Wildlife
(response to 6th GDP)
Wildlife
(response to 6th GDP)
Many species call the former StorageTek / Phillips66 site home. Some of these animals are visible from the roads surrounding the property. Because the site is private property, however, and Brue Baukol is not allowing Louisville residents access to it, we have to rely on the developer’s own reports to understand the types of wildlife in the interior of the property, their numbers, and their distribution across the site.
In the new GDP, structures are not clustered and no apparent effort was made to utilize surrounding topography and open space to create a visual buffer. Such a spread out development will devastate the wildlife on site. By wiping out wetlands and nearly all of the prairie dog habitat, there will be little left of the habitat upon which so much of Louisville's wildlife currently depends.
The GDP includes no limit on parking lots, roads, or concrete coverage. The sustainability document states that the project will not provide more parking than the City’s minimum requirements. However, this is still a huge addition to the built footprint as can be seen from the GDP drawings.
The RTR sustainability document states that the project will "Implement a habitat management plan for the full site (400+ acres)", but the GDP allows only 38 acres of open space
"We value Ecological Diversity . . . where the City, through its management of parks and open space and its development and landscape regulations, promotes biodiversity by ensuring a healthy and resilient natural environment, robust plant life and diverse habitats."
~City of Louisville Comprehensive Plan
“Natural features, historical and archaeological sites, and vegetation of the area, including trees, must be preserved to the extent possible.”
(Louisville Municipal Code, Title 16: Subdivisions: Chapter 16.16: Design Standards: section 010: item D (16.16.010.D))
By city ordinance, Brue Baukol must make every effort to protect the “natural features” of the land at Redtail Ridge. The natural features of a wild landscape include topographical elements constructed by wildlife at the site: nests, dens, and burrows. These constructions are not incidental to the landscape; they are as inherent to it as its hills and valleys, rocky outcroppings, streams, wetlands, thickets, and, as the ordinance notes, trees.
Preserving a property’s “natural features . . . to the extent possible” requires developers to think about them at the design stage. Buildings, roads, and parking lots must be situated in the landscape in such a way that creates minimal impact on the existing topography. Louisville’s Municipal Code language sets forth a rigorous standard requiring focused, demonstrable effort at preservation.
Brue Baukol’s 2020 survey of the prairie dog populations at the Redtail site estimates 142 acres of active prairie dog colonies. These colonies consist of visible burrow entrances connected by complex networks of tunnels. The map at right, prepared by Brue Baukol’s environmental consultants on January 6, 2021, shows the distribution of colonies at the site.
The map below, included in the GDP packet submitted to Louisville’s planning department in January 2021, shows the distribution of buildings, roads, and parking lots Brue Baukol plans for the site. It is clear from comparing the two maps that considerable development is proposed for what are currently active prairie dog colonies.
In the Prairie Dog Management Plan submitted to the planning department as part of its GDP application, Brue Baukol recognizes the overlap between its proposed development and the prairie dog colonies that are among the natural features of the site: “Construction activities associated with the proposed Redtail Ridge development are anticipated in several areas currently occupied by prairie dogs. It is estimated the project would impact 110.65 acres of active prairie dog colony” (page 5; emphasis added).
Because the buildings, roads, and parking lots proposed for Redtail Ridge are scattered all over the property, Brue Baukol’s environmental consultants concede that relocation of the prairie dogs elsewhere on the property is unfeasible. Their recommendation is that the developer try to either relocate the prairie dogs off-site or donate them to a raptor or black-footed ferret rehabilitation program. If these options are not feasible, they recommend extermination of the prairie dogs on the 110.65 acres of active colonies for which development is slated.
Prairie dog colonies are among the natural features at the Redtail Ridge site. According to Louisville Municipal Code 16.16.010D, Brue Baukol MUST make every effort to preserve those colonies. Relocating, donating, or killing the prairie dogs that build and maintain the colonies’ burrows is a destruction of these natural features.
The clear solution to preserving the prairie dog colonies at Redtail Ridge, and protecting the ecosystems that rely on the prairie dogs – from raptors to coyotes, foxes, and snakes – is to concentrate the buildings, roads, and parking lots in the section of the property where there are no colonies. This is the section right in the middle, where the StorageTek facility once stood.
Louisville’s Planning Commission and the City Council must enforce adherence to city laws and ordinances, including Municipal Code 16.16.010.
From Boulder county communication November 1, 2019[i]
"The applicant’s response to City comments includes this: “a Burrowing Owl survey will be conducted in accordance with Colorado Parks and Wildlife’s recommended protocol if development is planned in potential habitat during the owls’ migratory season” (emphasis added). Staff strongly recommends that an ongoing survey begin now, with the next breeding season. It is vital to establish baseline conditions, and to have several years of data before “development is planned in potential habitat.” Such work could be added to the forthcoming Prairie Dog Management Plan, because the species are closely connected.
Similarly, for raptors the developer’s responses state, “Biological assessments will be conducted as construction proceeds to determine whether any protected species are present” (emphasis added). This is necessary, of course, but raptor surveys should, again, begin now, and proceed in subsequent years to establish a baseline for the many species that might use the area. These include Swainson’s hawks, which are only here during the summer, and rough-legged hawks, which are only here during the winter. There are many other raptors – hawks, eagles, and owls -- that likely use the location now, for either breeding or hunting. Staff also notes that all species of raptors are “protected species.”
For jumping mouse and fringed orchid, the developer’s responses include, “…we will consult with Colorado Parks & Wildlife and the U.S. Forest Service….” The latter should be the US Fish and Wildlife Service, which administers the Endangered Species Act.
The final master drainage report should consider including defined setbacks (per Louisville’s determination) from all water features including lakes, creeks, wetlands, and ditches. "
Notes
[i] November 1, 2019. Included in the city council agenda and meeting packet for August 4, 2020 on page 66. https://www.louisvilleco.gov/home/showpublisheddocument?id=27894 page 1203 of 1282Prairie dog management plan does not include protection of habitat.
A commitment is needed for follow up burrowing owl surveys and raptor monitoring. Bird monitoring needs to address seasonality of species.
If endangered species consultations have occurred, communications have not been made public
These are the wildlife reports made available to the public on Brue Baukol’s Redtail Ridge website. All but the first were prepared by ERO Resources, an environmental consulting firm in Denver.
Biological and Cultural Assessment, prepared by CTL | Thompson, dated 2/19/2019
Environmental Evaluation Update, presented 5/13/2020
Raptor Survey Memo, dated 3/23/2020
Migratory Bird Treaty Act Memo, dated 1/19/2021
Burrowing Owl Survey Memo, dated 1/19/2021
Prairie Dog Management Plan, dated 1/19/2021
Last updated February 8, 2021