Click and behold, the LMJV's Alberta Park developers' pipe dream
On the VWC webpage, they tell you that the friends of Alberta Park and Wolf Creek, "are NOT your local grass-roots coalition fighting against this project." Well, I'm out here in my rural cabin, working on my own, occasionally communicating with others - and about as grass-roots as can be, I even have soil under my fingernails right now.
Though, it is true that this is NOT a "local issue"!
The Rio Grande River is an endangered interstate, international river, and LMJV wants to mess with its precious source waters.
That's personal for all Rio Grande River stakeholders!
I’ve been going through San Luis Valley Ecosystem Council’s VWC legal documents and came across a letter written by Christine Canaly, Director of the SLVEC, to the USFS’s NEPA Coordinator, just over twenty years ago.
It seems like a perfect cautionary essay (based on solid study) to start with and share with friends, including LMJV developers and USDA/RGNF powers that be. Two decades ago, a decision was made to focus exclusively on gaining access to Leavell McCombs Joint Venture’s Alberta Park inholding, while steadfastly ignoring the varied environmental (read physical reality) concerns raised in Christina’s appraisal.
Her thoughtful constructive advice was ignored by the governmental powers that be, and LMJV salesmen alike. That has resulted in twenty-years of squandered time and treasure with LMJV right back where they started.
Talk about throwing good money, after bad. Now in 2024 LMJV appears poised for victory. Yet, one way, or the other, it will be a pyrrhic victory since these issues haven't gone away.
Not to mention that the general economic feasibility index for such a 1980's inspired go-go dream project, and profits driver, gets thinner with every massive infrastructure damaging, global warming driven, extreme weather event eating away at the luxury market bottomline.
April 14, 2004
Rio Grande National Forest NEPA Coordinator, Divide Ranger District
13308 West Highway 160, Del Norte, CO 81132
Dear (for full text link here) …
I cut out the 325 word introduction and added some highlights.
SLVEC would like to draw your attention to a
Preliminary Geotechnical Engineering Study 9/29/86 & Preliminary Engineering
Geology Study 2/11/87, Prepared by Chen and Associates, Consulting Geotechnical
Engineers, 96 South Zuni, Denver.
Hydrology
Groundwater
“Ground water is expected to lie at a relatively shallow depth throughout most of the property. Ground water is at or near the surface all year long in the perennially wet areas. Seasonally high ground water is expected in most years in the seasonally wet areas.”
“The relatively shallow ground water table throughout much of the site could effect below-grade excavations or building construction. Artificially lower the ground water by pumping for temporary excavation of facilities. The ground water table can also be artificially lowered locally on a permanent basis for underground structures or elements such as building basements.” (how about underground parking lots?) “However, this becomes a significant operating expense and involves the risk of problems should the dewatering system fail.”
“If area subdrains are planned, it is advisable that a prototype be installed to evaluate actual field performance prior to design and installation of extensive area subdrains.”
“The surface water hydrology of the site should be evaluated by a hydrologist to study flooding potential.” Provisions need to handle concentrated water flow and erosion.
{Note. All of this digging will be mortally harmful to the fens, since they depend on the underground hydrology for their water supply - it is simply impossible to excavate into that meadow and surrounding area, without irreparably damaging thousands of years worth of evolved subterranean plumbing, ecosystems and their water filtering duties, and the fens, etc., they depend on.}
Soils and Sediment
“We recommend site-specific subsoil and foundation investigations be conducted at proposed building and other important structural locations prior to final foundation design.”
SW part of site – “Relatively high sediment concentrations may be associated with major storm runoff from these steep basins. The potential for small debris flows in addition to conventional flood evaluation should be assessed during future surface drainage evaluations by a surface water hydrologist.”
“The poorly drained areas, which make up much of the park floor and the valley bottoms of the two major steams, are open meadows and marshland.” “Embankment on the peat and much deposits have the potential for blocking ground water, which can result in ponding upgradient of the fills.”
“The main access road must traverse an area of difficult terrain along the south side of pass creek before it enters the site. It should be possible to construct the road through this area. The alignment should be laid out to reduce the amount of cut and fill required.
“We strongly recommend an engineering geological reconnaissance be conducted for the proposed Wolf Creek Pass Ski Area Village during the preliminary platting phase of the project in order to better evaluate the geologic conditions of the property and potential geologic hazards to site development. Such a study will probably be required for the preliminary platting phase by Mineral County and reviewed by the Colorado Geological Survey in accordance with Colorado Senate Bill 35.”
SLVEC believes this study brings up significant questions that to our knowledge still need to be addressed.
WATER RIGHTS
We understand that “Village at Wolf Creek” has secured water rights to replace depletions on the south fork feeding into the Rio Grande, but there is a difference between water rights and water availability. What sort of engineering study has been done to determine water availability and the adequacy of storage? What will the development do if drought conditions persist for any length of time? In 1977, drought conditions into the fall of that year stopped the stream from running, and the Wolf Creek Ski Area struggled to continue with their small scale operation. How would “Village at Wolf Creek” be managed under such conditions?
WATER TREATMENT/WATER QUALITY
Wastewater flow maximum projected at 378,270 gallons/day Chen and Associates 1986/87
Water availability is in short supply. As a result, waste water treatment at the Wolf Creek Ski Area is concentrated. How will the “Village at Wolf Creek” manage the concentration load of waste water treatment?
WETLANDS
According to the Department of the Army, Coors of Engineers letter from Anita Culp, Senior Project Manager, dated May 17 th , 2000, to Bob Honts -second paragraph, forth sentence “It is noted that several preliminary plan drawings include wetland boundaries.”
It goes on, third paragraph, third sentence, “Please be aware that any further discharges of dredged or fill material into waters of the United States, such as road crossing fills, building site fills, and possibly pond construction, will probably require an individual Department of the Army Permit.” This “individual Department of Army permit” is again suggested in a letter to Mr. Brian Estep, SE|Group dated October 19 th 2001. Has the “Village at Wolf Creek” filed for an individual permit as suggested by the Army Coors of Engineers?
In a October 1, 2001 letter submitted by the SE Group, consultants for the “Village at Wolf Creek”, page 4, Regulatory Status, “The Village at Wolf Creek” has proposed 25 water and sewer line crossings and three infiltration galleries in wetlands and/or streams. COE, Albuquerque District, letters dated May 28 and June 22, 1999 authorize utilization of Nationwide permits (NWP) 12 and 26 for authorization of these impacts to wetlands at the project site. NWP 26 is scheduled to expire February 11, 2002.” Has this permit been renewed?
It goes on to say that “Any additional discharges of dredged materials into Jurisdictional Waters not specified in the aforementioned letters will require additional permitting and approval from the COE.” SLVEC recommends that the COE use their discretionary authority and analyze this entire project.
Wetland Discrepancies
While viewing the wetland maps that have been submitted by the SE Group to the COE and comparing it to the Village at Wolf Creek Preliminary Development Plan, Wetland site 5 is highlighted and so is Wetland site 10, the former appears to be located in a multi family unit site and the latter runs through a road located on the plat. Has anyone bothered to do some thorough GIS/GPS work to determine the validity of these building sites? I see there have been some attempts to layer wetlands and development, but the devil is in the details and there doesn’t appear to be a quality analysis of the project area.
Final Hydrology Concerns
Data forms (7/26/01) submitted by the SE Group to the Army Coors of Engineers for their Routine Wetland Determination (1987 COE Wetlands Delineation Manual) under the HYDROLOGY category repeatedly check “No Recorded Data available” Does this mean that there hasn’t been a hydrologic study of the area done even though it was recommended by Chen and Associates back in 1986?
LYNX/WILDLIFE CORRIDOR/ MIS LISTING
In the original Decision Notice and Finding No Significant Impact that was signed in 1986, the third paragraph, second sentence reads “No threatened or endangered species are known to exist on any parcel nor is there key habitat for these species.” So much has transpired since 1986 and the reintroduction of the Canadian Lynx and listing of the Rio Grande Cutthroat Trout as a Management Indicator Species (MIS) acknowledges the reprioritization of Forest management that has been undertaken over the last twenty years.
The Lynx Reintroduction is considered a success and data sets from the Forest Service indicate the impact “Village at Wolf Creek” will have not only on a major Lynx migration corridor but their denning habitat (mango) as well. (Please see map) It appears this proposed development is in the middle of a major migration corridor (BLUE) between the South San Juan and Weminuche Wilderness areas. The territory of the Lynx is known to occur at around 10,000 ft. so the question becomes what sort of mitigation measures will the “Village at Wolf Creek” employ for the loss of habitat?
Alberta Reservoir is home to Rio Grande Cutthroat Trout, what impacts will this development have on the fisheries located on the property and below? Fingerlings are known to migrate from Pass Creek into the wetlands, what impacts will building have in terms of sedimentation loading downstream (water quality)? Regarding the concentration of treated water mentioned above, what impact will this have on the prize fishery below? Sensitive Plant Communities
There are many wetland plants mentioned in the SE Group study, has anyone checked for the Wolf Creek Primrose Orchid whose habitat matches that found in the “Village at Wolf Creek” project area?
COST OF COMMUNITY SERVICE ANALYSIS (COCS)
SLVEC is submitting A Revenue/Cost Analysis of Community Service Provision in Saguache County, Colorado with this scoping letter because it is important that Socio-economic issues be addressed in regard to this “Village at Wolf Creek”. The socio-economic impacts to the towns of South Fork and Pagosa Springs need to be addressed in light of the findings within this COCS, whose methodology has been used in over 80 communities throughout the country.
In summary, “The Saguache County findings make clear that while new residential development in the county increased the gross amount of income collected by the county (mainly through a marked increased in assessed valuation), the net fiscal impact on the county was negative.” What’s interesting about the “Village at Wolf Creek” is it is located in Mineral County where assessed value will be collected, but the community services will be provided in Rio Grande and Archuleta Counties, where workers will inevitably be required to live because of proximity to the “Village at Wolf Creek”. It should be noted that road maintenance, health, education and welfare make up the majority of the county budget. These costs will have to be absorbed by these neighboring counties.
HEALTH/AMS
Elevation at the site ranges from adjacent to the access road 10,240 to 10,850 ft. SW corner. According to an article that was reprinted in the New England Journal of Medicine, July 2001, AMS-Acute Mountain Sickness affects 40% of individuals sleeping at elevations above 10,000 ft. Has the “Village at Wolf Creek” considered the ramifications of these findings and how are they going to mitigate the impact of individuals arriving from sea level?
SLVEC understands that there are many other issues to address; impacts to the Wolf Creek ski area, construction and road maintenance on Wolf Creek Pass, traffic flow, air quality, the original land exchange and quality of recreational experience. We believe other groups and individuals will address these issues and give it the consideration it deserves.
In closing, SLVEC wants to emphasize the importance of an EIS that encompasses connective action and cumulative, direct and indirect effects. In short,“Village at Wolf Creek”, because of its location on the south fork feeding the head waters of the Rio Grande, it’s 10,000 ft. elevation, it’s proximity to pristine wilderness, wildlife migration corridors and Alberta Reservoir containing Rio Grande Cutthroat Trout, and impact to neighboring counties and the ski area, deserves careful scrutiny.
The person who originally conceived this idea is gone. May this idea rest with him. There is a reason this area was never developed, engineering study after engineering study subtlety but steadily indicates the difficulty in building on this site and the complexities associated with maintaining such an albatross. It is imperative that we take advantage of the wisdom and opportunity that has been provided to us, the fact that this area, almost twenty years later, still remains as pristine as it was when the idea was first conceived.
SLVEC wants to encourage that this inholding be purchased by a conservation buyer and the majority of it put back into public lands or protected by a conservation easement. We would like to help move it in that direction.
Thank you for your time and consideration.
Sincerely,
Christine Canaly
Director
Cc: Mineral and Rio Grande County Commissioners
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