PLAN-Boulder County Comments on OSMP proposed route alternatives for Trail 13 and Trail 14 in Spring Brook/Doudy Draw Natural Area

July 29, 2007

PLAN-Boulder County commends the OSMP staff for careful preparation of alternatives for routing these proposed trails in the short time frame available.

However, proper management of Open Space and Mountain Parks resources requires taking adequate time to ensure:

• sound trail construction at reasonable costs;
• trail sustainability;
• preservation of critical wildlife habitat and sensitive plant communities;
• compliance with Council's instructions that the area should be managed so that it could still be designated as an HCA, should that become desirable;
• adherence to the Visitor Master Plan (VMP) provisions for the goals of managing Natural Areas (p. 48) and for implementation monitoring (pp. 62-63)-specifically
• "Accommodate low-impact visitor activities where adequate trails exist or can be built, and resource impacts can be minimized."
• "Protect the quality of naturalÉresources (especially where high-value resources exist)."
• Implementation monitoring requirements are specified to measure change as a result of the actions taken. These can only be met if baseline data are collected. Otherwise most of the criteria in the implementation monitoring cannot be satisfied.

These elementary soil characteristics have not been taken into account in the initial routing proposal, apparently because of the rush to meet deadlines. This does not reflect badly on the staff who have worked on the detailed preliminary routes, but it does demonstrate that the planning process has been unwisely rushed, and that we need to take the time to do the job right. Rushing to try to begin construction this season will result in badly built, unsustainable, and very expensive trails; serious damage to the resource; an inability to properly monitor the trails' effects; and a much more costly future set of consequences to deal with. There is no major cost associated with taking the time to do the job right. The only problems associated with some delays are that current social trails will continue to be used for a time. The degradation caused by this process, and the difficulty of mitigation, will be trivial compared with that caused by trails built in the wrong places. Once new trails are built, there is likely to be greatly increased visitation in this area, which will enormously compound the problem if this is not done correctly.

Now that a preliminary agreement with the Denver Water Board regarding the canal crossing finally has been reached, it is time to rethink the trail alignments that were largely done without knowing where the crossing would be. Attempts to decide routing in advance of this milestone disrupted monitoring plans for both the Goshawk Ridge Trail and Trails 13 & 14. It is hard to route a trail or to plan monitoring when you don't know where it is going! We congratulate the OSMP staff who have brought these difficult negotiations to a preliminary conclusion. However, it is time for another careful look at the alternatives.

We believe that, in light of the recently negotiated mid-canal crossing location, trail alternatives need to be seriously reconsidered. For example, two possible alternative routes for the Trail 13-Stem Trail have not been considered. These are:

• Following the old railroad grade, which already has a bed installed, so that little additional disturbance would be caused by trail construction, unstable Pierre Shale routes would be largely avoided, and there would be far less potential for providing an invasion pathway for noxious weeds; one bridge would need to be built;
• Up the west side of the stony ridge to the east of the drainage. This route would avoid much of the sensitive habitat disturbance that will result from the currently proposed stem trail, and it has enough gravel cover that it may well provide a route that has better soil characteristics, and that gains most of the required elevation at a moderate angle and follows a direct path that would discourage shortcutting. By keeping to the west side of the ridge, views down to Lindsey Pond can probably be avoided.

A third significant problem relates to invasive weeds in the area. Jointed goat grass (Aegilops cylindrica Host) is a major problem on a large number of trails in the OSMP system. This invasive species is difficult to control, and it is easily spread by hikers, animals, and probably mountain bikes. The seeds fit the grooves in Vibram soles, and they will probably fit many bicycle tire treads. A. cylindirca is spread as a seed contaminant in agricultural areas, and thence by grazing livestock like horses, because the seeds survive passing through the guts of ruminants.

Jointed goat grass has become a serious problem and has seriously infested the bottom of the Doudy Draw Trail. The proposed rerouting of the Doudy Draw Trail before this invasive is controlled will only ensure that the infestation moves up the slope and becomes much larger and more difficult to control. Yet the Suitability Analyses do not even mention this invasive except to say that there is a possible problem during construction of Trail 13 Stem if construction is done from the direction of Doudy Draw. There is no mention of it being spread by users, not only to this trail, but to all the others being proposed.

This issue must be seriously considered and preventative measures must be taken before trail construction. Otherwise, it is highly likely to damage the resource and to result in major expenses for weed control.

Recommendations

Our principal recommendations and observations are as follows:

1. delay construction until next year;
2. do not build a trail in Spring Brook Meadow; there are a number of alternative routes for the currently mapped Trail 13 alternatives. This meadow provides: exceptional habitat for deer and elk; possible presence of Preble's Jumping mouse; confirmed lion hunting grounds; vulnerability to weed invasion, as demonstrated by presence of high-priority weeds (such as Dalmatian toadflax and Sulfur cinquefoil) along the existing social trail;
3. funneling visitors into Spring Brook meadow will inevitably promote off-trail travel throughout the area, including the length of the meadow along the desire-line and the current social trail northward;
4. implement the control of jointed goatgrass in Doudy Draw this fall and winter, and verify that control has been successful before attempting to schedule the construction of the rerouted Doudy Draw Trail or Trails 13 and 14;
5. as the next step in the public input process, provide maps at a scale useful for trail planning that include critical wildlife habitat areas, critical plant communities; and soils/geology. These are fundamental tools for planning ecologically sustainable trails;
6. complete a monitoring plan for the natural resources, including evaluation of resource impacts; compliance monitoring; visitor conflict issues; and plans for management actions when expected criteria are not achieved;
7. as a first step, build a modified route from the Doudy Draw stem trail-possibly up the west side of the stony ridge, staying far enough west to avoid tempting views into the Lindsey Pond area;
8. this approach should connect with upper Trail 14, which should be followed around its current route, except that it should be re-routed onto the terrace, far enough back to avoid the ecotone, but always less than 100 meters from the edge, avoiding relict grasslands, and fragmenting the forest habitat as little as possible;
9. monitor the impact of this trail in order to provide adequate impact data for consideration of Trail 13 alternatives;
10. while the usage of Trail 14 is being monitored, consider the possible routes for 13, including the possibility of routing the upper alternative farther south;
11. among the criteria for Trail 13 that need to be achieved is the routing of Trail 13-Stem along a less damaging route, which does not repeatedly cross the riparian shrubland, does not remain in the terrace/slope ecotone for long stretches, and does not follow long traverses of unstable, slumping Pierre Shale; there appear to be several possibilities for achieving these goals.
12. for upper Trail 13, which seems more likely to present a possible route that minimizes resource impacts than lower 13, utilize the time while 14 is being monitored to achieve a well-planned route;
13. one possibility for routing 13 is to follow the currently proposed alignment for upper 13 approximately 200 yards above the intersection with the currently proposed Trail 13-Stem, and then proceed west and then slightly north to join the current alignment of Trail 13-Springbrook.

Reference:

Squire, M., 2001, Stability of Cretaceous Pierre Shale slopes, in Kuehne, M., Einstein, H.H., Krauter, E., Klapperich, H., and Poettler, R., eds. Essen, Verl. Glueckauf.

Thank you for considering this important request.

Sincerely,
Pat Shanks, Chair
PLAN-Boulder County
The People's League for Action Now