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HomeMy WebLinkAboutExhibit V - RFC letter dated 05.29.2013To: May 29, 2013 Garfield County Board of County Commissioners 108 8th St. Glenwood Springs, CO 81601 Attn: Tamra Allen, Garfield County Planning Manager RE: Proposed Changes to Article 7 of the Unified Land Use Resolution of 2008 (Phase II) Dear Ms. Allen, Thank you for the opportunity to comment on the proposed changes to Article 7 of Garfield County’s Unified Land Use Resolution of 2008. Roaring Fork Conservancy is concerned about the detrimental effects to water resources posed by the complete deletion of Section 7-203 (Protection of Wetlands and Waterbodies) and substantial modification of Section 7-204 (Water Quality from Pollutants). Both sections protect water resources from unintended, yet potentially harmful, development impacts. Maintaining the protections afforded in Sections 7-203 and 7-204 preserve Garfield County’s long-term economic development potential by retaining riparian features beneficial to both private and public interests. The proposed changes to Sections 7-203 and 7-204 remove protections for wetlands and riparian vegetation which serve as natural buffers against detrimental development impacts such as sedimentation, erosion, and contamination from hazardous and non-hazardous pollutants. Wetlands and riparian vegetation play an integral role in stream health by trapping sediments and reducing erosion.1 They also help manage pollutants, including nutrients and pathogens, in the water supply. However, development can degrade and deplete wetlands, thereby impairing these functions. According to U.S. Environmental Protection Agency, “wetlands trends on nonfederal lands indicate a loss rate of between 70,000 and 90,000 acres annually, most of which is due to increases in development.”2 1 Wegner, S., 1999. A review of the scientific literature of riparian buffer width, extent and vegetation, http://www.rivercenter.uga.edu/service/tools/buffers/buffer_lit_review.pdf. 2 U.S. Environmental Protection Agency (EPA), 2001. Our Built and Natural Environments, p. 19, http://www.epa.gov/smartgrow th/pdf/built_chapter2.pdf (citing U.S. EPA, Office of Water Wetland Page). BOARD OF DIRECTORS Ramsey Kropf President Rick Neiley Vice President Jennifer Sauer Secretary Ted Borchelt Carter Brooksher Stephen Ellsperman Jim Light Rick Lofaro Executive Director Don Schuster Diane Schwener Past President Rivers Council Liaison Jacque Whitsitt Town of Basalt Representative Larry Yaw Valerie Alexander Yaw PROGRAM STAFF Rick Lofaro Executive Director Claire Britt Office Manager Sharon Clarke Watershed Action Director Sarah Johnson Education Outreach Coordinator Tim O’Keefe Education Director Chad Rudow Water Quality Coordinator Heather Tattersall Land, Water & Policy Coordinator Sarah Woods Director of Philanthropy The loss of Section 7-203 and 7-204’s protections could leave Garfield County’s water resources unnecessarily vulnerable to development impacts. According to the State of the Roaring Fork Watershed Report 2008, more than 75% of the Roaring Fork River’s riparian and instream habitat in the Lower Roaring Fork Subwatershed is directly impacted by developed land use activities. In the same area, more than 78% of the bank is severely degraded, and the remaining area is heavily modified.3 Removal of riparian protection through the proposed Unified Land Use Resolution changes could potentially accelerate degradation, thereby increasing potential water quality concerns. A key impact of concern is erosion. Since natural vegetation reduces erosion, a loss of riparian buffer protections could result in additional loss of soil, vegetation, and riverfront areas attractive to developers. This process could also increase sediments in the river, potentially affecting aquatic life by reducing light for photosynthesis in plants and setting off a chain reaction of decreased food sources for invertebrates and fish populations feeding on the invertebrates. Sedimentation further threatens invertebrate populations by filling interstitial spaces essential for habitat.4 Increased sedimentation and a potential decline in fish population could harm Garfield County’s economy. Garfield County boasts a strong tourist economy associated with hunting, rafting, and fishing. Hunting and angling result in a $300,000 economic boost to direct spending in Garfield County, while the same recreational pursuits provide over 550 jobs.5 Increased river sedimentation could limit the viability and attractiveness of these economic drivers. In addition, the Garfield County communities of Rifle, Battlement Mesa, and Silt, along with many others, rely on the Colorado River for drinking water. Increased sedimentation, along with increased nutrients, pathogens, and other pollutants, could lead to higher drinking water treatment costs for residents.6 The removal of Sections 7-203 and 7-204 from Garfield County’s Unified Land Use Revision impairs the County’s long-term economic growth by removing protections that ensure riparian features remain beneficial to private and public interests. In the 2008 Garfield County Public Opinion Survey, 83.5% of respondents ranked “Encourage protection of river-fronts and wetland areas” as a 3 Ruedi Water & Power Authority, 2008. State of the Roaring Fork Watershed Report, Ch. 4, Sec. 4. 4 Bartenhagen, Katherine A., et al. WATERSHEDDS Sediment, http://www.water.ncsu.edu/watersheds/i nfo/sediment.html. 5 http://www.garfieldlegacy.org/Benefits___Tools.php. 6 Bartenhagen, Katherine A., et al. WATERSHEDDS Sediment: http://www.water.ncsu.edu/watersheds/info/sediment.html. 4 or 5, with 5 being the highest rank and corresponding to Great Benefit. In the same survey, respondents ranked “Water Quality and Quantity” a 4.42 on a scale of 1-5, with 5 being Very Important.7 Roaring Fork Conservancy agrees with the polled constituents on the value of these resources. We respectfully request that the protections offered in Sections 7-203 and 7-204 remain in the Garfield County Land Use Code. Thank you for your efforts and consideration. Sincerely, Rick Lofaro Heather Tattersall Executive Director Watershed Action Coordinator 7 http://www.garfield-county.com/community-development/garfield-county-opinion-surveys.aspx.