To support of my claim that when it comes to Alberta Park, the watershed as it currently exists is far more valuable to Rio Grande River stakeholders than the prospect of some speculative "luxury village" development scheme.
I submit this policy statement by the U.S. Fish and Wildlife Service: Fens landscapes are a "category 1" resource because they are "essentially irreplaceable." USFWS mandates that every reasonable effort should be made to protect them.
Such as stopping the destruction before it begins!
Consider the reality - bulldozing that land for a huge development is guaranteed to irreparable destroy the hydrologic integrity of the Alberta Park watershed with it's interlacing fens landscape, which stores and filters water for the Rio Grande River. Not to mention the destruction and disruption of that huge wildlife sanctuary.
Furthermore, consider the economic, environmental and water supply realities of 2015 and moving forward in time. The value of Alberta Park 'As Is' increases in leaps and bounds with every new year.
While the financial outlook for a "village" dedicated to the luxury vacation home market, hours and hours from the nearest airports of note, at over ten thousand feet elevation with it's 66% oxygen supply, get shakier with every season.
I submit the following evidence for the importance of leaving Alberta Park unmolested by speculative "development."
Regional Policy on the Protection of Fens, resource category 1, as amended
U.S. Fish and Wildlife Service Region 6
January 20, 1999
From page two:
"Because of their uniqueness and importance, Region 6 decided that all its functioning fens, which were identified on U.S. Geological Survey, National Wetlands Inventory, ... fall within Resource Category 1 of the Service's "Mitigation Policy" (Federal Register Vol.16, No.15, February4, 1981).
The mitigation goal for Resource Category 1 is no loss of existing habitat value. In other words, because of the irreplaceability of the type habitat, every reasonable effort should be made to avoid impacting that habitat type."
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U.S. Fish and Wildlife Service Region 6
Peatland Mitigation Policy Considerations
Ecology Offices
Colorado Field Office
Lakewood, Colorado
December 1997
Revised January 1999
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
{I have quoted some key sections and added the bold highlights.}
Memorandum
To: Project Leaders for Ecological Services, Refuges and Wildlife, and Fish and Wildlife
Management Assistance, Region 6
Management Assistance, Region 6
From: Regional Director, Region 6
Subject: Regional Policy on the Protection of Fens, As Amended
January 20, 1999
United States Department of the Interior
Fish and Wildlife Service
Mountain-Prairie Region
page one
"This policy was originally approved by Acting RD Mary L. Gessner on June 8, 1998. As a result of input received from users, Region 6 decided to clarify some of the language regarding the soils aspect of fens. The modifications are minor from a policy standpoint.
One of the Fish and Wildlife Service's wetland priorities in Region 6 (the Mountain-Prairie Region) is the protection of conservation of fens. Fens are wetland that are primarily made up on organic soil material (i.e., peat or muck). Because they take thousands of years to develop, they are essentially irreplaceable. ...
Although fens only occupy a minor portion of the landscape, they perform important hydrological and water quality functions. For example, rare native cutthroat trout often benefit from the water cleansing action of fens in headwaters of streams. They also often possess unique biotic assemblages, especially fens that are high in pH and calcium. ..."
page two
"Because of their uniqueness and importance, Region 6 decided that all its functioning fens, which were identified on U.S. Geological Survey, National Wetlands Inventory, ... fall within Resource Category 1 of the Service's "Mitigation Policy" (Federal Register Vol.16, No.15, February4, 1981). The mitigation goal for Resource Category 1 is no loss of existing habitat value. In other words, because of the irreplaceability of the type habitat, every reasonable effort should be made to avoid impacting that habitat type."
"Functioning fens are those that (a) continue to support native plant communities and perform the functions inherent to fens or ..."
{The various patches of fens within the Alberta park watershed definitely fall within this category.}
¶ 12 "Mitigation for losses of fen wetlands is problematic because, as mentioned above, the rate of organic material (e.g. peat) accumulation in fens is extremely slow. For example, many of the fens of Colorado are over 10,000 years old with organic soil accumulation rates ranging from 4.3 to 16.2 inches per thousand years. In consideration of this slow accumulation rate, such wetlands cannot seriously be considered a renewable resources. In addition, removal of organic material (i.g. for peat mining) results in alteration of the site hydrology and the substrata in which fen plant species can grow. Therefor, onsite or in-kind replacement of peat wetlands is not thought to be possible. Furthermore, at present there are no known reliable methods to create a new, fully functional fen or to restore a severely degraded fen."
¶13 "Because of their vulnerability, protection of all fens are a priority in this Region. Including those which have not yet been mapped and officially designated as Resource Category 1. ...
"Because unavoidable impact will rarely be satisfactorily compensated by replacement of in-kind habitat. Region 6 Ecological Services Field Offices will normally recommend denial to all permits for project that may adversely affect functioning fens. ..."
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U.S. Fish and Wildlife Service Region 6
Peatland Mitigation Policy Considerations
Table of Contents
List of Tables and Figures
Introduction p.1
Region 6 Mitigation Policy p.1
Definition of Peatlands p.1
Type of Peatlands p.3
Classification Based on Source of Water and Water Chemistry (nutrient supply)
Bogs
Fens
USFWS Wetland Classification/The Cowardin System p.6
Classification Based on Floristic Characteristics p.6
Classification Based on Hydrogeomorphic Method (HGM) p.7
Geomorphic Setting p.7
Hydrodyamics p.13
HGM Classification of an Extremely Rich Fen South Park
Scarcity of Peatlands in Colorado p.17
Species Endemic to, or Dependent, on Peatlands p.17
Peatland Functions p.20
Ground Water Discharge Sites p.20
Short-term Nutrient Retention p.21
Long-term Nutrient Retention p.21
Plant and Wildlife Habitat p.21
Retention of Heavy Metals p.22
Uniqueness of Peatlands in Colorado p.23
Threats to Colorado Peatlands p.23
Peat Mining p.24
Real Estate Development p.25
Water Development Projects p.26
Grazing and Haying p.26
Replaceability of Colorado Peatlands p.27
Rate of Peat Accumulation p.27
Mitigation for Wetland Losses from the Removal of Peat p.28
Mitigation Policy Habitat Value p.28
References and Literature Cited p.29
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Uniqueness of Peatlands in Colorado p.23
"Many of Colorado's peatlands are unique based on their assemblages of plane and animal species, as well as their water quality improve function of retention of heavy metals. The unique plants and animals found in some Colorado peatlands are discussed in the Species Dependent on or Endemic to Peatlands section of this report. The metal retention characteristics of peatlands are discussed in the Functions of Peatlands section of this report."
Threats to Colorado Peatlands p.23
Peat Mining p.24
Real Estate Development p.25
Water Development Projects p.26
Grazing and Haying p.26
source: http://www.fws.gov/mountain-prairie/es/fen/FWSRegion6FenPolicy1999.pdf
source: http://www.fws.gov/mountain-prairie/es/fen/FWSRegion6FenPolicy1999.pdf
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