Saturday, August 25, 2012

VWC-DEIS 1.6.5 Climate and Air Quality

{revised 9/2/12}
Reviewing the VWC-DEIS you'll notice a number of points worth a closer look. To facilitate that I will use this blog for my study notes, organized into single issue threads. Each will quote the USDA Forest Service - Village at Wolf Creek Access Project - Draft Environmental Impact Statement section in question.

{For clarity I have added breaks between sentences and highlights where appropriate.  Wording has not been altered.}
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Draft Environmental Impact Statement - Village at Wolf Creek Access Project

United States Department of Agriculture

USDA Forest Service
Rocky Mountain Region
Rio Grande National Forest
Divide Ranger District
Mineral County, Colorado
1.6.5 Climate and Air Quality 
1.6.5 Climate and Air Quality
Issue 1: Indirectly, the Action Alternatives have the potential to impact the air quality of the project site and adjacent population centers by facilitating development of the private parcel.
Analysis Area: Project site and population centers in Mineral, Archuleta and Rio Grande Countiesand nearby Class I areas.

・ Document estimated ambient concentrations of particulates, sulfur dioxide, nitrogen dioxide, and carbon dioxide of the Analysis Area and compare them to state and Federal standards.
・ Determine the particulates, sulfur dioxide, nitrogen dioxide, and carbon dioxide levels potentially generated by the future development and compare these levels to applicable state and Federal standards, and document the impacts of these pollutants on the air quality of the project site and adjacent population centers.

Issue 2: The indirect/connected effects of the Action Alternatives have the potential to impact the air quality related values (visibility) of Class 1 Areas including the Weminuche and South San Juan Wilderness Areas.
Analysis Area: Weminuche and South San Juan Wilderness Areas

・ Employ EPA-approved model(s) to evaluate ambient air quality and visibility impacts on nearby Class 1 Areas associated with future development of the private parcel.

Issue 3: The indirect/connected effects of the Action Alternatives have the potential to generatepollutants typically considered "greenhouse gases," including carbon dioxide (CO2), methane(CH4) and nitrous oxide (N2O).

Analysis Area: Project site - Indicator:
・ Estimate the order of magnitude of the greenhouse gas emissions of the project.  VWCAP-DEIS

 {The details are at 4.5.2 "Cumulative Climate and Air Impacts"}
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What I found disturbing was that the DEIS contains nothing about our long term "Climate Change" related water challenges.

Why?  Isn’t this process supposed to help our foresters not make a big mistake? 
Why ignore this important issue?


There is this statement:
VWC-DEIS - Page 4-56   Chapter 4.  
Environmental Consequences Moderate Density Development Concept  

{...}Conversely, while climate change has been projected to have incremental impacts on various aspects of human activities at some unknown point in the future, there are no methodologies available at this point to predict any impacts on the project being analyzed here.”

Such words as "some unknown point in the future" or "no methodologies... to predict any impacts" are a bit disingenuous in the face of scientific knowledge.
Below is a list of reasons why these factors deserve immediate attention.  This information should be included in the deliberations and the FEIS.

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On Climate Change in the Southwestern U.S.
"Climate change is already affecting fish, wildlife, plants and their habitats around the globe. The Service's Southwest Region has been working with the U.S. Geological Survey (USGS)
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Global Change Reports and Assessments
"According to the Analysis of Global Change Assessments by the National Research Council:

“Water supplies will become increasingly scarce, calling for trade-offs among competing uses, and potentially leading to conflict.”"
University of Arizona
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Climate Change over the Southwestern U.S. as predicted by Regional Climate Models
American Geophysical Union, Fall Meeting 2011, abstract #GC21A-0861
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Study predicts permanent drought in Southwest
The National Center for Atmospheric Research

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Then there's the Bark Beetle global warming connection.
The sad fact is that higher elevation trees within the Rio Grande National Forest are under attack and dying in massive numbers.  Now these areas are becoming ripe for major forest fires.  And not in some indeterminate future, a ride over Wolf Creek Pass makes that frighteningly clear.

How will that information be avoided in the sales brochures?  

Why is it missing from the VWC-DEIS as another reason why Red McCombs should abandon his notion of a luxury resort in a dead forest at 10,500’ - instead he should return Alberta Park to the RGNF for the benefit of all down stream stakeholders?

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Indirect Effects of Development Concepts  
Bark Beetle

“The potential for a spruce bark beetle infestation, which now impacts 38 acres of the private land parcel, to reach epidemic levels in the near future is high within the Analysis Area due to the severe drought conditions the Rio Grande NF experienced in the early 2000's.  

If the beetle epidemic does spread, the elimination of infested trees from the Analysis Area could potentially reduce the rate of spread of the beetles at a stand level.  In addition, any spruce tree thinning projects associated with the development concepts may improve stand health to resist further attack.  

However, given the scale of spruce beetle outbreak over the entire Rio Grande NF, it is unlikely that the actions associated with Alternative 2 would control the spruce beetle outbreak over large areas adjacent to 
the Analysis Area, and hence the project's effects on the spruce beetle epidemic are negligible. 
Page 4-66 

Chapter 4. Environmental Consequences 
Draft Environmental Impact Statement  Village at Wolf Creek Access Project 

~ ~ ~ ~ ~ ~ ~ Direct Effects of Land Exchange

The land exchange would also result in the transfer of a 38-acre spruce bark beetle outbreak in the 
southern portion of the private land parcel (USFS, 2011b) to Federal ownership.  See Figure 3.6-3.  

However, spruce beetles are presently at epidemic levels in lands surrounding the Analysis Area and 
all mature spruce on the exchange parcels may be infected over the next several years.  The Forest 
Service would hence be responsible for managing the spruce beetle epidemic on the acquired non- 
Federal parcel.

Page 4-64   Chapter 4.  Environmental Consequences 

Draft Environmental Impact Statement  Village at Wolf Creek Access Project
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Why doesn't the VWC-DEIS use this opportunity to note the consequence of the Bark Beetle infestation is that in another ten years there probably won't be any living Spruce left standing in the area?  Instead what we will have is a fire danger situation worse than any we have known hereabouts... and the RGNF wants to facilitate a project right into that future?

Why doesn't the VWC-DEIS point out that this will further ruin the speculative village’s sales prospects.  Why do all the powers-that-be steadfastly ignore such contra-indicators?  

There's no good reason to allow the trade - and every reason to make LMJV deal with the parcel they originally acquired, thus helping him realize it’s time to abandon his pipedream.

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Global Warming is Doubling Bark Beetle Mating, Boosting Tree Attacks Up To 60-Fold, Study Finds - Think on Apr 30, 2012
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Western US Bark Beetles and Climate Change
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Tiny bugs, big destruction: Bark beetles on a rampage
By Anne Minard - December 2011

     Four Corners Free Press
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Visit the Colorado State University search page
and do a search for Bark Beetle and Wolf Creek Pass to get all the historical details of this invasion.

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Dear Friends of Alberta Park and Wolf Creek, 
we have this one moment to tell the Rio Grande Forest Service and the US Department of Agriculture's powers-that-be what a destructive boondoggle this luxury Village at 10,500± elevation would be.

But, they'll never listen to you, if you don't contact them!
Here's where to do that, but you need to do it now, September:

Commenting on This Project
The Forest Service values public input. Comments received, including respondents’ names and addresses, will become part of the public record for this proposed action. Comments submitted anonymously will be accepted and considered; however, anonymous comments will not provide the agency with the ability to provide you with project updates. The Forest Service wishes to provide you with as many opportunities as possible to learn about our activities.

Official Deadline for comments: 9/30/2012. (or is that Friday the 28th, or Monday the 1st?)

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