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Home My WebLink AboutCPW Glenwood Springs Office, Area 8 Service Center 0088 Wildlife Way • Glenwood Springs, CO 81601 PH: (970) 947.2920 September 19, 2025 Garfield County Community Development Department 108 8th Street, #401 Glenwood Springs, CO, 81601 Submitted via email to jleybourne @garfieldcountyco.gov and ghartmann@garfieldcountyco.gov RE: Harvest Fork PUD, PUDA-07-25-9079 and PUDA-12-24-9048 Mr. Leybourne and Mr. Hartmann, Colorado Parks and Wildlife (CPW) appreciates the opportunity to comment on the Harvest Roaring Fork PUD project in Garfield County. CPW has a statutory responsibility to manage all wildlife species in Colorado, and CPW encourages Realty Capital Management to afford the highest protections for Colorado’s wildlife species and habitats. The Harvest Fork PUD project is proposed to encompass approximately 283 acres located between Colorado Highway 82 and the Roaring Fork River in Garfield County Colorado. This project will encompass the Cattle Creek drainage and the associated riparian corridor to the confluence with the Roaring Fork River. This riparian area is held under a conservation easement by Roaring Fork Conservancy. This project involves the development of both commercial, recreational areas, and up to 1500 residential units that can have substantial impact to both aquatic and terrestrial species in the area. This type of development will not only have a direct impact on-site, but will have indirect impacts to the surrounding public lands with the potential of several thousand new residents now recreating on them. Jeff Davis, Director, Colorado Parks and Wildlife Parks and Wildlife Commission: Richard Reading, Chair ∙ James 'Jay' Tutchton, Vice-Chair ∙ Eden Vardy, Secretary ∙ Jessica Beaulieu ∙ Frances Silva Blaney ∙ John Emerick ∙ Tai Jacober ∙ Dallas May ∙ Jack Murphy ∙ Gabriel Otero ∙ Murphy Robinson 1 The area proposed for development is currently used by a variety of species such as mule deer, elk, river otters, black bear, raptor species, herons, and other small mammal, bird and aquatic species. This area is directly adjacent to mapped elk and mule deer critical winter range across HWY 82 to the east, and other high priority habitat for deer and elk. The project area is one of the last undeveloped parcels on the valley floor and while not mapped as severe winter range, winter concentration,or even winter range, it annually supports a large number of elk and deer seasonally. While the upper portions of the property have been largely scraped and re-graded, some vegetation has persisted and is providing some level of habitat. The lower riparian areas, within the conservation easement, are relatively high functioning habitats supporting many different species. The elk that currently use the parcel will likely be displaced to adjoining parcels that are less densely developed, potentially creating conflicts with other land owners. The level of development proposed in this application will have both direct and indirect impacts to wildlife and wildlife habitat. In order to minimize the potential impacts please consider the following recommendations: Due to the high level of use of this area by deer and elk, and its proximity to Highway 82, CPW recommends that appropriate measures be taken to prevent wildlife from entering or crossing the highway at the proposed development entrances. Game guards or other recognized alternatives, should be placed across the length of any breaks or deviations in wildlife fencing along the roadway. Game fencing should also be extended from the northern terminus of the Hwy 82 game fencing, west to the Rio Grande trail in the North Frontage neighborhood, as that area has been the site of numerous deer/elk/vehicle collisions as deer and elk try to cross Hwy 82. Black bears are known to inhabit the project site and adjacent properties. The proposed development raises specific considerations regarding potential human/bear conflict, particularly related to waste management and food attractants. Improperly managed trash receptacles, bins, and storage areas in both commercial and residential developments can become strong attractants for bears, leading to increased bear-human conflicts, habituation, and potential threats to both human safety and wildlife health. Bears attracted to readily available food sources, including garbage, frequently become habituated to human presence, increasing risks of property damage, vehicle collisions, and management actions, including lethal removal of problem bears. To proactively address and mitigate these potential impacts on bears, CPW recommends consideration of the following strategies during construction and general operation of the development: ● Install round handled doorknobs on all exterior doors. ● Avoid planting any fruit, berry or nut bearing or producing trees or shrubs for landscaping. ● Install bear-resistant trash receptacles throughout the facility, particularly in parking areas, fueling zones, and near food service locations. 2 ● Ensure regular trash removal schedules to prevent accumulation and potential attraction. ● Fully enclosed or locking bear resistant storage for communal waste bins and dumpsters. ● Deploy signage and visitor education programs to inform customers and employees about proper waste disposal practices and bear awareness. ● Ensure waste storage and food-related operations are located in centralized portions of the development, away from habitat edges, to minimize bear attractants near natural habitats. ● During construction, all food trash must be stored in an IGBC - certified bear-resistant container or taken off site at the end of each day. ● Use only bear proof dumpsters and store trash securely until the morning of pickup. The area of proposed development is in close proximity to several historic osprey nests on the Roaring Fork River. CPW recommends no surface occupancy (beyond that which historically occurred in the area) within 1⁄₄ mile (1320 feet, 400 meters) radius of active nests. No permitted, authorized, or human encroachment activities within 1⁄₄ mile (1320 feet, 400 meters) radius of active nests from March 15 through August 15. In addition to the osprey, there are several historic Great Blue Heron colonies within the RFC conservation easement area. The specific site has moved up and down the river as the herons have killed the trees they are in, but generally remain in the Cattle Creek confluence area. The CE held by RFC is specific that buffers with adequate vegetational screening be established before neighborhood construction can begin. The Wildlife Impact Report provided by Colorado Wildlife Science, LLC addresses this issue and those recommendations should be followed. The Roaring Fork River is designated as a Gold Medal Water and is an important resource to the community. This designation as an Aquatic Sportfish Management Waters falls under High Priority Habitat and are CPW-mapped waters where the protection and enhancement of aquatic habitat is important to maintaining sportfish and their associated recreational opportunities. The CPW recommended window for in-stream or riverbank work projects is between August 15 and September 30 th to avoid disruption of spawning behavior and activity of local fishes, including Rainbow Trout, Brown Trout, and Mountain Whitefish. Any instream disturbance (e.g., any activities in the wetted channel including crossings, maintenance, repair, or construction) should occur within this window. Deviations from this construction window should be justifiable and based on necessity, and should not exceed 4 days beyond the stated work window. In-channel disturbance (including worksite clean-up) must halt no later than October 3 to avoid impacting the locally imperiled whitefish population. 3 Implementing best practices to minimize downstream river turbidity include visually monitoring turbidity 100 meters downstream of the construction site. If water clarity is noticeably different 100 meters below the site of disturbance, pause construction activities to allow water to clear before resuming. Discourage the creation of tubifex worm habitat by reducing areas of fine sediment deposition. To prevent the spread of aquatic nuisance species (e.g., Zebra/Quagga Mussels, Whirling Disease, New Zealand Mud Snail), any equipment used in the Roaring Fork River or Cattle Creek, should be cleaned prior to and after construction. All equipment should also be allowed to thoroughly dry between work sites. Disinfection with QAC: Remove all mud and debris from equipment (tracks, turrets, buckets, drags, teeth, etc.) and spray/soak equipment with a disinfection solution containing quaternary ammonia compound (QAC). Treated equipment, keeping it moist for at least 10 minutes. The recommended concentration for any commercially available QAC product used to disinfect equipment is 6 ounces of QAC solution per gallon of clean water, or disinfection with Hot Water: Spray/soak equipment with water heated to more than 140 degrees Fahrenheit for at least 10 minutes. Also of importance to CPW is the revegetation of disturbed soils and the control of noxious weed species. Much of the project area has previously been disturbed and as such a variety of undesirable weeds already exist on-site. To minimize impacts, CPW recommends that open space and undeveloped areas of soil disturbance be revegetated with native species by using a native seed blend that closely matches the surrounding vegetation to restore ecological function and maintain habitat integrity. Where ground disturbance occurs, establish a diverse plant community, including native grasses, woody plants, and broadleaf forbs, to support wildlife nutrition and cover. Prevent the spread of invasive plant species and listed Noxious Weeds by incorporating a comprehensive weed management plan, including monitoring and treatment as needed. Conduct long-term monitoring to assess revegetation success and complete weed control and maintenance to ensure the establishment of a functional, native plant community. CPW recommends leash ordinances and strict enforcement of outdoor domestic pets in the residential areas after development. Loose or uncontrolled dogs can have a significant impact on wildlife including direct and indirect mortality, increased stress and disturbance, and displacement to less preferred habitats. Further, dogs can be viewed as a prey item for predators. These impacts and conflicts can be mitigated by keeping unsupervised outdoor dogs in a fully enclosed kennel (including roof) near a residential building and otherwise leashed or under direct human supervision and control when outside. The North and South Riverfront neighborhoods of the Harvest Fork PUD proposal pose substantial concern for habitat degradation and potential human impact by residents if enforcement is not done to ensure that access to the Roaring Fork River through the conservation easement areas is controlled. Per language in the CE, neither human intrusion nor recreational trails are allowed within the CE areas. Fencing, signage, education and enforcement are necessary so that residents comply with the restrictions, but also have an 4 understanding of the importance of the riparian areas for wildlife. These concerns also extend to the Nature Area Neighborhood as described in the development ordinance. Overall, there are potentially substantial impacts to wildlife to be considered for the Harvest Fork PUD project. CPW has concerns for both terrestrial and aquatic species in the area proposed for development, along with high potential for degradation of riparian areas currently protected under a conservation easement. As this PUD application is vague on details, additional recommendations are likely when specific Neighborhood planning begins. As stated above, 1500 new residential dwellings will have on-site as well as off-site impacts. With the potential of 3000-6000 new residents there will be an increased appetite for recreation on surrounding public lands and resources. The proposed level of on-site development will limit the potential for on-site mitigation. With ever tightening budgets and increasing costs to implement habitat enhancements, CPW would encourage the applicants and the county to explore the potential of establishing a mitigation fund that could help pay for off-site mitigation work in the surrounding area. As the project moves forward CPW would be happy to discuss this potential further. Thank you again for the opportunity to comment on the Harvest Fork PUD project. We appreciate your consideration of our recommendations to avoid and minimize impacts to wildlife. In addition to the recommendations above, please incorporate the mitigation measures outlined in the Wildlife Impact Report completed by Colorado Wildlife Science. If you have any additional questions regarding wildlife concerns for this project, please contact Assistant Area Wildlife Manager, John Groves, at 970-948-3013 or john.groves@state.co.us. Sincerely, Matt Yamashita Area Wildlife Manager CC: J Groves-AAWM File 5