out at the mall or downtown or get in trouble. I think I'm a pretty good kid and I stay out of trouble cause I have fun on my property and do lots of things outdoors. I want to be a professional soccer player when i grow up. every day after school i come home and shoot at my goals and.. I have some really expensive goals and nice soccer balls {that are expensive) and if they got stolen i would be really upset. I don't want people looking at me when I practice either. im really shy, and that would stink. Also my dog has been getting harrassed by coyotes. I don't know if my parents have talked to you about this, but I got my dog on my birthday 5 years ago and if a coyote hurts her or kills her I'd be a mess. It scares me when they are around. Could you do something to protect dogs from the coyotes? Oh, and my sister Melanie's bedroom looks at the fence by Open Space and she would be bummed if people could look in her window. She's 16 and she needs her privacy. Please don't make it harder for us to use the trails and please don't put one next to our home. Thanks, Eric Kronenberg 21 Paula Martin 12/5/2008 Boulder CO Comments from Prairie Ecosystems are attached Dear Mr. Gershman: Thank-you for inviting me to provide comments an the proposed Grassland Ecosystem Management Plan. I am attaching my comments here because I felt that they were too extensive to be pasted into the comment page provided an the website. Please forgive my tardiness; 1 was really overwhelmed in early November and was also unable to attend the meeting. The deadline for comments simply slipped my mind. I did not begin to review the document until today, and would like the opportunity to absorb the content more thoroughly. It would be wonderful to get together with you sometime. I have been residing in Boulder for the past five years. I hope that this is acceptable. Please let me know if I should forward elsewhere. With kind regards, Paula Martin 726-345-8293 Michael Delaney 12/5!2008 Boulder CO I attended the public meeting at the West Senior Center on the draft grasslands plan on November 20. I did not speak because another gentleman made my point. I disagreed with much of what was said both by those who want only to consider prairie dogs and by those who are in favor of mare public access because we are the owners. While I haven't studied the plan exhaustively a quick read shows that the staff who developed the plan are very much on the right track. I especially approve of higher levels of protection for wetlands and riparian corridors. So thank you and please resist the calls to change significantly the planned restoration and protection of these most misunderstood of our open space lands. Also an owner Michael Delaney Peggy Kaufman 12/7/2008 Boulder CO I use the grasslands weekly. I run and hike on the Dowdy Draw trails Eldorado trails and the Shanahan Ridge trails. I live in Devil's Thumb and use the trails for exercise for me and my dog. While I think the study environmental impact is important I think keeping the trails open to people and dogs is extremely important. This is the reason we live here in Boulder and in this neighborhood. We use the trails and enjoy the beauty they offer. I clean up after my dog and stay on the trails when I run. Problems arise when you begin to close trails or make different rules for each individual trail. I want to be able to run my dog to Eldorado and back using the Shanahan trails and the Mesa trail. For a large part of the summer we can't use the Eldorado trails and have dogs off leash because of nesting birds. I am aware of the rules and abide by them. But please don't take away our ability to get a long distance trail run in and the ability to exercise our dogs off leash I don't think it is possible to have a good run with a dog on leash and run on a trail (with the uneven surface rocks etc.). Ray Bridge 12/7/2008 Boulder CO FOBOS Comments are attached Mark, Obviously, I still haven't really digested the whole thing, but I remain in awe of what you've accomplished. Hopefully, we can actually bring the goals of the plan to fruition. Attached are FOBOS's comments, necessarily less thorough than is called for, but, hey, it's only a month since it was revealed. I do have a couple of requests for information, which I'll send Monday. Best regards, Ray Bridge 22 Jennifer Kwasniewski 12/8120Q8 Boulder CO City of Boulder Open Space and Mountain Parks P.O. Box 791 Boulder, CO 8Q3Q6 December 4,20Q8 Re: Grassland Ecosystem Management Plan Dear OSMP staff: I appreciate the opportunity to review OSM P's draft Grassland Ecosystem Management Plan (the Plan). OSMP staff have clearly spent considerable time and effort on this document. I believe that time and effort has been well spent in the consideration of habitat and wildlife conservation (i.e., flora, fauna, wetlands and riparian areas) as specific targets of the plan. Agriculture Operations on OSMP lands are also reasonably considered in the Plan. However, the Plan is incomplete in that it does not properly consider Recreational Use as a focal target. These focal targets drive the entire planning approach of the document. The targets in the Plan are based on the purposes of the City Charter for Open Space with the exception of Recreational Uses, which for same reason was not identified. Without fully integrating Recreational Use as a target into the Plan, OSMP's recommendations are not consistent with the City Charter and OSMP is unable to perform a balanced evaluation. Identification of Recreational Use as a target will allow OSMP to determine the key attributes of Recreational Use and indicators for those attributes. Threats to Recreational Use would be identified and a Best Opportunity Analysis would be conducted. Finally, implementation strategies, objectives and initiatives would be prepared for Recreational Use. Ta accomplish this important modification, OSMP should revise the Plan to evaluate Recreational Uses as a target on par with the other OSMP charter purposes. Alternatively, OSMP could strip the Plan down to present only the ecological data for the Mixed Grass Prairie Mosaic, Xeric Tallgrass Prairie, Mesic Bluegrass Prairie, Black-tailed Prairie Dag and Associated Species, Wetlands, Riparian Areas and the White Racks Area and remove all recommendations about threat assessment and haw to improve the ecology, reserving any and all recommendations, strategies and decision-making to the TSA process. By doing so, OSMP will be in a position to effectively balance competing goals that may exist within the purposes of the OSMP Charter and OSMP staff will be better able to integrate the long-term sustainability of natural systems with recreational use and agricultural operations. Absent this significant shift in focus, the Plan is one sided and only focuses on conservation goals to the exclusion of recreational use. Without a level of visitor access, residents will cease to support the Open Space and Mountain Parks program. OSMP staff are charged with finding a balance that allows for visitor access while maintaining ecological functions. Treating Recreational Use on par with conservation is critical to finding that balance. In addition to this global, and fairly significant comment, I present the following specific comments to the Plan as an attachment to this letter. Many of these specific comments may be rectified by a full integration of Recreational Uses as a target of the Plan. I appreciate the opportunity to comment on this Plan and look forward to reviewing OSMP's next steps. Very truly yours, Jenifer Kwasniewski Attachment Attachment to Comments on OSMP Grassland Plan • On page 29 of Chapter 1, OSMP staff should explain how trails and greenways located near riparian areas impacts those areas. The implication is that trails and greenways negatively impact such areas. Although it is fairly apparent how gravel mining, road construction and residential development negatively impact riparian areas, it is not so apparent how a trail impacts the functionality of a riparian system. • On page 33-34, Table 2 should include Recreational Use as a target and include key attributes for that target. Those key attributes could include: Trail Condition (maintenance condition, singletrack vs. doubletrack or road, etc). Trail Availability, Trail Location, Trail Views, Trail Connectivity, Trailhead Availability and Condition, Trail Experience Opportunities (nature viewing, bird watching, rack climbing access, exercising) and Trail Use Opportunities (hiking, equestrian, dogs, and mountain bikes). Indicators for these attributes can be developed that area measureable and technically feasible. With proper definitions, they can be precise and consistent, specific, sensitive and timely. For example, one indicator for Trail Availability could be miles of trail per acre of OSMP land. Indicators for Trail Condition could be percentage of trails in very good, good, fair and poor maintenance condition and percentage or trails that are singletrack, doubletrack and road. Trail Use Opportunities could be measured by the miles or 23 percentage oftrails available to each user group. • On pages 36-38, it is unclear how OSMP went from table 4 to table 6. I believe more explanation should be included in the text. • On page 43, OSMP describes how roads/urban areas and trails were used to reduce the block size calculations. The ratio between roads/urban areas and trails is presented as 2:1. Specifically, roads/urban areas were presented as creating a 200 meter buffer that was excluded from the block size and trails were presented as creating a 100 meter buffer that was excluded from the black size. In contrast, riparian areas were presented as creating a 20 meter exclusion from the block size. I find it difficult to believe that roads and urban areas are only 2 times mare disruptive than trails (or conversely, that trails are half as disruptive as roads and urban areas} and ask OSMP to provide data to support this conclusion. Trails exist in nature (i.e., animals create trails themselves} and do not seem to disrupt wildlife to as great an extent as the 100 meter figure would suggest. Even trails used by humans, dogs and horses, while more disruptive than an animal trail, cannot be even half as disruptive as 100 feet of asphalt with cars driving by at 60 miles per hour or as a residential development. This is especially true in the grassland areas, which do not have the trail density/user density of the Chautauqua area. It would seem to me that trail disruption should be much lower than that far roadslurban areas and closer to the figure presented for riparian areas. Finally, OSMP does not show how proximity to agricultural land affects block size. If OSMP intends that this be included in the roadslurban areas category, I believe it should be separated out with its own buffer zone, as agricultural land would seem to be less disruptive to wildlife than roads and urban areas, but more disruptive than riparian areas and trails. • On page S7, table 17 shows that Total Phosphorous (for Ponds} is rated as "Good", but further down, Total Phosphorous (for Ponds} is highlighted in blue and shown as "Not Rated." Please explain this discrepancy. • On page 58, OsMP states that road and trail density are an indicator for connectivity. I do not dispute this conclusion, however, I believe that roads and trails should be evaluated separated when determining their impact on wetlands, as the magnitude and nature of their impact would seem to be disparate. This comment caries on to page 60, where roads and trails are combined in table 18 and page 62, which summarizes the impact or roads and trail density collectively as falling outside the acceptable range. Moreover, I believe to truly understand the impact of trails on the connectivity of riparian areas, designated and undesignated trails should also be evaluated separately so that sound decisions regarding trail management can be made. • On page 60, OsMP lists several indicators of riparian condition that have not yet been rated. As an Environmental Scientist specializing in contaminated site remediation, I recognize these indicators as relatively easy to measure and able to provide objective data. I urge OsMP to complete the studies associated with these indicators as soon as possible, as they will provide a good, objective baseline for measuring improvements. This comment carries onto page 61, where OsMP states that this data collection is proposed. • On page 62, some very interesting text is presented almost as a side note in small green font. Why is this text not shown as part of the "regular" narrative? The green text seems to imply that much of the negative impacts to riparian areas have been caused by substandard mining reclamation activities in the past. Reducing this point to a side note minimizes the chance that solutions to this problem are evaluated. • On pages 69 and 70, OsMP presents a figure of recommended trail and road density (34 mtha} within a 200 meter buffer of wetlands and riparian areas. Roads and trails should be evaluated separately and trail density should presented as within a 100 meter buffer ar less. In addition, OsMP should explain the basis for 34 meters of roadltrail per hectacre of land. • In Chapter III, OsMP should more fully explain how staff went from attributes, targets and indicators to threats. The threats are simply presented with little explanation as to how they were determined. • On page 71 in the last paragraph, OSMP should represent item 4 as "incompatible dog management by guardians and not just as "dogs" (i.e., use only the text in parentheses.}. This should also be carried out in table 22 on page 22 (item 3) and page 74. Dogs in and of themselves area not the problem, incompatible and inappropriate management by dog guardians is the problem. • OsMP should show how they calculated each ranking in table 22. Based on the data in Chapter II, I was surprised to see so many High and Very High rankings. For example, the ranking of Very High for Incompatible Trails/Recreation on Prairie Dogs seems quite high and was not something I gleaned from any text in Chapter I I or any of the appendices. Also on table 22, Roads seem to be missing as a threat. My concern with how OsMP calculated the ranking of some of the threats is exacerbated by the text on page 74. Many of the threats indicated as Very High in 24 table 22 are described in a less-than definitive manner on page 74. Specifically, many of the threats listed as Critical Threats are referenced with words such as "may have" and "may result". These qualifiers do not support strong statements that certain activities are very high threats. More information on OSMP's calculations far the rankings may help address these questions. My particular concerns involve presumptions that trails ARE a threat when OSMP can only state that they MAY be a problem. This issue is a good example of why Recreational Use needs to be evaluated as a stand-alone target and may be addressed by doing so. • On page 74, OSMP states that trails create disturbed ground, which is a preferred location for weedy plants. I agree that disturbed grounds are preferred locations for weedy plants in general, but my experience has been that properly maintain trails are weed free (i.e., they are dirt and rocks). Does OSMP mean that the sides of trails are disturbed enough to be fertile ground for weeds? If so, this should be clarified. • On page 74, I have several concerns with the text on "dogs": o I recommend that the text include language that distinguishes between dogs on leash and dogs off leash. I believe many of the perceived problems caused by dos are really the problem of dogs that are not controlled in the right places. In certain areas, requiring and enforcing leash laws is a simple solution that has not been fully utilized. o In addition, more rigorous enforcement of waste pick up can also reduce this problem significantly. o Regarding feces, there is little discussion in any OSMP documents of the impact of horse feces on water quality and nitrogen contribution. o Regarding the last sentence in the section, do wild animal trails create places where weeds can germinate and grow? • On page 91, road density and trail density should be evaluated separately, as the two would seem to have very differing impacts on wetlands and riparian areas. • On page 96 in table 25, OSMP proposes a reduction figure of recommended trail and road density within a 200 meter buffer of wetlands and riparian areas. Trail density should be separated out and presented as within a 100 meter buffer or less. In addition, OSMP should explain the basis for recommending a 50% reduction in trail and road density. Trail density in the grasslands is currently among the lowest for OSM P lands. Moreover, riparian areas and wetlands present some of the most desirable locations for recreational users. Instead of jumping to the recommendation to reduce density, OSMP should consider a more balanced approach that seeks to find specific locations near wetlands and riparian areas that may realize lower impact by trails than other, more sensitive areas. This issue may be resolved by evaluating Recreational Use as a stand-alone target. • On Page 98 in table 26, item 9 states an action calling for OSMP to "Close and restore undesignated trails and discourage their (re) establishment." Instead, OSMP should evaluate both designated and undesignated trails to determine which ones pose the lowest impact on other targets. Some undesignated trails may be very appropriately located and constructed and could be added to the list of designated trails. Conversely, if OSMP has direct evidence that certain designated trails are problematic, they should be relocated or replaced with appropriately located undesignated trails. The goal should be to have a desirable density of appropriately located and constructed trails to support meaningful and enjoyable recreational use. Evers Pund 12/8/2008 Eldorado Sprin CO To whom it may concern I am writing in opposition to a proposal to close open space to my neighborhood. While I believe that we should preserve our environment I think it is tragic to remove people from that area. After a long day of school work or a bad day I lie to go up into the open space and clear my mind and have some peace. After I come down that little hill near my house I feel like it's been one of the best days of my LIFE. I love open space. It is one of the most healing places around. Please don't take that away from me. Evers Pund age 10. 4817 Eldorado Springs Drive P.S. The view on the hill is beautiful. You can see most of the valley from up there! You will take that away from me AND my neighbors if you close open space. 25 John Parsons 12/8/2008 CO To Whom This Concerns: I have lived in the Boulder area for about 8 years and Open Space is one of the reasons. Open Space is a local treasure and like all treasures needs protection. If you "bury" this treasure by closures and access restrictions, then Open Space will no longer be a treasure. Access and use can be managed properly by adequate enforcement of the current rules and regulations. We do not need further closures or restrictions of access and I would argue we need less. As I understand it the PEOPLE OWN THE OPEN SPACE and the PEOPLE APPROVED THE PURCHASE OF OPEN SPACE FOR USE. If the Boulder city and county officials choose to close the space far arcane and bogus environmental reasons, then I promise you, I will vote all city and county officials out of office. I will also campaign to get all of my friends and associates to do the same. Again, this is our land that was purchased for our use. YOU HAVE NO RIGHT TO CLOSE THE OPEN SPACE LAND UNLESS THE PEOPLE VOTE TO CLOSE THE OPEN SPACE. We want and demand access not closure at the behest of a few wacked out environmentalists and conservationists. Use of treasures is what makes it a treasure. John Parsons Michael Katz 12/8t2008 Boulder CO Comments from Michael Katz are attached Janet Machol 12/912008 Boulder CO :The Grassland Plan looks a thorough ecological study has been done but the impact to the public on public access does not seem to be discussed. (I have only skimmed this plan.) There is mention of of goals to reroute and close trails but there does not seem to be any discussion of whether issues other than the dollar cost will be taken into account. For instance the South Boulder Creek trail currently follows a creek for miles. I can see that it may be good to move the trail away from the creek along some of its length however will OSMP leave a bit of it along the creek so that people can enjoy and learn to appreciate creeks? From the write-up it sounds like the goal would be to never have a trail near a creek. It would be good if there were a section added to the study to discuss haw trail closure and rerouting will involve consideration of public recreation. In all but the most sensitive and rare ecological environments I would vote that the trail closures and relocations should be a compromise between conservation and public access. 26 Larry MacDonnell 12/10/2608 Boulder CO Thanks to staff for a truly outstanding effort. The first real effort to link ecological values with land use planning. Recommend that chapter 1 be used to prepare an op-ed piece for the Camera so the more general public can have a better idea of the remarkable lands included in the open space system. Recommend consideration of a sustainable agriculture plan for open space properties. It has been included in this grasslands plan in part because there are important grasslands that are irrigated and grazed. But the management of agricultural uses of open space deserves its own consideration. I think there is general support for continuation of agricultural uses but there are concerns about whether the practices are consistent with other values of the lands. We probably need a process that considers this matters separately. I am pleased with the attention given to riparian areas and the interest expressed in restoration of degraded areas. Several of the proposed strategic actions include consideration of flaws and instream values as well. The South Boulder Creek Stakeholders Group will be using the information developed for this drainage to help develop recommendations for a series of flaw and habitat improvements that will be implemented aver time. This process should help implement several of the actions identified in this plan. On p. 49 the statement that ~SMP water rights can be lost to abandonment for nonuse is not accurate. Abandonment requires intent to abandon. I would suggest including something like the reliability of its water supply as a key attribute far wetlands. Un p. 60 hydrologic regime is identified as important. I would include the groundwater levels. We hope to see some improvement in the flow regime in South Boulder Creek. It would be useful to have an analysis of what ecologic outcomes would be possible at what flow levels to help in our process of improving streamflows. i am really pleased to see the beginnings of developing same clear management objectives related to protection and enhancement of the system's grasslands. I hope we can apply these targets to specific lands and begin developing clear management objectives and actions that will reduce threats restore degraded resources and provide long term protection for these areas. Lindsey Sterling Krank 12/11/2008 Boulder CD One of our scientists members just weighed in w/this comment an the GMP. Could you please add it to the KBW comments? p.s. What is the next step and timeline of the planning and comment process Thanks much, Lindsey Comment- On page 5 it says they will note any predators during other surveys- if a coyote is preying on PDs then they move through the area and leave little sign of their presence. How will this be detected if the surveyors are out there a month later? Seems like the open ended horned lark issue. I disagree with them using criteriaimeasurementsthot are not clearly defined or that they have no info on. If they do not have a clear protocol for predator surveys- fine but then don't use predators as a measurement of PD colonies. On the other hand, based on their response it seems that if they found coyote scat or tracks then it would improve the ranking even if the coyote was just walking through the colony. Just seems this is not well defined and it seems difficult to use it for a criteria if they are not specifically monitoring for commensal predators- it's like saying when it reaches a certain temperature we won't go outside although we don't have a thermometer to measure the temp. I also agree that it will be difficult to measure and improve conservation target success if they are unwilling to expand/ improve the indicators of success- which in this case would be more pd territory to improve commensal/ predator abundance. The predators require large tracts of land with prey so if they not wanting PD expansion how are they expecting to see more predators? Sharon Collinge 12/13/2008 Boulder CO Sharon Collinge Comments Mark, Hello/ I've finally had a chance to review the grassland plan, and realize that my comments are a week late. So, I completely understand if you are unable to formally accept them. But here they are... Now I know what you've been doing for the past two years! Whew--this is an incredibly thorough document, and kudos to you for spearheading this effort. It's a really fine piece of work. Thanks again for the opportunity to participate. Best wishes, Sharon Sharon K. Collinge Associate Professor of Biology & Environmental Studies University of Colorado Boulder, CO 80309-0334 (303) 735- 3242 sharon.collinge a%7colorado.edu http:l/www.colorado.edu/eeb/EEBprojects/Collinge Lab/ 27 David Buckner 12!15!2008 Boulder CO Mike, Mark, Joe: I have now spent a fair amount of time examining the OSMP Draft Grassland Plan it is representative of a tremendous amount of effort and thought. And as such I cannot say that I have fully digested the comprehensive and complex contents. As I progress in this, I will separately provide some details including comments on such things as quantitative management goals. But as a whole this is a fine effort to deal with the husbandry of a precious resource. Your task as you are I am sure you are painfully aware is to navigate a path through small but very angry crowds of special interest -devotees without dropping the baby -the natural and agricultural resource remnants that have so carefully been assembled as OSM P. And it is clear that this endeavor is made more difficult yet by the political history that lead to a visitor management plan and various prairie dog commitments before the accomplishment of an overall resource-based plan. There is of course, no practical chance of reversing history, and there will be continuing pressure to a) allow unrestricted playground passes to support the growth of a local industry (recreation) and b) relent and subject all OSMP lands to the effects of simplistic management for the benefit of a single fossorial rodent, blindly trusting that whatever benefits these ground squirrels is the automatically the best thing for prairies. The Draft Grassland Management Plan is a well thought-out effort to incorporate rational thought and science into the continuing efforts to preserve and enhance long- term management of OSMP grassland ecosystems. Data accumulated on grassland condition and composition during past OSMP management has frequently been used by OSMP and others to explore the many areas of grassland ecology that are unknown. The GLMP has made use of much of the extensive accumulated data from as long as 20 and more years in the past to draft the proposed guidelines and goals. This is not racket science it is actually more complex than rocket science --and there is no owners manual with all the answers. All that can be done is to conservatively go fonivard, doing as much as is possible to learn about how these biological systems work and what human controlled changes they can and cannot absorb without degradation. The draft GLMP is doing the right thing clearing the path forward in this process. Thank you, David L. Buckner 1077 So. Cherryvale Road Boulder, CO 80303 28 MOLLY SOMMERVILLE BUCHANAN P.C. Molly S. Buchanan 1580 Lincoln Street, Suite 700 msb@msbuchananlaw.com Denver CO 80203 Telephone: 303.825.0416 Fax: 303.825.3202 December 5, 2008 Via a-mail and Courier Mark Gershman, Project Manager City of Boulder Open Space and Mountain Parks 66 South Cherryvale Boulder, Colorado 80303 NOTICE OF MINERAL INTERESTS AND OIL AND GAS LEASEHOLD INTERESTS OWNED BY ANADARKO LAND CORP. ANADARKO E&P COMPANY LP AND KERR- McGEE OIL & GAS ONSHORE LP Re: Open Space and Mountain Parks/City of Boulder Draft Grassland Ecosystem Management Plan Dear Mr. Gershman: This Notice of Mineral Interests and Oil and Gas Leasehold Interests is submitted to the City of Boulder Open Space and Mountain Parks and the City of Boulder (hereinafter together the "City") and constitutes notice to the City and comments for the Grassland Ecosystem Management Plan ("Grassland Plan") that the City proposes to adopt and for which the City has invited comments from the public. Anadarko Land Coip. ("Anadarko Land"), formerly known as Union Pacific Land Resources Corporation, Anadarko E&P Company LP ("Anadarko E&P"), formerly known as Union Pacific Resources Company, and Kerr-McGee Oil & Gas Onshore LP ("Kern-McGee"), a subsidiary of Anadarko Petroleum Corporation (collectively the "Anadarko Entities"), own mineral interests and oil and gas leasehold interests that underlie over 5,600 acres that are included within the property that the City proposes to manage pursuant to the Grassland Plan ("Planning Area"). The Anadarko entities wish to give notice to the City of the mineral and oil and gas leasehold interests they own within the Planning Area and make the City aware that: i) the purposes of the Grassland Plan and the manner in which the Plan is implemented may significantly impact the ability of the Anadarko Entities to develop their mineral resources; and ii) the Anadarko Entities assert their continuing rights to develop their minerals and oil and gas leasehold interests in accordance with mineral reservations included in deeds and oil and gas leases and other title documents of record. This letter is notice to the City of the oil and gas leasehold interests and severed mineral interests owned by the Anadarko Entities within the Planning Area and comments on the 29 Members of the City of Boulder Open Space and Mountain Parks and the Planning Commission and City Council for the City of Boulder December 5, 2008 Page 2 Grassland Plan as follows: 1. The Mineral and Oil and Gas Leasehold Interests Owned by the Anadarko Entities. Anadarko E&P owns oil and gas interests in five sections of land included in the Planning Area, covering approximately 2,080 acres. The property in which Anadarko E&P owns oil and gas interests is identified in Exhibit 1. Anadarko Land owns hard rock mineral interests in four sections of land included in the Planning Area, covering approximately 1,600 acres, and also coal interests in ten sections of land included in the Planning Area, covering approximately 3,120 acres, or a total of 4,720 acres in which Anadarko Land owns either coal or all hard rock mineral interests. The property in which Anadarko Land owns hard rock mineral interests and coal interests is identified in Exhibit 1. Ken'-McGee owns oil and gas leasehold interests in five sections of land included in the Plamiing Area, covering 883 acres. The property in which Kerr-McGee owns oil and gas leasehold interests is identified in Exhibit 2. 2. The Impact of the Grassland Plan on the Development of the Mineral Resources within the Planning Area. The Planning Area consists of approximately 24,000 acres, and the Grassland Plan identifies eight "focal conservation targets," including black-tailed prairie dogs, the White Rocks Area, and agricultural operations, as well as certain types of ground cover and specific types of land areas in relationship to ground and surface waters. The Grassland Plan also identifies ways to improve conditions in the Planning Area to support the conservation targets and actions to be taken in support of the targets. The Grassland Plan does not specifically prohibit or regulate land use activitiest within the Planning Area; however, the Anadarko Entities are concerned that the City may implement the Grassland Plan in ways that prohibit or otherwise impose conditions that are more onerous for the Anadarko Entities in the development of the minerals within the Planning Area. Such a result would have a significant impact on the Anadarko Entities which collectively own mineral and oil and gas leasehold interests in approximately 5,600 acres within the various sections of land included in the Planning Area. Colorado case and statutory law provide that the mineral owner owns an independent property right to make reasonable use of the surface, to include access to and use of the surface 1 With respect to oil and gas drilling within the Planning Area, the chart included in the Grassland Plan on page 73 indicates only that oil and gas drilling will have "medium" impact on the White Rocks target. 30 Members of the City of Boulder Open Space and Mountain Parks and the Planning Commission and City Council for the City of Boulder December 5, 2008 Page 3 estate to explore for and extract minerals.z Actions by a government entity which may have the effect of reversing this basic tenet of Colorado property law and thereby deprive the mineral interest owner of its vested property and contractual rights may violate federal and state constitutional provisions. Further, any regulation or prohibition of mineral development within the Planning Area by the City may constitute a regulatory taking, especially where the operator is deprived of all economically viable use of land or his investment-backed expectations to develop his property.3 The Anadarko Entities request that the City provide for the private property rights of mineral interest owners and their lessees in its development of the Grassland Plan and in the adoption of any iteration of the Grassland Plan by the City. The Anadarko Entities continue to assert their rights to explore for and produce the minerals that they own and lease within the Planning Area. Please make this letter and the comments a paz-t of the record in the proceedings. Very truly yours, Molly Sommerville Buchanan, P.C. Molly S. Buchanan MSB cc: Maz-la Jones, Esq. Keith Crouch, Esq. Don Ballard Teny Enright Dave Bell 2 See Frankfort Oil Company v. Abrams, 4l3 P.2d 190 (Colo. ] 966). Note also, Gerrity Oil & Gas Corporation v. Magness, 946 P.2d 913 (Colo. 1977), which discusses in a footnote on page 927 the principle that the owners of both estates must exercise their rights in a manner consistent with one another. 3 See, for example, Lucas v. South Carolina Coastal Council, 505 U.S. 1003, 112 S.Ct. 2886, 120 L.Ed. 2d 798 (1992). 31 EXHIBIT 1 Anadarko Mineral Interests in Sections of Land Included in Proposed Boulder Grassland Planning Area Township 1 North, Range 69 West Oil, Gas and Hard Coal Rock Minerals Section 5: All 640 acres Section 7: N/2 320 acres Section 17: N/2N/2 160 acres Township 1 North, Range 70 West Section 1: E/2; SW/4* 480 acres Section 13: N/2NE/4; NE/4NW/4 120 acres Township 1 South, Range 70 West Section 9: NW/4NE/4 40 acres Section 15: NE/4; N/2NW/4; SW/4NW/4 280 acres Section 17: SW/4 160 acres Section 19: SW/4; E/2 480 acres Section 23: N/2 320 acres Section 27: N/2 320 acres Section 29: SW/4; S/2NW/4 240 acres Section 35: S/2; NE/4; E/2NW/4; SW/4NW/4 600 acres Township 2 South, Range 70 West Section 5: S/2; W/2NW/4 400 acres Section 17: All 640 acres 3120 acres 2080 acres Total Anadarko Mineral Acres: 5200 acres *All minerals except coal 32 EXHIBIT 2 Kerr-McGee Oil and Gas Leasehold Interests in Sections of Land Included in Proposed Boulder Grassland Planning Area Township 1 North, Range 69 West Section 4: SW/4; W/2SE/4 240 acres Section 5: S/2; NW/4 480 acres Section 6: SE/4; NW/4 160 acres Township 1 South, Range 70 West Section 23: S/2SE/4 (portion) approximately 2 acres Section 25: NW/4NW/4 (portion) approximately 1 acre 883 acres 33 ~p~~D E/I q~ ~vs • fi4 ~Q? • Memorandum To: Grasslands Ecosystem Management Team Boulder Open Space and Mountain Parks Department Open Space Board of Trustees Boulder City Council From: Boulder Area Trails Coalition Guy Burgess, President burgesshgCa~gmail.com 303-499-0354 Subject: Comments on Draft Grassland Ecosystem Management Plan Date: December 4, 2008 It seems to us that the Draft Grassland Ecosystems Management Plan has made enormous progress in understanding the current status of OSMP's grassland and riparian ecosystems as well as outlining opportunities for improving the health of those systems. Unfortunately, the Draft Plan's exclusive focus on non-human aspects of the ecosystem limits its ability to advance larger OSMP policy goals. The goals explicitly stated in the City Charter, the Visitor Master Plan, and the various Trail Study Area processes reflect a broader vision for the management of OSMP properties. These documents (with their clear mandate to balance environmental preservation, passive recreation, and other goals including agriculture} see Boulder's citizens and the many plants and animals which inhabit OSMP lands as part of the same ecosystem. In this context, the principal goal of OSMP is to foster a harmonious balance which allows both human and non-human elements of the ecosystem to flourish. To do this OSMP needs to move beyond what I have called "separation ecology" with its focus on preserving the environment by simply limiting human presence wherever possible. In its place, OSMP needs to pursue a vision of "connection ecology" which recognizes that humans are also part of the ecosystem. This, in turn, suggests that OSMP should supplement the Draft Grassland Ecosystem Management Plan with an ongoing search for the most effective ways of accommodating the continually expanding need for human visitation while simultaneously protecting the non-human environment and fostering a fully functioning ecosystem. To do this OSMP needs to add needs to integrate the following elements into the plan: • An inventory of the kinds of experiences that humans currently find enjoyable and attractive within OSMP grassland and riparian ecosystems, • An inventory of opportunities for promoting environmental understanding through interpretive materials and environmentally instructive visitation opportunities (such as BATCO P.0. Box 19726 Boulder, CO 80308 34 access to birdwatching spots or opportunities to watch farmers actually grow crops over the course of a season}, • An inventory of similar and as yet undeveloped opportunities for expanding visitation to meet the needs of an ever-growing population, • An assessment of haw highly people value each experience. (For example, time spent near lush riparian areas is likely to be more of a highly valued than time spent in hot dry grasslands.} • An assessment of the nature and magnitude adverse impacts on non-human species associated with each of the above experiences. • Identification of options for restructuring current (or structuring possible future) experiences in ways which limit environmental costs while maximizing human benefits. This infarmatian could then provide a sound basis for the upcoming Trail Study Area processes as well as more immediate tJSMP and C?SBT decisions about the management of these properties. We expect that with cleverness and dedication this approach could, at minimal cost of the non-human environment, provide highly enjoyable, highly enjoyable passive recreation opportunities which also allow Boulder residents to appreciate and better understand the nonhuman environment and the city's agricultural and historical heritage. As currently written the Draft Grassland Ecosystem Management Plan doesn't address these critical issues. If it is not corrected, we are concerned that many exciting opportunities for simultaneously advancing OSMP's preservation and recreation goals will be missed. After all, you can't find solutions to challenges if you don't look. BATCO ? P.O. Box 19726 ? Boulder, CO 80308 www.bouldertrails.arg 35 : ~ ~ • • • !!u' 4 wce i~?r Nur~r~ rt::u Nt~r:<~ ('c'Jp;c Itt Iiuulat:~ l.C~t~tn_, BOULDER (DUNiI' November 27, 2008 Mike Patton, Director Mark Gershman, Environmental Planner Open Space Board of Trustees Boulder, CO 80306 Re: Grasslands Ecosystem Management Plan Dear Mike, Mark, and Members of the OSBT: On behalf of the Boulder County Horse Association (BCHA) I would like to take this opportunity to provide our response to the recently released Draft Grasslands Ecosystem Management Plan (GEMP). We appreciate the voluminous amount of research and passion that went into the new Grasslands Plan. However, we are concerned that, as written, it seriously overreaches in its attempt to protect the prairie from any human presence. We submit that the level of protections it recommends is in sharp contrast with the eight unprioritized purposes specified in the Boulder City Charter for Open Space and Mountain Parks. We fully support the consensus position letters written by BATCO and the Boulder Outdoor Coalition, which express multiple concerns about the plan. We also wish to reiterate some specific equestrian concerns, as well as some common ones, to the Plan. 1) The GEMP seeks in inappropriate ways to change the Visitor Master Plan. For example, among the many discussion points of the VMP were Management Zone boundaries and definitions. These included designating the area south of Lookout Road between 75th and 90th Sts as a Passive Recreation Area. There is a large equestrian center adjacent to this property, and the East Boulder Gun barrel Trail system goes through it. These are popular equestrian areas in a system where equestrian suitability is becoming harder and harder to find. We appreciate being able to go off-trail in the Gunbarrel Hill area, and we believe our historic use of this area has created no inappropriate impacts (e.g. social trails, weeds, or ground-nesting birds). All of the resources there, and all of the uses there, were examined in great detail in 2005 during the VMP, and nothing has PO Box 19601 Boulder, Colorado 80308-2601 web site: www.bou{derhorse.org 36 changed. We were satisfied with the PRA designation. Now the GEMP comes along and insists that the area needs to be reclassified as a Natural Area and managed for ground- nesting birds and prairie grass (p99). We disagree Qust as we disagreed with the post-VMP change of Springbrook Mesa from Natural Area back to de-facto HCA}. We believe it is inappropriate for a research project like the GEMP to attempt to trump the hard-won VMP. 2} The GEMP is incorrect in citing horses as being vectors for weeds {p74}. We have conducted extensive research of the literature, interviewed other public land managers, and contribute our own anecdotal experience to this very important issue. Responsible equestrians hate weeds as much as land managers do, and we object to being singled out as a vector when the overwhelming preponderance of the evidence worldwide is that horses are simply no more responsible for the spread of weeds than any number of other vectors, including wildlife, wind, water, vibram soles, bicycle tires, and ranger trucks. We are attaching herewith a copy of the position paper BCHA adopted in May 2008 in support of our assertion that "Horses Should Not Be Singled Out in the Battle Against Noxious Weeds." 3} The GEMP should not be used as a management tool for making recommendations about trails and public access that should be made instead during the various Trail Study Area processes. The Grassland study should be only what we all were led to believe it was going to be as detailed in the December 27, 2007 memorandum to the OSBT: a research compendium of data about various natural resources found in the plains of Boulder County. That memorandum contained no hint of any sweeping recommendations to close 50% of all trails within a 200 meter buffer of riparian and wetland areas, no recommendations to close 45% of all prairie grasslands for ground nesting birds (this entire subject seems to have inserted itself into the plan since last year}, no recommendations to manage prairie dogs (that was what the 1996 Prairie Dog Habitat Conservation Plan was supposed to do}, etc. 4} The GEMP is inconsistent, unclear and arbitrary about the actual recommendations it does make. For example, the document clearly carries the recommendation to close half of all the "best" visitor quality trails in the entire system because of unsupported riparian or wetland concerns (including South Boulder Creek, Dry Creek, Doudy Draw, Teller FarmlEast Boulder, Boulder Reservoir, Coot Lake, and many others, p96), yet upon discussion with its author, it appears that he feels the goal can be accomplished by "closing all undesignated trails instead, just as it says in the VMP." We note that the VMP does NOT indicate that "all" undesignated trails must be closed in Natural or Passive Recreation Areas, which are in fact most of the GEMP areas as well. When asked about the rationale behind the 50% trail closure number, the author merely said that "asking for 100% would be perceived as unreasonable" yet he had no basis for the 50% or any other number. PO Box 19601 Boulder, Colorado 80308-2601 web site: www.boulderhorse.org 37 5} The GEMP contains new and unacceptable definitions of resources that seem unnecessarily controversial. For example, in order to protect as much of the OSMP domain as possible under the rubric of the GEMP, the author has included "wet meadows" in the "wetland" classification. Yet most wet meadows are merely formerly irrigated hayfields. We acknowledge that some of them may have some characteristics of natural wetlands, but to pretend that they are all pristine undisturbed habitat is disingenuous at best, and at worst will prevent many desirable visitor experiences from occurring on OSMP. 6) The GEMP takes an unnecessarily hard-line approach to recommendations about habitat blocks. Particularly troublesome is the recommendation that new trail development should be severely limited in grasslands areas (p97}, and that any new trails should be built only on the periphery of habitat blocks. We submit that utilizing existing cultural features such as the old railroad grade on West Beech, or the old ranch roads and bridges on the South Dry Creek alignment, will result in safe, high-quality visitor experiences while minimizing environmental impacts. Each of these trail proposals should be evaluated on its own merits under the TSA process, rather than being "trumped" by the GEMP. Trails that were approved under earlier TSAs (such as the Marshall Reservoir trail) should move forward regardless of the GEMP. 7) The GEMP is unnecessarily pessimistic in its outlook, which makes it an unbalanced document. For example, it perceives trails only as "very high threats" to grasslands (p72-73}, and nowhere even mentions that trails could have inherent educational benefits and "very high quality visitor experiences" as well. Similarly, although the plan includes agricultural properties, only passing mention is made of them. These farmlands and ranchlands could very well host a variety of trails that would educate the public about our common but vanishing agricultural heritage, while also providing quality recreational opportunities. For all of the above reasons, BCHA recommends that the GEMP be edited and restricted so that it fulfills only its original purpose: a resource inventory of OSMP properties from the first foothill to the Weld County line, to be used to inform the various TSA processes in those areas. Sincerely, Suzanne Webel BCHA External Vice President GEMPRECSI.BCH PO Box 19601 Boulder, Colorado 80308-2601 web site: www.boulderhorse.org 38 TRAIL HORSES SHOULD NOT BE SIN(9LED OUT IN THE BATTLE AGAINST NOXIOUS 1lVEED3 A Position Paper of the Boulder County Horse Association May 2008 Abstract Horses have long been the quintessential icon of the diverse American traditions of fanning, ranching, mining, exploration, settlement, hunting, outdoor recreation, and nature appreciation on public lands. Of the approximately 6.9 million horses in the United States, about a third (2.9 million) are used as recreationa[ trail companions and a means of transportation into front country and backcountry settings (American Horse Council, 2001). About 145,000 horses call Colorado home, and approximately 57,000 of those horses are considered to be recreational trail horses, including pack stock (Colorado Horse Development Authority, 1999; AHC, 2001). In Colorado alone, recreational trail horses provide a $500 million economic benefit and support 5,200 full-time jobs -the state's larges# equine-related category (AHC, 2001). In recent years regulatory pressures have increased on all forms of recreation, from municipal parks to National Parks. Although statewide the number of acres in the public domain has increased, and trail mileage has increased somewhat, neither has increased as fast as the population; meanwhile, maintenance budgets have been shrinking. These imbalances have created tensions among trail user groups, environmentalists, and public land managers, as each constituency fights for its share of what it sees as a shrinking pie. Equestrians have come under more than their share of scrutiny, specifically over a generalized anxiety about whether horses spread noxious weeds on trails and public lands. The Colorado Horse Council, Back Country Horsemen of America, Boulder County Horse Association, and others have conducted extensive research into the available literature on this subject, and have discussed the issue directly with researchers in the field and with agency personnel. We also contribute considerable personal experience representing thousands of trail miles ridden. Jt is our professional belief That horses are not significant vectors in the spread of noxious weeds ornon-native vegetation. We support best management practices to control the spread of weeds of all kinds, and we outline some of these principles in this paper. 39 i~~ Introduction Noxious weeds and other invasive plants are causing widespread damage to ecosystems throughout North America. In 2002 alone, more than 196,241 acres were considered lost to knapweed in Colorado. This silent invasion reduced native habitat for myriad flora and fauna, diminished the quality of grazing land for livestock, and caused more than $10 million in lost production (Beck, 2008). It will take many years, significant willpower and manpower, and extensive financial resources to restore this land to its pre-infestation state (if indeed that is ever to be possible). Cheatgrass (Bromus tectorum) dramatically increases the frequency of fire in sagebrush-dominated shrublands from a historic interval of 60-110 years to less than five years recently, and native plants are often unable to recover from such frequent fires (Whisenant, 1990). Colorado maintains a list of 72 noxious weeds divided into three categories. List A species are designated by the Commissioner for eradication; List B species have a state noxious weed management plan developed to stop their spread; List C weeds will receive some resources to jurisdicfions that choose to manage these species (Colorado Dept. of Agriculture, 2008}. Additional considerations, beyond the scope of this position paper, include native vs. non-native species, invasive vs. non- invasive species, and the widespread cultivation and use of livestock forage, which in tum may or may not be classified as invasive, native, etc. Public lands in Colorado have traditionally been managed for a variety of purposes. Most public land management agencies try to implement a set of best management practices to control the spread of noxious weeds while continuing to support a reasonable balance of other uses, such as recreation and agriculture. Known vectors for the spread of noxious weed seeds include wind, water, truck tires, boats, birds, wildlife fur and that of other mammals such as dogs and cats, hiking boot soles, mountain bike treads, and the intestines of many animals such as elk, deer, and cattle. Horses are often implicated in the latter category, but Eric Lane, former Golorado State Weed Coordinator, asserts that horses are no more to blame for weeds than any of the aforementioned known vectors (1998, pers. comm. Cindy Lair, Program Manager with the Colorado Department of Agriculture State Conservation Board, agrees, saying that "Horses are not important weed carriers. Public land management agencies need comprehensive plans for weed management, but singling out horses for trail and access restrictions out of concerns about weeds is inappropriate" (2008, pers. comm.). The research discussed below specifically evaluates horses and their effectiveness, or lack thereof, at spreading weeds. While there is no doubt that some vegetation does germinate from horse manure, the preponderance of evidence from documented, controlled studies in the field and in the laboratory support the assertion that horses have a minimal role in the spread of weeds and exotic species for a variety of reasons. 40 The Claims As~ainst Horses Fear: Some researchers claim that horses are responsible for spreading weeds via their digestive systiems. St.John Sweefing and Moms (1990) found that when horses were fed a mixture of weedy seeds in Australia, many species were able to pass through horses with little or no loss inviability. Campbell and Gibson (2001) found in Illinois that the overall density of exotic species was greater on trails that allowed horses than on those that did not; also, 44°1° of the species found in horse manure were aliens, and only one of those species was present in the surrounding vegetation. Janzen (2001) found that non-native seeds can be passed through a horse's digestive system, but no attempt was made to determine 'rf the seeds were viable. Wells (2006) collected manure from which she claimed three "state-Listed" species germinated: cheatgrass, shepherds purse, and yellow foxtail. A recent study by Wells and Lauenroth {2007) collected manure found along a single trail on Colorado's Western Slope, from a few animals that had been trailered in from other locations, and found that 10 native anti 10 alien species germinated from 12 samples, with aliens comprising 85% of the seedlings that emerged. These studies are being used to justify banning horses because of a concern that equine-borne weeds might become establ"shed along trails. Fear: Other researchers claim that horses are responsible for spreading weeds because they create physical disturbances to soil that make conditions favorable for germination. Landsberg et al (2001) suggested the likelihood of weed invasion from horse traffic through disturbance of the soil. Cole and Spildie (1998) found that horses destroyed more vegetation than hikers or llamas on experimental tracks through existing vegetation. These studies are being used to justify banning horses from trails because the disturbed ground might provide a hospitable seed bed for weeds to become established. But Here is The Rest of the Storv Fact: Most horses will not eat weedy hay or live weeds if they are given the opportunity to graze on good quality pastures or hay (Boulder County Horse Assoc., 2008). Many noxious weeds are toxic to horses, and many other undesirable weeds are unpalatable, and most will be avoided unless the horse is starving. Most horses in a starved condition are not taken out on trails for recreational purposes. Fact: Most of the studies that recovered viable seeds from horse manure or that germinated seedlings from horse manure found that noxious or invasive species were not present. Of the 654 seedlings painstakingly nourished by Wells and Laurenroth {200, not a single plant belonged to any of the Class A or B species listed as unoxious" by the State of Colorado, and only one, cheatgrass, is found on the Class C List (12 were grasses, sedges, and rushes, six were forbs, and one was a tree). No attempt was made to determine what the horses had eaten before starting the ride. The only other research in Colorado that found any state- listed species was that of Wells {2006), which is inconsistent because a search of all the listed weeds in Colorado in 2008 revealed that only cheatgrass is included). 41 - Fact: Most of the plant species characterized in these studies as non-native, exotic, or alien, are actually ubiquitous and are often valued as forage species. In the Wells and Lauenroth study (2007), Kentucky bluegrass (1°oa pratensis) was found in 9 of the 12 samples and contributed 59% of the seedlings. But Kentucky bluegrass is a perennial, non-invasive, cool-season, sod-forming grass which is used throughout the United States for golf courses, lawns, pastures, and erosion control. In the Campbell and Gibson study (2001}, white clover (Trifoiiurn repens) and lespedeza (Kumrnererowia sfriafa) were also listed as exotic species. But white clover is an herbaceous perennial legume valued as a forage crop for American livestock, and lespedeza is widely used as a stabilization cover crop in many parts of the United States {Guinn et al, 200$). 'these common plants are not found on any state's noxious or controlled weed lists. Fact: Most seeds found in horse manure are not viable. Janzen (1987) and Cash, Barney and Gagnon {2006) found that the mastication and digestion of viable weed seed by the equine digestive system reduced seed viability by 98%. In the latter study, the researchers actually dosed horses with known quantities of weed seeds, including leafy spurge and spotted knapweed, and report that "total passage of viable weed seeds through 72 hours ranged from 0 to 2%." Equine physiology may play a role in decreasing the ability of seeds to remain viable. Seeds must be sufficiently small and tough to get past the large strong molars of the horse, and those that do must still survive the acids and enzymes of the horse's gut. Evidently some do, but most do not. Fact: Most viable non-native seeds that are f®und In h®rse rraanure fail #o mature. Wells and Lauenroth {2007) spread their manure samples over a layer of sterile potting soil in a greenhouse, watered them daily and fertilized them with Miracle Gro every 2 to 3 weeks hardly the typical fate of similar manure samples deposited out in the field. Campbell and Gibson (2041) found that 23 non-native species germinated in their greenhouse but only 3 non-naive species germinated from fecal samples in the field. And Gower {2006) conducted a recent study in the eastern United States which investigated the ability of seeds recovered from horse manure to germinate along the trail where deposition ac#uaily occurred; only 1 % of the 288 hay, manure, and hoof debris plots established on horse trails at five sites in five states contained any live plants at the end of the first growing season. Fact: Most horse trails do not exhibit any more non-native vegetation than do krails that are closed to horses. Cole and Hall (1992} found that the change in exotic species cover at campsites used by backpackers and horsemen over anine- yearperiod in the Bob Marshall Wilderness of lulontana was "virtually identical." Another study in a Montana wilderness displayed no difference in the quantity of spotted knapweed (Ce~taurea maculosa) between backpacker and equestrian campgrounds (Marcus et al, 1998}. Similarly, Soehn (2001) found no difference between horse-use and hiker-only sites in Great Smoky Mountains National Park. Gower {2006) found that non-native species composition and percent of total plant species did not differ between horse and hiker trails in the eastem US. 42 f Fact: Many studies, including one in Rocky Mountain National Park, have demonstrated that while non-native species may occur near trails, they exist only in much lower numbers away from the trail and do not pose a threat to the ecosystem as a whole (Weaver and Adams, 1996; Benninger-Truax et al, 1992; Gower, 200fi)_ Not all of these studies focused on equestrian trails, but the pattern was consistent regardless of trail-use types (Quinn et al, 2008). Fact: Most established trails are probably not further disturbed as a unique result of horse travel (Weaver and Adams, 1996; Landsberg et al, 2001). Other than equestrian trail users, disturbances to wildlands which render the soil more hospitable to weeds include fires, diversion of natural water sources, road and trail building, vehicles, logging, hikers, in#ensive grazing, and vegetation trampling {see summary in Quinn et al, 2008). Fact: Most large herbivores carry seeds inside them, not outside in their hair coats (Janzen, 1984). Trail horses' coats are rarely shaggy and their lower legs are usually short-haired and smooth, making it unlikely that weed seeds would adhere to them. Grooming the horse before and after riding takes care of any stray plant matter. Conclusions Some of the studies referenced above conclude with startling exhortations to trail managers, for example, to "be very aware of the potential for riding and pack stock to transport alien plant seeds for long distances along recreational trails" (Wells and Lauenroth, 2007). Advice like that has prompted some land managers to suggest that horses be banned from extensive trail systems, that they be quarantined for several days before going on public lands, or that they be required to wear "diapers" merely because of this passibility. Vl/e submit that those are draconian steps, attempts to solve a problem that simply does not exist. We fully accept the importance of contemporary ecosystem management to ensure the health of naive plants and animals, and weed management is a vital part of that process. We acknowledge that in some locations under certain conditions, equine- bome vegetation can become established along trails on public lands. However, the overwhelming body of scientfic research, coupled with expert opinions and anecdotal evidence, indicates that horses are an insignificant vector, and only one of many, in the spread of weeds and other non-native plants. Barry Reiswig, retired Director of the National Elk Refuge in Jackson, WY and a 31-year veteran manager with the US Fish & Wildlife Service at other National Wildlife Refuges, states uncategoricaliy that "Most weeds are spread by vehicles. Horses in my experience are not a major source of weeds in the back country. Many wild animals such as deer, elk, bison etc also spread weed seeds. If anyone thinks they can control weeds by simply banning stock, they are sadly mistaken" (pers. comm., 2008). 43 Dr. Gene Wood, Professor of Forest Wildlife Ecology and Extension Trails Specialist at Clemson University, concludes that "the scientific evidence fails to demonstrate that recreational trail stock signficantfy contribute to the invasives problem at the landscape level Furthermore... it is very difficult to even imagine recreational trail stock as a significant contributor to the problem when considered in the context of all other well known pathways and vectors° (Wood, 2006). Finally, recreational trail horses comprise a tiny fraction of total trail users. For example, in April of 2006, 73,816 recreational users visited Rocky 1Vlountain National Park, 224 of which were °either° snowmobiles or horses. Similarly, 25,911 recreationists visited Redwood National and State Parks in California, of which only 496 were day-use horseback riders {NPS Public Use Statistics Office Website, 2006). Boulder County Parks & Open Space regularly reports that about 2% of its annual visitors are equestrians (BCPOS website, 2008). The number of horses out on the traits nationwide is statistically small compared to other visitors, and carries a similarly small potential for impacts. In spite of our relative{y small demographics, trail use and equestrian access to public lands is extremely important to the horse people who choose that form of recreation. We recommend that equestrians and public land managers alike adhere to the following set of best management practices to reduce the spread of weeds on public lands: 1) Ahnrays feed horses the best quality forage available. 2) Use certified weed-free hay or processed feed when planning to ride on public lands. 3) Carry on#y certified weed-free hay to trailheads or horse camp sites. 4) Clean up and remove manure and spilled hay at trailheads and campgrounds. 5) Educate constituents to identify noxious weeds. 6) Control weeds in and around horse corrals, pastures, and fences. 7) Adopt a trail and conduct frequent weed-pulls along it. 8) Groom horses and pick out their feet be#ore bringing them to the trailhead in order to remove any hitchhiking seeds from their coats and hooves. "The bottom line is that horse trails can be maintained on most natural areas without unacceptably impacting ecological values° (Williams and Conway-Durver, 1998). If these guidelines are followed, land managers will be able to avoid draconian measures with regard to restricting equestrian use, and horse people will be able to continue enjoying the many diverse forms of public land that have been open to them for centuries, for many more years to come. 44 References American Horse Council, 2001. Horse Indus#ry Statistics. www.americanhorsecouncil.ora. Beck, K. George, 2008. Colorado Noxious Weeds, www.ext.colostate.edu/pubs/nacres/03110. htm I Benninger-Truax, M., J. L. Vankat, and R.L. Schaefer, 1992. Trail corridors as habitat and conduits for movement of plant species in Rocky Mountain National Park, Colorado. Landscape Ecology 6(4~: 2fi9-278. Boulder County Horse Association, Colorado Department of Agricul#ure, 2008. Colorado's Poisonous Menace: Do You Know What Your Horse is Eating? Plus Pasture Management 101. Boulder, CO, 16p. www.boulderhorse.orQ. Boulder County Parks & Open Space, 2008. w~vw.bouldercountyapenspace.org. Campbell J.E. and D.J. Gibson, 2001. The effect of seeds of exotic species transported via horse dung on vegetation along trail corridors. Plant Ecology 157:23-35. Cash, Dennis, Lance Barney, and Sandy Gagnon, 2006. Can horses spread weeds? http://www.animalrangeextension.montana.edularticlesfforage/Fall/horses- weeds.htm Cole, D.N. and T.E. Hall, 1992. Trends in campsite condition: Eagle Cap Wilderness, Bob Marshall Wilderness, and Grand Canyon National Park. USDA Forest Service, Intermountain forest and Range Experiment Station. Research Paper INT-453, 41 pp. Cole, D.N. and D.R. Spiidie, 1998. Hiker, horse and (lama #rampiing effects on native vegetation in Montana, USA. Journal of Environmental Management 53:61- 71. Colorado Horse Development Authority, 1999. Colorado Horse Power: a brief look at the numbers and economic impact of Colorado's horse industry on Colorado's economy. Co-sponsored by Colorado State University Cooperative Extension and Colorado Horsemen's Council, USDA National Agricultural Statistics Service. Denver, CO, 14pp. Colorado Department of Agriculture, 2008. State Noxious Weed List. www.colorado.gov Gower, Stith T., 2006. Are horses responsible for introducing non-native plants along trails in the eastern United States? A final report to the American Endurance 45 Riders Conference. Dept. of Forest Ecology and Management, University of Wisconsin, http://forestecology.forest.wisc.edu. Hall, C.N. and F.R. Kuss, 1989. Vegetation alteration along trails in Shenandoah National Park, Virginia. Biological Conservation 48:211-227. Janzen,D., 1981. Enterolobium Cyclocarpum Seed Passage Rate and Survival in Horses, Costa Rican Pleistocene Seed Dispersal Agents." Ecology 62(3), pp.593- 601. Janzen, D., 1984. Seed dispersal of small seeds by big herbivores: foliage is the fruit." The American Naturalist, v1223,pp338-353. Landsberg, Jill, Bill Logan and David Shorthouse, 2001. Horse riding in urban conservation areas: Reviewing scientific evidence to guide management. Ecological Management & Restoration 2 (1), 36-46. Marcus, W.A. et a1.,1998. Spotted knapweed distribution in stock camps and trails of the Seiway-Bitterroot Wilderness. Great Basin Naturalist. 58, 156-166. National Park Service Public Use Statistics Office Website, www.nature.nps.gov/scats/viewReport.cfm, 2006 Quinn, Adda, 2008. Various references, EnviroHorse, www.californiastatehorsemen/enviro/index. html Quinn, Lauren D., Bonnie Davis, Mietek Kolipinski, Sibdas Ghosh, Connie Berto, and Adda Quinn, 2008 in prep. The role of horses as potential vectors of invasive plant spread: a literature review. Dominican University of California, San Rafael, CA. Quinn, Lauren D., Mietek Kolipinski, Vania R. Coelho, Bonnie Davis, John-Mary Vianney, Orgiltuya Batjargal, Monika Alas, and Sibdas Ghosh, 2008 in press. Germination of invasive plant seeds after digestion by horses in California. Natural Areas Journal. Soehn, D.A. and K.D. Johnson, 2001. Exotic plant species at backcountry horse camp si#es in Great Smoky Mountains National Park, 28~' Ann. Nat. Areas Assoc. Conf. 3-6 Oct. 2001. Cape Canaveral, FL. St. John Sweeting, R.S., and K.A. Moms, 1990. Seed transmission through the digestive tract of the horse. Proceedings of the 9th Australian Weeds Conference; 6- 10August 1009. Adelaide, Australia: Weed Management Society of Australia, Inc. p; 137-139. 46 Weaver, V. and R. Adams, 1996. Horses as vectors in the dispersal of weeds into native vegetation. In: R.C. H. Shepherd (Ed.), eleventh Australian Weeds Conference Weed Science Society of Victoria, Melbourne, Australia, pp. 383-387. Wells, Floye H., 2005. Alien plants on recreational trails in the Colorado Rocky Mountains [thesis]. Fort CoAins, CO: Colorado State University. 80p. Wells, Fioye H. and William K. Lauenroth, 2007. The Poten#ial for Horses to Disperse Alien Plants Along Recreational Trails. Rangeland Ecology & Management 60(6), pp 574-577. Whisenant, Steven G., 1990. Changing fire frequencies on Idaho's Snake River Plains: ecological and management implications. in McArthur, E. Durant; Romney, Evan M.; Smith, Stanley D.; Tueller Paul T., compilers. Proceedings -symposium on cheatgrass invasion, shrub die-off, and other aspec#s of shrub biology and management; Gen. Tech. Rep. INT-276. Ogden, UT: US Department of Agriculture, Forest Service, Intem~aun#ain Research Station, 4-10. Williams, Buzz, and Linda Conway-Durver, 1998. Horses in Ecological Reserves. National Trails Training Partnership, www.americantrails.orglwildlife/wildEQclemson. html. Wood, Gene W., 2006. The role of recreational trail horse use in the introduction and spread of invasive species. Equestrian Land Conservation Resource, Clemson University, www.elcr.org. prepared by Suzanne Webel External Vice President, Traits & Public Lands Chair Boulder County Horse Association PO Box 19601 Boulder, CO 80308-2601 WEEDPOSPAPER1 FINBCHA.doc 47 Draft Grassland 1Vlanagement Plan Comments from Boulder County Audubon Society What we like most about this plan is that it's comprehensive, based on a thorough and sound resource inventory, and sets goals that can be carried out and monitored. Overall, we believe it is very well thought out and reflects a tremendous amount of staff expertise and work. Thank you so much for your efforts. One significant weakness in the plan is its failure to deal directly with the issue of reestablishing extirpated species. Within each target section, there should be a list of extirpated species with a discussion of the opportunities and barriers for reestablishing each species. "It's not possible" should not be an excuse for not addressing opportunities and barriers. We believe that if this discussion and analysis is not included, then we will miss out on golden opportunities to recover populations of some extirpated vertebrate species, including pronghorn, sharp-tailed grouse, mountain plover, and long-billed curlew. We will also miss out on key elements that need to be addressed to create a more natural and sustainable prairie mosaic. A second potential weakness is the failure to set landscape-level goals for desirable riparian woodlands. Our current riparian wetlands are overcrowded with deciduous trees, facilitating invasion of Boulder County by non-native woodland species, including fox squirrel, opossum, blue jay, and many others; and, discouraging establishment of riparian tallgrass prairies and wet meadows which could serve as habitat for native species. We would like to see an analysis of the pre-European structure of riparian communities and what can be done (using fire, grazing, and other management tools} to restore that dynamic mosaic. We support staffs recommendation to reduce trail mileage within close proximity of wetlands and riparian woodlands. However, to promote clarity, we encourage you to specify how much of the proposed 50% reduction would consist of social trails as opposed to designated trails. We are not quite clear about how OSMP's annual progress in meeting the goals established in the plan will be communicated to stakeholders and the general public. Are we looking at 10 year, 20 year, or periodic updates? How will stakeholders be kept informed of alterations in the plan? Finally, this plan proposes a tremendous amount of monitoring work. Boulder County Audubon and Boulder County Nature Association, as always, are willing to help coordinate monitoring efforts with staff and to help recruit and train volunteers. Specific Comments: Page 22: Don't forget to mention mountain plover as a prairie dog colony associated species. This is one extirpated species that can be reintroduced into our grasslands, and that should be mentioned. Also, pronghorn and sharp-tailed grouse would not be associated with prairie dog colonies. 48 Page 26, second paragraph: Two locally rare and declining birds, American bittern and northern harrier, also nest in wetlands on Boulder OSMP properties (Hallock and Jones 1999). Page 28: Riparian woodlands also support nesting long-eared owls, considered rare and declining in Boulder County (Hallock and Jones 1999). Page 31: The White Rocks cliffs were considered one of the few natural nesting locations for barn owls in Boulder County, not Colorado. We've known of barn owl nesting sites on cliffs in southeastern Colorado for several decades. Page 44: Figure 11 shows the opportunity to create a large block of grasslands (10,400 acres) among Boulder ~SMP lands, Boulder Parks and Open Space lands, and Rocky Flats National Wildlife Area. What steps have been taken or will be taken to ensure that "compatible management" occurs among the three agencies? Page 53: When discussing burrowing owl nesting success in prairie dog colonies, you referenced a 1993 report by Steve Jones. To make this more curY•ent, you might want to reference the 2003 booklet: Jones, Stephen, and Linda Mahoney. 2003. Owls of Boulder County. Boulder County Nature Association. You might also want to specify that an apparent cause of the decline is "habitat fragmentation leading to increased mortality of young owls." Boulder County burrowing owl nests have low fledge rates compared to documented High Plains averages. Page 54: We knov~~ of no documentation showing that rough-legged hawks prey on prairie dogs. They have small talons and specialize on small rodents, such as voles. They hunt predominantly in wetlands and moist grasslands. They are certainly not "prairie dog specialists." Prairie falcons do prey on prairie dogs (young ones, we've actually witnessed a couple of captures). Page 61, top two lines: "Species such as New Zealand mud snail." (Always singular when you name individual species) Pages 62-3: What we didn't see in the section is direct reference to one of the biggest problems with our riparian woodlands: too many trees, many of the non-native willows, paralleling streams and providing range-extension routes for species of eastern deciduous woodlands such as white-tailed deer and blue jay. Here, it would be useful to go back into the past and attempt to reconstruct the nature and structure of historic riparian woodlands under a more natural fire and grazing regime. Then you could set a target that creates large treeless spaces between cottonwood groves along prairie streams. An example of a target would be: less than 30% of linear streambank on the plains is shaded by deciduous trees. 49 White Rocks: Nesting rock wrens might be another good indicator of habitat health. The presence or absence of barn owls probably reflects more on the vigor of local great horned owls than on the quality of the nesting and foraging habitat. Pages 65-&9: You rate the burrowing owl populations as "good" based on a single year of relative nesting success (2048). There were no successful burrowing owl nests observed on city open space during 2006 and 2007, so a rating above "fair" is not justified. Page 75: Here, again, you might explain how severely riparian woodlands have been affected by absence of fire and flooding--turning isolated stands of cottonwoods into unnatural gallery forests. Page 77: Great horned owls prey on and displace long-eared owls and they prey on burrowing owls (both rare and declining in Boulder County). Otherwise, this is a well thought out list of threats, quite comprehensive. Page 91: Again, historic (or natural) grove structure, density and species composition should be included as an important criterion for assessing quality of riparian habitats. Page 96: 15. "Reestablish at least two of the three known extirpated grassland bird species by 2028." If you don't state this specifically, and you don't list your specific plan for recovering each extirpated vertebrate species (you should include specific discussions of all of them, including ones, such as ferret and grizzly bear, that you are sure cannot be recovered), then you will never get it done--and your grassland plan will be ignoring important components of intact ecosystems. Page 97: Number 6 strikes us as a bad idea. Artificial perches are used by great horned owls and prairie falcons to hunt burrowing owls. In fact, this may be a principal cause of low nest productivity in Boulder County. If you look at areas where burrowing owls have nested recently in Boulder County, you'll be hard put to find a nesting site that doesn't have telephone poles or trees cunning through or along the periphery of the prairie dog colony. Page 98: We're confused by number 16. If these are "transition" or "removal" areas, why would you want to import prairie dogs into them? Page 99: 36: Again, we disagree. There are way too many cottonwoods as it now stands. Page 100: Let's add a number 44: "Cooperate with Boulder Parks and Recreation to determine strategies for increasing nesting success of Northern Harriers (Boulder County rare and declining) west of Boulder Reservoir." And a number 45: "Cooperate with the Colorado Division of Wildlife and Boulder County Parks and Open Space to investigate feasibility of reintroducing pronghorn, sharp-tailed grouse, mountain plovers, and long-billed curlews to Boulder open space." 50 Number 46: "Institute along-term study of burrowing owl nest site selection and nesting success with the goal of determining landscape and other factors (including size of prairie dog colonies, proximity of raptor perches, proximity of roads and trails, and surrounding land uses) that contribute to nest failure or success." Page 108: Action 6 (artificial raptor perches). This initiative is very unappealing to this particular stakeholder and should be scrapped. Nesting platforms for ferruginous hawks, specifically, might be a good idea. Page 109, action 16: again, this one makes no sense to us. Page 114, action 33 (moving trails out of riparian corridors). We enthusiastically support this initiative, as we have for several decades. Literature Cited Hallock, Dave, and Stephen Jones. 1999. Boulder County avian species of special concern. Boulder County Nature Association: www.BCNA.org 51 Parks and {open Space Department i • • Administrative Office: 5201 St. Vrain Road • Longmont, Colorado 80503 • Tel: (303) 678-6200 • Fax: (303) 678-6180 Fairgrounds: Affolter House• 9595 Nelson Road • Longmont, Colorado 80501 Tel: (303) 678-6235 • Fax: (303) 678-6322 MEMORANDUM To: 1Vlark Gershman, Environmental Planner From: Larissa Read, Natural Resource Planner Date: December 3, 2448 Re: Comments on OSMP Grassland Ecosystem Management Plan Thank you for the opportunity to comment on the City of Boulder Open Space and Mountain Parks Grassland Ecosystem Management Plan (Grassland Plan). Several Boulder County Parks and Open Space staff reviewed the document and attended your November 24, 2448 open house. These staff members included planners, a wildlife specialist, a plant ecologist, and a weed specialist. In addition, I participated in some of the early interagency scoping meetings for this Grassland Plan. We greatly appreciate these invitations to become involved as a collaborative land manager in the Boulder County region. We have the following comments to share with you regarding the Grassland Plan, which we have grouped by general topic area. 1. We are very supportive of the overall conservation-based approach to grassland management that is the focus of this plan. We believe this approach suits OSh•ZP's vision for their properties, and provides a clear focus for the priorities of the department and the City. We applaud OSMP for taking a strong stance for conservation of these unique and important grassland resources. We also support the concept of protected corridors along riparian areas and wetlands, especially where social trailing has degraded ecosystem values and functions. In addition, we believe your plans for weed management are thorough and will provide solid management on your properties. We also congratulate OSMP for planning to place a considerable effort on monitoring of these resources in the future. As a fellow land management agency, we understand how difficult it is to uphold commitments to monitoring, and we support OSIUIP in their efforts to do so. We also applaud OSMP for engaging a wide array of stakeholders and partner agencies throughout the planning process. 2. Although we are supportive of the conservation-based approach to this plan, we have some concerns about the hierarchy and interaction between the Grassland Plan and other OSMP plans including the Visitor Master Plan, the various Trail Study Area plans, and the City's prairie dog management policies. We suggest that clarification of this issue be a priority in future revisions of the draft. We believe such clarification will aid other land management agencies in understanding and partnering towards OSI~IP's goals. It will also remedy some of the concerns Cindy Domenico Ben Pearlman Will Toor County Commissioner County Commissioner County Commissioner 52 that the public has about how the Grassland Plan implementation relates to other OSMP directives. We understand the reasoning by which OSMP chose an approach similar to that of The Nature Conservancy; however, we have some concerns that it does not fully incorporate the human dynamics that are important aspects of management and use of OSIVIP grasslands. We suggest that the document be embellished with references to the other plans, especially those that deal with human use, and how they will inter-relate. 3. We understand that the intent of the Grassland Plan process was to develop a detailed, conservation-based approach to grasslands under OSMP management. However, we are concerned that the plan is in some regards too detailed, and in others, not detailed enough. For example, Chapter V contains information on Conservation Objectives (Table 25) and Conservation Strategic Actions (Table 26), which are all highly detailed. In addition, four Initiatives were developed, with several more Conservation Objectives and Strategic Actions for each. This detail is not matched v~~ith basic details on costs, schedule, and information about who will carry out these items. We are concerned that Chapter V lays out an overly ambitious set of actions and initiatives that will be difficult for OSIVIP to successfully meet. We understand the value in setting high goals as a land management agency, but we suggest that Chapter V provides too much detail on strategic actions without much detail on how it will be accomplished. 4. We are concerned that overall grassland conservation efforts will be compromised without proper enforcement of OSMP dog regulations, especially dogs under voice and sight control. We have all experienced or heard reference to numerous situations where dogs are not under control on OSMP grassland properties. In addition, both leashed and unleashed dogs are seen in grassland areas where they are prohibited. V4~e are all aware of the effects of dogs on ecosystem and wildlife values in grasslands. This becomes a greater concern to us on OSMP properties that abut Parks and Open Space properties, where dogs are required to be on-leash at all times. We suggest that a commitment be made by OSMP and the City to better enforce its dog regulations in order to support the conservation efforts so carefully laid out in the Grassland Plan. 5. We are appreciative of OSMP's efforts towards collaboration with us and other land management agencies towards protection of grassland resources on the Front Range. In particular, it is important that we continue communication on management decisions that affect our jointly owned properties. In addition, we request that OSMP consider the impacts of its management decisions on adjacent or nearby Parks and Open Space properties. We mention one topic above, that of dog control on grassland properties near ours. We also point to examples such as infestations of Eurasian watermilfoil and garlic mustard, where better control by OSMP might have mitigated infestation on our properties. We understand that the City has more limited weed control options than Parks and Open Space. Because weed management is of great concern to the public and partner agencies, we encourage and support OSMP in seeking a broader range of management alternatives for weed control. We also suggest that you state in the Grassland Plan the species or species lists that you intend to monitor or control, and clearly reference your own weed management policies. If you would like to discuss these comments, please contact me at 343-678-6273 or lread@bouldercounty.org. We will continue to support OSIVIP as it moves this Grassland Plan through its public and approval processes. We look forward to continuing our collaboration for management of these important grassland ecosystems. 53 • Page 2 . To: City of Boulder Open Space~X; Mountain Parks From: Board of Directors Boulder Mountainbike Alliance Subject: Comments on Grasslands Management Plan The Boulder Mountainbike Alliance (BMA} is extremely disappointed by the Grasslands Ecosystem Management Plan (GEMP). While the GEMP provides an excellent resource inventory of our grasslands, it takes the unfortunate step of recommending management actions based solely on maximizing environmental preservation. The GEMP authors seem to have forgotten about the VMP key policy to "Use the least restrictive means possible to reduce visitor conflict and minimize impacts on the environment." This is untenable on two counts: 1) Section 176 of the Charter and the Visitor Master Plan (VMP) clearly indicate that Boulder's open space lands serve multiple community values, including both environmental preservation and passive recreation, and 2) The GEMP did not survey, discuss, or explore the recreational values of our grasslands, so it has no basis upon which to assess possible synergies between recreation and environmental preservation or to make even-handed trade-offs when necessary. You can imagine what a "Grasslands Recrec~ion Management Plan" would look like if it tried to maximize recreation values without appropriate surveys or consideration of the local ecosystems -there might be recommendations to drastically increase the density of trails, cut through habitat blocks, build trails through ground-nesting bird habitat, put more trails close to riparian areas, and so forth. BNIA does not suggest that such an approach is appropriate, but uses it to illustrate the one-sided and deeply flawed attempt to turn the GEMP into a management plan. Bottom line -the GEMP should be considered a resource inventory to inform management discussions that will occur in the relevant VMP Trail Study Area processes. The management recommendations contained in the GEMP would eliminate some of the most sustainable and high-use trails in the Open Space and Mountain Parks (OSMP) system, such as South Boulder Creek and Dry Creek. These trails are not causing any observable environmental problems and, in fact, provide high value to the citizens of Boulder. Furthermore, the GEMP recommendations would eliminate the possibility of 54 creating critical regional connector trails such as the proposed UPRR rail trail from Erie to Boulder, a trail following the old RR grade through the Beech Open Space to create a connector from the City of Boulder to Heil Valley Ranch, and trail segments to connect the East Boulder Trail with the rest of the OSMP system. These opportunities, and any potential tradeoffs between environmental and recreational values, merits a full discussion with the community. This is what the tl MP Trail Study Area (TSA) processes were designed to do. Consequently, the Boulder Mountainbike Alliance suggests the following: 1) All management recommendations that involve tradeoffs between Charter purposes should be scrubbed from the GEMP. Management of our open spaces should occur through the VMP TSA processes. The GEMP can still provide important management recommendations for invasive weed control, grassland restoration, and other ecosystem objectives - as long as those recommendations do not involve trading off charter purposes. 2} An explicit description should be included within the GEMP that indicates what its purpose is with respect to the VMP. To avoid the appearance of bias, we suggest the GEh~IP should be defined as a resource inventory and management plan that will inform the TSA processes. It seems appropriate to us given the attempt to restrict recreation in this document, that an explicit statement be included that indicates the primacy of the VMP and TS A processes in determining OSMP management direction. As always, BMA appreciates the opportunity to comment and participate in these processes that engage the community. We remain an active supporter of OSMP's efforts to snake our public lands all they can be. Together, we will create a plan in the meeting rooms and an environment on the land that we all can be proud of. 55 To: Open Space and Mountain Parks & Open Space Board of Trustees Re: Grasslands Ecosystem Management Plan, Nov. 2008 Draft for public comment Thank you for the opportunity to provide our feedback on OSMP's Grasslands Ecosystem Management Plan (GEMP). We appreciate the enormous amount of work that Staff has put into this plan over the last two years. The document provides a remarkably detailed catalog of the ecological resources within the City's grasslands areas. However, we are very concerned that the plan is incomplete: it addresses OSMP's habitat and wildlife conservation resources and objectives but does not consider the recreation resources and objectives, or quality of the visitor experience for the grasslands area. As a result, the plan is unbalanced and anti-access. The GEMP far oversteps its mandate in making draconian recommendations regarding recreational access, which should be removed from the plan. Under the Visitor Master Plan, trails and recreation are the purview of the TSA process. We want to be very clear that the GEMP should not be seen as superseding the TSA process, which is the process that City Council passed with community support. The GEMP should represent input to the TSA process, with respect to ecological resources and goals in the grasslands areas. The plan makes three major controversial recommendations with regard to trails and recreation in the grasslands, which we address in detail below. 1. Reduce trails within 200 m of wetlands and riparian zones by 50% in 10 years. This recommendation has the appearance of being anti-trail. There are two possibilities for "reducing" trails near wetlands: close them or relocate them. The plan should be specific about what is being recommended for particular existing trails. We are especially concerned about some of the gems of the OSMP system, such as the South Boulder Creek Trail, Dry Creek Trail, East Boulder Trail, Coot Lake trails, Boulder Reservoir, Left Hand Trail, Sawhill Ponds trails, and others. Also, how does this recommendation impact major future trail connections, such as the Teller Farm to Dry Creek and Dry Creek to South Boulder Creek connections that are included in the Boulder Valley Comprehensive Plan, the Union Pacific RR Boulder-Erie Rail Trail, and the Marshall Reservoir Trail that was approved in the Southern Grasslands TSA? Regardless of whether trails are closed or relocated, this recommendation will reduce visitor access to prairie wetlands by 50% or more at a time when area population and visitor numbers are increasing. This is a stunning effort to take away access to these lush areas that provide a unique visitor experience, without even looking for ways of allowing people and wildlife to coexist. 2. Increase the area of seasonal closures by a factor of six to protect ground-nesting birds. This recommendation is clearly anti-access, and is premature until the full impact on the visitor experience is known. Also, OSMP needs to consider that, while seasonal closures have been generally supported by the public, excessive application of this management tool may reduce public support for and compliance with the regulations. Since GEMP looks only at the conservation goals and resources, these issues are not addressed. 3. Locate new trails in large habitat blocks around the edges of these blocks. This recommendation will certainly result in a lower quality of visitor experience, as the edges of parcels tend to be next to roads or development. People visit open space to get away from cars, development and noise, and an unsafe or poor quality of visitor experience reflects badly on the City's Open Space program. It is impossible to make a balanced assessment of this issue until the current and potential recreational resources have been thoroughly inventoried. The City Charter lists eight unprioritized purposes for the Open Space program, including both conservation and passive recreation. Clearly, the conservation and recreation goals are highly interconnected, and neither can or should be considered separately. Considering only conservation goals, as was done in the current draft of GEMP, can only lead to the conclusion that trails and recreation have a negative impact on reaching those goals. However, without some level of visitor access there will be no support for the program, so clearly both access and 56 conservation are needed. So, for example, the cost/benefits analysis on p. 96 of the plan does not consider the cost of reduced visitor enjoyment of the land, such as reduced support for the program, reduced understanding of and appreciation for wildlife habitat, reduced mental, physical and spiritual well-being of the citizens who paid to preserve this land, etc. Furthermore, we do not agree that visitor access is necessarily a threat to habitat conservation (e.g., p. 72-73, Table 22). There is a big difference between responsible, sustainable use and rampant use. OSMP needs to consider ways to foster the former while discouraging the latter, rather than simply trying to discourage all access. OSMP's grasslands areas, especially east of Broadway, are currently greatly underserved with visitor amenities, relative to the Mountain Parks. For example, at the end of 2007 there were 4.0 miles of designated trail per square mile of land in the Mountain Parks (West TSA), while outside of that area there were just 1.2 miles per square mile (similar to the Indian Peaks Wilderness). This means that residents of the eastern part of Boulder, and in the towns to the east that are abutted by OSMP land, have relatively few nearby opportunities for passive recreation on OSMP land. This imbalance should be rectified with the construction of new sustainable trails in the eastern portion of OSMP -specifically, in the vast grassland area under discussion in the GEMP. The GEMP is both a protection plan and a restoration plan, and these are very different activities. The restoration component is essentially experimental. There is no possibility that the OSMP's grasslands will be restored to their pre-settlement condition, as many species have been permanently extirpated, and conditions have radically changed. In future, climate change will play an increasing role in shaping all ecosystems. Hence, the restoration component of the GEMP is an attempt to engineer the grasslands ecosystems in a way that has unknown consequences. It is obvious that, in order to be successful and sustainable, this experiment in habitat restoration within an urban area needs to include human visitation. In conclusion, this draft of GEMP displays a clear anti-recreation, anti-trail bias which is not consistent with the City Charter or the Visitor Master Plan. As a management plan, this document would be a disaster for the community, leading to even more conflict and acrimony, and a major reduction in support for Open Space. OSMP can fix this problem either by including a detailed inventory of current and potential recreation resources and goals in the GEMP, or by being very clear about the relationship between GEMP and the TSA process. We believe the GEMP should simply inform the TSA process about ecological resources and status within the grasslands area, while all recommendations and decision making should be done within the broader framework of the TSA process, as is consistent with the Visitor Master Plan. Sincerely, Boulder Outdoor Coalition: Boulder Area Trails Coalition (BATCO) Boulder Mountain Bike Alliance (BMA) Flatirons Climbing Council (FCC) Friends Interested in Dogs and Open Space (FIDOS) Boulder Trail Runners (BTR) Boulder County Horse Association (BCHA) 57 Comments on the Grasslands Ecosystem Management Plan December 2, 2008 I have two overriding concerns about the Grasslands Ecosystem Management Plan (GEMP}: a lack of balance in its objectives and implementation strategies and a blindness to unforeseen and undesired consequences. Lack of Balance The Grasslands Ecosystem Management Plan is a reasonable start at studying environmental resources in the grasslands managed by OSMP. However, the GEMP is also a biased attempt to close trails and prevent public access. This lack of balance must be corrected. "The Grassland Plan is intended to provide a framework of on- the-ground management, public policies and landslwater acquisition priorities to conserve the ecological values of Boulder's grasslands "Ensuring agricultural production" is only seen within the context of "conserving ecological values", and thus the GEMP is focused on only on one or two of the eight Open Space purposes. The Grasslands Plan studies the environmental resources, but it does not place them into their larger context. These lands are open space adjacent to hundreds of thousands of people who vote and pay for open space. These citizens have limited close-by recreational opportunities. In contrast, the Visitor Master Plan (VMP) sought to reach a balance between recreational, environmental, and agricultural resources. This took a great deal of community discussion and compromise, but different goals were addressed, and there was a balanced outcome. The GEMP has been presented as on the same level as the Visitor Master Plan (UMP). However, it lacks balance and a larger perspective. A Recreational Access Plan that sought to increase recreational access without concern for environmental, agricultural, or scenic values would have as little balance as the Grasslands Plan does now. There are two ways to address this lack of balance. First, the Grasslands Plan should only be used to inform the Visitor Master Plan and Trail Study Area process. It should not be a way to unilaterally close trails and restrict access that the Visitor Master Plan incorporates. If it is so easy to bypass the compromise reached in the Visitor Master Plan, why will anyone respect it in the future? Second, any recommendations that the Grasslands Plan makes should consider the larger context and longer term considerations. We do not want to appear as foolish as the wildlife managers who exterminated wolves to protect deer and the natural lands in their trust. Blindness to Unforeseen and Undesired Consequences The grasslands that ring Boulder are the closest and easiest areas for most people to visit. If we want to encourage less use of fossil fuels, do we want to close more areas that they can visit without driving? How will people be sensitive to the consequences of global climate change if we prevent them from experiencing it? 58 "Nature deficit disorder" is a recognized problem with children today. We do not want to further separate future citizens from their natural environment, especially the natural lands that they can visit on foot or by bike. The environmentalists of tomorrow come from people who experience natural environments today. The richness of life in riparian areas and wetlands creates an especially engaging experience. Overuse of seasonal closures will undermine public support and compliance with them. To protect existing seasonal closures, please do not expand them six-fold. Simple-minded goals, like reducing trails within 200 meters of wetlands, need to be adjusted for many factors. For example the OSMP Operation Center at Cherryvale is within 200 meters of the wetlands along South Boulder Creek. Should Cherryvale be relocated? Actually, because Cherryvale is on a bluff above the creek and the wetlands, it proximity is less important than if it were on the same level as the wetlands. The same reasoning applies to trails. With vertical separation, a trail may be placed closer to a wetland with minimal impact (and with better views}. The biggest consequence of proceeding with an unaltered Grasslands Ecosystem Management Plan will be to undermine respect and support for OSMP, the Visitor Master Plan, and the TSA process. The Grasslands Plan does not take other Open Space purposes into account, and it should not override existing political decisions. Thanks, Chris Morrison 4100 Aurora Ave. Boulder, CO 80303 59 Friends of Boulder Open Space Comments on Grassland Ecosystem lUlanagement Plan -December 5, 2©d8 General Friends of Boulder Open Space commends the Open Space and Mountain Parks staff for this excellent document and for its well supported methodology for evaluating the OSMP grassland resources, and for setting targets for achieving and managing healthy ecosystems, based on a solid, scientifically based suite of measurements and practical long-term monitoring. The Executive Summary states that the "Grassland Ecosystem Management Plan (Grassland Plan) focuses upon the conservation of the 24,000 acres of OSMP lands dominated by mixedgrass and xeric tallgrass prairie." This is completely appropriate and should not be watered down. Some have advocated that the plan should incorporate methods for balancing recreation needs in the plan. The Executive Summary places the Grassland Plan in the context of the other plans that have been adopted to govern other objectives, including recreation, as does the background material on pages 5-7. Chapter 1, page 5 clearly states its relation to the Visitor Master Plan. This is a Grasslands Ecosystem Management Plan, and it quite properly focuses on managing the grasslands ecosystem. The right way to deal with conflicting proposed uses of open space lands is with the VMP process, which is intended to do the balancing. The only way OSMP can appropriately balance conflicting demands is to have a clear methodology for managing the resource that carefully identifies the components of the natural systems and defines a healthy state for each, along vNth ways to determine how various uses would impact that state. This is what allows a land manager to determine whether a particular location is especially important or not, what activities might degrade its health, quality, and value, and, finally, to measure the effects of use over time, in order to practice adaptive management. Consideration of competing uses has no place in the evaluation of the resources, nor in measuring their health. Good evaluation and measurement are the tools that are needed to determine the potential effects of competing uses and then to evaluate the effects if trails are built, if livestock is grazed, if fires are allowed to burn, etc. Planning Approach The use of the CAP approach is an excellent methodology: disciplined, scientifically based, and transparent. As you know, FOBOS has long advocated a clearly defined approach to monitor and manage the system resources. CAP, and the department's implementation of it in this plan should provide an excellent structure for properly managing the resources, and the 24,000 acres of grassland in the system are urgently in need of such management, as the overall "Fair" state indicates. Moving that state to "Good," and avoiding degradation will pose a significant challenge over the next few decades, particularly in light of demands for various kinds of use, the continuing effects of past land- use practices. Existing problems vNth invasive weeds already pose a significantthreat, and research indicates that the effects of global warming and excess nitrogen load are likely to exacerbate that threat. FOBOS has three concerns about the implementation of the CAP approach: • Appropriate funding of implementation, particularly for monitoring and mitigation actions, will be particularly difficult in an environment that will become significantly more difficult, rather than remaining relatively static. • Given the granularity of the approach, there is a significant danger that a set of actions and judgment of their successor failure will be taken in isolation, whereas they will occur in conjunction with a number of other factors operating on the same target. Managing this complexity effectively will require significant discipline. • Any tradeoffs that allow uses that may degrade the quality of the resource need to be made without changing target states or ignoring potential effects. On the contrary, when tradeoffs are made, it is critical that potential effects be documented, that planning include potential actions when degradation is greater than anticipated, and that monitoring be done to measure the effects. Note that tradeoffs must take into account all effects on the plan and its 60 implementation. For example, the criticality of large habitat blocks is well documented in the plan. Hence, a proposed trail's effect on such a large habitat block would have impacts extending far beyond those immediately along the corridor, and it is vital to take them into account. Focal Conservation Targets The selection, definition, and mapping of the focal conservation targets is an admirable synthesis of what we know about the resources and about specific goals for which we need to manage, including ecosystems, specific unique enclaves like White Rocks, and non-ecosystem goals and aggregations of issues, such as the prairie dog associates and agricultural operations. We hope that there is a continuing long-term effort to refine the nested targets, attributes, and suites of actions in each of the focal conservation targets. The current plan is an excellent first draft, but it is inevitable that it will require constant refinement to achieve its goals Strategic Initiatives The initial list of strategic initiatives is excellent. With respect to Initiative 1 (Large Block Habitat Effectiveness}, we would urge you to attempt to increase the number of blocks (Table 21, pages 66-68} of both Mixed Prairie Mosaic and Xeric Tallgrass Prairie that are maintained at good/fair condition, in cooperation with other agencies as appropriate (Strategic Action 26}. Because of the importance of blocks of continuous habitat for ecosystem health and species viability, this would be one of the most effective ways to improve our management of the system. Under Initiative 3, Aquatic Systems Management, Action #17, Evaluating dog restrictions in selective riparian areas to protect sensitive species, should be implemented. Benefits are high and actual impact on dog guardians would be modest. Stating that it has low feasibility because it is "not likely to be appealing to dog guardians" is unpersuasive. Strategic action #21 should aim a little higher in its goal. We should be able to achieve more than three bullfrog-free ponds supporting leopard frogs by 2015. Monitoring We note the statement under goal #3 that "Often times maintaining a target in the Good condition is easier and less expensive than trying to improve its condition once it becomes degraded. Monitoring the key attributes of targets that are already within an acceptable range of variability will help ensure targets in Good condition stay that way." We heartily concur and emphasize that careful monitoring of newtrails and appropriate adaptive management are therefore critical. Slow degradation of resources that goes unnoticed causes important ecological losses and is expensive to remedy after the fact. The strategy of explicitly prioritizing monitoring activities is exactly right. The practical effectiveness of this strategy will, of course, be dependent on budgetary and staffing considerations over time. We hope that the department will place a high priority on these activities, in spite of conflicting demands. One critical problem in achieving this goal is the neglect in the planning process to budget this necessary monitoring in the cost of new trails or additional access points. Judging the impact of new trails in the system requires the monitoring described, as does doing adaptive management of those trails. But these costs are typically ignored. This results in bad planning, because the additional costs area "surprise," and bad management, because the necessary monitoring and adaptive management are not done, resulting in a buildup of needed compensatory maintenance. The staff ranking of monitoring priority "Very High" to "the indicators associated with grassland vegetation composition and structure, grassland nesting birds..." is an excellent evaluation. Rare plants and individual species monitoring are important, but they are likely to be improved if adequate attention is paid to the vegetation composition and structure, together with a few indicator species, while the reverse is not true. Our review of the detailed monitoring table of indicators, priority, and methods has been necessarily cursory. In general the list of attributes and their prioritization is excellent. 61 For both the exotic species assessments using RAM (page L-3}, we would suggest that it is critical both that pattern analysis be done, and that particular attention be paid to correlations both with established trails and with new trails. Neither is mentioned in the methods. Control methodology, trail suitability analyses, and best practices for trail building are all dependent on building better understanding of the patterns of establishment of exotic species. Conclusions This is a superficial reaction to a monumental plan, but after aone-month review, the superficiality is inescapable. The scope of the plan is (and should be) comprehensive and overwhelming. Its general structure and thrust are focused exactly where they should be-on a careful understanding of the resource and a detailed methodology for its preservation and management. Once again, FOBOS congratulates the staff on ajob well done. Implementation will be challenging, and we encourage OSMP to do the necessary follow-up to actually achieve the goals that the plan sets our so well. 62 City of Boulder Open Space and Mountain Parks P.O. Box 791 Boulder, CO 80306 December 4, 2008 Re: Grassland Ecosystem Management Plan Dear OSMP staff: I appreciate the opportunity to review OSMP's draft Grassland Ecosystem Management Plan (the Plan). OSMP staff have clearly spent considerable time and effort on this document. I believe that time and effort has been well spent in the consideration of habitat and wildlife conservation (i.e., flora, fauna, wetlands and riparian areas) as specific targets of the plan. Agriculture Operations on OSMP lands are also reasonably considered in the Plan. However, the Plan is incomplete in that it does not properly consider Recreational Use as a focal target. These focal targets drive the entire planning approach of the document. The targets in the Plan are based on the purposes of the City Charter for Open Space with the exception of Recreational Uses, which for some reason was not identified. Without fully integrating Recreational Use as a target into the Plan, OSMP's recommendations are not consistent with the City Charter and OSMP is unable to perform a balanced evaluation. Identification of Recreational Use as a target will allow OSMP to determine the key attributes of Recreational Use and indicators for those attributes. Threats to Recreational Use would be identified and a Best Opportunity Analysis would be conducted. Finally, implementation strategies, objectives and initiatives would be prepared for Recreational Use. To accomplish this important modification, OSMP should revise the Plan to evaluate Recreational Uses as a target on par with the other OSMP charter purposes. Alternatively, OSMP could strip the Plan down to present only the ecological data for the Mixed Grass Prairie Mosaic, Xeric Tallgrass Prairie, Mesic Bluegrass Prairie, Black-tailed Prairie Dog and Associated Species, Wetlands, Riparian Areas and the White Rocks Area and remove all recommendations about threat assessment and how to improve the ecology, reserving any and all recommendations, strategies and decision-making to the TSA process. By doing so, OSMP will be in a position to effectively balance competing goals that may exist within the purposes of the OSMP Charter and OSMP staff will be better able to integrate the long-term sustainability of natural systems with recreational use and agricultural operations. Absent this significant shift in focus, the Plan is one sided and only focuses on conservation goals to the exclusion of recreational use. Without a level of visitor access, residents will cease to support the Open Space and Mountain Parks program. OSMP staff are charged with finding a balance that allows for visitor access while maintaining ecological functions. Treating Recreational Use on par with conservation is critical to finding that balance. In addition to this global, and fairly significant comment, I present the following specific comments to the Plan as an attachment to this letter. Many of these specific comments may be rectified by a full integration of Recreational Uses as a target of the Plan. I appreciate the opportunity to comment on this Plan and look forward to reviewing OSMP's next steps. 63 Very truly yours, lenifer Kwasniewski Attachment 64 Attachment to Comments on OSMP Grassland Plan • On page 29 of Chapter 1, 05MP staff should explain how trails and greenways located near riparian areas impacts those areas. The implication is that trails and greenways negatively impact such areas. Although it is fairly apparent how gravel mining, road construction and residential development negatively impact riparian areas, it is not so apparent how a trail impacts the functionality of a riparian system. • On page 33-34, Table 2 should include Recreational Use as a target and include key attributes for that target. Those key attributes could include: Trail Condition (maintenance condition, singletrack vs. doubletrack or road, etc), Trail Availability, Trail Location, Trail Views, Trail Connectivity, Trailhead Availability and Condition, Trail Experience Opportunities (nature viewing, bird watching, rock climbing access, exercising) and Trail Use Opportunities (hiking, equestrian, dogs, and mountain bikes). Indicators for these attributes can be developed that area measureable and technically feasible. With proper definitions, they can be precise and consistent, specific, sensitive and timely. For example, one indicator for Trail Availability could be miles of trail per acre of 05MP land. Indicators for Trail Condition could be percentage of trails in very good, good, fair and poor maintenance condition and percentage or trails that are singletrack, doubletrack and road. Trail Use Opportunities could be measured by the miles or percentage of trails available to each user group. • On pages 36-38, it is unclear how OSMP went from table 4 to table 6. I believe more explanation should be included in the text. • On page 43, OSMP describes how roads/urban areas and trails were used to reduce the block size calculations. The ratio between roads/urban areas and trails is presented as 2:1. Specifically, roads/urban areas were presented as creating a 200 meter buffer that was excluded from the block size and trails were presented as creating a 100 meter buffer that was excluded from the block size. In contrast, riparian areas were presented as creating a 20 meter exclusion from the block size. I find it difficult to believe that roads and urban areas are only 2 times more disruptive than trails (or conversely, that trails are half as disruptive as roads and urban areas) and ask OSMP to provide data to support this conclusion. Trails exist in nature {i.e., animals create trails themselves) and do not seem to disrupt wildlife to as great an extent as the 100 meter figure would suggest. Even trails used by humans, dogs and horses, while more disruptive than an animal trail, cannot be even half as disruptive as 100 feet of asphalt with cars driving by at 60 miles per hour or as a residential development. This is especially true in the grassland areas, which do not have the trail density/user density of the Chautauqua area. It would seem to me that trail disruption should be much lower than that for roads/urban areas and closer to the figure presented for riparian areas. Finally, OSMP does not show how proximity to agricultural land affects block size. If OSMP intends that this be included in the roads/urban areas category, I believe it should be separated out with its own buffer zone, as agricultural land would seem to be less disruptive to wildlife than roads and urban areas, but more disruptive than riparian areas and trails. • On page 57, table 17 shows that Total Phosphorous (for Ponds) is rated as "Good", but further down, Total Phosphorous (for Ponds) is highlighted in blue and shown as "Not Rated." Please explain this discrepancy. 65 • On page 58, OSMP states that road and trail density are an indicator for connectivity. I do not dispute this conclusion, however, I believe that roads and trails should be evaluated separated when determining their impact on wetlands, as the magnitude and nature of their impact would seem to be disparate. This comment caries on to page 60, where roads and trails are combined in table 18 and page 62, which summarizes the impact or roads and trail density collectively as falling outside the acceptable range. Moreover, I believe to truly understand the impact of trails on the connectivity of riparian areas, designated and undesignated trails should also be evaluated separately so that sound decisions regarding trail management can be made. • On page 60, OSMP lists several indicators of riparian condition that have not yet been rated. As an Environmental Scientist specializing in contaminated site remediation, I recognize these indicators as relatively easy to measure and able to provide objective data. I urge OSMP to complete the studies associated with these indicators as soon as passible, as they will provide a good, objective baseline for measuring improvements. This comment carries on to page 61, where OSMP states that this data collection is proposed. • On page 62, same very interesting text is presented almost as a side note in small green font. Why is this text not shown as part of the "regular" narrative? The green text seems to imply that much of the negative impacts to riparian areas have been caused by substandard mining reclamation activities in the past. Reducing this point to a side note minimizes the chance that solutions to this problem are evaluated. • On pages 69 and 70, OSMP presents a figure of recommended trail and road density (34 m/ha} within a 200 meter buffer of wetlands and riparian areas. Roads and trails should be evaluated separately and trail density should presented as within a 100 meter buffer or less. In addition, OSMP should explain the basis for 34 meters of road/trail per hectacre of land. • In Chapter III, OSMP should more fully explain how staff went from attributes, targets and indicators to threats. The threats are simply presented with little explanation as to haw they were determined. • On page 71 in the last paragraph, OSMP should represent item 4 as "incompatible dog management by guardians and not just as "dogs" (i.e., use only the text in parentheses.). This should also be carried out in table 22 on page 22 (item 3} and page 74. Dogs in and of themselves area not the problem, incompatible and inappropriate management by dog guardians is the problem. • OSMP should show how they calculated each ranking in table 22. Based on the data in Chapter II, I was surprised to see so many High and Very High rankings. For example, the ranking of Very High for Incompatible Trails/Recreation on Prairie Dogs seems quite high and was not something I gleaned from any text in Chapter II or any of the appendices. Also on table 22, Roads seem to be missing as a threat. My concern with how OSMP calculated the ranking of some of the threats is exacerbated by the text on page 74. Many of the threats indicated as Very High in table 22 are described in a less-than definitive manner on page 74. Specifically, many of the threats listed as Critical Threats are referenced with words such as "may have" and "may result". These qualifiers do not support strong statements that certain activities are very high threats. More information on OSMP's calculations for the rankings may help address these 66 questions. My particular concerns involve presumptions that trails ARE a threat when OSMP can only state that they MAY be a problem. This issue is a good example of why Recreational Use needs to be evaluated as a stand-alone target and may be addressed by doing so. • On page 74, OSMP states that trails create disturbed ground, which is a preferred location for weedy plants. I agree that disturbed grounds are preferred locations for weedy plants in general, but my experience has been that properly maintain trails are weed free (i.e., they are dirt and rocks). Does OSMP mean that the sides of trails are disturbed enough to be fertile ground for weeds? If so, this should be clarified. • On page 74, I have several concerns with the text on "dogs": o I recommend that the text include language that distinguishes between dogs on leash and dogs off leash. I believe many of the perceived problems caused by dos are really the problem of dogs that are not controlled in the right places. In certain areas, requiring and enforcing leash laws is a simple solution that has not been fully utilized. o In addition, more rigorous enforcement of waste pick up can also reduce this problem significantly. o Regarding feces, there is little discussion in any OSMP documents of the impact of horse feces on water quality and nitrogen contribution. o Regarding the last sentence in the section, do wild animal trails create places where weeds can germinate and grow? • On page 91, road density and trail density should be evaluated separately, as the two would seem to have very differing impacts on wetlands and riparian areas. • On page 96 in table 25, OSMP proposes a reduction figure of recommended trail and road density within a 200 meter buffer of wetlands and riparian areas. Trail density should be separated out and presented as within a 100 meter buffer or less. In addition, OSMP should explain the basis for recommending a 50% reduction in trail and road density. Trail density in the grasslands is currently among the lowest for OSMP lands. Moreover, riparian areas and wetlands present some of the most desirable locations for recreational users. Instead of jumping to the recommendation to reduce density, OSMP should consider a more balanced approach that seeks to find specific locations near wetlands and riparian areas that may realize lower impact by trails than other, more sensitive areas. This issue may be resolved by evaluating Recreational Use as a stand-alone target. • On Page 98 in table 26, item 9 states an action calling for OSMP to "Close and restore undesignated trails and discourage their (red establishment." Instead, OSMP should evaluate both designated and undesignated trails to determine which ones pose the lowest impact on other targets. Some undesignated trails may be very appropriately located and constructed and could be added to the list of designated trails. Conversely, if OSMP has direct evidence that certain designated trails are problematic, they should be relocated or replaced with appropriately located undesignated trails. The goal should be to have a desirable density of appropriately located and constructed trails to support meaningful and enjoyable recreational use. 67 Thank you for this opportunity to review and comment on the Grasslands Plan In a word: WOW I have not been able to invest the time to review the Grasslands Plan that this document deserves. It is by necessity: long, complex, and contains many interrelated sections. Based on my decades-long interest in and study of our native grasslands, my participation in the public process as the plan was developed, and the few hours that I have had to review this document, I will limit my comments to 6 points. 1. "Sustainable Natural Resource Conservation" - The document rightfully reminds us of and grounds this document in the OSMP Mission and the Purposes for open Space from the City Charter's by printing them on pg. 2 of the Executive Summary. We can neither achieve this Mission nor the Purposes without such a Plan. Now, finally, we have in hand a resource plan to guide the management of our 24,000 acres of Grasslands and ensure conservation of the ecological values and agricultural production of these lands in a way that is parallel to the 1999 Forest Plan. Our extremely competent ~SMP staff, who I'm sure have worked long and hard to create this Plan, are to be commended! Sustainable management of the grasslands resources must be guided by the objectives, actions, and monitoring set forth in this Plan if we are to achieve what is envisioned in the documents that ground our open space program. 2. We must NOT continue down the costlypath on which we have been going - ~verall "fair" rating for the Grasslands tells us that many of the indicators of viability are outside the acceptable range. The way we are currently managing our grasslands is NOT sustainable. The Plan gives us a comprehensive set of objectives and actions to guide management and address threats. These must be pursued -and the Plan tells us that the health of the grasslands "could be restored to a "Good" rating with a reasonable level of effort." It is essential for us to "attend to this conservation need before the quality of our grasslands system falls to "poor" and requires even greater effort". Is it possible to estimate {or even give an order of magnitude guesstimate} of the expense and possibility of achieving restoration from "fair" to "goad" - vs. the cost and achievability of letting our grasslands decline further {from "poor" to "fair"} before we act? It seems to me that only by seeing this second cost & feasibility {which will undoubtedly be more expensive and possibly un-achievable} will the wisdom and value of immediate restoration efforts be clearly perceived. 3. Importance of Large Blocks and Management of Multiple Factors - The wisdom in this Ecosystem Management Plan is the fact that the focus is on managing for sustainability of a mosaic of many different grassland eco-types {including the soils, vegetation and non-plant species} in an integrated way -and NOT managing for individual species! In addition, the critical importance of LARGE blocks of land is key. Many studies emphasize the importance of block size and interdependent elements in sustaining healthy grasslands. For example: 68 Predators such as raptors need perches {as pointed out on p. 108, #6}, but if we put trails along riparian corridors with trees {i.e. perches} raptors vacate the area. Without predation, prairie dog populations increase -and especially in smaller blocks/fragmented plots -prairie dogs decrease the quality of vegetative cover and exotic species invade. Trails also lead to the loss of native grass cover {as documented in both ESCO reports and published university studies). And the grassland health declines, perhaps to the level that it is unrecoverable. The Plan authors undoubtedly understand such interlocking & cumulative threats, but it is not clear to me that in implementing this plan there is a way to assure funding and implementation of the multiple interactive Actions that will lead to success. What will prevent OSMP from concluding the "failure" of an Action or it's lack of success when it's lack of success is due to the fact that complementary Actions were not taken at the same time? Similarly, "large blocks" are essential for the conservation of many of the ecological values described in this document. I strongly encourage you to expand Strategic Action #26 and in Table 21 under Goals to increase the oq al to at least two blocks of mixed grass {2,000 A} and xeric tallgrass {1,000 A} . To achieve this higher goal, OSMP should explore opportunities to collaborate with other land management agencies {as referred to in the plan) and formalize agreements of management goals & actions for adjacent parcels. 4. Monitoring the effectiveness of the highest priority strategies The proposed monitoring strategy is essential to "allow staff to repeat effective strategies elsewhere and refine or abandon ineffective strategies" -however, as mentioned in #3 above, a strategy must be defined to make sure that effectiveness or ineffectiveness is not assumed because of a single action. If used with a larger more integrated view of multiple factors, feedback from monitoring will help OSMP allocate resources appropriately to conserve the Grassland Plan targets. In addition, as noted in the Plan and mentioned in #2 above, responding early is easier and less expensive than trying to improve degraded conditions -and I would claim is essential if we are to regain and sustain the health of our native grasslands ecosystems in the face of limited financial resources, the threats of climate change, and increased human populations in our Metro region. 5. Threats from Climate Change I believe that the most constructive action OSMP can take as an agency to prevent the threat of invasive weeds due to Climate Change, N-deposition, and other human- induced threats is manage the Grasslands to insure the health of the native grass communities and other interrelated species. Research studies which are well-known to OSMP staff show that among the strategies that increase the threat of invasives/exotics are trails {e.g. the compaction that comes with trails} and the people and dogs, horses and other non-natives that carry in seeds/non-native species. The Plan should emphasize the importance of conserving large blocks free of disturbance as an action to guard against this threat. 6. Small typo 69 In the Executive Summary, I believe there is a typo in Conservation Objective #14. Thank you for your concerted, ongoing efforts to sustain our grassland ecosystems. Karen S. Hollweg 4440 Greenbriar Blvd Boulder, CO 80305 303-494-2016 khollwec cr stanfordalumni.orq 70 Location Comment Boulder Grassland Ecosystem Management Plan Comments- Lindsey Sterling Krank {Prairie Dog Coalition} & Deirdre Butler {Sierra Club} for Keep Boulder Wild 12/07/08 4SMP responses in blue New KBW comments in gray 1 71 Location Comment Location Comment General Document contains much accurate information and provides a good read General The 1996 Prairie dog Habitat Conservation Plan specifically set aside 4635 acres as Prairie Dog Habitat Conservation Area. This plan identifies only 340 acres specifically as Prairie Dog Conservation Area. This is a 93% reduction in dedicated space. Please provide the justification for this large reduction. In addition, the 1996 PD-HCP further defined 176 acres as Transition Areas which may subsequently be reclassified as habitat conservation or removal areas. This 2008 plan discusses a maximum 2,840 acres as the highest threshold OSMP will let prairie dogs occupy. This is still a 43% decline from original intentions and a reverse in conservation for an imperiled species in North America. KBW would like to see x,000 acres set aside again so the city can have more options. 2,840 acres is too low and does not allow room for fluctuations. This low of a number will not allow OSMP to contribute to the solution for other non-lethal management options from anywhere outside the OSMP system including, Parks & Rec, Utilities, prairie dogs imperiled in the Urban Wildlife IVlanagement Plan. Thus, we will be faced with more difficult decisions more often w/ 2,840 acres being such a limiting number. This number needs to be increased. ?,Yv?"'~; ~T)L~iii~~tl~"~', Orly' ~~~0 aCI"eS fn the clitlre dJ'il' al'ea lti 111 Siligly be Tllanagcd ~_t3i" 111'<7~2"le ,logs. These arez>ns are designated as Pz airie Dog Conservation Areas. While you could include the 10% of Grassland Preserves as ~~~ell, that is still only atotal of 1140 acres being managed singly for prairie dogs species singly. KBW recommends the amount of Prairie dog ~'onservation :Areas be increased to at least 1,673 acres which will at least mimic the 1996- 2007 maximum extent occupied in the HCAs. 1~'e «~°ould also like to see the maximum ;Acreage of 2840 acres of prairie dogs be increased to 3,500 acres which «rould acconltnodate ~he~ maximum en~tent of prairie dogs occupying OSNIP habitat in 200. General The draft plan repeatedly and accurately discusses the problem of lost habitat for prairie dogs and associated species due to development issues and historical land use practices but their failure to adequately address these issues in the present draft plan only means OSMP may be allowing history to repeat itself. General Draft plan lacks a general understanding of prairie dog behavior and how they function within colonies. Report lacks an explanation of how prairie dogs disperse, population regulation, natural expansion and contraction based on simple attrition etc.. KBW is concerned that without explaining all of these factors in the plan, it is misleading to present the document as is to a decision maker that may not clearly understand prairie dog ecosystem ecology. i~l3ih' suggests ~~)Sl~ii' include a short educational piece of prairie dog ~lanagernent so readers can have a better idea of what the plan encompasses. ~~'e~ can ~~rovide something here if you like. ~~~s~~:~~~~~ ~~4'hile the OSI~IP staff states their intention is to obviously manage for all of the ~:~~onsei-~-ation targets in the GNIP, btpd and associates are one of the conservation ta~`b~;~~~~. i~Votably, staff has spent a great deal of time examining and researching many best practice management techniques and created a fancy plan through using the TNC Conservation Action Plai111ing process. However, while stair states their intention is to improve habitat and 2 72 Location Comment -onditions for file btpd and associates, text. and language allcl syntax perhaps do llot give talc Man that overall feeling. Instead, it seems areas where prairie dogs occupy that receive a fair to poor ranking ~~~i11 be humanly intervened upon and prairie dogs «~i11 perhaps be removed. This may be addressed by removing the btpd as a threat for example. Other ideas that. lend he plan an overall negative feeling for prairie dogs is the t~~~ide-spread use of the term ~•emoval without mentioning relocation and that lethal control is being reintroduced as a tool 2or our Open Space lands. I~]3~?~' ~bz~~wF;t4= e~~-t.~1-all 1 ~~gzl<~~4 1~c- 1~ F :Sit~.~~1 tc3 l~~t tllc pl<~1. `.1~.,°a~ reflect Stag's Stilted lntentlonS. Pg. 3 Prairie dog acreage should be listed as a range if you do not have one number. Perhaps you could insert 1800 acres as the current number w/ a sign and the note can indicate the fluctuations. You have to look in 3 places to find pd acreage. This should not be necessary. ~~v'~ 1':t.:iiilllllelld ~_?~7:~It~' States the aCreaL;l: (}cc~lplcd t)1' a iallae 1~1 ills ffabls ill pg..~. General How did the loss of water rights in the transition areas suddenly become an issue? How does prairie dog presence affect loss of water rights? The potential loss of water rights did not recently emerge as an issue, nor is it restricted to transition areas. It has been along-term concern of the OSIVIP department. In the 1996 plan, irrigated lands were considered unsuitable as locations for consen%ation of prairie dogs (p. 20). The stated reason was that irrigation rendered the areas unsuitable. Although not articulated in the 1996 plan, ceasing irrigation was not considered an option because of the potential loss of watel• rights or the reduction of their value as well as the adverse effect it would have upon the need to fulfill the charter purposes addressing agricultural conservation. These same concerns face OSMP now. Open Space and Mountain Parks' water rights are valuable property rights under Colorado law, the measure of which is their historical consumptive use for irrigation. Any non-use of an OSMP water right, whether intended or not could result in abandonment of that 1•ight. Even if it does not result in abandonment, non-use can result in a reduction in the value of the water right for use by OSMP in the future for purposes other than irrigation. For this reason the plan proposes several management strategies to reduce or eliminate the potential for non-use. These include the selection of whel•e we seek to conserve prairie dogs, the ways that prairie dogs can be managed on irrigated lands and around irrigation facilities, (i.e. removal allowed), and an examination of the water portfolio to determine if there are ways to use existing water rights that would improve the configuration of the Grassland Preserves. ~-Io«i many acres of prairie dogs are on irrigated lands? Ho~~,T many of these acres are It:-t',,_'?a$_l~' 111Cluded ?21 $1?~ r,'[?~r2~ 1 `11:~ tY;111`:;?ff~4)9] al e.`s`~ Figure 1 ~~'hich areas, not included in the GMP area, have prairie dogs? Please provide this information. How will the colonies not included in the GMP be managed? Why weren't these areas included in the planning area? All colonies that we own and manage are included in the planning area. 3 73 Location Comment General In 2006, the CoB voted to pass the Urban Wildlife Management Plan and reduce prairie dog Pg. 6 colonies from &20 acres to 150 acres over time. This contributes to a significant decline in prairie dogs in Boulder. The GMP would further reduce the opportunity for prairie dog conservation and tie our hands when making management decisions. ~Pg. 21 OSMP mentions sylvatic plague and discusses the decline of the prairie dog population. Plague creates an overall doumward trend in prairie dogs. While OSMP and others have definitely observed a rebound over time in some/ most populations after plague epizootics have occurred, prairie dog populations still decline as a whole. Because OSMP does not perform density counts, this occurrence is not documented on our lands. There are many examples throughout the Great Plains where post epizootic populations never reach the same level as they once did and show great fluctuation over the years, never to reach original numbers again. OSMP mentions multiple times throughout the document that plague is merely a lot~~ threat to prairie dogs on OSMP. In reality, plague is the number one reason ~~e must be controlling all the other anthropogenic threats: it is uncontrollable, unpredictable and can nearly wipe out an entire colony by 100%. These colonies may or may not come back and scientists say the overall trend is still downward (Reading, 2008). If we were to change the threat of plague to high or very high for prairie dogs and assoc. species, how would that change the plan at all? OSMP is not familiar with the examples given above or Reading 2008. We would be interested in seeing these to make sure we are using all applicable information. Responding to plague is challenging. We have been collaborating with researchers funding on an NSF/NIH grant to better understand how plague operates. The Grassland Plan should be revised to make mention of the research associated with plague as a strategy to improve our understanding and management. Perhaps the most significant element of the plan with regards to plague response is the preserve design. The protected areas include the conservation of smaller, isolated colonies that either have escaped the effects of plague in the past or have seen less frequent plague return. This element of prairie dog conservation was introduced as part of the 1996 plan. Dusting with insecticides, is another traditional management techniques to address plague. In the past OSMP has responded to the recotnmendations of Boulder County Health with regards to plague. The health department's primary concern is human well-being rather than prairie dog consen%ation and their recommendation typically affect colonies after plague has affected prairie dog populations. It seems that post-plague dusting would have little effectiveness on addressing the effects of plague. OS1~•IP is not aware of research into the effectiveness of preventative dusting of wide area. Such an strategy would however raise significant concerns because of the cost, ,impact to non-target organisms and consistency (or lack of it) with the city's existing integrated pest management policies. These policies seek to minimize the use of biocides, including those derived from natural sources. ~~'e welcome your ideas about what strategies might be effective in abating the threat posed by plague. ~1Q z-;-;~M,~k~~~.Pzyj~.~_~~a.~:~~i.3~.~w t.~~tl.3si~~~'4'~°~.5..,5~.1~t4asi~,.~~fli~~" 4 74 Location Comment t3cn~-c1- ~,oological Foundation. To corltirm this idea, please contact Ptiell at 3{)3-3~6-4y4~ or rreadin 1e,denverzoo.org. `,~:'hile~ Boulder County Health Dept.'s main concern is people, maybe the PCA should be ~~Q<lnage~d singly for prairie dogs as is the designation's intention as ~~rell as public health. In e~is case, «~e would suggest OS~IP examine dusting colonies if plague is found up-front to duce the influence of plague in these areas. There are papers that show plague halting at ~9~e dusting line. I can find the one by Dean Biggins if you want me to. I have given it to you 4=11 before. Other plague management strategies include dusting primary consel`~~ation areas ~ m-hen plague hits a nearby colony «'e had success with this on the Southern Plains Land ":'rust a fe~~~ years ago and also in Conata Basin this year. _`avdyyditionally, t~ e bppelieve rgqe~colonization post plague can poq cyycur best in a mix of large scale n .1~'•~l li,., S-.]~..~< .]-i~lil.Ii,f, l >%)ll.cl4~~:,r~l ~~ll ~)l?.w%., it i~~:.`;w ~1 <i: {a ;i`:Illl It°,t1L7. Ell)tJ'. Pg. 22- Prairie The sentence of prairie dogs being the subject of animal rights groups has a negative Dogs & People connotation. ~~'ti r~:c:olnln~ ~~l this statement needs either further explanation as to why animal rights groups have taken on the issue (explain the long-term persecution and affects of human-imposed death) or it should be deleted. Pg. 22 -Prairie ,~'e r~ cc~rnlnelld that C9S i~IP also mention the people and scientists who have petitioned to Dogs & People list the prairie dog as listed on the ESA if you are going to keep this paragraph. If you are going to mention the `animal rights' groups who have taken an interest in prairie dogs, to not be exclusive, let's also list the birders, conservation and environmental groups, scientists and nature lovers too. Pg. 34 Please explain why BTPDs and associates only have 2 key attributes. Pg. 36 Still in review Pg. 51 OSMP states that although prairie dog populations have declined from plague outbreaks recently, populations have repeatedly recovered due to the small number of survivors still colonizing the area or surrounding unaffected colonies. Again, because plague is unpredictable and uncontrollable we can not count on the fact that there will always be an adjacent colony or survivors to help repopulate. This is a false argument overall and needs to be removed from the plan or include the overall downward trend in the population. ,.v~~'C)r11111C;rlc`,. fir 11S tla~~ Y 1[7 'a"1``ltvi ?i]l:; ?1,.~ ~>1112 Lf~•;J~a' ~L9~ °ti a';x~3~ arl exp c3lila,;: ]L? t le U~ ew~V ll '"lIV{.'~V 75 Location Comment Pg. 51 Please state where, and how many prairie dogs, and how many times, OSMP relocated prairie dogs out of the GPA into areas vacated by plague. Pg. 52 t?Vhile we recognize, the 10-26% range is probably supported in scientific literature, we are not sure it is an accurate estimate of what historically occurred in the OSMP area. This upper threshold is also limiting and we would like to see it increased. An increase in this range would probably also be supported in the literature. We would like to see this number allow for more flexibility and not tie down OSMP decisions. Additionally, please provide scientific backing for this range of occupancy was determined. *Pg. 52 Please clarify how you would manage for the 10-26% number. Is it possible that OSMP would let our pdog acreage get to 10% of 800 acres (the stated minimum) or 80 acres? Please clarify this in the plan. OSMP would manage the grassland preserves in a way that would seek to meet the viability criteria for all targets contained within them. Part of this is the 10-26% range for prairie dog occupation proposed in the plan. If prairie dog occupation drops below 10%, relocation into the grassland preserves ~~vould be pursued when the relocation criteria could be tnet. Above 26%- removal could be "assessed if prairie dog occupy more than 26% and vegetation composition fall below identified thresholds" identified thresholds equate to the middle of the fair rating for mixed grass prairie (pg. 86 of plan) 10% of 8,000 = 804 acres- this represents the minimum number of acres that would allow us to remain within our viability standards. Anything below this would put us out of our acceptable range. This minimum represents the very lowest level of occupation that would be appropriate. This number assumes that both Prairie dog conservation areas and multiple objective areas are vacant, and that no transition or removal areas continue to have prairie dogs, so 800 acres is lower than would be likely to occur on our properties. ~~,'e recommend the 1 U°~o being increased to a minimum of 12-15° o and that the upper ~e~reshold of 26°ro also be increased and stated as flexible. ~~~e recommend OSI~ZP clearly ;~~ates that pdogs may not be re~move~d if they occupy more than 26°% if those lands are found 9~~itable to support prairie dogs. In the first paragraph of your response he~re~, `vegetation compositioX~' needs to be clarifye~d as vegetation com osition as defined in the relocation criteria. *Pg. 52 Please provide Keep Boulder Wild with details/ maps of those areas identified in Table 14 so we can identify the location of the prairie dogs colonies in the removal and transition areas. Please clearly state how many acres of prairie dog habitat is in each category. (Thank you ,so much for the maps you provided to KBW on 12/01/-9. However, we need toad and stt~eet names to be included so we can identi exact colon locations and make colon visits.. *Pg. 53 How is "presence" of predators defined? Badgers, coyotes, and fox are opportunistic feeders. Most likely transitory predators would be found at dif~'erent times in BTPD occupied areas. How will OSMP determine the use of areas by predators? 6 76 Location Comment Prairie dog colonies that meet specific habitat conditions (i.e., acceptable landscape context, area, previous history of owl occurrence) will be surveyed for Burrowing Owls multiple times throughout the spring and summer. When surveying for owls, staff tivill note any other predators or commensals or their sign observed during the survey (see page ~3 in the Grassland Draft Plan for complete list). For the colonies that are not part of the Burrowing Owl monitoring regime, OSMP annually maps the extent of prairie dog colonies to deterniine the level of prairie dog occupancy within each colony. Observations of predators or commensal species or their si n durin this curve will also be recorded. pg. 53 If a prairie dog colony has a fair or poor rating, does that mean is it up for removal? What is this process? Table lb What about the Golden Eagle? Pg. 53 Burrowing owls have been recorded on Parks & Rec land in 2006 at Boulder Reservoir and in 2007 at Valmont Park. Pg. 53 OSMP does a good job laying out the decline of associated prairie dog species. ~Pg. 55 Please define what the `threshold of acceptability' is. The threshold of acceptability is the dividing line between "Fair'' and "Good" viability ratings. See figure 5 on page 38. The threshold of acceptability would be the line between "Fair" and "Good". General Does OSMP plan to deter plague from occurring in the grassland preserve area? Or does OSMP plan to let the exotic disease dictate the size and recolonization of prairie dog colonies in the s stem? Please ex lain. Figure 17 What was OSIVIP's reasoning for rating a large prairie dog colony as a removal colony in between the North Grassland preserve and the East Grassland Preserve? The IBM colony was classified as a removal area based on the management area designation criteria. Some of the reasoning is: -The property falls within fair,~poor habitat suitability - A large portion of the property is an irrigated hayfield - Although nearby, this colony is not directly adjacent to Grassland preserve area - There are no observations of sensitive species known In addition, this colony has been the site of significant conflict in past with lethal control occurring on the adjacent private property. ;~'hile~ reducing conflict in this area is desirable, «re recommend this site either 1) be~ ~~-~nlsidered as a removal site or 2) serious measures are undertaken to prevent recolonization ~.;~~'this property. Prairie dogs occupy many surrounding areas to this property and the colony 7 77 Location Comment Table 21 reconl~77Ln~ the 10-26% range increased to allow for expansion and to foster collaboration between the other lands in the Boulder area. Table 21 OSMP states they would like to see more predators and associated species on their landscape, but do not allow for an increase in prairie dog populations to attract these species. This seems like a disconnect. Pg. 71 Could the last paragraph be interpreted as stating that prairie dog occupation could be included as an incompatible surrounding land use and therefore a widespread threat? Table 22 Would OSIVIP consider adding irrigation as a very high tlueat to prairie dogs on this table? Table 22 Please explain why sylvatic plague is only a medium threat to BTPDs and associated species? We respectfully disagree with this classification and think it should be ranked as high or very high. Figure 19 Could you please provide us with this map w/ an overlay of occupied prairie dog colonies. Please also make this map be large enough to determine location of colonies. Pg. 83 There are also many members of our community that enjoy prairie dog vie~~~ing and their presence. Students do prairie dog projects, citizens write letters to the editor saying hour they do not want prairie dogs to be killed and tourists write in how much they enjoyed the prairie dogs on the bike path. Positive associations such as these and their associated species should also be included in language discussing the complaints against prairie dogs. Pg. 84 Page 84, Criteria for Designation in C?ther IVlanagement Categories, Prairie Dog Conservation Area: "Professional judgment" is very open ended and allows individuals at OSMP to make the final call on areas. Figure 20 There seems to be a plethora of transition areas. What is the justification for each of these rankings for each colony? *Table 24 Does OSMP have colony specific data for each of these colonies (slated transition and removal) which clearly shows how you were able to classify each colony as such? Could you please provide that to KBW? Please see attachtnent T-24 ~Pg. 86 etc. What is the current definition of removal? We request that the term "removal" be defined as non-lethal techniques e.g. passive relocation, relocation. (Ex. In the irrigation situations) Currently the term removal is used in reference to anything that would result in prairie dogs being taken off of a site. This could include relocation, passive relocation, or lethal control. All removal would be conducted in a manner consistent with the city's wildlife protection ordinance. The Grassland Plan describes certain conditions under which particular removal techniques would be used. The techniques that are available vary with the management designation of the colony. Lethal control could be used in removal areas or in transition areas in the event that fewer than 20 animals remain on the colony following relocation efforts. Lethal control could also be used on irrigated fields or 8 78 Location Comment irrigation structures if other options were not available such as passive relocation or relocation. OSMP has not used lethal control on our properties for many years and would do so only in the absence of other options to tneet the viability standards for grassland plan targets including agriculture. In grassland preserves, removal would be considered if occupation exceeded 26% and viability for vegetation communities fell below the middle of the fair range. Since it is not certain that removal would occur in this situation (only be assessed), methods to be used have not been defined. No removal would occur (relocation or lethal control) on Prairie dog conservation areas or multiple objective areas. ~~'e~ recommend the relocation criteria be~ reexamined ~~,~ith an experienced prairie dog relocator ~~~ho is good ith botany (Pam ~~'anek) and more realistic. Specific suggestions ~~a~~nlied iil the t~g~prop~~74~~:~ ~~i~i~e~ldi~z. Pg. 97 In regards to constructing raptor perches, we have worked w/ Eagle Scouts in the past who worked on this as their final project and it was a good collaboration and an opportunity for good press for wildlife and the community Strategic OSMP mentions coordinating with multiple agencies, scientists and groups to enhance other Actions Table targets such as overall vegetation and wetlands./ However, this is not mentioned for prairie dogs. Is OSMP open to including some collaborative projects in the field to improve/ enhance prairie dog ecosystem habitat? If so, where does the department see ideas for these projects that would be helpful to you? *General According to your numbers and definitions, if pd populations exceed 26% occupancy rate at any location, OSMP will manage pd populations w/human intervention. Is population `thinning' something OSMP will now practice on our Open Space lands? OSMP would only consider controlling prairie dog occupancy levels in the grassland preserves. This could happen if prairie dog occupancy exceeded 26% AND vegetation viability standards dropped below the middle of the fair range (as identified in relocation criteria). In the event that both of these events occurred (occupation level and vegetation viability degradation), removal tiom the grassland preserves could be considered. It is not assumed that removal would occur; only that it would be an option to be assessed. The specific wording from the plan is found on page 86: "removal would be assessed if prairie dogs occupy more than 26% and vegetation composition fall below identified thresholds". As with all management categories, OSMP would strive to use non-lethal techniques whenever possible. The 26% threshold does not apply to other management designation such as prairie dog conservation areas or multiple objective areas. 9 79 Location Comment Figure 17 Is the North Grassland Preserve only 1% occupied? Does OSMP plan to relocate pdogs slated for removal into this area? If yes, how many of the removal colonies will be relocated into this area? How many removal colonies will remain slated for removal? The North grassland preserve was approximately 1% occupied when mapped in 2007. When our 2008 mapping is complete by the end ofthe year, we will know what the current occupancy levels are. Since 10% is the lowest occupation level considered desirable for the grassland preserves, OSMP would like to relocate prairie dogs into this grassland preserve. The transition and removal areas would be the most desirable location for prairie dogs to come from for relocation into the grassland preserves. This would allow us to move forward in meeting the plan goals not only for minimum occupancy levels of the grassland preserves, but for transition areas and removal areas as well. Once the grassland plan is in its final form, we can begin assessing areas that are appropriate to serve as receiving sites within this grassland preserve and our prairie dog conservation areas. Once sites are identified using the relocation criteria, we would seek to move prairie dogs from transition and removal areas if resources are available to do so. Because our 2008 mapping is incomplete, plague remains active on our system, and uncertainty about how many acres of vacant grassland preserve prairie dog colonies are ready to act as receiving sites, it is impossible at this time to speculate on the number of acres to be relocated or remaining when relocation becomes possible. There has not been a date set for finalizing the grassland plan (will depend on time needed to address public and policy-maker comments) and currently financial resources are not identified to allow relocations on our properties. As a result, the time that relocation might begin is uncertain. It is likely that current acreage of occupancy on transition and removal areas is likely to change before we are able to begin relocation. Although limited in its applicability as discussed, the table provided as part of this document provides occupancy figures for transition and removal areas from our 2007 mapping which is the most current, complete data that we have. Page 86 According to OSMP interpretation, the southern grassland preserve is poor habitat for prairie dogs. Doesn't this conflict w/ your choice to pick this location as an area designated for prairie dogs and their associated species and/or does this make the habitat suitability model inaccurate in some areas? Please explain *General How many acres are designated as: Grassland Preserve Areas- 8000 Prairie dog Conservation Areas- 340 Multiple Objective Areas- Tranistion Areas- Removal Areas- The table (below) provides acres occupied for the various management designations based on both 2007 data (most recent complete mapping) and at maximum occupancy levels (all areas mapped as occupied within the time period 1996-2007). 10 80 Location Comment a. Where are these acres accounted for? Ex: Are there areas in the GPAs, PCAs or MOAs that exceed 26% and are therefore going to be removed? Are these acres currently accounted for in the approx 1800 ac. of pds presently occupying OSMP? b. Please clearly state these numbers for the above designations in the plan. Please see table c. Would pds be allowed to occupy more than 26% of any areas in the GPA? 26% occupancy applies only to grassland preserve areas, not prairie dog conservation areas or multiple objective areas. Removal and transition areas do not have occupancy standards, so if prairie dogs «-ere not able to be removed at any time from these areas, they would persist at whatever occupancy levels were present. Removal from these areas would strive to focus on areas that complete removal is possible. See table at end of document Se~e~ ge~ne~ral comments on pg. 2 ~~'e recommend NIOAs and ne~~-~ly acquired lands also be considered for receiving sites in areas Frith suitable habitat. Please clearly state that PCA will be considered for relocation regardless of occupancy levels. Please clearly state in the plan ho«~ many acres have been lost to plague over the years. For example, t17e North GP being reduced from 53°% occupied to less than 1°io occupied by pralrle dOgS as a result t0 pl~~~Alt k?otlt~`q. ~ t~~OI'?3'~~~t3dS ~l ~:'3};~'~~~; plE~~rte pt~~'Llr~', be painted for decision makers. Pg. 95 How does the 2028 objective for vegetation composition to achieve a good ranking directly affect prairie dogs in the Best Opportunity Areas? Can achieving good vegetation rankings create human intel•~~ention/ relnoval areas for prairie dogs? Pg. 98 What kind of gradient of support does OSIVIP wish to establish for pdog conservation? Pg. 98 Creating leash laws in wildlife areas/ prairie dog colonies is a great idea. Pg. 98 KBW applauds acquisitions and management agreements with neighbors to create a large block of conserved grassland in the Northern area, especially if these management a eements allow for rairie do ex ansion. Pg. 101 What type of removal does OSMP want to implement for prairie dogs exceeding 26% occupation. Again, KBW would like to see the 26% increased to allow for more flexible management decisions. *Pg. 103-122 How are the strategic actions numbered? I can not find them all. Starts w/ #3, moves from #5 to #9. I don't see #2 anywhere? How can I tell if I am missing some? The strategic actions are numbered in table 26 (pg 9'7). Strategic action #2 falls into 11 81 Location Comment Initiative #4 on page 116. Pg. 144-105 KBW applauds strategic actions #5, 12 and 13 Pg. 145 In regards to strategic action #26, Has the city or OSMP considered any types of incentives for adjacent land owners to make room for prairie dog expansion onto neighboring lands? *Pg. 147-148 In relation to strategic action #1, does the prairie dog grazing that is listed as a causing factor to the presence of invasive weeds mean prairie dogs will be removed from these areas? Are these areas marked as removal or transition areas in the pd classifications? Removal of prairie dogs is dependent on management designations and the discussed 26% ceiling in grassland preserves. Prairie dog management «~ill follow the management designations. Prairie dogs may be identified as a threat in areas that removal is not allowed by the management designation- in these cases, prairie dogs were decided to the be predominant management priority. Pg. 149 Strategic action #14- Did OSMP consult w/ prairie dog relocators to adopt these guidelines? Why is OSMP creating additional guidelines to the ones in place already by CDOW? Pg. 149 Strategic action # 16- in review Pg. 149 Strategic action # 19- Research conducted by Sam Fuhlendorf at Oklahoma State Univ. may be helpful here. Pg. 114 Strategic action #35- KBW does not approve of OSMP's new business of removing prairie dogs from their native habitat. Pg. 117 Agriculture practices- in review Pg. 122 How will staff monitor prairie dog protection and what protections are being referred to here? A-9 Does OSMP land have documented American badgers? C-5 Which of the eight critical wildlife habitat areas have prairie dogs? How are these colonies designated? ~;~-aa2 tt- e re-commend OS~Il' consider and account for the rest of Proctor's study_ and good point below in strategic action #47 From J. Proctor GIS model for identifying potential BTPD Habitat in the Great Plains Shortgrass Prairie page 13.... "Prior studies found a high coi7-elation betFVeen prairie clog presence and certain soil associations. However, when the individual soil factors were studied in conjunction with slope and vegetation factors, soil depth was not found to be a factaa~ while soil texture was onl~~ a minimal factor....For the 12 82 Location Comment vegetation factor, statistical tests analyzed both the iti-INL~VI value (biomass) and vegetation code. Vegetation code is of greater use in defining suitable habitat because prairYe dogs are know°n to be associated with lower biomass, but whether this is a factor they select in colonizing an area. or whether this is a result of their presence is not clear. It could be in fact that prairie dogs prefer areas with greater biomass, but their presence over time results in low biomass values associated with these towns." D-51 OSMP states that although current data demonstrates pdog populations ability to rebound after plague epizootics, there may at one point be too few colonies or individuals to reoccupy OSMP prairie dog areas. However, management guidelines outlined in the GEMP do not account for that. Rather, it seems prairie dogs overall will be on the decline of all of the management recommendations are implemented. If there is specific information requested to finalize this comment, please let us know. Otherwise, this will be included as one of our comments. *D-52 Does OSMP plan to remove or lethally control prairie dogs from Grassland Preserves, MOAs and PCAs if they exceed the range of occupation( currently 1Q-26%)? Please clarify how OSNIP will determine when prairie dogs will be lethally controlled. Prairie dogs would not be removed from prairie dog conservation areas or multiple objective areas. 26% occupancy thresholds apply to grassland preserves only. Within grassland preserves, methods of removal have not been discussed as removal would only be ASSESSED at the point that occupancy exceeded 26% and vegetation viability dropped below identified levels (please see answers to previous questions for details). If lethal control were identified as an option, all other options would be exhausted first. ['l~ apse ole~~a-1~,- ~t171ain this ij7 t11Er piein. ~l;~i-ili~<Atior~ a7i<~~ <aicl o~~ st<~t~ ~t~te~~~iofl~s h~ ~~,tr~iz~g *D-52 What does ARV stand for? Acceptable range of variation (see pp. 37-8) General KBW is concerned that the Boulder GEMP is trying to accomplish too much. There is a clear desire to conserve every characteristic of OSMP's unique ecosystem. However, this does inhibit focused attention to conserving the larger scale ecosystems on the OSMP landscape and really improving and enhancing those enough to make state wide contributions to conservation. D-52 & General How does current pdog colony mapping compare to historic pdog colony occupation`? 13 83 Location Comment D-52 Lomolino & Smith appears to be mis-represented. The paper may have referred to a much larger landscape scale and takes into consideration that most rnetapopulations in the U. S. have been interefered with. Furthermore, most conservation scientists on the Prairie Dog Coalition (the best in the country) scientific committee would state that if an area is allotted to prairie dogs, they should be allowed to occupy that habitat without human interference such as `thinning.' Scientists also agree that prairie dogs regulate their own population through individual control such as infanticide and aborting their pregnancies etc. Additionally, while prairie dog populations may contract and expand, that does not mean their numbers are also expanding. 1~~e recommend this Fact needs t~ be siz~.ted <~a1cl evident in the plan to aid in the reE3~ier's understanding. D-54 Please scientifically support w/ literature the statement, "Habitat that supports nesting burrowing owls provides a higher level of ecological function than prairie dog colonies where burrowin owls are absent. D-55 Please scientifically support w/ literature the statement, "Habitat that supports horned larks provides a higher level of ecological function than prairie dog colonies where bun•owing owls are absent. D-54 & D-55 KBW believes the above 2 statements are too generalized and perhaps inaccurate. There are many ways to measure ecological function of prairie dog colonies. Measuring just one variable to determine the level of ecological function is not representative of the colony in it's entirety and thus, the specific colony may be erroneously categorized. recommend ~~z ~;e sentences ire cV<~rilied or retno~ eci. D-55 OSMP has not collected data in the past on horned lark presence on pd colonies, however now «~ants to use their presence as an indicator of associated species presence and therefore contribute to colony ranking. If a specific pd colony has been ranked as `good' in the past w/o horned lark presence, could this indicator now change it's status to `fair' or `poor' and therefore be slated for removal? If yes, KBW disapproves of this indicator as a measurement of ranking. The fact that there is a management objective to increase horned larks, but OSMP has no current data on horned larks is a failure. ~D-56 Predator review overall conservation target #54- KBW sees a disconnect in OSMPs desire for more commensal and predator species on prairie dog colonies, yet not a desire to allow prairie dog populations expand enough to encourage associated species development. Please explain the department's theory here. In other CAP's including mixed-grass and prairie dogs, prairie dog acreage was increased as a goal to encourage associated species. OSMP is striz•~ing to balance multiple objectives within the grassland ecosystem management planning area. In some cases, this requires that prairie dogs be managed to allow for desired conditions to be attained or maintained for all targets. In order to encourage sensitive associated species, we have attempted to protect prairie dogs in areas most likely to provide habitat for sensitive species. Grassland preserves were designed based on resen%e design and landscape ecology principles likely to apply to predators and associated species sensitive to human disturbance. In addition, we included strategies targeted at attracting sensitive associated species such as Ferruginous Hawks. Expansion of prairie dog occupation would sacrifice our ability to meet viability standards and 14 84 Location Comment objectives for other grassland ecosystem management targets. Based on this response and examination, commensal and predator abundance or associated animal species composition may need to be removed as an indicator for success in the plan. T1iis specifically relates to strategic actions #4&50. If OS1~-IP has no baseline data to currently measure these indicators of success on, but wants to use these indicators to measure future success, then there is no criteria established for which to improve on. What happens if after measurement you find this indicator to be poor? To improve this, you would need more prairie dugs, yet the plan does not allow for this. w'e recommend this indicator of success either be removed or reexamined to allo~~-• for irnprovernent ~~-•hich ultimately means a11o«~ for expansion of prairie dogs. Additionally, In the paper referenced below, the objectives of the study were to compare small rodents, birds and vegetation on and off prairie dog colonies and provide baseline information on potential nontarget impacts from prairie dog control programs. In conclusion: "Prairie dogs act as ecosystem regulators by maintaining shortgrass plant associations with less mulch cover and to«°er vegetation height. These vegetative features, combined with high bu17•ow densities, provide qualih~ habitat for some species of small rodents such as deer mice and grasshopper mice. However, vegetative manipulation by prairie dogs negatively impacts rodent species associated with dense vegetation of mixed grass sites. Greater avian densities and species richness on prairie dog to«°ns can be attributed to patchiness clue to prairie clog activih~, lower amounts of mulch and lower vegetation height which may result in grater visibility of macroarthropocls and seeds than that on mixed grass sites...these results indicate that prairie dogs influence birds, small mammals and vegetation. So, if the objective of OSIvIP is to increase biodiversity, particularly horned lark densities, then the best course of action to take would allow greater densities of prairie dogs which will encourage nesting and hunting activities of avian species. Prairie dogs ~~•ill increase visibility of certain rodents and insects attractive to a variet~% of birds, mixed grass prairie sloes not necessarily provide this. Recall, increasing horned larks and nesting ground birds is a big component of this plan (Flora. and Fauna :Associated with Prairie Dog Colonies and Adjacent Ungrazed I~~Iixecl Grass prairie ln~~'''~-~',~.Y t ~z„3~~ T''i's j ~v~w~-.-, f ~^:_,?~,~.1T?1P1~S'.r~,,~{911r?~~P~ f'~ ~,;5"t `,~~i~',S`~,~Yr,~. ~ 7d.~~~ .t`~[:'~:. 19g~.~ D-57 For confirmation, all active prairie dog colonies monitored by OSMP are ground-truthed, correct? F-2 Please explain how incompatible grazing by native prairie dogs can be more of a threat than non-native livestock and additional agricultural practices that occupy significantly more acreage than prairie dogs. Is OSMP willing to reexamine this threat or reconsider the indicators used to rank this threat? 15 85 Location Comment F-2 If the incompatible prairie dog activity is ranked as high for both irreversibility and contribution of altered vegetation structure and animal community composition, then how will we ever be able to achieve F-17 What is going on w/ the btpd and associates row on pg. F-17? F-19 The theat ranking overall of sylvatic plague is of high concern to KBW. In a recent CAP (same planning implemented in GEMP) planning session for prairie dogs in the Northern Great Plains Eco-region, a table full of prairie dog experts and those more associated w/ syh~atic plague overall than OSMP, ranked sylvatic plague as a very high threat. Even considering Collinge's most recent data suggesting a trend in population rebounds, this trend can not be guaranteed in the future. "I'1~~.1 ~ ~ i I~ P~-> , Y ~-h3•c~n~ sc~~< $ 115 iuu~r~~$ C'a81k881g be rt'~'BSIttC~ tY19:C3''b~~ 5,101;± T:: ,~~1`7~~1~54~' t.^~ I`+ 111~~;~5 clli3~'t t'w'~r.C~3;~.~,E.! ill :',Tc,$,a~..t ~3V t."l~:$81 ~,tiiththis chan~~. Appendix G & Still in review G-14 This table can not be read at all. Please provide this table in a legible hard copy. H-1 Did OSMP consult w/ an experienced pd relocator to write the btpd receiving site relocation criteria? H-1- PDC Criteria #1- KBW disagrees that existing burrows must be evident. Numerous successful Areas relocations have occurred in areas w/o pre-existing burrows. This also limits relocation and could prohibit OSMP from reaching 14-26% occupancy in some areas. Even in relocations where pre-existing burrows are present, it is best to :9f7811<;ti3-~~~:,~ add additional burrows to accommodate territorial behaviors and coterie size etc. Additionally, what about historical occupation? There may be places where pdogs historically occupied these areas although existing burrows do not exist presently. Furthermore, this is not criteria included with the CDOW permitting process. Lastly, soil type and precipitation are both factors that can make this type of determination too inconsistent. While it is important to have and consider historical information, it should not be a decision making point. ~t~ line this indicates that the soils and vegetation were once suitable and does provide more immediate protection from predators, it should not be tantamount for pdog relocation. In general, any site with less than 6°ro slope and sandy laarn to loam cla}r texture soils (Reading and Machett 1997) in addition to meeting vegetation requirements should be considered as a good potential receiving area. for pdogs. Another consideration is the distance of a potential release site from existing prairie dog colonies which is important when translocations are designed to help build colony complexes. Maximum distances between colonies may be detei-xnined by estimated dispersal distances of prairie clogs. t~ rLC01]ll]1v11d $1llS cr1Gc8"ta sug.r~,~i$~-d a~ $he t8d'S$ p~aCc.~s $C! ~41411~, blt$ 710$ .183 c:xL1U~8~%U c;at~cs()8~'. H-1- PDC Criteria #2- This is a CDOW stipulation for the Northern CO region and the idea behind it is Areas to allow room for expansion. This does not however mean that when an actual relocation is performed, only 10 animals are placed in one acre. A relocation release site may encompass 10 acres to allow for 100 pdogs, but the pdogs will only be released onto a few acres as they 16 86 Location Comment would naturally occupy. This should be clarified. H-1- PDC Criteria #3- Some experts would suggest that applying insecticide such as delta dust is more Areas important than letting 12 mos. pass in time. Is dusting also a criteria? We believe CDOW requires dusting in the permitting process. Please confirm if you agree. Regardless, the 12 mos. Guideline set forth by CDOW is a guideline, not a regulation. The same experts would probably say that once an area is dusted, it is safe fore relocation. This could be an area for research to be conducted if not. But, KBW suggests that the 12 rno. passage be a guideline for OSIVIP as well and not an enforceable regulation. H-1- GP Areas See comments for criteria 1-3 above. ~H-1- GP Criteria #7- Where did these standards come from and what are they based on? They appear Areas too constricting. b.- which native species, specifically what fortis and graminoids and woodies is OSMP looking for? Please provide these specifics in the report. c.- relative perennial gramoinoid cover at least 60%- based on what? Which species is OSMP referring to or does the dept. just mean cool season grasses, or warm season grassed? Where did these criteria come from? (a) The relocation criteria for vegetation condition were developed by using the viability indicator ratings for several indicators of condition for the Mixedgrass Prairie conservation target. The methods for the derivation of the viability indicator ratings are detailed in Appendix D: Detailed friability Assessment. Standards for relocation were designed to allow for recovery of previously occupied mixedgrass sites to the extent that native vegetation, suppressed by year-round prairie dog grazing, could re-establish dominance and diversity in order to stabilize and retain soils, prevent a cumulative loss of native plant species in long-term occupied sites, provide good habitat for prairie dogs and associated species during future colonization, and contribute to achieving conservation objectives for mixedgrass vegetation condition in the Grassland Preserves. Relocation standards for vegetation take into account that a previously occupied site would take many unoccupied years to attain a condition matching that of the surrounding unoccupied plant communities. The relocation standards set condition objectives at lower thresholds (e. g., the middle of "Fair") than the thresholds set for vegetation composition in the Mixedgrass Prairie target as a whole ("Good" or better). The relocation standard for selected conservative species richness is set at the Poor/Fair boundary, because consen~ative species generally require longer periods to recover from disturbances (e.g., year-round grazing), aiid a low level of recovery for these species was deemed a reasonable expectation for areas that may experience recolonization within a relatively short time frame after becoming unoccupied. Again, what scientific literature related to prairie clogs supports this criteria'? e recommend i; egetation criteria for relocation be established in consultation with an experienced prairie clog relocator or scientists ~vho ha~re published on suitable prairie dog habitat. This criteria seems to be um~ealistic. ti~'e ha~,~e not seen literatuire to support these 18 plants and 22 °,~o 17 87 Location Comment cor er. Just looking far these 18 species could be complicated. I'or example, many forb species are seasonal meaning you would need to observe the site from about mid April through the encl of October to fully assess forb species. Cnaminoicls could be warm or cool season here again you need to look from April through the end of August to fully icientifi~ all species. j'i'e recommend that OSI~%IP consider the most important to prairie clog's diet is a hetrogenous mix available year round. Another way to consider suitable vegetation composition for prairie dogs is a good mix of cool and warm season grasses where the area is predominately warm season grasses. Additionally, some evidence of fortis and succulents particularl~~ prickly pear cactus would be ideal. ~~'e~ recommend removing the unrealistic and limiting criteria. of 18 plants and 22 cover and instead replacing the language with something similar to the above parameters. Again, the most important element to all of this is that prairie clogs are provided a heterogeneous mix in their diets. That is then need a variety of plants to properly provide them nutrients. "Prairie dogs may alter their clietai-~~ preference in response to seasonal changes in the nutrient content of available forage." See Forage preferences in two species of prairie clog: implications for hibernation and facultative heterothermy by Lelmler, Biggins and Antolin Journal of Zoology 269 (2006) 249-2~9 (b) OSMP is looking for any native species. Standards were developed for native species richness rather than for the presence of a specific set of species primarily because of the variation in the distribution of many plant species across the OSI~IP grasslands. There are several different plant community types within the IVlixedgrass Prairie target, each with a different suite of characteristic species. Standards requiring the presence of particular plant species would be more difficult to meet than standards based on generalized measures of vegetation composition. (c) Graminoid cover refers to the relative cover of all native perennial grass species, including cool and warm season species. A relocation criterion was developed for native graminoid relative cover, because many perennial native grass species are dominant, characteristic species in unoccupied OSMP grassland communities and are good indicators of the degree of recovery from previous prairie dog occupation. OSMP vegetation sampling data from mixedgrass communities indicates that perennial graminoid cover is the dominant component of the total native species relative cover in vegetation outside of prairie dog colonies. The cover of native perennial graminoid species declines over time in prairie dog colonies, and fortis typically increase in cover. For the relocation criteria, the threshold for native graminoid relative cover was placed in the middle of the "Fair" rating for overall native species relative cover. This is a lower standard than that for native species relative cover for the Mixedgrass Prairie target as a whole. *H-1- GP Criteria #8- KBW could not review habitat suitability model in the plan. Please supply a Areas legible version. Please see attachment. H-1 18 88 Location Comment Acreages of prairie dog colonies within each Updated - Mana ement Cate o 9/26/08 Pdogs Pdogs 07 % of GP in Grassland Preserves Acres (maxi % of GP max acres 2007 North BVR, BLIP, Beech 3187 1683 53 19 0.60 East Jafa /L nch 728 216 30 205 28 South Southern Grasslands 4127 676 16 611 15 Tota! 8042 2575 32 835 10 341 264 Pdogs Pdogs 07 Multi le Ob'ective Areas max acres 400 205 Pdogs Pdogs 07 Transition Areas max acres 1042 339 256 90 19 89 Colony ID Mana ement Cate or Pro ert Acres Criteria 1 Criteria 2 Criteria 3 Criteria 4 Criteria 5 Criteria 6 1 Transition Area Abbott 19.40 Yes Yes No Yes No Yes 2 Transition Area Andrus -north 12.70 No Yes Yes Yes No No ive rea n - s s awson -sou es o o es o es 32i ~~~sition Area Rla II ~J~s ~@s ~@ ~@@ f~@ ~@§ 3~ fiF@f1~l~l®h ~f@~ Rt~l~on 4~:8~ ~@@ R~@s NHS ~@~ ~4~s ~@@ 3~ ip}~I~{~I~Qf~j,ive Area (e'~r~d~lacker ~@@ ~@§ ~j~s ~@@ ~@s ~@@ 3~ ~rl;~r~erve ~@fi~~~Soot Lake 31~:~#~ ~@@ ~@@ ~J@s ~@@ ~l~s ~@@ 3~ ~F@@@I@~~ ~F@@@fii@ ~@~Ae~c~ren~l4~on 2~~:$~ ~@@ ~@@ ~@@ ~@@ 1Y@@ NJ@S 3~ ~i;~~erve north T~~S 1~~$ ~@>3 ~@@ T~~S ~@@ ~rl~l,~}r~erve ~@ r@~1d rtc~kith 3~:~~k NHS ~@@ NHS ~@~ MI@s ~@@ fiF@F~@I~I®f9 ~lF=@@ r?ove -south f~® ~@@ f~® ~@@ f~® ~@5 ~tl~tcl~i@~erve ~LI~--i~orth 12~:$~ Y@@ ~@@ ~J~s ~@@ 1~~ ~@@ ~F@@@I@F9~ ~F@@@fii@ ~Lo~i~ti~ta 2~~:96 ~@@ ~@@ ~J~s ~@@ ~~S ~@@ 41 Transition Area ~BrCor - L asture 37.08 Yes Yes No Yes Yes No ~Ca~ti I@~ ~ ~~Area r~tgacci ~~:~9 i'@~ ~~@ R4@s ~@~ ~j~s Y@~ 43 Grassland Preserve ~~~~03 Corp - L pasture 40.19 Yes Yes Yes Yes Yes No erve arp - s s erve or s s s - s n- s serve are ison - wes s s s s o s u i e ec ive rea M.CE -south Yes Yes Yes Yes o Yes 61 Transition Area Johnson north 1 37.94 Yes No Yes Yes No Yes 62 Transition Area Klein -Dry Creek 26.01 No No Yes Yes No Yes 63 Multiple Objective Area Klein -south 3.70 Yes Yes Yes Yes No Yes 2~ 9a Location Comment Transition Area ~alf~ 1~.1~ Yes No Yes Yes No Yes ®9 ~ril~al;erve ~a lior Associates -new 8.~1 Yes Yes it4es Yes ~4es 114es 186 iil~srd,P~erve t~sociates - NW B~.~Q Yes MJes Mies ides ides Yes 18~ Grassland Preserve for Associates -south ~,6.~8 Yes No Yes Yes Yes 114es 186 ®r~~~ler4dl }~e~~u,~rea S1~vshti~ld Associates west 5~.8Q Yes Mies Yes Yes Mies Yes 189 Be~aei~id~eserve ~1.c~~ie4ss~thtes west 46. Mles No lies Yes Mles Yes 104 ~r~~~~~g~~~ation Superior Associates west 9.77 Yes No Yes Yes Yes Yes o s erve o s s erve eJ 16 s s 73 ~f~ servation Minnetrista 51.78 Yes Yes No Yes No Yes 1 ~D~ ~reasition Area ire 76.9 it4es 114es it4es Yes No Yes 1 ~3 Transition Area Ad~1rltButte -east ~.8~ ides No ides Yes No Yes 1 ~8 AZ~IrVa ~~nt Butte -west 69.8 No No ides Yes ides lies 111 ~f~t~~t~servation Van Vleet -east 15.76 Yes No Yes Yes No No 1 s s i s rea s rea s b u /V eet -south 88 ~fi~ ~8~~~ation Schneider -east 27.60 Yes No Yes Yes No Yes 1 ~9 island Preserve '~e~tk~~rest ~6.~8 lies Mles Yes Yes No Yes 190 1Ghal~i ~I~ ~e~ive Area 5~ah~e east 2.05 Yes Yes Yes Yes ~4es 114es 191 1Ghalfi ~I~ ~e~ive Area elsouth 1.96 Yes ides Yes ides it4es it4es 192 ®r.~~pler~dki}~e~~,~rea '~i.`ai~mh~f 46.f~~ Yes Yes Yes ides ides it4es 193 Transition Area B~iethorth 16.69 Yes Mies Na Yes No No 194 1Ghal~i~rl~i~e~ive Area Stee~outh 48.9 Yes Yes ides Mies No lies 125 ~i~t~~t~~servation Gebhard 0.63 Yes No Yes Yes No No s i~ k 3 . 2. 21 91 Location Comment 22 92 To: Open Space and Mountain Parks From: Michael Katz, 42 Benthaven Place, Boulder, 80305 Re.: Grasslands Ecosystem Management Plan (GEMP) December 5~', 2008 I a.m writing to provide OSMP with comments on the Grasslands Ecosystem Management Plan (GEMP). While I am not a scientist, I am a frequent visitor to Boulder open space and have been a staunch supporter of the open space program since I first came to Boulder in 1972. While my interest in the environment predates my amval in Boulder, a great deal of what I have learned about the natural world has come through my experience and observation while on Boulder open space, as well as by reading the publications of the many environmental organizations to which I belong. While some of what I say here is critical of the GEMP, I believe that I share most of the values and goals of OSMP. I am a strong believer in the protection and preservation of the environment for its awn sake, but I also believe that an essential requisite of achieving that goal is to make the natural world an integral part of all of our lives. Thus, when I read something like the GEMP--which only addresses environmental concerns--I find myself wondering "What will the adoption of this Plan actually mean `on the ground;' and how will it change the landscape (literally) and limit the visitor experience?" I have read the letter to OSMP from the Boulder Outdoor Coalition (BOC) of which I am a member, and I agree with all of the points contained in that document. I am also a member of Friends Interested in Dogs and Open Space (FIDOS); and although FIDOS is a signatory to the BOC letter, I believe that they may be providing OSMP with some additional input--although I have not seen it. While I do not speak for FIDOS here, I think my comments are likely to reflect the views of many in the community who recreate with dogs. L) The GEMP Point of View. Obviously the GEMP was written by ecologists, and their primary focus is on the preservation of the land and species that exist in our grassland environment. They are singularly focused on the health of this ecosystem based not only on the species that are found here now, but with an eye toward the species that were once here and/or could be sustained in this type of ecosystem. The GEMP is also concerned with "restoration" where the authors find the environment lacking by some measure of its former~r potential-health and diversity. For these reasons, although the Plan is certainly an impressive undertaking, it strikes me as rather one-dimensional and even a little out of touch. For example, while it makes mention of some of the changes to this environment over time as a result of such things as deliberate extirpation of species, wide spread agriculture, suppression of fire, etc., it does not seem to make a realistic assessment of what should be expected of this 24,000 acres of grassland that are now intertwined with houses, farms, and urban development. And while the writers no doubt understand that this land is no longer remote, separate, or pristine, they seem to completely ignore a major reason for its acquisition: Its value to the community as a place for people. The fact that accommodating human use involves trade o$'s that will result in less than optimal habitat quality and species numbers or diversity from a purely ecological point of view is, at best, only grudgingly recognized without 93 seeming to be accepted and incorporated into the plan. I)n The GEMP Assessment of Threats. While the GEMP certainly contains many references to human impacts on this ecosystem that go back well over a century and have nothing to do with recreational use, it nonetheless lists incompatible trails, recreation, and dogs as among the Critical Threats (p. 74). This would be remarkable enough given the lack of scientific evidence to support this claim, but it is even more surprising in light of the obvious: The complete transformation of the American grassland ecosystem as a result of historical patterns of settlement and use. Clearly it was not recreation, or dogs on ranches and farms, that essentially wiped out the tall and short grass prairies that are the subject of the GEMP. It was primarily farming and ranching. Yet agriculture rates as only a Medium Threat in the Plan (pp 75-76). The only way this ranking of threat can be explained is that the authors assume that they can protect the land from further agricultural incursion, whereas recreation and dogs cannot be "contained" within any reasonable limits-an assumption that is in no way rational or scientific. The threat from recreation and dogs apparently comes from disturbance of birds and mammals, trampling of vegetation, soil disturbance and/or increases in nitrogen in the soil favorable to invasive plants, and transference of seeds. No doubt all of these things do occur to some degree, but so as to constitute a critical threat to this ecosystem-that is, place its very existence in jeopardy? I think this view borders on a hysterical reaction, just as it downplays the historical reality. It not only fails to see the "big picture," but, sadly, represents what I think is an unfortunate bias on the part of the staff who share it. The GEMP is replete with "soft" references to what a dog (or recreation) "can" or "may" do; and sinularly soft references to things such as species "sensitivity." But the fact that a dog can or may chase a deer or a cow, eat a bird or frog, or kill a squirrel or prairie dog, hardly justifies the conclusion that this is routinely happening, will happen, or will amount to a serious threat to the ecosystem if it ever happens. Likewise, species may be "sensitive" to human activity-i.e. capable of being disturbed for some period of time or displaced in some number or for some distance-but that hardly rises to the level of a critical threat to the health or survival of that species in the real world. If it were so, this open space ecosystem, with all its diversity and abundance of native plants and animals, would be long gone by now. To put some of this in perspective, in her 2007 book "The Silence of the Songbirds, " Dr. Bridget Stutchbury examines the reasons for the decline in songbird numbers in North America. In her entire book she makes only o~te reference to dogs with regard to impacts on birds. Specifically, in her chapter on "predation" she mentioned that dog tracks-along with those of many other mammals such as racoon and skunks-were picked up on tracking plates near bird nests in a study in suburban Maryland. I gave a copy of this book to Mark Gershman of OSMP last February after he had sent FIDOS a copy of an Australian bird study entitled Biology Letters by Peter Banks and Jessica Bryant. That study had documented some changes in both numbers and variety of bird species along trail corridors in the inunediate aftermath of both human and human/canine presence. In light of what I had read in her book, I decided to contact Dr. Stutchbury and ask her opinion of the Australian bird study. We had an e-mail exchange, and I 94 enclosed her comments in the copy of the book I gave Mr. Gershman. (I am providing another copy of those comments with this letter.) As can be seen by what she says, Dr. Stutchbury was critical of the Australian study in part because impacts need to be measured over weeks and months, and not "minutes;" and more importantly because the real concern is whether birds suffer lower nesting success (or even mortality of adults) when people and dogs are present as opposed to more mundane or fleeting effects as a result of disturbances. Therefore, I would submit that the GEMP's frequent use of the term "sensitivity" regarding various species carries little weight; and is revealing in that it thinly veils both a lack of specificity of harm being done mush less proof of long term and serious consequences. To underscore the point further, I have previously provided several OSMP staffwith a portion of a transcript from an NPR program called Living oar Earth that aired in May of 2005. The subject of that program was the impact of magpies on songbird populations, and hidden cameras were used to observe nests. One of the surprising results of the study was that it revealed songbird populations increased as the number of magpies increased. But, more to the point is that the hidden cameras showed that it was predominantly squirrels that came in and ate the eggs and the babies. Perhaps even more interesting was the revelation that deer were seen to eat of a lot of the eggs and nestlings of the ground nesting birds. (I am enclosing a copy of that portion of the transcript of the show with this letter.) I think it is reasonable to ask whether "species sensitivity" to the presence of humans or dogs stacks up against such predation in the "big picture." Closer to home is a study by Scott Nfiller, Richard Knight, and Clinton Miller entitled "InfJrrence of Recreatio~ral Trails on Breedi~ig Bird Communities. " This study was conducted in1994-95 on City of Boulder Open Space and Mountain Parks property, both in forest and mixed grassland communities. They recorded 13 bird species in the grassland ecosystem and 29 bird species in the forest ecosystem. They found three grassland species significantly more abundant along control transects than along trails; and five forest species significantly more abundant along control transects than along trails. (Conversely, Robins were significantly more abundant along forest trails.) They also found that two of those three grassland species increased in abundance with increasing distance from trails, and four of those five forest species increased in abundance with increased distance from trails. (Robins were found to be more abundant near forest trails than away from them.) They also noted that two species-Black-Billed Magpies and House Finches-were n~rly found along the forest and grassland trails; and that for all except one of the bird species where they found less abundance in proximity to trails the "zone of influence of trails" was about 75 meters. They state that they were unable to answer the question whether the influence of recreational trails on bird communities that they observed was due to the physical presence of the trail (habitat edges) or Innnan distrirbance. And despite the fact that "the intensity of recreational activities on our study area was extremely heavy," their conclusion was fairly mild: "The potential effect of recreational disturbance cannot be discmmted." Another, even simpler, example of the GEMP's bias-or at least a lack of perspective-is that while dogs chasing prairie dogs is mentioned under Critical Threats, Sylvatic Plague is characterized as a Low Threat to prairie dogs (p. 77). This, despite the fact that the Plague has periodically taken a great toll on prairie dog numbers, and that the GEMP states that it has the "potential to 95 significantly reduce prairie dog populations quickly in an unpredictable and unmanageable way." While I am sure that some dogs have chased prairie dogs, and even caught them, it would seem that in any common sense real Life assessment of risks the GEMP has this threat assessment turned upside down. It is very interesting that while invasive plant species are separately listed under Critical Threats, the GEMP places substantial blame for this problem on trails, recreation, and dogs-yet another example of a bias that fails to place the theoretical into a bigger real world picture. I must insert a personal experience here that I think might illustrate my point. The GEMP makes reference to "difficult to control invasives," and specifically links knapweed to trails and recreation. . ICnapweed is a subject I know something about. I own a home on 7 acres of what was once an upland farm in the Door County Peninsula of Wisconsin where I now spend my summers. Door County, like Boulder County, is a beautiful place that prides itself on having a strong environmental ethic. It has lots of public land--five state parks and several county parks-along with 250 miles of shoreline and thousands of acres of land protected by private organizations such as the Nature Conservancy and the Door County Land Trust. Like Boulder, the Door Peninsula has several microclimates and a diversity of ecosystems, from wetland to dune to northern boreal forest; and there exists a remarkable diversity of native plant and animal species. Knapweed is so pervasive in Door County that it is often referred to as "Door County Heather;" and I have spent countless hours digging out knapweed on the land that I own. But if there is one thing that is absolutely clear, it is that the many thousands of acres of fields and meadows where this plant flourishes in Door County were never used for recreation and have few trails. Instead, these lands were all tilled and farmed for generations. Once that activity ended the knapweed took hold because it had been mixed in with the farmers' hayseed and out-competed many of the native flowers. The contrast with the grasslands, meadows and forests on Boulder open space-particularly west of Broadway-is striking. Despite all of our miles of trails, decades of use, and millions of visitors, we have a truly amazing native plant community. Penstemon, golden banner, western blue flag, arnica, Indian paintbrush, aster--the list goes on and on from March through October. And, perhaps as striking, is the lack of the invasive plants such as chicory and knapweed along our miles of trails. The point of all of the above is not to argue that dogs or recreational activity have no impact at all; nor it is to argue against seasonal closures, careful planning of trails, and avoidance of particularly vulnerable populations of plants and animals when possible. Rather, the point is to contrast the type of impacts we've seen with the notion that passive recreation is a Critical Threat that will imperil the ecosystem. III} The GEMP Vision for this Land. I get the impression that the OSMP ecologists have a vision for this ]and that approximates a wildlife preserve or a botanical garden. To the extent that they would like it to be that way, that vision is not realistic. The land which is the subject of the GEMP is not private land, nor is it a blank slate on which to create~r re-create-the ideal prairie ecosystem. It is owned by the public, and the community has had access for years. It is fair to say that an essential element of the "compact" between the people of Boulder and our municipal government is that access will remain a major component of the open space program. There are many land trusts and conservancies within this 96 country that have used private funds to buy critical, endangered, or even degraded lands for restoration and preservation. I myself am a major supporter of one such group-the Door County Land Trust. And of course the work of the Nature Conservancy is well known, and highly regarded. Indeed, the West TSA will use a planning framework developed by the Conservancy known as Conservation Action Planning. But when referring to such a model for the management of Boulder open space it should be remembered that these private organizations typically limit access and trails, and they are very restrictive with regard to recreational opportunities. Which brings me back to my question: "What will this land be like in light of the GEMP?" It is not too much to ask of OSMP that restrictions on access, forms of recreation, or the closing or realignment of trails, be justified-and not simply with general statements about what recreation "can" or "may" do, or numerous references to "sensitivity" of species. Policy decisions need to be backed by numbers--and cause and effect relationships. After aII, the Endangered Species Act and the various environmental protection laws that deal with serious environmental threats to plants, animals, and humans all require this. It is not generally acceptable to place prohibitions on human activities-even those that are much more disruptive than passive recreation-without "making the case." It is possible-and necessary-to know the health of a species, how many individuals are left, how many were there 5, 10 or 20 years ago, what are the reasons for the change in numbers, and what speck actio~r is needed to stabilize or reverse the trend. Only then can the costs and benefits be weighed and informed policy decisions be made. It is true that the laws to which I refer are federal laws, passed by a congress that is not, as a body, as environmentally "friendly" or as opposed to human activities as, for example, the Boulder City Council. This is probably a good thing for all of us in Boulder; and OSMP is certainly fortunate that it will have an easier burden of persuasion in "making the case." But OSMP should not forget that the people of Boulder are the owners of this land, we are the "body" that most matters, and we are watching to see what will develop. Conclusion. It strikes me that there may not be another 43,000 acres of Iand in the United States more fussed over, studied, and having more money spent per acre on management than the City of Boulder open space. Perhaps some EPA Super-Fund site, or a wildlife preserve somewhere that contains dozens of endangered species...? I don't know. We have had years of VPAC and Community Group Forums, not to mention the development of the Visitor Master Plan (VNiP). Just when one might think we were done and it was safe to "go back into the water" comes the TSA process, also scheduled to take years. And now, on top of those layers of management and study we have the GEMP. I think that the BOC has it right when they say that the GEMP should not be something that trumps the VMP or the TSA process, but rather should inform it. Blanket GEMP policy "wish lists," such as reducing trails within 200 m of wetlands and riparian zones by 50% in 10 years, are fairly arbitrary and should be regarded with skepticism. And OSMP should resist "micro-management" of the land and the species on it. It isn't needed, and it cannot be done. 97 Below are Dr. Bridget Stutchbury's comments on the Australian bird study by Peter Banks and Jessica V. Bryant contained in "Biology Letters." These comments represent the full text of four separate a-mails on the subject that Dr. Stutchbury sent to Michael Katz in January 200'• Hi I'll lookup the article and get back to you. My personal experience is that dogs are a disturbance (chasing squirrels etc) to birds and may reduce nesting abundance and nesting success; but in a different way than cats. Dogs do not usually stalk songbirds or attack their nests deliberately. The big difference is the lack of supervision of pet cats that are allowed outdoors (whereas dogs are typically controlled to a great extent by their owners who are nearby) and the exceptionally large population of feral cats and their active maintenance by misguided cat lovers. Bridget Hi Michael I was not very convinced by the Biology Letters article. I thought the authors repeatedly over-stated the importance of their findings. The study was carefully conducted - so they do deserve credit for that. First, though they show a "41% reduction in the numbers of birds", this actually translates to a real difference between detecting 10 birds per census vs 7 birds per census (for areas where dogs are already allowed). For species, they found an average of 5.4 vs "only" 4 species when a person & dog walked down the trail. Percentage-wise this is a big difference, but one should be careful to extrapolate from these small numbers to making grandiose claims that dogs can "cause a depauperate local bird fauna". My second main concern is that the effects they measured, which are real, are so short term and fleeting effects. They did their census immediately after the dog and/or person walked down the trail, so the low numbers show that birds will temporarily move away from the immediate area. I have noticed this in my own solo walks through the woods -many forest birds will shut up and move away from where I am (which is annoying since I'm trying to see the colour bands on their legs, or find their nests). What we really should be concerned about is whether the number of birds settling and breeding in an area is reduced by dog walking (e.g. measured over weeks & months, not minutes) and whether these birds suffer lower nesting success (or even mortality of adults) when dogs are present. These more serious effects can 98 & do occur in the instance of housing near woodlots and ATV use, for instance. Best wishes Bridget Stutchbury Hi Michael I am meeting with all my grad student today, for our weekly "lab lunch" and chose the dog walking study for our discussion paper. Its a great of example of exactly what you describe in your email - a superficial study where authors deliberately lead readers astray. Best wishes, and thanks for the very enjoyable exchange.... Bridget Yes -you may share my emails regarding dog walking & birds... best, Bridget 99 Below is portion of tent from NPR show Living on Earth, which aired the week of May 2T~, 2005. Program was entitled "Mad about Magpies," and discussed how they are hated and even hunted by people in the Western United States. Of particular interest is the portion of show where Kevin McGowan of Cornell Lab of Ornithology talks about putting cameras on birds nests to see who actually eats the eggs and chicks, and finds something quite interesting and contrary to people's observations and beliefs. Whole text of show can be found-and heard--by searching for Living on Earth: Mad about Magpies. HAND: Yeah, that's from The Birds too, my point being that it's really hard to untangle fable, in this case film, from scientific fact when it comes to magpies, corvids, and well, nature in general. Kevin McGowan of the Cornell Lab of Ornithology says all this magpie directed malevolence is misplaced. MCGOWAN: Partly it's because some of the things we see them do we don't like. And, we don't have a sense of how important that is to the whole grand scheme of things. So we see them come in and take a robin's nest and eat the babies and we're all upset by that and we think of them as these nasty thieves kind of thing. Well in fact they're not thieves, they're just trying to raise their own young. HAND: In fact, one study found that songbird populations actually increased as the number of magpies grew in the area. McGowan believes we label magpies and other corvids as wanton killers simply because they are big obvious birds and when they do something we find distasteful, we notice it. Whereas lots of unexpected predators in nature sneak by unnoticed. MCGOWAN: As studies recently have been putting cameras on bird nests and seeing who it is that's actually coming in and eating those eggs and babies. What we're Ending is that it's predominantly squirrels. HAND: Squirrels? [MOVIE CLIP] HAND: And McGrnvan says nest carers Izave caught another unlikely suspect Deer eat a lot of eggs and nestlings of ground cresting birds I tell you, I didn't expect that But it's not just a gr~estiofe of then: accidentally breaking eggs as they're cropping grass either. There's video of them ach~ally cl~asing dmvn little fledglings that are trying to run away from the nest and grabbing them and gulping tltern dmvn. 1QQ Comments on the Boulder Upen Space and Mountain Parks Proposed Grassland Ecosystem Management Plan Prepared by: Paula Martin; Director Prairie Ecosystems 720-345-8243 / pdbaby101(a~,aol.com 101 Boulder OSMP generally represents the best of the best in open space management. Once again, BOSMP has created a proposed management plan that is thorough and integrated. The varied habitats incorporated in the planning region, alone represent a serious challenge. Add the variables of human use and wildlife management and it becomes exceptionally difficult to achieve a balanced and successful plan. The attention to detail of the multiple habitats, uses, and wildlife are presented in awell-researched and rational context. I appreciate the opportunity to comment on the cutting edge and potentially world-class proposed Grassland Ecosystem 1Vlanagement Plan. I am a sixth generation native to the plains of Colorado. I have worked with numerous species of prairie dogs in eight states and Mexico for nearly twenty years. The primary focus of my experience has been with developing humane relocation and conservation techniques. This focus has evolved into creating standards for relocation, habitat suitability models, and prairie dog threshold models. I have been specializing in resolving conflicts between prairie dog advocates, prairie dogs, and anti-prairie dog contingents for the greater part of the past decade. For these reasons, my comments will focus on the aspects of the proposed plan which pertain to Black-tailed prairie dogs; their habitat and management. Much of the content on the Boulder OSMP website page on prairie dogs is based upon a brochure that I authored in the 1990s. First and foremost, I sincerely applaud BOSMP for seriously restricting the use of lethal control as a management option for existing prairie dog colonies. I believe your proposed plan represents the most progressive approach to prairie dog management in this regard. A) The Significance of Boulder to Black-tailed Prairie Dog Conservation My primary comment is not directly related to the plan, but to the importance of successful prairie dog colonies and complexes in Boulder County. I am convinced that Boulder and Fort Collins, Colorado represent two of the most significant opportunities to ensure the survival of the Black-tailed prairie dog. While the overall occupied acreage may seem relatively small in the overall picture, the goal of preserving prairie dog towns in central Colorado may be realized in Boulder and Fort Collins. 102 Large prairie dog complexes exist elsewhere, but they are often the victim of unregulated shooting and poisoning (for example, an extremely remote proposed wilderness area in New Mexico recently loss the largest Back-tailed prairie dog towns through shooting). It is not only difficult to regulate lethal removal activities in these remote regions of the West; it is equally as challenging to gather accurate population data. Even in areas where the Black-footed ferret has been introduced, the presence of prairie dogs often becomes a catalyst for serious conflict and these areas are often reduced to what could be considered a wildlife war zone, (such as central Kansas). State and local laws, as well as public misconceptions tend to promote the slow, but steady elimination of prairie dogs from large regions. Of course, plague outbreaks play a major role in the decline and potential extirpation of remote prairie dog towns. This dynamic has been documented most recently on Comanche National Grasslands in Colorado and the Black-footed ferret introduction areas in South Dakota. The peaceful and democratic opportunity to conserve prairie dogs in Boulder is both welcome and of key importance. Regional extirpations arc often downplayed in their importance to species survival, but the `death by a thousand cuts' dynamic is exactly what has lead to the imperiled status of prairie dogs everywhere -Where do they retain any real protection? The positive 90-day finding to the current petition (Wildearth Guardians 2007) to list the Black-tailed prairie dog as federally Threatened or Endangered was issues by The U.S. Fish and Wildlife Service during the week of December I, 2008. Such a swift and certain announcement of the positive finding should also be incorporated in decisions pertaining to prairie dog occupancy. With that being said, I would like to offer some brief comments and input on the following subjects: 103 B) Prairie Doh Colony Management Desi6nations Prairie dog Conservation Areas (PCAs) appear to be limited to five locations. Considering the previous and current, more limited, extent of prairie dog colonies on BOSMP, I find this number to be inadequate. The determining factors and steps leading to the designation appear reasonable and are applauded, but determinations should be adjusted to include more conservation areas. In the document, it is stated that recent plague outbreaks have reduced populations, but populations were not entirely extirpated and they may begin to rebound. Given the unpredictable and relatively uncontrollable nature of plague outbreaks, it is important to err on the side of caution and not assume that a subsequent plague outbreak could not eliminate large sections of key prairie dog populations on BOSMP. It's important to acknowledge the large acreage which was lost to plague over the past few years. Transition Areas should not only be used as a tool to limit prairie dog populations, but also to encourage education, and reasonable management and acceptance of prairie dogs. This slight shift in language and focus could produce some surprisingly pleasant results. I am concerned about potentially limiting prairie dog occupancy to 14%-26% of available habitat. This may be based upon solid data from one document and under certain circumstances, but it is important to allow for other data and the significance of BOSMP to prairie dog conservation to figure into occupancy rates. I have serious misgivings that this restriction could be used to initiate unnecessary removal or cause PCAs to be re- designated as Removal or Transitional Areas. The 14% - 2&% occupancy rate should be used as a general guideline, but colony locations should be evaluated individually. I am in agreement that 144% occupancy of available habitat is not a reasonable goal for prairie dog conservation, but it is also highly unlikely. 104 For the purpose of clear understanding, it would be helpful if the maps included street names and / or the names of the open space regions designated. Additionally, the colors chosen for differentiating Removal and Conservation Areas are difficult to discern. I would like to see prairie dog inhabitation listed in terms of current and previous occupied acreage and density. C1 Urban Populations An apparently substantial number of prairie dogs currently reside in what could be considered an urban habitat. Biologically speaking, some of these populations may not provide a significantly positive impact on the ecology of the region. While larger areas of prairie dogs are important ecologically, it is also important to recognize the reasons for retaining some in-town populations. Urban populations are not completely void of other species. I have witnessed raptors, including burrowing owls, (Santa Fe and Albuquerque, NM), badgers, fox, and coyotes on urban populations on dozens of occasions. Additionally, during urban relocations other species are often found inhabiting the burrows, including tiger salamanders. Of course, the function of prairie dogs on soil and vegetation maintenance is restricted and often eliminated in urban circumstances. However, if prairie dogs are residing in a given area that does not provide direct and unmanageable conflict with human use, conserving these populations should be a goal of the plan. Urban populations also provide positive functions in terms of resilience during plague outbreaks (due to their isolated location); and also as populations to help augment ecologically important colonies of the region after declines following a plague epizootic. The additional functions that the prairie dogs may provide are educational opportunities 105 D) Associated species I am pleased to see the extent of consideration relating to species associated with prairie dogs. It would be helpful to provide information about Bald Eagle nesting and hunting locations and how they relate to prairie dog towns. Perhaps this overlap could be helpful for enhancing PCAs and opportunities for research. Larger occupied acreage would be likely to improve habitat for burrowing owls and may attract Ferruginous hawks to the region. Indeed, the proposed plan outlines the ongoing decline of burrowing owls in general, and the disappearance of mountain plovers from Boulder County. This information provides a catalyst for conserving prairie dogs in the plan and promoting expansion of occupied acreage to promote ecosystem function. E) Prairie Doi Relocation Guidelines The biological information provided for evaluating the habitat suitability of potential prairie dog relocation sites is relatively acceptable. However, it is important to also include political issues as a category, such as proximity to property boundaries and adjacent property use /habitat suitability, as well as any leases which may be held on the property. This element would help to prevent future conflicts with prairie dogs. I do not believe that it would pose a serious obstacle to designating relocation sites. Guidelines should also be defined which represent the most progressive methods available and highest survival rate for removal, land preparation, release, and post-release survivorship. Post release monitoring and the potential need for supplemental support during extended periods of drought may also be considered.* 106 F) Closing Comments The proposed plan outlines the great loss of prairie dog towns and associated species as close as Louisville and Superior. It is important that the last bastion for prairie dogs in the region be thoughtfully and thoroughly preserved. As scientific information about environmental concerns becomes increasingly more available to the general public, the awareness and respect for wild lands and open spaces will increase. The long-term value of wildlife and western heritage is becoming ever more apparent. Additionally, the goals and intentions of traditional western land uses and conservationists are becoming more congruent. With the cooperation of varying segments of our society, we will be able to conserve the most beautiful and productive aspects of what makes out region unique -thus creating awin-win situation for both our natural heritage and the future of our culture. Our long-term wealth and persistence in the Rocky Mountain West depends on it. 107 Nov. 21, 2008 TO: OSMP FROM: Tim Seastedt RE: comments upon Grassland Management Plan. Introduction and Overview The public comment meeting on 11/20 did not identify what I see are any serious deficiencies in your plan. The conversation did suggest the following two points: 1..Your knowledge base of this system far exceeds what the public was able to see or read. For example, Mark's response about managing prairie dogs in aplague-mediated landscape demonstrated an awareness of the uniqueness of key management concerns. 2. Capacity building needs more emphasis (and this is restated below... something I sensed before the meeting). In particular, it's time for some outside the box win-win strategies to solve OSMP-neighbor relations as well as some creative new human uses of OSMP lands that are compatible with and enhance OSMP mission objectives. I taught a class this semester on how plant communities were being influenced by global environmental change factors. The class focused on local and regional ecosystems and spent time studying climate change, atmospheric chemistry (carbon dioxide and nitrogen deposition effects), changes in disturbance return intervals (e.g., fires and floods), fragmentation and human disturbance effects, and invasive plant and animal species. The class also made several field trips to public lands in the area Given that background, I asked them first to list what they thought were the greatest threats to OPSM, and we then voted on what was most important from their list. Invasive species and human issues (the combination of fragmentation, trails, disturbance, etc) were their greatest concerns. Thus, the class concurred with some of the `very high' threats identified in the report. They were not presented the specific problems with dogs on Open Space prior to the exercise so that didn't make their list. Second tier issues included fire suppression (which matched up well with your identified concerns), but then the class -perhaps not surprisingly given the course content- identified climate change and atmospheric chemistry issues as something that needed to be identified and factored into your program. If there's one omission in the plan, it's the recognition that the combination of fire suppression, climate and atmospheric changes are now upon us, and our OSMP ecosystems are showing responses similar to those currently being reported in the scientific literature. That fact needs to at least be acknowledged in a forward- lookingconservation program. While it was obvious from the public comment session that this was not on their radar screen. It is very much on the radar screen of land managers, as indicated by the articles I've shipped to you recently. If one accepts these findings (and obviously, I do), one has to think that the dominant warm season plants (species with the Ca photosynthetic pathway) on OSMP are at risk by increased competition from cool-season plants (species with the C3 photosynthetic pathway). What limited 108 data we have support this contention. While this risk can be minimized with management, it should be acknowledged. Further, I think most of the class agrees with me that the majority - butnot all - of the current threat of invasive species is related to other global environmental change factors that are expressing themselves locally. The actual threat is directional environmental change, which expresses itself as species change and particularly as invasive species problems. The implications for management are large in that, unless you mitigate for the causes of species change, getting rid of the undesirable species will not necessarily generate a desirable outcome. That fact has to be up front in any management or restoration effort involving invasive species. Again, you may already know this and have it factored in, but that fact wasn't obvious. A second fact about directional change means that the way your report treated `feasiblity' and `benefits' is weakened due to the fact that what has worked in the past may not work in the future. Some specific examples are included below. Things I really like about the report: 1) Inclusion of a real monitoring plan! Thank you! Given the expectations of change due to environmental drivers, monitoring assumes even more importance than it has in the past. 2) Overall, I appreciated the viability assessments. This is viewed as a superior way to do ecosystem management in that it "focuses on what we want." ThaYs key, and the monitoring will allow you to assess if you're moving towards those goals. 3) Recognition of how the altered hydrological regime is affecting lowlands and riparian areas. Serious vegetation transformations have occurred because of this (indeed, and have `spilled over' into roadside and lowland prairie sites), and making decisions to `live with iY or do what it takes to fix it are appropriate. However, some linkages between the impacts of altered groundwater and site characteristics and management were not made in the report. (For example, attempting to remove or reduce selected plant invaders without controlling the hydrological regime is probably a very large waste of time and money.) As your own OSMP staff member, Robert Crifasi published in Environmental Management in 2005, your riparian systems are very much "hybrids" and need to be managed for what we want. These are not "natural" systems but can be managed for maximum biodiversity, etc. as such activities are viewed desirable for both cultural and ecological reasons. Issues to discuss: The use of community associations as targets (e.g., a phytosociological approach) is not going to work, at least, not for long. These associations are human conceptualizations that are valid if the rules that formed the associations remain intact. But, the rules have changed and are going to change even further. Community interactions are in a state of flux due to new and altered biotic interactions (e. g., Suttle et al. 2007, Tylianakis et al. 2008). New species combinations and changes in plant dominance are the realities of global environmental change. However, target 109 species lists, target dominant species, and target richness values remain appropriate and logical management goals. Estimation of the historical range of fire return intervals appears a bit conservative. An acceptable range of 5-30 years seems in conflict with the Veblen et al. (2000) finding for the low-elevation Ponderosa savanna areas of the Front Range. (Fires likely moved from the plains into the Front Range, although the 2002 Overland fire demonstrated the opposite was also possible.) You cite the Veblen study in the references, but don't seem to use those results in the calculation of fire return intervals? A larger issue is the emerging finding that, once outside historical range of variability, disturbance events don't function in a traditional fashion. For fire, the concern might be that the consequences of fuel loading produces too hot an effect or that the existing seed bank is so altered that post-fire succession is now a novel phenomenon. Add to this the fact that the global change drivers of climate, carbon dioxide, and nitrogen deposition also interact with fire return intervals. At Konza Prairie, the historical fire return interval now appears too infrequent to prevent woody species expansions onto the prairie. You will likely experience the same problems, particularly because private inholdings are likely to function as refugia for woody seed sources that will be spread by wildlife and humans. And, of course, the large degree of fragmentation and trails guarantees human-related introductions as well. Thus, my feeling is that OSMP acknowledge and attempt to obtain a lower average fire return interval, at least in `prime' areas. I realize that this goal is constrained by strong sociological and economic considerations, and these issues may preclude a target return interval. Further, expect `fire effects' to change in the coming years. This suggests a fairly generic concern about your Feasibility Analysis. You point out that feasibility involves using a strategy that has been shown to work before. Under the "new rules" imposed by global change drivers, what was feasible may not work or work differently now. This holds for fire, and this holds for managing invasive species. Similarly, benefits attributed to certain management actions maybe over- orunder-valued. As I mentioned, the `viability assessment' was viewed as an excellent attempt at providing an assessment of current conditions. Unfortunately, in terms of conservation strategies, it appears that much of what will be done will be to get rid of what we don't want rather than maintain or improve what we want? If I've missed this point, I apologize, and the monitoring should provide an evaluation of that issue. However, the newest literature, for example, is fairly consistent in showing that invasive species removal, alone, does not enhance native species abundance or diversity. The current scientific literature negates the paradigm that some ecological benefit is (implicitly) obtained by killing non-native species, yet this fact has been slow to reach managers, perhaps because there's long-standing and continued public support for killing non-native species. This is now viewed by much of the scientific community as xenophobia. This does not mean that individual non-native species are not problems, but as the current report has used the generic position of natives versus non-natives, iYs important to recognize the limitations of this approach. You cannot necessarily enhance desirable species by killing undesirable species and that needs to be incorporated into more proactive management actions. 110 How can OSMP best address the identified conservation issues in an era of global environmental change? The synergistic effects of changing climate, atmospheric chemistry, fragmentation, fire suppression and novel species are real. For example, the expanded growing season, carbon dioxide enrichment, and nitrogen deposition all individually favor cool-season photosynthetic pathways, and together, they change the rules of plant competition. These are pathways common to most Open Space plant species, but by species that historically occupied perhaps a maximum of 50% of plant cover. Clearly that cover percentage is going to increase regardless of the fact that our entire current suite of invasive species (save a few grasses seen outside of OSMP) are cool season species also favored by these environmental changes. Our dominant warm season species, the species that characterize much of the tallgrass prairies and a substantial portion of the mesic prairies, are going to continue to decline unless `strong' (potentially new) management techniques that favor these species are employed. Further, the local and regional science findings support the contention that woody species are also favored by current changing conditions. Again, something other than classical management of grasslands will likely be necessary to keep shrubs as a modest fraction of plant cover, particularly in the foothills. The environmental change effects impose limitations on the values given to "Key Attributes and Indicators." A system containing native and non-native species may now be more resilient to (say) drought than a community consisting of natives. Richness of native species may not as good a sustainability index as total species richness, particularly for selected ecosystem services. Finally, while I was very pleased to see the emphasis on capacity building, I was surprised to read that certain actions were "low feasibility" because of the lack of critical personnel needed in this capacity building dimension. This is a logical, high priority activity. Make getting these postions or personnel a priority and go after it! As you state, this is how you obtain necessary resources, leverage new resources, and win support for your conservation goals. This is an area that needs to be given as high or higher priority of activity as any specific management action proposed herein! Specific comments: Threat evaluations: I've copied your statements below, and follow those with my comments in italics. Invasive Plant Species Non-native plant species displace native vegetation because they compete directly with native plants for places to grow, nutrients, sunlight and soil moisture. Heavy growth of exotic species can create self-sustaining monocultures by blocking access to resources and germination sites. Over longer periods of time, some non-native species deposit chemicals into the soil that inhibit the growth of other plants. 1. The most recent literature indicates that most (but not all) invasive species are CONSEQUENCES rather than causes of change. These plants are opportunistic species that are exploiting a) change in fire return intervals, b) enhanced carbon 111 dioxide levels c) increased nitrogen deposition and d) change in growing season temperature/moisture considerations. If you are unable to alter the causal mechanisms, you are unlikely to get rid of the invaders. Indeed, the most common phenomenon now observed is that invaders replace otherinvaders. Thus, investing heavy resources that focus only on invaders may not be yourlargest return on management dollar! 2. There is VERY LITTLE scientific support to indicate that new species are threats to native species at landscape scales (and the presentation you're making here is a landscape scale.) The species do interact with habitat destruction to reduce native abundance, and the species do extirpate species at small spatial scales. The biggest threats come from trophic interactions (predator-prey) rather than competitive interactions (e.g., plant replacing plant). 3. The literature about plants changing soil chemistry isover-sold. For example, your web page identities knapweed as allelopathic. However, the most recent literature shows that this is not the case or at least the chemicals identified as the allelopathic agents are incorrect. What happens is that the plants form positive feedback loops with soil microflora, just as native dominant plant species do. Non-native invasive plants also degrade habitat for native animals by displacing food plants, pollen sources, and cover for nesting or hiding. Weeds can reduce the availability and nutritive value of forage for livestock. Non-native woody plants in grasslands provide perch sites where none would normally be found. These can be used as perches by nest parasites to locate host nests. Some bird species select nesting habitat based upon visual appearance. When invasive species alter the appearance of an area, some species may avoid nesting there. Weeds can also affect the fire regime by creating areas that burn hotter or cooler than uninfected areas. The above paragraph describes some but not all invaders, and also describes some native species. Some invaders are relatively benign or even contribute to ecosystem services of an area (Williams 1997, Graves and Shapira 2003, Ewel and Putz 2004). For example, there's data to suggest that areas with native and non-native species together fix more atmospheric carbon dioxide, arguing that they're better at carbon sequestration than native species alone. Likewise, certain non-native species support our local honeybee industry, a benefit that should be recognized in the agricultural contributions of open space. While we would prefer native species, nonnatives do provide ecosystem services and that fact should be recognized. If we can't replace the non-natives with natives for either economic or ecological reasons, we probably should leave well enough alone? An emerging pattern in the literature is that where control of one invader has been successful, the most common response is the increase in another invader (Thomas and Reid 2007). 1 would have tied OSMP IPM strategies directly to the Dewey and Anderson 2006 recommendations (which formulated what 1 think are very close to the same plans stated here. This relates to Patrick Murphy's observation that early detection and eradication is a primary, ongoing activity throughout OSMP. The program needs more transparency. 112 Comments upon conservation strategies Action 1 (IPM). Even if this is seen as important by the public, the "very high" ranking is unwarranted and the scientific literature indicates that the benefits of action (if stand-alone without reseeding or enhancement of natives) is over-rated. IYs time to merge your IPM program within a true restoration program. Action 2 Grazing enhancements. What is not clear here is the "very high" costs. Seems to me that some win-win collaborations could reduce those to a lower category? Grazers and grazer owners should benefit, so why can't the land owners? Action 7. I couldn't find the text on this item. If this is containment activity, fine. If this is a local eradication attempt for regionally abundant species, this activity should be low priority. Action 22. If these are regionally abundant species, this is another `forever' activity with very few long-term benefits. Fix the problem that caused these species to be here or accept the species in areas where they currently exist. Action 30. So, do I tell my aquatic ecologists that they're unlikely do anything useful? How does one move the benefits of this activity beyond the "low" category? And....where's the equivalent statement for upland research issues? Action 36. The very high cost may reflect OSMP's `go it alone' strategy. IYs time to form more frequent strategic partnerships with proactive groups like Wildlands Restoration Volunteers, etc. Action 37. Exploit opportunities? Take advantage of natural high snowmelt and/or storm events. The ranking of threats sometimes doesn't match the text? For example, you cite David Buckner's data that shows that xeric tallgrass sites are largely immune to invasions by the current suite of non-native plants, yet you have it (F-7) listed as a `very high' threat? References Cole, D.N. et al. 2008. Naturalness and beyond: protected area stewardship in an era of global environmental change. The George Wright Forum 25: 36-56. Ewel, J.J. and F.E. Putz. 2004. A place for alien species in ecosystem restoration. Frontiers of Ecol. Environ. 2: 354-360. Graves, S.D. and A.M. Shapiro. 2003. Exotics as hostplants of the Califomiabutterflyfauna. Biol. Conserv. 110: 413-433. Suttle, K.B., M.A. Thomsen, M.E. Power. 2007. Species interactions reverse grassland responses to changing climate. Science 315: 640-642. 113 Thomas, M.B. and A.M. Reid. 2007. Are exotic natural enemies an effective way of controlling invasive plants? Trends in Ecology and Evolution 22: 447-453. Tylianakis, J.M., R.K. Didham, J. Bascompte, and D.A. Wardle. 2008. Global change and species interactions in terrestrial ecosystems. Ecology Letters 1 L (early on-line view). Veblen, T.T., T. Kitzberger and J. Donnegan. 2000. Climatic and human influences on fire regimes in ponderosa pine forests in the Colorado Front Range. Ecological Applicarions 10:1178-1195. Williams, C.DE. 1997. Potential valuable ecological functions of nonindigenous plants. In Assessment and Management of Plant Invasions (Luken, J.O., and J.W. Thieret, eds). Springer Verlag. 114 To: Open SpaceMountain Parks From: Ed Mills FIDOS Re: FIDOS Comments an Grassland Ecosystem Management Plan FIDOS has been a cooperative and productive partner with OSMP management throughout the VMP and first two TSA studies. We have worked in concert with staff to implement such innovative and creative programs as the Green Tag Program Trail Head Leashing and corridor V&S among others to provide opportunities for a high level of visitor experience for dogs their guardians and other visitors. FIDOS is committed to continue this effort to insure the proper steps are taken in balancing resource protection while making the visitor experience work. While the Grasslands Management Plan (GEMP) does an extraordinary job of inventorying the resources of the Grasslands Ecosystem it& ? ?s inherent flaw is the exclusion of critical issues concerning balancing the goals of preservation and recreation. The plan addresses habitat and wildlife conservation resources and objectives but not recreational resources and objectives. The current draft GEMP displays a clear anti-recreation anti-trail bias which is inconsistent with the City Charter Visitor Master Plan and TSA process. Unfortunately the implementation of the current draft as proposed as a management plan outside of the VMP and TSA process theatens the very frame work of public process and cooperation established thus far. The GEMP should be used as it is: a study to be incorporated into the Grasslands TSA's. It should not be the management plan to trump other management plans and agreements outside the bounds of the VMP and the balance of OS purposes envisioned in the open space charter. The elimination or re routing of half the popular hiking and dog walking trails at South Boulder Creek Trail Dry Creek Trail East Boulder Trail Coot Lake trails Boulder Reservoir Left Hand Trail Sawhill Ponds increasing the area of seasonal closures by a factor of six and routing of trails around the exterior of areas of highly desirable interest {all of which are called for in the plan) are particularly troubling. There are acceptable levels of impact associated with insuring a high level of visitor experience which we ignore at or awn peril. Direct experience with nature is the most highly cited influence on environmental attitude and conservation activism. Outdoor play and nature experience have proven beneficial for cognitive functioning reduction in symptoms of ADD increase in self-discipline and emotional well being at all developmental stages. Direct experiences of nature tend to be neither particularly hazardous nor momentously spectacular but evidently intrinsically important to bath development and conservation. Oliver R.W. Pergams Department of Biological Sciences University of Illinois at Chicago. The GEMP should be used as a valuable tool. It's recommendations and management planning should be done within the broader framework of the process as is consistent with the Visitor Master Plan. Within this framework FIDOS and OSMP staff can continue their cooperative efforts towards expanding V&S opportunities visitor studies educational efforts and compliance with regulations. Anything less threatens to undermine this cooperation and the buy in and support of the public. Strengthening the connection between the public and their open space through both quality access opportunities and conservation can only advance our open space goals. Ed Mills FIDOS President 115 Comments on Draft Grassland Ecosystem Management Plan December 13, 2008 Sharon K. Collinge This is an incredibly thoughtful, careful and thorough document. I applaud the OSMP staff for a job very well done. The conservation targets have been appropriately chosen and defined; and the planning, monitoring, and management actions are clearly specified. A few things struck me as I read this document; some of which are easier to address than others-these are described below. I) It is quite distressing to me that the study concludes that "The overall viability rating for the Grassland Planning Area is "Fair" (p. viii). Because the majority of open space lands are grasslands, it suggests that Boulder OSMP really has a fantastic opportunity to contribute meaningfully to the regional conservation and restoration of these nationally and globally imperiled ecosystems. Grasslands are among the most diverse, yet neglected ecosystems in terms of conservation efforts. There is clearly much work to be done, and this document effectively identifies particular priorities and locations for conservation and restoration activities. 2) It is also quite revealing that recreation poses such a high threat to all conservation targets (except Agricultural Operations; Table 22). This suggests that managing recreation through the V MP is really critical to achieving the goals of the Grassland Management Plan. I hope that this document can be used meaningfully to guide further trail building and placement as pressure continues to mount to provide increased recreational opportunities. The information in Table 26, however, suggests that the action to "Limit new trail development in the best opportunity habitat blocks to maintain their ecological function" has very high potential benefit but low feasibility. Somehow this tension needs to be resolved; perhaps through continued public education and outreach. 3) Many monitoring activities are listed as "plaruied," while fewer are listed as "ongoing." I wonder about the budgetary constraints on completing the planned monitoring efforts. While we will hopefully be able to increase the number of CU researchers involved with specific monitoring and management objectives, there still may be a shortfall in terms of personnel and dollars to complete these monitoring goals. If that's true, I'm concerned about how "adaptive" the management efforts will truly be. In the absence of good monitoring information, it will be difficult to know how to alter management actions, or whether they should remain the same. I am pleased to see a presentation of ideas to enhance funding for and participation in monitoring efforts. 4) This is a minor point, but I was a bit confused about how landscape context is defined in this document. I think it is a crucial aspect to consider in this management plan, so am glad to see it included. My understanding of landscape context is that it is the composition and configuration of land use/land cover surrounding a particular patch or location in the landscape. So it was unclear to me how "fire regime" for example, was considered a key attribute of landscape context. 116 Please take few moments to answer the questions below: 1. What a-r~e the stye gths of Open Space and Mountain Parks' agr~Qlturv progr~ ~ LQ~! 2. ~Iow would you improve Open Space~Mountain Parks' agricultural pro ? ~ ~ ~ 3. What would you do to improve how OSMP balances a[~'h-~'~ man ei ent G" with, theme conservat f biological diversity? ~ s C ~s~r~ ~ ~L°-e l ~ - 4. How would you ensure ongoing gricu ure in Boulder County ten years from now? ~ 4i / ~ 5. What actions would you recommend that OSMP take (or support) to ensure ongoing agriculture in Boulder County twenty ears from now? h.~.d G-b Sri vf~~•~-M- tom" 6. Do you have specific comm, e~nts~ to ake regarding the dra~ft~ ~G~ra~ssland Ecosystem~~~ Management Plan? C,',~,=,~i~ ~ ~n~~~"~.`,-~-`-' i~~~~~ "Zo'~~ ~ J ~ , , ~ s a~z~~ Please use the other side of this sheet to share additional thoughts you might have on the draft Grassland Ecosystem Management Plan. You can read more about the Grassland Plan or share your feedback on the web at www.~-asslandplan•org or contact Andy Pelster 303-413-7644 for more information. ~ ~G~~ 117 < <S r.G~i i~ 2~~ ~ ~'S/yl~ ~ ~ ~ ~~s ~ ~o ~ ~ ~ ~ ~ -2~~ s _ ' ~ 118 Grassland Plan Questionnaire Response 1. The strength of the agricultural program is the realization that the management and protection of grasslands is a major component of agriculture. By accepting that good agricultural practices are generally compatible with sound ecological practices, the City is confirming that the use of open space for agricultural uses is an efficient and ethical method to manage grasslands in this County. 2. The Open Space agricultural program generally treats agricultural operators as the enemy rather than a partner. The lease conditions and the length of lease are not supportive of agricultural use of the land. By shortening the leases to months rather than years, the lessee has no incentive to manage the lands for the long term. The City regularly disregards the needs of the leasee to manage land for agriculture. In most cases the practices proposed would improve the quality and character of native grasslands. The best example is the restriction of the control of prairie dogs and non-native weeds. The City's approach on their fee ownership land is to not control the prairie dog population. As with any natural community by inappropriately changing the balance of nature's system, the results are negative for all concerned. Because many of the parcels owned by the City are relatively small and isolated, the prairie dog population cannot naturally expand into new habitat. The prairie dogs are trapped on the City open space and when the population expands beyond the carrying capacity for the habitat, that habitat deteriorates rapidly, the native grassland is destroyed, and the prairie dogs are forced to remain in extremely compromised living conditions. The prairie dogs consume all available native grasses, leaving the site essentially open to non-native weeds. When the leasee wants to control weeds to help re-establish native grasslands, the City OSMP do not allow any weed control because that is the remaining food source for the prairie dogs. Effective measures to reverse this cycle and to partner with the agricultural community will result in a desired improvement in OSMP's ag program. 3. The existing system, as managed by OS1~iP does not consider agricultural practices as a priority for this County. The agricultural uses (as defined by the lease) of OSMP property puts the needs of the farmer last even when the standard of care for agricultural activities are consistent with good land management practices. To improve the balance between biological diversity and agriculture the County needs to understand that to achieve a sustainable result, the needs of agriculture to manage land should be analyzed. By restricting agricultural practices because it disturbs the sensibilities of the community rather than based on the tecluiical understanding of native grasslands results in low grade agricultural lands and even poorer quality grasslands. 4. The City needs to understand how agriculture, primarily outside the City limits, functions. The City seem to have a limited understanding of agricultural practices and how those practices are valuable in protecting 119 existing areas of grassland and potentially resurrect the land already damaged. The City needs to fairly balance the needs of agriculture and conservation of open lands. However, in many cases the City does not have a difficult challenge because the objectives of the City and the farmer are often the same. The agricultural use depends on the land to function and the City wants to protect open space. Both parties have a vested interest in succeeding. 5. OSMP needs to analyze agricultural practices in Boulder County to understand the essential needs of agriculture and then develop a plan that integrates the agricultural practices into the management of City lands. In many situations agricultural use is considered a negative for open lands even when the person is deriving their livelihood from the land. The OSMP understands that management of unused Land is expensive. The City is well aware of the numerous complaints when the management of open space falls to the City. Weed and pest control on City land adjacent to land productively used for agriculture are a constant source of additional tune and expense for neighboring agricultural uses. Until the City considers agriculture as a critical part of the City open space, the long term fate of agriculture is in question. 6. The Grassland Management Plan is essentially flawed. The study does not make a full and clear analysis of the impacts of the proposed management approach on the quality and sustainability of native grasslands in Boulder County. By including a separate section devoted to prairie dogs without a clear analysis of the impacts of unmanaged prairie dogs on native grasslands is avoiding the issue. It would seem that the results of the present protection and management of prairie dogs is one of the key issues that the technical staff preparing the Plan would be addressing. I would have to question the validity of the study when a key piece of information that the decision-makers would require for a well informed decision is not addressed. 120 Please take few moments to answer the questions below: 1. What are the strengths of Open Space'~y~and Mountain Parks' agricultural pr.~o-{gram? [i~'p _ ~~'~"~~Iw~ i:~'ui"tJ`rv-Z~ )J,j+ u`'t ~~t"`r~-[:~/.~--V /~:.:Vy~,.:_:. t;,U .'~.~.A~~~it ~ 1 S~ , ?~JU IL ~i"~ v~. '~'1M...V,~-~-c~ {Z~t..1.C'.1~ AJV 2. How would ~ou improve Open Space and Mountain Parks' agricultural program? , ~ 1 0~~ y~ r 1 _ y{. r~~ t~i ~ ~ C~ti? Y~:.~ ~J13;1. It.C.vV\ .r`-'.f~{~l~ '11~~:~1X_., ~IC~~L yyy~~~~~,'7f,~y°yQ~YlS~ !lJ .~1'~~. _.~'~V-+.~^~~ /.~~~~~/~i /l ` I... 1, V LYVIJ~~ ~ ~"'11i 1~CZ1 ~ '.T'l Vim`, ~~"vM ~ ~'~c ~i::.i'~ ~1.~ ~.7~L.~V+Rr~l C": ~1,, (7~~t. i"u:~''~ C...l.^C'!~''+t-K,S~- `}~ILZ~ :~"'~.LA ,v'r c~ 3. What'would you do to Improve how OSMP balances agricultural management with the conservation of biological diversity? } ~ ~ ~ ~ ..u~ G~N~ CJV~° +L ,Y~ i "iCJ`~. 1~s.-~ ~ i 71;c:: ~bc , _ f ~~.i~Y~~~"dr~`{~~ 4'~'lafL~ ~ ~ "L~ ~Z~~ {I~7i5fiC.l~"/~T, ~ ~~Lv. (w~ ~rv~~~J"4c.e ?lr v~~ 4. How wo ld you ensure ongoing agriculture in Boulder County ten years from h nom I~~~' c~,-~z~ ~i~~v ~~~a ' ~ 4~ ~ A ~ ~"n ~ _ .X,2.CL.~L~ iL,l` ~ . JL~_ ~ .~,`j'ZLI~..L ~C.i, -~-~e ` ~.'w4,1J e (~°~iz_ ~~±az~ ~~,~'-~i-~w ~~r..~..~ _~°uc'Y~~ ?~?~-c~~ _.~~~.~,.Zv,~Kr" J 5. What actions would you `recommend that OSMP take (or support) to ensure ongoing agriculture in Boulder County twenty years from now? _ " '~fYYLtii>~ 4k~ J ~ ~r~- ,~.(;~..~J ('.U1 .;L.r I ~ ~ ~ a.4D-J's-~.,'~Cr.'D 6. Do you have specific colnlnents to make regarding the draft Grassland Ecosystem Management Plan? ~J~-~~~ ~ r f . ^ ~ ~~tc ,cwt ;?~'~k..~`i~,~' L~.L~c~ cp~,c7 c~Ut.~.~,, c~:~..~1,`~-~ ~-~t ~ n ~ r, ~ ~'1 i7 1 121 Please take few moments to answer the questions below: 1. What are the strengths of Open Space and Mountain Parks' agricultural program? 2. How would you improve Open Space and Mountain Parks' agricultural program? ~-zvz - c. , ~ L,; ~ '"t"' ~ `~K'~ ~1i1 'r,~ ~ yC~L I ~ ~~~L~-ice -LG' ~+ct F' C.t ycc GL .-G~.t '-t.%' ~ti~c+ 3. What would you do to improve how OSMP balances agricultural management with the conservation of biological diversity? 4. How would you ensure ongoing agriculture in Boulder County ten years from n pw? y~ J ,iL-9'LCiL. ii-.:j,~~ i;~^7Yl..,i~, L.iC2•'J~-'cc ,~c.'` ~ /~"Z.~ ~~t.~~'.~~,r.; 5. What actions would you recommend that OSMP take (or support) to ensure ongoing/~a~gp~r/iculture in Boulder County riventy years from now? y" I; ~~v,~ L 2. ,~,Gt }'vim % ~G,~,-~ `L~ Grp-C~c-~~"J7?y~`-~ ~~°~j`` ` 6. Do you have specific comments to make regarding the draft Grassland Ecosystem Management Plan? Please use the other side of this sheet to share additional thoughts you might have on the draft Grassland Ecosystem Management Plan. You can read more about the Grassland Plan or share your feedback on the web at www.~rasslandplan.or~ or contact Andy Pelster 303-413-7644 for more information. 122 ATTACHMENT C Grassland Plan Comments Not Highlighted for Discussion «~ith Proposed Staff Responses Recreation The trail density in the GPA is lower than that of the 11~ountain Parks; therefore, the GPA is undeiserved from a recreational perspective. OSMP has not developed service standards for the trail system or the visitor experience based upon achieving a certain level of trail density (miles of trail/area). Direction contained in the VMP links the level of trail development to providing safe, aesthetically pleasing and physically sustainable access to destinations. Other factors that inform trail development include minimizing conflict with agricultural land management practices and protecting plant and wildlife habitat. The habitats and terrain are significantly different in the mountain backdrop and the grassland planning area. These differences naturally result in different levels of trail density. The mountain backdrop has also been in public ownership for the longest time. The trails developed in this area were established before modern sustainability standards and habitat protection considerations were in place. A good example of this is the network of trails leading to the numerous climbing destinations. Higher trail density in the mountain backdrop may also be due to the large number of undesignated trails in that area. The City Council-approved VMP does distinguish designated from undesignated trails and anticipates that some undesignated trails in the mountain backdrop will be closed. The Grassland Plan does not uiclude a needs assessment for visitor resources or take into consideration trail alignments described in the Boulder Valley Comprehensive Plan. The Boulder Valley Comprehensive Plan's proposed trail alignments were taken into consideration when OSMP conducted a trails needs assessment during the development of the Visitor Master Plan. The outputs of this process included the Trails Study and Prioritization Report and the inclusion of new trail proposals each year in the VItiIP's project phasing section (pgs. 69-70). BVCP trail alignments are conceptual, and provide latitude in addressing a variety of logistical factors (environmental impacts, private property, trail sustainability, road crossings, etc.). The Grassland Plan provides information about ecological and agricultural factors that may affect the placement of BVCP trails in the Grassland Planning area. Implementation of regional trails identified in the BVCP will take place within the context of the TSA process in some cases. Some trails (e.g. Lyons to Boulder Trail), will be developed by S:~OSMP~PLAN~GEMAP~Public Process~0225090SBTStudySession~Attachments`Other Issues and Responses.doc 1 partner agencies outside the context of the TSA planning process. This is an example of a trail project that OSMP has been strongly advocating for a long while. OSMP should not extend wetlands defmition and protection to "wet meadows". These aie not pristvie or undisturbed, and their protection could prevent desirable visitor activities on OSMP lands. Wetlands on OS1~~IP lands are regulated by the City of Boulder Planning and Development Services department and the US Army Corps of Engineers. Wet meadow included in the Grassland Plan's wetland target are likely to meet the city's or the federal government's definition of wetlands, or possibly both. OSMP is not suggesting that these areas are pristine, and agree that some may arise at least in part because of irrigation practices supporting agriculture. However, as indicated in the plan, these areas do provide important ecological functions, including providing habitat for species listed under the Federal Endangered Species Act. OSMP seeks to protect these functions while balancing the need to provide visitor access and continue agricultural practices. Identification of areas as wetlands means that OSN1P is obliged to avoid or minimize impacts to the ecological value of these areas, but it does not automatically eliminate visitor access to those areas. Horses should not be singled out in the battle against noxious species. The draft plan does not refer to horses as an especially important contributor to the establishment and spread of weeds, only as one contributor. Exotic species monitoring should include an analysis of correlations of weed patches with new and established trails. OSMP mapped over 15,000 acres of the Grassland Planning Area for over 30 species of noxious weeds between 2006 and 2008. This data is being used to aid management priorities and planning, locate noxious weed hotspots, provide a base condition for mapped properties, and is being used to analyze correlations between current infested areas and environmental factors and human related disturbance such as trails. In addition, OSMP is conducting and has contracted ecologists to conduct plant studies along new trails to determine the impacts of trails on native and exotic plant communities. Why does OSNIP consider there to be a 100m area around trails wherein wildlife habitat is degraded? This seems too large. Reports published in peer-reviewed scientific journals, some containing research conducted on OSIVIP, have estimated the "area of influence" surrounding recreational trails wherein wildlife occurrence is decreased. It is believed that wildlife disturbance is not caused by the actual trail itself but rather from the recreational use of the trail. Some S:~OSMP~PLAN~GEMAP~Public Process~0225090SBTStudySession~Attachments`Other Issues and Responses.doc 2 studies, including one conducted on OSMP (Miller et al. 2441), show that off-trail use elicits a flushing response quicker than on-trail use, presumably because off-trail traffic is unpredictable and inconsistentmaking it difficult for wildlife to habituate. Research has documented that the probability of occurrence and animal abundance increases with increasing distance from recreational trails. According to researchers, Grasshopper Sparrows, a GMAP nested target, did not nest within 54 meters of a habitat edge (Delisle and Savidge 1996). In the same study, the mean distance from the nest to an edge was 119 meters. OSMP staff concurs with research biologists that trails can act as a habitat edges for sensitive species such as Grasshopper Sparrows. Ina 1998 study on OSMP lands, the abundance of ground-nesting birds, such as Grasshopper Sparrows, Vesper Sparrows and Western Meadowlarks was reduced in a 144-meter buffer around OSMP recreational trails. Using this recent, locally collected information, staff estimated the area of influence of OSMP recreational trails to be approximately 144 meters. Belthoff, J.R. and B.W. Smith. 2443. Patterns of artificial burrow occupancy and reuse by burrowing owls in Idaho. Wildlife Society Bulletin 31: 138-144. Delisle J.M. and J.A. Savidge. 1996. Reproductive Success of Grasshopper Sparrows in Relation to Edge. Prairie Naturalist 28: 147-113. Miller S.G., R.L. Knight, and C.K. Miller. 2441. Wildlife responses to pedestrians and dogs. Wildlife Society and Bulletin 29: 124-132. Miller S.G., R.L. Knight, and C.K. Miller. 1998. Influence of Recreational Trails on Breeding Bird Communities. Ecological Applications: 8:162-169. If urban areas have an area of impact that degrades wildlife habitat, why don't lands being cultivated for agriculture? Agricultural cultivation does have impacts upon wildlife habitat. Inappropriate agricultural practices are identified as a source of stress for several of the grassland plan targets. OSMP manages to mitigate these effects as much as possible. Agriculture is included as a desired target in the Grassland Plan given OSMP's chatter goals to preserve historical agricultural practices and our role in supporting local small family farming operations. Recreational use can be incompatible with farmng and ranclivig activities. Wliy is there no strategy to avoid placement of trails through areas of agricultural production? S:~OSMP~PLAN~GEMAP~Public Process~0225090SBTStudySession~Attachments`Other Issues and Responses.doc 3 While we have a history of recreational trails on lands leased for agriculture, OSMP has routinely tried to avoid selecting trail alignments that would be incompatible «~ith agricultural practices. In cases where impacts are unavoidable, ranchers and farmers are compensated for direct loss of leased ground through reductions in their lease payments. The plan does not provide an assessment, inventory or analysis of agriculture in the GPA, yet it recommends taking actions that will affect agriculture. This is inappropriate. The plan does not demonstrate an understanding of agricultural practices in Boulder County, and the function of non-OSMP lands in protecting and restoi~ng grasslands. The Grassland Plan provides an assessment and analysis of agriculture. There is a description of agriculture operations as a target (pp 17-20). The viability of agriculture is discussed on pages 48-50. Agricultural operations are included in the threat assessment (Chapter III). The best opportunity analysis for agriculture can be found on pp 78-80. Compared to other OSMP purposes, agriculture seems to be given the "back seat" when it comes to management prioritizing. Agriculture is managed in the context of all OSMP purposes. When making the inevitable decisions about which purpose to emphasize in a given situation, OSMP land managers may choose to emphasize agricultural objectives, or agriculture may be considered less important than other purposes. OSIVIP leases over 14,000 acres, or 60% ofthe Grassland Planning Area, to agricultural tenants. The OSMP program has and continues to expend resources to purchase and manage water rights and extensive water diversion and delivery infrastructure primarily for agricultural use. The department also builds and maintains fences to support the agricultural program. OSMP employs four full-time staff to manage leases, lands, and water for agricultural conservation. The grassland plan clarifies OSMP's objectives for agricultural management, and describes the strategic actions needed to achieve long-term agricultural sustainability. It would be easier for lessees to farm if OSMP: • invested more in infrastructure improvements (irrigation, barns, graineries). • allowed lessees to burn ditches, apply herbicides and insecticides without so much process. • Controlled weeds more aggressively OSMP must follow Council-approved guidelines administered by the city's IPM coordinator in the Office of Environmental Affairs. Use and application of pesticides on S:~OSMP~PLAN~GEMAP~Public Process~0225090SBTStudySession~Attachments`Other Issues and Responses.doc 4 city owned property and within city limits is regulated by the city's Integrated Pest Management Policy. The policy is intended to provide a basis for pest and vegetation management that will protect human health, the environment and non-target organisms and seeks to achieve these objectives by using sound approaches to reduce and eliminate, where possible, the volume and toxicity of chemical pest control treatments. It should be noted that OSMP weed managers must also follow these policies when applying pesticides to OSMP land. OSI~•IP staff will continue to facilitate the administrative process in response to the needs of agricultural tenants. OSMP currently invests in agricultural infrastructure improvements as budgeted capital funds allow. There are significant capital needs with a land system the size OSMP manages that includes the large number of management objectives. Ditch burning is currently completed through a coordinated effort with the City of Boulder's Wildland Fire Division. Agricultural personnel will continue to facilitate this process and attempt to burn more ditches each year. Prescribed fire and agricultural burning presents a difficult management challenge in the urban interface. The plan does not include consideration of local food production and organic fai•~ning. Strategic Action #34 "Evaluate alternatives to historical and current agricultural practices such as Community Supported Agriculture" will be modified to clarify that local food production and organic farming are considered alternatives to current agricultural practices. Monitoring How will the Grassland Plan address the need to collect baseline uiformation to detect the effect (positive or negative) of management strategies? The Plan includes viability attributes (e.g. species composition) and measurable indicators (e.g. number of native plants) for each of the eight Grassland Plan targets. OSMP staff is developing a prioritized monitoring program to measure selected indicators (measuring all indicators identified in the plan is probably not possible from a cost perspective). Staff will be employing standard methods to collect and analyze the data necessary for measuring change, if any, to the indicators over tune. OSMP recognizes the importance of baseline data, and intends to design monitoring and management actions to gather such information. It will be challenging to attribute successful conservation to specific strategies on particular targets, especially given the number of other factors operating simultaneously that affect the target. How will OSMP know if success is due to a S:~OSMP~PLAN~GEMAP~Public Process~0225090SBTStudySession~Attachments~Other Issues and Responses.doc 5 particular action, or failure is because a critical strategy was not unplemented simultaneously? OSMP will work to focus monitoring efforts on those indicators that will be sensitive to change and sampled to reduce the confounding effects of other environmental variables or human activities. OSMP will not be conducting highly manipulated experiments to isolate the effects of specific strategies. Due to limited resources, we will typically need to make the assumption that if we employ a strategy and simultaneously our target meets the viability standards, the strategy worked. OSMP will also rely on the scientific literature and professional judgment of staff and other experts to help determine whether such assumptions are reasonable. Develop a research agenda to answer questions about uncertain cause and effect relationships, and the effectiveness of restoration and threat abatement strategies. The monitoring chapter will be appended with a list of priority research questions identified during the development of the Grassland Plan. The Grassland Plan contains many new monitoring initiatives. How will OSMP fund monitoring and mitigation in the current economic climate? OSMP will seek to develop monitoring approaches that are fiscally sustainable. This may mean changes to historic monitoring practices, and will require that OSMP prioritize which indicators it seeks to measure and develop approaches that use staff time efficiently. To confer the greatest benefit on the organization, monitoring is a long-term commitment. OSMP is working on partnerships with other land management agencies, CU researchers and students to help achieve objectives. Some local non-profit agencies have offered funding for research that could be coordinated with the monitoring needs of the grassland plan. Miscellaneous Riparian woodlands are overcrowded with deciduous trees supporting populations of uivasive animals such as blue jays, fox squirrels, opossum, and discouraging tallgrass prairie and wet meadows. OSMP should examine pre-European structure and try to restore a more varied mosaic. (set standard (e. g. < 30% of stieambank shaded by deciduous trees) Plains and foothills riparian areas are characterized by the presence of deciduous trees. On the eastern plains, these trees are often the only large woody species in a matrix of low growing herbaceous vegetation. Cottonwoods (Populus species) are the most S:~OSMP~PLAN~GEMAP~Public Process~0225090SBTStudySession~Attachments`Other Issues and Responses.doc b common riparian tree in plains riparian forests. Most vertebrate species in Colorado utilize riparian areas for some part of their life-cycle. Water development has altered most western riparian areas and affected the ecological functioning of these systems. Riparian vegetation responds and adjusts to regulation and alteration of streamflow depending on geomorphology, water use and other factors. While riparian woodlands have expanded on some rivers, they have declined and in extreme cases collapsed on others. Riparian woodlands in the planning area have certainly been altered by water development and other anthropogenic factors but the long-term adjustment of woody vegetation to these disturbances is unknown. A 1997 C)SMP research report found that from 1937 to 1995, the riparian woodlands on South Boulder Creek between Marshall Road and Baseline Road decreased by 57% but increased (recovered?) to 19371evels by 1995. While colonization of riparian areas by non-native wildlife species has been noted in recent decades, it is unclear whether these invasions are the result of changes in riparian tree density or other factors. Be more aggressive with conservation strategies. • Increase the number of large habitat blocks by working with other land management agencies. • Increase the number of bullfrog-free ponds by 2015 to more than three. The strategies in the grassland plan were designed to be feasible and cost effective. The plan will be amended to reflect that these are minimum acceptable rather than maximum levels of service delivery. In order to avoid over-committing and underperforming during uncertain economic conditions, C~SIVIP recommends retaining the strategies and objectives as stated. OSMP should take a more active role in the reintroduction of extirpated species (plains sharptail grouse, mountain plover, long-billed curlew and pronghorn antelope) and include a discussion of the opportunities and barriers to revitroduction species by species ~SMP staff feels that there is considerable work ahead for the first 14 years of Grassland Plan implementation collecting baseline data, restoring degraded sites, and adjusting grazing, fire and weed management practices. However, the plan anticipates participation in projects to reintroduce extirpated species led by the appropriate state or federal agencies responsible for species recovery. Recovery efforts for state listed animal species would be led by the Colorado Division of Wildlife. Federally listed species recovery efforts for both plants and animals would be led by the US Fish and Wildlife Service. Why wasn't hunting included as a strategy to address big game and migratory bird management issues? OSMP staff did not identify any viability issues with big game or migratory bird populations that hunting would help address. In addition, lethal control in general and hunting in particular have not been the community's preferred option as the first S:~OSMP~PLAN~GEMAP~Public Process~022509OSBTStudySession~Attachments`Other Issues and Responses.doc 7 choice for wildlife management in the city of Boulder or for city-owned open space lands. Hunting on ~SMP lands is specifically prohibited by ordinance. The City should provide foi• the private property rights of mineral interest owners and their lessees (from oil company) The City of Boulder has adopted regulations regarding the permitting process for oil and gas operations on land owned in fee by the City and acquired with Open Space funds. The Grassland Plan is not intended to modify or supersede these regulations in any way. S:~OSMP~PLAN~GEMAP~Public Process~022509OSBTStudySession~Attachments`Other Issues and Responses.doc ~ ATTACHMENT D OSl1'IP's Community Services Provided in the Grassland Planning Area OSMP encourages a myriad of visitor experiences in the Grassland Planning Area. Access and enjoyment are supported by 31 trailheads (74% of all trailheads on OSMP) and 80 miles (56% of the total miles in OSMP) of trails. These include the Dry Creek and South Boulder Creek Trails--some of the most visited trails on the OSMP land svstetn. About 22 miles of these trails have been built to be wheelchair accessible. Among other activities, visitors enjoy biking, hiking, running, horseback riding, nature study, dog walking, painting, meditating and photography in the Grassland Planning Area. For many years, OSMP has offered formal education programs, informal outreach programs, interpretive materials, and volunteer opportunities to enhance visitors' enjoyment of the grassland and provide ways to learn about these ecosystems. OSNIP provides free guided nature hikes for schools, community groups and the public in the Grassland Planning Area. Between 2005 and 2008, 73 CU, K-12 school, and scout groups took part in nature programs focused on grassland related topics. Seventy groups participated in educational programs about riparian and wetland areas associated with grasslands. During the same time, OSMP staff led 93 guided "Natural Selections" nature hikes offered to the general public that specifically focused on prairie ecosystems, including prairie dog towns, the uniqueness of the tallgrass prairie, Native Americans, pioneers, grassland plants and birds, nature journaling, photography, geology, rejuvenation hikes, and special areas focuses in the Southern and Northern Grassland HCAs. Although most were hikes, some were bicycle or «-heelchair tours. OSIVIP offers 5-10 wheelchair accessible hikes each year, primarily in the grasslands, highlighting the rich flora and fauna of these areas. There are also joint wheelchair hikes with Audubon society twice a year focused on bird watching in the grasslands. Each year we sponsor an Adaptive Mountain Bike Clinic, offering wheelchair users the chance to use all terrain wheelchairs on some challenging trails in the grasslands. In 2004 OSMP helped organize and participated in a regional Grassland BioBlitz. The overarching purpose was to do a 24 hour species inventory of grassland ecosystems to capture a snapshot of the species diversity and richness present. On OSMP property ecologists censused species on Jewel Mountain. Concurrently, OSMP's education stafF provided hikes into the area as well as interpretive stations where public could learn about what the scientists had found and area's biodiversity in general. In addition to staff led activities, OSMP seeks to enhance the visitor experience through interpretive signs located tlu•oughout the system: including prairie dog signs on Foothills Trail, mining and local history signs at the Marshall 11~Iesa trailhead, and grassland ecosystem signs along the new Spring Brook Loop trail. Additional grassland interpretive signs are planned for the expanded trailheads at Flatirons Vista and Doudy Draw. 1 OSMP's printed materials also encourage visitors to get to know their grasslands. Sections of the Marshall Mesa and Doudy Draw / Eldorado Mountain brochures focus on the prairie, and OSMP grasslands were the feature article in the Winter 2002 issue of the Open Space Naturally newsletter. The free OSMP wildflower brochure provides color illustrations of many grassland plants, and YValking Tl~rougl~ History on 1~Iarshall Mesa explores the coal mining history of this area in an ecological context. Other venues for sharing the richness and beauty of the grasslands include a 2008 video, produced by OSMP about the restoration of the Coal Creek riparian area. The video has been featured on Boulder's television channel. Interpretive tables placed at trailheads are another way OSMP communicates messages to visitors. This type of outreach has occurred annually at many trailheads in the grasslands, including but not limited to: Chautauqua Trailhead, Sanitas, Bobolink, Marshal Mesa, Doudy Draw, Flatirons Vista, South Mesa, Diy Creek, and Foothills Trails. These interpretive tables feature a staff person may have an animal mount (such as a prairie dog, badger or hawk), some scat samples of animals active in the area recently, and a flower brochure to enrich the visitor's awareness of their surroundings and inform the hike they are about to take. Staff answers questions and are prepared to share vignettes about the area or current information about OSMP management Trailhead outreach is also used to inform people about guided hikes and invite people to visit new trails as they open. Not all outreach is stationary. OSMP staff and volunteers have been doing roving outreach, hiking trails, with a focus to enhance the visitor's experience with information or just a friendly smile. Our outstandingly creatij~e and popular Meadow Music program was originally designed to be given in the Chautauqua meadow. It has become so popular, with hundreds attending each week, that it has been moved to the larger nearby Chautauqua Park. The music, written and performed by OSMP staff, uses comedy and prose to sing to the beauty and complexity of our locally preserved lands, including OSMP's grasslands. At Boulder's Farmers' Market OSMP has staffed a booth that often included displays of plants and animals found on the prairie. Conversational topics include issues such as weeds and their management, dogs, and the natural history of prairie dogs, coyotes, foxes, raptors and other denizens of the prairie. Some community members find on-going volunteerism their preferred way to connect with and pursue in depth learning about OSMP's grasslands. The Department provides many opportunities for volunteers. In 2008 more than 700 volunteers contributed over 11,000 hours in the grasslands helping staff in the following programs: • Herbarium volunteers collect plant specimens for OSMP's herbarium and monitor rare plants and weeds. Some of these volunteers have been part of the program for more than 20 years. • Wildlife monitors track bats, frogs, hayfield birds and raptors 2 • Trail Guides visit trails, enhancing visitors' experiences by providing infoi7nation on area features, natural and cultural history and seasonal management • The Stewardship Program provides opportunities for individuals, families, businesses and organizations to learn about and care for the land through shared work in the field. Projects include habitat restoration, area and trail care, and building and restoring trails and structures • Volunteer Naturalists provide nature programs, mostly interpretive hikes, for children and adults throughout the year • Hosts greet the public and provide information and outreach at community events, trailheads and facilities OSMP will continue to offer a wide variety of opportunities for the public to learn about and participate in grasslands. All visitors approach OSIVIP from a unique place on a spectrum from awareness to appreciation to action. In structuring education and volunteer programs, OSMP will continue to provide venues for people to enjoy the grasslands at all points along that spectrum. Brochures, interpretive signs, staff at information tables, and trail guides all provide brief contacts to raise awareness; nature hikes for the public and school groups create more in-depth experiences that foster appreciation. OSNIP's many volunteer programs help visitors give back to the grasslands they have come to appreciate, and to help spread the word to others. 3 ATTACHMENT E VIletland and Riparian Buffers and Trail Density It is common for land management agencies, including OSMP, to designate bu, ffer^s around wetlands and riparian areas to protect them values and functions. For example, the city ofBoulder's land use code includes wetlands regulations, which identify regulations specifac to wetland buffers. Wetland and riparian area buffers are important habitat for the survival of a wide range of vertebrate species. In the GP~1, these areas are critical for the survival of several species, some of which are rare and imperiled •.y _ ~ ~ The northern leopard frog (left) was once abundant ;G, and is currently undergoing dramatic, non-cyclical ®®k o elation declines tlu~ouahout its ran e m western p PA b g T` , . ~ ~ North America. The species' range and decline _ includes the Boulder Valley. In 2007, the US Forest . ° Service roduced a conservation assessment for the ` ~ species. Their recommendations included minimal ~ ~ intrusion into the buffers of wetland/riparian area • ~ complexes. They suggested a 200m buffer width, y ~ ~ ~ ~ acknowledging limited information upon which to base buffer width determinations. Since wetland/riparian area buffers are also critical habitat for many other species, including the federally ~ threatened Preble's Meadow Jumping Nlouse (right), , and nesting waterfowl {below), OSMP determined that ~ ,.fir reducing the trail density in these buffer areas would be ~ ° ~ _ a reasonable way to conserve wetlands and riparian ~ , areas through the Grassland Plan. Trail density was chosen as an indicator of impact to buffer areas because trails and roads around wetlands and riparian areas can directly destroy habitat, create barriers for amphibian and small mammal dispersal, introduce disturbances such as human and dog recreation, and serve as conduits for predators and pathogens. Trails and roads are also sources of sedimentation, which can adversely affect aquatic habitats important to amphibians and fish. ' ~y" ~ ^~w Recent site-specific projects on Open Space and . Mountain Parks confirmed community support for ;'!,y - • ` ~«~a~~ ~ protecting wetland and riparian areas in the ~ Eldorado Mountain/Doudy Draw Trail Study Area. - ^Y_ f The plan included conservation strategies that '~~':~~.4 - ~ . ~ ° ~1t . protected these habitats by closing undesignated r. Y;~..~~,~, , ; trails around Lindsay Pond, re-routing the existing . ' ~ ~ _ us~~~ ,a: ~ Doudy Draw trail out of the drainage, and avoiding ~ ~ wetlands and riparian areas when planning for new txails. In the Grassland Plan, OSMP used conditions around Lindsay Pond and the upper reach of Dowdy Draw to describe unacceptable levels of trail density. Those two wetland/riparian complexes had road/trail densities in the 200 m buffer between 30 and 55 meters/hectare. OSMP used this as the threshold between acceptable and unacceptable conditions. Staff proposed managing the buffer areas so that most (75%) had atrail-road density of less than 46 meters/hectare. Or in other words, the range of acceptable condition is to have 75% of the buffer areas v~~ith a road/trail density from 0-46/meters/hectare. To deternline the current status of wetland buffers in the Grassland Planning Area, staff used GIS to define 414 wetland and riparian complexes on OMSP, created 200 meter buffers around each, and then determined the density of trails (both designated and undesignated) within these buffers. We found that conditions were outside the acceptable range. Most (75%) wetland/riparian complexes had aroad/trail density < 61 m/ha in the buffer area. Improving this situation ~~~ould mean closing or removing trails from the buffers. Recognizing that impacts to trails could adversely affect the visitor experience, staff evaluated the relative contribution of designated and undesignated trails. The OSMP Visitor Master Plan had already called for the closure of undesignated trails that were not to be formally designated. Staff conducted an analysis to see if it would be possible to meet the wetland buffer road~`trail density objective by focusing on undesignated trails. _~fter analyzing the relative contribution of designated and undesignated trails to traiL~road density in the buffer areas, OSMP found that the objective could be achieved by addressing impacts from undesignated trails alone. Closing undesignated trails in «--~etlandlriparian buffers would take place as a part of TSA implementation. This approach avoids taking action on a trail prior to its consideration for designation, and gives OSMP a way to prioritize the large number of possible undesignated trail closures in a TSA. Staff would seek to prioritize the closure and reclamation of undesignated trails that entered wetlands or riparian areas, then those that affected the 200 m buffer. Other factors (e.g. impact to other sensitive habitats, aesthetic concerns) are also used to prioritize undesignated trail closures. OSMP has historically, and may continue to take action to protect wetland and riparian values from severe impacts by closing or re-routing trails prior to the completion of a TSA plan. Achieving a particular road-trail density in the wetland/riparian buffer does not mean that OSMP will never construct trails in these areas. The acceptable range of variation allows up to 46 meters/hectare in the buffer area. This reflects the inevitability and desirability of trails in and around wetlands for a variety of purposes (e.g. the aesthetics of creek side travel, the need to approach and cross wetlands and riparian areas to move from place to place, and the size of the areas covered by the 200 m buffer). Several trails have been built in wetland/riparian buffers in the Eldorado Mountain/Doudy Draw, and the Marshall Mesa/Southern Grasslands Trail Study Areas. Although C~SMP seeks to avoid impacts to wetland/riparian areas and their buffers, sometimes those impacts are unavoidable. In those cases, staff seeks to minimize the impacts through design. For example, it was impossible to avoid the High Plains trail's crossing of Coal Creek, and its riparian area. The trail alignment was designed perpendicular to the creek and surrounding riparian area to minimize impacts. It is likely that it «~ill be possible to meet both the objectives of the Grassland Plan and build trails in ~~vetlands/riparian buffers in a thoughtful and sensitive manner. The attached map shows the location of wetland/riparian buffers and roads, designated trails, and undesignated trails in the Grassland Planning Area.