Double play at the Village at Wolf Creek

Recently there was a must read article in the Durango Herald.

I'm trying to stay within Fair Use guidelines so I'm posting a chopped up version of the most important points.  I recommend reading the entire article at:

http://durangoherald.com/article/20121010/COLUMNISTS37/121019986/0/SEARCH/Double-play-at-the-Village-at-Wolf-Creek

The Durango Herald

Double play at the Village at Wolf Creek

by Dan Randolph

October 10, 2012

[...] 

[...] 

[...] 

To proceed with the swap, the Forest Service had an appraisal done to establish the value of the now public land parcel... The value of five single-family home sites is clearly less than the value of the proposed Village. 

[...] 

However, the appraisal that is being used to establish the value of the public land that would be traded used five single-family homes sites as the proposed use. 

The Forest Service and McCombs... can’t have it both ways. If the proposal is for the Village, then the land must be appraised for that use. Alternatively, the EIS could match the appraisal and should consider only five homes. 

[...] 

The Forest Service argues in the EIS that the agency must allow year-round highway access, of the type needed for the Village, to allow for the “reasonable use and enjoyment” of the current private land parcel. The question becomes whether “reasonable use and enjoyment” necessitates the Village. 

There are thousands of private in-holdings... Do they all have the right to the access necessary for 1,700 units?... The whole EIS is predicated on this absurd notion... The appraisal is based on the “highest and best use” of the parcel – five homes – rather than the dreams of the McCombs family. 

Before the analysis goes any farther, the public has the right to understand why the Forest Service appears willing to trade the value of five home sites to facilitate a development of more than 1,700 units. 

[...]

Dan Randolph is executive director of the San Juan Citizens Alliance.

Freedom to inform refused by the USDA Forest Service [updated!]

There it is.  

The Gag Order stands firm and I may not share excerpts from the revealing pages 50 and 51 "Highest and Best Use Analysis" section.

Read on for The Rest Of The Story. . .

Climate Change's broader effects cause more worry

I would like to offer some more background supporting my claim that VWC-DEIS authors - and in fact, Mr. McCombs and his developer Clint Jones - need to start paying attention to the complex realities that climate disruption will be forcing on us.  

Whether you want to admit it, or deny it, we are entering a brave new world where global warming driven changes are going to overwhelm those who choose to continue ignoring it!

Destroying the integrity of the Albert Park Watershed for an unfeasible speculative scheme is not in the best interests of anyone.  

The Impact of Climate Change on Ski Resort Operations and Development: Opportunities and Threats

To support my claim in yesterday's VWC-DEIS Comment, namely, that the future bodes ill for such grand speculations as Mr. McCombs dream of bulldozing the Alberta Park Watershed into a luxury vacation village.   I submit a few highlights from the following report, but encourage you to view the entire study at:

http://dspace.mit.edu/bitstream/handle/1721.1/42018/226339450.pdf?sequence=1

The Impact of Climate Change on Ski Resort Operations and Development: Opportunities and Threats
By  Daniel D. D. McGill
B.S., Human and Organizational Development, 
1999 Vanderbilt University
Submitted to the Department of Urban Studies and Planning in partial fulfillment of the requirements for the degree of Master of Science in Real Estate Development at the Massachusetts Institute of Technology September 2007
© Daniel D. D. McGill All Rights Reserved.

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The Impact of Climate Change on Ski Resort Operations and Development: Opportunities and Threats

By Daniel D. D. McGill
Massachusetts Institute of Technology
September 2007

ABSTRACT
This thesis serves as a pedagogical guide to the ski resort industry, and presents a broad overview of the unique issues that accompany climate change. {...}

With few exceptions, existing literature on this topic has neglected to consider what opportunities might emerge as a result of climate change. While the field of climatology is an ever evolving science, the ski industry would be wise to take note as global warming is likely to prove one of those tectonic forces that gradually – but powerfully – changes the economic landscape in which they operate.

VWC Land Exchange Real Estate Appraisal - p50 - Local Market Conditions

Open letter to the authors of the Village at Wolf Creek Land Exchange - Environmental Impact Study.

Earlier this month I made a Freedom of Information request for a copy of the Village at Wolf Creek land exchange Appraisal Report.  I received it this past Tuesday (9/25/12) along with a cover letter that is pretty much a Gag Order.  Considering the late date I actually set it aside.  But now that the comment period has been extended by ten days I felt an obligation to at least open it up and try to wade through the two volume, 200 some page report. 

So, I’m reading along in the “VWC LEX - Non-Federal Parcel volume underlining a provocative paragraph here and there, but moving along just the same, considering I’m under a gag order.

But, then I came to page 50: ”Local Market Conditions,” and "The Village at Wolf Creek."  I’m sorry but it hit me like a slap in the face and makes me want to scream: “I told you so!”  

Come on, even the appraiser, who clearly believes that development is the “highest and best use” of this land - admits that the project is not financially feasible in the current market... and does anyone actually believe the market will be improving?

What in the world is the point of facilitating this out-of-reality scheme of a billionaire - {who builds a Formula One race track for fun and thinks it’s a civic improvement} - in the face of the economic reality of our area - as spelled out on page 50?  Keep in mind we are talking about source waters to the Rio Grande River Basin.  

For one, please consider the creeping impacts of the global warming, you authors so glibly wrote off.  After all the crop failures and other economic losses from this summer’s heat waves and drought will have far reaching economic impact.  Furthermore, the physics of global warming guarantee that this is just the beginning of the pain our economy will be feeling - at all levels.

Can we get real?  The happy dreamy days of the 80s, when this obsession was born are over, never to return.   

The details of the Village at Wolf Creek Proposed Land Exchange Real Estate Appraisal Review’s “non-federal” volume, page 50, regarding our local conditions is chilling to the bone.  But, I’m not allowed to share any of the details with others.  However, you authors of the EIS can read every word of it... please don’t ignore it, {the way you’ve tried ignoring the cascading consequences of our planet’s climate situation}, in your deliberations.

It is time to turn this McCombs’ Village at Wolf Creek versus Alberta Park Watershed discussion around and find some way to convince Mr. McCombs that it is in the best interest of everyone involved, including the empire he will be leaving his daughter, to find some way to return his current holding to the USDA Forest Service, or a nature conservancy arraignment.

[ “Dear EIS authors imagine my surprise, and relief, this morning when I pulled out the “second” volume of the VWC LEX Appraisal only to discover that I was sent two copies of the same report.  I wonder if that means the second was given to me for sharing?  In any event, I stand corrected, the Appraisal appears to be one volume of about a hundred pages.” ~ ~ ~ 

Nope wrong again.  Rereading my cover letter, I see that yes indeed Mr. McClure did indicate there should be two separate reports.  So since I have two copies of the volume marked “non-federal” I wonder if someone is looking at two copies of “federal” or whatever the other report was titled. ]

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

~~~~~~~~~~~~~~~~~~~~~~~~~~~

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Dear Friends of Wolf Creek, the United States Forest Service will never listen to you, if you don't contact them!

Here's where to do that, but you need to do it before Thursday, October 11th

Village at Wolf Creek Land Exchange Proposal #35945
https://cara.ecosystem-management.org/Public/CommentInput?Project=35945 

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.

Forest Service extends comment period on Village at Wolf Creek Access Project to October 11th

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~  

News Release
--FOR IMMEDIATE RELEASE—
September 27, 2012
Forest Service extends comment period on Village at Wolf Creek Access Project
Monte Vista, Colo., September 27, 2012 –The Rio Grande National Forest (RGNF) is extending the 45-day comment period on the Village at Wolf Creek Access Project Draft Environmental Impact Statement (DEIS) ten more days to October 11.  

Pagosa Daily Post - Village at the Top of the World

I thought I was finished posting, but I noticed Friends of Wolf Creek has posted a couple informative articles from the Pagosa Daily Post, that examine the details of the various development options being entertained.

My apologies for not getting this up sooner.  

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Village at the Top of the World– Part One

September 13, 2012

 Bill Hudson

From the Pagosa Daily Post on September 13, 2012: Clint Jones, the real estate developer from Austin, Texas who now serves as point man for the Leavitt-McCombs “Village at Wolf…

READ FULL ARTICLE

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Village at the Top of the World– Part Two

September 13, 2012

 Bill Hudson

From the Pagosa Daily Post on September 13, 2012: Read Part One A significant body of prior research regarding mountain resort operations and mountain resort developments makes it clear that…

READ FULL ARTICLE

Shared Comment - VWC-DEIS 35945 - Why no Impact Study of the costs of a failed VWC development?

Submitted at: https://cara.ecosystem-management.org/Public/CommentInput?Project=35945

====================================================

In closing, why don’t you Village At Wolf Creek Environmental Impact Study authors examine the important question of the Environmental Impacts a failed Village At Wolf Creek development will leave behind?  Namely, a torn up mangled watershed.  Given the dying forest; the drying water resources; and haggard future economic prospects, an altogether likely outcome.

My complaint with the VWC-DEIS 35945 is that it does a great job of presenting the developer's rosy economic argument and promises, from the perspective of a 1990s daydream. But, it contains no assessments that measure the extend of damages a failed project will have on the Alberta Park eco-system and the local economies or the good of the American people during the challenging years we are facing?

Shared Comment - VWC-DEIS - 1.6.5 Climate and Air Quality

Submitted at: https://cara.ecosystem-management.org/Public/CommentInput?Project=35945

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What I found most disturbing was that the DEIS contains nothing about our long term "Climate Change" related challenges.

In fact, the VWC-DEIS makes an out and out false assertion when they stated:

1.6.5 Climate and Air Quality 

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 available to predict any impacts" are disingenuous in the face of scientific knowledge.  Below are a few of the many studies that support my claim.  This information should be included in the deliberations and the FEIS.

 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

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)

http://www.fws.gov/southwest/Climatechange/index.html
~ ~ ~ ~ ~ ~ ~

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.”" 

http://www.globalchange.gov/publications/reports/scientific-assessments/us-impacts/regional-climate-change-impacts/southwest#issue1
~ ~ ~ ~ ~ ~ ~ 

Climate Change in the Southwest Observed Climate Changes

University of Arizona 

http://www.climas.arizona.edu/sw-climate/climate-change
~ ~ ~ ~ ~ ~ ~ 

Climate Change over the Southwestern U.S. as predicted by Regional Climate Models

American Geophysical Union, Fall Meeting 2011, abstract #GC21A-0861 

http://adsabs.harvard.edu/abs/2011AGUFMGC21A0861G 
~ ~ ~ ~ ~ ~ ~ 

Study predicts permanent drought in Southwest
The National Center for Atmospheric Research 

http://www.ucar.edu/communications/staffnotes/0705/drought.shtml

 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 

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.  These areas will become 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 contra-indicator for Red McCombs' notion of a luxury resort in a dead forest at 10,500’ - instead he should be encouraged to return Alberta Park to the RGNF for the benefit of all down stream stakeholders?

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 

4.6.1.2.2 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 
~ ~ ~ ~ ~ ~ ~

4.6.1.2.1 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."  

~ ~ ~ ~ ~ ~ ~  

Why don't the EIS authors use this opportunity to note the Bark Beetle infestation is unstoppable and that in another decade, or sooner, there won't (in all realistic probability) be any living spruce trees left standing around Wolf Creek Pass?  Instead, coupled with the expected drier conditions, what we will have is a fire danger situation worse than any we have known hereabouts... why are EIS authors trying to facilitate a project right into that future?

Why not point out that this will further ruin the speculative village’s sales prospects?  Why not point out that this will further ruin the speculative village’s sales prospects?  And increase the chances of this speculation becoming a spectacular failure.

EIS authors should stop ignoring 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 and to find some honorable way to return his parcel back to the Rio Grand National Forest or a nature conservancy.


After all your charge is to protect the interests of the American people first and foremost.

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Shared Comment - VWC-DEIA 35945 - 4.7.1 Direct and Indirect Environmental Consequences

Submitted at: https://cara.ecosystem-management.org/Public/CommentInput?Project=35945

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Regarding the description given at:

4.7.1 Direct and Indirect Environmental ConsequencesPage 4-73 - Chapter 4. Environmental Consequences - Draft Environmental Impact Statement - Village at Wolf Creek Access Project   4.7.1 Direct and Indirect Environmental Consequences

 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

I believe the take away message is that any digging and development in Alberta Park ~ whether on LMJV's current holding or slightly uphill and conveniently snuggled up against the highway ~ will cause irreparable harm to that biologically productive portion of the headwaters of the Rio Grande River Basin.  After all, it isn’t like there isn’t still plenty of wetlands and fens located on the desired parcel, or that uphill development won’t impact the watershed below it.

~ ~ ~ ~ ~ ~ ~

I know we love to think tomorrow will be better and with more opportunities than today so that any dream is achievable.  But, please look around at the 2010s world - why won’t the EIS authors acknowledge the unrealistic nature of this 1980s Dream Development in a time when economic, water and environmental issues are expected to become most challenging indeed?  

It occurs to me thinking about the inevitable and not all too distant future, when the spruce forest in and around Alberta Park is dead - those unmolested fens and other wetland features are going to be needed more than ever.

Why were you writers of the VWC-DEIS turning a blind eye to those down to earth challenges the future holds for us and our kids.  Why let yourselves be mesmerized by a salesmen’s fast talk?  

~ ~ ~ ~ ~ ~ ~ 

How will facilitating the destruction of an integral part of a precious wetlands, you know source waters for the Rio Grande River Basin, help our kids who depend on a healthy Rio Grande River as much as we depend on jobs?  

Help RGNF find a way to finally lay Red McCombs' pipedream to rest?  In order to secure the biological, ecological health of this headwaters of the Rio Grande River Basin for the future generations that depend on a healthy Rio Grande River, even more than they depend on a few hundred temporary jobs?

Why not entertain how to get Mr. McCombs to consider returning that parcel back to RGNF or into a nature conservancy?

Shared Comment - VWC-DEIS 35945 - 1.10 The ANILCA act of 1980

Submitted at: https://cara.ecosystem-management.org/Public/CommentInput?Project=35945

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1.10 The Alaska National Interest Lands Conservation Act of 1980
Draft Environmental Impact Statement - Village at Wolf Creek Access Project
Page 1-15   Chapter 1.  Purpose and Need for Action

Draft Environmental Impact Statement - Village at Wolf Creek Access Project

Page 1-15   Chapter 1.  Purpose and Need for Action

1.10 The Alaska National Interest Lands Conservation Act of 1980

Section 3210(a) of the Alaska National Interest Lands Conservation Act (ANILCA, Public Law 96-487) specifically addresses the right of access to privately owned inholdings within Forest Service lands.  Section 321 reads as follows:(3)

etc.,etc..

It seems to me, this whole land swapping is because the Rio Grande National Forest officials don’t want Forest Service Road 391 turned into a high traffic road... and with the ski area parking lot and all that mess, it’s just a nightmare for them to think about.  That’s as it should be.  But that’s what Mr. McCombs bought into with his original 1986 landswap.  The one where he promised officials and regular folks that he would build a nice exclusive private getaway for wealthy folks.  He was talking a couple hundred cabins or so.  FSR391 could probably have been modified to accommodate that without too much pain.

But what happened, after Mr. McCombs acquired this special piece of land is he’s the one that did a total flip on everyone and decided he NEEDED a village ten times the size of his stated plan.  

Why does the USDA-USFS feel an obligation to Mr. McCombs?  Particularly since he is the one that went back on his assurances made during the original land swapping!  Why is he being afforded so much leverage in these current landswap dealings?

Wasn’t ANILCA intended for folks who suddenly found themselves surrounded by Federal Lands?  Why would it apply to a speculator who traded into a special landlocked piece of National Forest Land?  Under false pretense at that!  

Why doesn’t the USDA-USFS-RGNF fight to regain and protect that headwaters watershed to the Rio Grande River Basin?

I hear there are an assortment of offers, possibilities for LMJV to trade that land for something more realistic at lower elevations.  Also, rumor has it there are various land conservancy organizations waiting for that call from Clint Jones or Red McCombs.  

Why doesn’t the USDA-FS pro-actively encourage that sort of a resolution to this impasse?

 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

My question for EIS authors would be:

Can it be argued that ANILCA’s previsions regarding road access were passed because of the massive amount of Federal acquisitions in Alaska at the time - so that the many people who suddenly found themselves surrounded by USDA Forest Service and other Federal Lands would have a legal right to gain road access to their land?

Therefore could it be argued that it is inappropriate for speculators, such as LMJV, who knowingly swapped/purchased a prime parcel of landlocked US Forest Service real estate within the boundaries of the established Rio Grande US National Forest - to claim that ANILCA gives him a legal standing to demand access for a high traffic road to said parcel?

Shared Comment VWC-DEIS 35945 - 3.4 Water Rights and Use

Submitted at: https://cara.ecosystem-management.org/Public/CommentInput?Project=35945

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Your DEIS 34945 presented an unacceptably optimistic developer’s appraisal, rather than a sober examination of the looming water crisis in the south west.  And gave the following piece of key information short shrift.

~ ~ ~ ~ ~ ~ ~

Draft Environmental Impact Statement - Village at Wolf Creek Access Project
Chapter 3.  Affected Environment - Page 3-25
3.4 Water Rights and Use
3.4.1 Scope of Analysis
“However, these (LMJV) water rights are relatively junior in priority and could be placed on call by downstream senior water rights.” 

Given that the water situation is becoming more restricted, how are junior water rights going help fill those two years worth of storage capacity for a village?

Shouldn’t the final Environmental Impact Statement include some science including the important information within the links listed below:

According to United States Global Change Research Group

(Integrating federal research on global change and climate change)  

http://www.globalchange.gov/publications/reports/scientific-assessments/us-impacts/regional-climate-change-impacts/southwest  

We have these key issues to face and prepare for:

1. Water supplies will become increasingly scarce, calling for trade-offs among competing uses, and potentially leading to conflict.

1. Increasing temperature, drought, wildfire, and invasive species will accelerate transformation of the landscape.

1. Increased frequency and altered timing of flooding will increase risks to people, ecosystems, and infrastructure.

1. Unique tourism and recreation opportunities are likely to suffer.

1. Cities and agriculture face increasing risks from a changing climate.

~ ~ ~ ~

Here are a few more informative links that provide the information needed to make the final EIS more complete that the draft EIS.

NOAA: Extreme Weather 2011 - Factoids

http://www.noaa.gov/extreme2011/factoids.html 

IPCC Special Report on Extreme Weather 

http://ipcc-wg2.gov/SREX/ 

Political leaders play key role in public understanding of climate change

http://researchnews.osu.edu/archive/climthreat.htm

Shared Comment VWC-DEIS 35945 -1.7.1 Health and Human Safety at a High Altitude Resort

Submitted at: https://cara.ecosystem-management.org/Public/CommentInput?Project=35945

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It’s interesting, all this money spent on studying and discussing a land trade clearly meant to facilitate a speculator’s dream of attempting to develop a grand luxury resort at ±10,500’ elevation.

A dream hatched in the go-go 80s, when nothing was too big to grab for.  But, this is the 2010s and our kids will be forced to deal with a much different world than the one we got to know.  I know Republicans love to believe they can ignore what Earth Scientists are learning and what all of us, who are interested, can observe.  But, you members of the EIS team should show the science more respect than you did in the DEIS.

How about weighing the viability of Red McCombs’ 80/90s pipedream?

As a business plan for a luxury village, why set oneself up for financial disaster by ignoring that this “village” will be put where folks breath 70% of the oxygen they would at sea level?  How does that impact the dream's viability?

===========

Here is an example of how the VWC-DEIS resolves such lynchpins to success:

1.7.1 Health and Human Safety at a High Altitude Resort Numerous commenters were concerned about the health and safety of people at a high altitude development.  Individuals are responsible for their own health, and living, working and recreating at high altitude is an individual choice and responsibility.

~ ~ ~ ~ ~ ~ ~

On the one hand, I can understand USDA and RGNF wanting to stay away from this touchy issue.  But we have a real health and business issue just the same: Very Thin Air! Yes, it is a personal choice.  But it is also an undeniable medical reality at Alberta Park - reflecting on the chances of this Village at Wolf Creek becoming an economic bust; which brings up the question: why destroy that wetlands area to begin with?

  

From a sales perspective, how does a speculative development succeed when it already eliminates a major portion of the target demographic from it’s potential buyer base for health reasons? 

Are there plans for building a high altitude medical center as in Telluride?  Who’s paying for it?

Considering the irreparable damage digging and building will inflict on this headwaters of the Rio Grande River Basin it seems irresponsible to ignore factors that so negatively reflect on the prospects for such an ambitious project at ±10,500’.  

Shouldn't these realities cause some hesitation among the powers-that-be in their headlong drive to facilitate this high stakes gamble?

 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

And what’s the deal with hiding the elevation of the land (10,160’ - 10,880’) deep in the small print.

Seems like some were trying to hide that important factor.

~ ~ ~ ~ ~ ~ ~ 

3.6 Vegetation Resources 3.6.1 Scope of Analysis The Analysis Area for vegetation resources is located east of the Continental Divide in the Rio Grande River Drainage Basin and encompasses the Federal and non-Federal exchange parcels and that portion of the private land parcel not exchanged. The total area is ±504.3 acres and ranges in elevation from approximately 10,160 to 10,880 feet.  ~  

Page 3-34   Chapter 3. Affected Environment

Will your FEIS make a point of including that info up front?  A factor that certainly will impact the business viability of a luxury residential village?

This leads to another question:  Why does the USDA-RGNF always accept the speculator/developers interpretation of what's important?  Can we please think this through before facilitating tearing up this important wetlands?  

~ ~ ~ ~ ~ ~ ~

How will facilitating the destruction of an integral part of a precious wetlands, you know source waters for the Rio Grande River Basin, help our kids who depend on a healthy Rio Grande River as much as we depend on jobs?  

Why no attempts to get Mr. McCombs to consider returning that parcel back to RGNF or into a nature conservancy?

Shared comment:DEIS #35945 - Page 2-46/47 - Employment Status

Well folks we are in the last week of the Village at Wolf Creek land swap DEIS  comment period.  Earlier in the month I made at least three comments through the DEIS comments page at 
https://cara.ecosystem-management.org/Public/CommentInput?Project=35945

And I sent them a hard copy covering eight DEIS items.  They have sent no acknowledgment that they received my letter and quite honestly I don't know if it's policy or not to acknowledge receipt of comments - or if we just have to wait until their final report to see what's in and what may have been overlooked.

Given that I've put this much effort into putting together this critique, I figured I should take out some insurance as I make a last round of comments through their comments page.

So I'll be posting my comments here and take a 'screen shot' of the comment page confirmation that pops up after hitting the send button for my own record.

And those of you out there who care - this is it, the final few days to make your considered opinion known to the powers-that-be.

===================================================

Page 2-46/47 - Employment Status

It’s interesting when it comes to Climate Change driving the Bark Beetle forest kill and Climate Change already creating drought conditions with numerous government sponsored studies warning us to prepare for worse... you EIS author’s write an out and out falsehood such as: 

VWC-DEIS - Page 4-56   Chapter 4. “{...}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.”

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But when you want to paint a rosy developer friendly impression, it’s done with confidence going out to the 2040s.  

VWC-DEIS, Page 2-46/47  -  Employment StatusPage 2-46/47 -  Chapter 2. Description of Alternatives Draft Environmental Impact Statement - Village at Wolf Creek Access Project 
“Alternative 3 Maximum Density Development Concept  
Employment Status.  As with the Alternative 2 Maximum Density Development Concept, the longer term impact of this development concept would likely be a reduction in the ongoing unemployment rate, although this would depend on other cycles in the regional/national economy.  During the 30- year phase in period, the Maximum Density Development Concept of Alternative 3 would generate a cumulative total of over 9,723 construction FTEs, or an average of 324 construction related FTEs in each year.  Upon completion in year 2044, ongoing Village operations would generate a total of 2,271 annual FTEs – these FTEs would continue into the future for as long as the Village maintains operations.”

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It’s my examination of such glaring “oversights” that have turned this whole VWC-DEIS drama into such a fascinating, though brutally depressing, exercise in watching willful self-deception in action for me.  

How can you EIS authors seriously claim that our physical environment in 2030s and 40s will resemble the world we loved these past decades of our lives - how can you presume to project employment figures based on past experience?  While remaining blind to the fundamental eco-system disrupts we are witness?

Drive over Wolf Creek Pass for a taste of future shock. . .
And it’s not local!  Different, but similar, disruptions to age old eco-systems are occurring all over this nation and the planet. Why pretend these cascading consequences aren't going to seriously impact all aspects of the Village at Wolf Creek’s viability?  Or the importance of an unmolested Alberta Park watershed?

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Why no look at the cost of a failed project?  
Why doesn't the Environmental Impact examine that potential?   The Rio Grande River needs Alberta Park to remain an unmolested key component of the Wolf Creek watershed more than ever.  Not a plowed up mess left by another developer with big pipedreams, but cash bust and gone home just the same.

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

How will facilitating the destruction of an integral part of a precious wetlands, you know source waters for the Rio Grande River Basin, help our kids who depend on a healthy Rio Grande River as much as we depend on jobs?  

Why not entertain how to get Mr. McCombs to consider returning that parcel back to RGNF or into a nature conservancy?

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Here’s a tiny sampler of real scientific information that you authors chose to ignore in your DEIS, will you repeat the “oversight” in your 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)

http://www.fws.gov/southwest/Climatechange/index.html

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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.”"

http://www.globalchange.gov/publications/reports/scientific-assessments/us-impacts/regional-climate-change-impacts/southwest#issue1

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Climate Change in the Southwest Observed Climate Changes

University of Arizona

http://www.climas.arizona.edu/sw-climate/climate-change

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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

http://adsabs.harvard.edu/abs/2011AGUFMGC21A0861G 

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Study predicts permanent drought in Southwest

The National Center for Atmospheric Research

http://www.ucar.edu/communications/staffnotes/0705/drought.shtml

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Climate Change and Bark Beetle epidemic

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BioScience 60(8):602-613. 2010
doi: http://dx.doi.org/10.1525/bio.2010.60.8.6

http://www.bioone.org/doi/abs/10.1525/bio.2010.60.8.6

Climate Change and Bark Beetles of the Western United States and Canada: Direct and Indirect Effects

Barbara J. Bentz, Jacques Régnière, Christopher J. Fettig, E. Matthew Hansen, Jane L. Hayes, Jeffrey A. Hicke, Rick G. Kelsey, Jose F. Negrón and Steven J. Seybold

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http://www.pnas.org/content/106/17/7063.short

Temperature sensitivity of drought-induced tree mortality portends increased regional die-off under global-change-type drought

1. Henry D. Adams^a,^b,¹, Maite Guardiola-Claramonte^a,^c, Greg A. Barron-Gafford^a,^b, Juan Camilo Villegas^a,^d,^e, David D. Breshears^a,^b,^d,^f, Chris B. Zou^g, Peter A. Troch^a,^c and Travis E. Huxman^a,^b,

1. Edited by Harold A. Mooney, Stanford University, Stanford, CA, and approved March 5, 2009

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http://www.sciencedirect.com/science/article/pii/S0378112709003296

Stand characteristics and downed woody debris accumulations associated with a mountain pine beetle (Dendroctonus ponderosae Hopkins) outbreak in Colorado

1. Jennifer G. Klutsch^a, José F. Negrón^a, Sheryl L. Costello^b, Charles C. Rhoades^a, Daniel R. West^a, John Popp^a, Rick Caissie^c

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BioScience 58(6):501-517. 2008
doi: http://dx.doi.org/10.1641/B580607

http://www.bioone.org/doi/abs/10.1641/B580607

Cross-scale Drivers of Natural Disturbances Prone to Anthropogenic Amplification: The Dynamics of Bark Beetle Eruptions

Kenneth F. Raffa, Brian H. Aukema, Barbara J. Bentz, Allan L. Carroll, Jeffrey A. Hicke, Monica G. Turner, and William H. Romme

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http://www.bioone.org/doi/abs/10.1603/0046-225X(2008)37%5B281:CFAWHS%5D2.0.CO%3B2

Environmental Entomology 37(2):281-292. 2008
doi: http://dx.doi.org/10.1603/0046-225X(2008)37[281:CFAWHS]2.0.CO;2

Climate Factors Associated with Historic Spruce Beetle (Coleoptera: Curculionidae) Outbreaks in Utah and Colorado

Elizabeth G. Hebertson¹ and Michael J. Jenkins²

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