1787 south broadway, suite 200 denver, co 80210 re .... ecological report.pdf · main channel of...

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CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com July 15, 2016 Randy Roberts Craft Bandera Acquisition Company, LLC 1787 South Broadway, Suite 200 Denver, CO 80210 CORE Consultants Project Number 15-054 Re: Habitat Assessment – Independence Community Craft Bandera Acquisition Company, LLC Elbert County, Colorado Dear Mr. Roberts: CORE Consultants, Inc. (CORE) presents this project memo summarizing a habitat assessment of the proposed Independence Community (Project) in Elbert County, Colorado. The Project encompasses approximately 1,011 acres located at the northeast corner of the intersection of Hilltop Road (CO 158) and Delbert Road (Attachment I: Independence Community Site Location Map). Low-density residential development borders the Project to the north. Agricultural and undeveloped lands border the site to the west, south, and east. Proposed preliminary Project components include single family residential units, community trail systems, access roads, utilities, a school site, stormwater management facilities, and wastewater management facilities. CORE completed a desktop review and site reconnaissance of the Project for the following natural resources and potential biological constraints: Significant topographic features; Potentially jurisdictional water features and floodplains; Potential for occurrence of federally listed threatened and endangered species (TES) and associated habitats; Federally designated critical habitat; Potential for occurrence of state threatened (ST), endangered (SE), and special concern (SC), and associated habitats. Publicly available data sources reviewed via desktop included the United States Fish and Wildlife Service (USFWS) Information Planning and Conservation (IPAC) System, USFWS Critical Habitat Portal, Colorado Parks and Wildlife (CPW) species profiles and spatial data, USFWS National Wetland Inventory (NWI), United States Geological Survey (USGS) National Hydrography Dataset (NHD), Federal Emergency Management Agency (FEMA) Flood Insurance Rate Maps (FIRM), and USGS aerial imagery. A site reconnaissance was conducted on June 29, 2016 to ground truth results of the desktop review.

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Page 1: 1787 South Broadway, Suite 200 Denver, CO 80210 Re .... Ecological Report.pdf · main channel of Henderson Gulch is located within the southeast of the Project (Attachment II: portion

CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com

July 15, 2016 Randy Roberts Craft Bandera Acquisition Company, LLC 1787 South Broadway, Suite 200 Denver, CO 80210 CORE Consultants Project Number 15-054 Re: Habitat Assessment – Independence Community Craft Bandera Acquisition Company, LLC Elbert County, Colorado Dear Mr. Roberts: CORE Consultants, Inc. (CORE) presents this project memo summarizing a habitat assessment of the proposed Independence Community (Project) in Elbert County, Colorado. The Project encompasses approximately 1,011 acres located at the northeast corner of the intersection of Hilltop Road (CO 158) and Delbert Road (Attachment I: Independence Community Site Location Map). Low-density residential development borders the Project to the north. Agricultural and undeveloped lands border the site to the west, south, and east. Proposed preliminary Project components include single family residential units, community trail systems, access roads, utilities, a school site, stormwater management facilities, and wastewater management facilities.

CORE completed a desktop review and site reconnaissance of the Project for the following natural resources and potential biological constraints:

• Significant topographic features; • Potentially jurisdictional water features and floodplains; • Potential for occurrence of federally listed threatened and endangered species (TES) and associated

habitats; • Federally designated critical habitat; • Potential for occurrence of state threatened (ST), endangered (SE), and special concern (SC), and

associated habitats.

Publicly available data sources reviewed via desktop included the United States Fish and Wildlife Service (USFWS) Information Planning and Conservation (IPAC) System, USFWS Critical Habitat Portal, Colorado Parks and Wildlife (CPW) species profiles and spatial data, USFWS National Wetland Inventory (NWI), United States Geological Survey (USGS) National Hydrography Dataset (NHD), Federal Emergency Management Agency (FEMA) Flood Insurance Rate Maps (FIRM), and USGS aerial imagery. A site reconnaissance was conducted on June 29, 2016 to ground truth results of the desktop review.

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Habitat Assessment for the Independence Community Elbert County, CO July 15, 2016

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CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com

ENVIRONMENTAL SETTING

The Project area lies within the Middle South Platte Cherry Creek watershed, referenced as 8-digit Hydrologic Unit Code (HUC) 10190003. Topography of the Project consists of gently rolling hills and swales within the pine oak woodlands and foothill grasslands level IV ecoregions of the Southwestern Tablelands level III ecoregion (Chapman et al. 2006). Elevations of the Project range between 6,450 and 6,650 feet above mean sea level (AMSL) and generally slope downward from the west to the east. Land use in the region is typified by woodland and rangeland; residential development is increasing throughout the surrounding vicinity of the Project. Typical herbaceous species of the region include buffalograss (Bouteloa dactyloides), mountain muhly (Muhlenbergia montana), green needlegrass (Nassella viridula), western wheatgrass (Pascopyrum smithii), needle-and-thread (Hesperostipa comata), blue grama (Bouteloua gracilis), and blue bunch wheatgrass (Pseudoroegneria spicata) (USGS 2011). Typical woodland vegetation would include ponderosa pine (Pinus ponderosa), Gambel oak (Quercus gambelii), mountain mahogany (Cercocarpus montana), western serviceberry (Amelanchier alnifolia), and chokecherry (Prunus virginiana). Wetlands and Waters of the U.S. The USFWS NWI and USGS NHD datasets were reviewed for the presence of potentially jurisdictional wetlands and Waters of the U.S. (WOUS) within the Project. Aerial imagery was reviewed to locate water features not included within the NWI and NHD datasets. Spatial data indicated that multiple unnamed tributaries to the main channels of Cool Creek and Henderson Gulch lie within the Project. Two unnamed tributaries to Cool Creek drain the northern portion of the Project in a northern direction. An additional unnamed tributary to Cool Creek is located along the western boundary of the Project and flows north, converging with the main channel approximately 400 feet from the Project boundary. Two unnamed tributaries to Henderson Gulch drain the eastern portion of the Project in an eastern direction. Roughly 200 feet of the main channel of Henderson Gulch is located within the southeast portion of the Project (Attachment II: Independence Community Habitat Assessment Map). NWI wetlands are scattered throughout the property. Imagery interpretation indicated that three NWI wetlands are manmade stock ponds. The remaining four NWI wetlands do not appear to exhibit significant saturation or surface water; however, field reconnaissance and a formal wetland delineation would confirm desktop findings. FEMA Zone-A Floodplains The Project is located within the boundaries of FEMA FIRM panel 08039C0250C, Elbert County. The Project includes approximately 1.00 acre of FEMA Zone-A floodplain in the southeastern portion of the Project; this floodplain is associated with Henderson Gulch (Attachment II). Federal TES The USFWS IPAC database (USFWS 2016) was used to determine the potential for occurrence of federally listed TES within the Project. The IPAC query listed one mammal with the potential for occurrence within the Project (Table 1).

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Habitat Assessment for the Independence Community Elbert County, CO July 15, 2016

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CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com

Table 1. TES WITH THE POTENTIAL FOR OCCURRENCE WITHIN THE PROJECT AREA (USWFS 2016)

FE=Federally Endangered; FT=Federally Threatened

Preble’s Meadow Jumping Mouse Preble’s meadow jumping mouse (Zapus hudsonius preblei; PMJM) is listed as a federal TES and is threatened ST species in Colorado. PMJM occur along the Front Range throughout several counties in Wyoming and Colorado. Preferred habitat includes well developed riparian corridors with gentle slopes and adjacent grasslands that allow for movement in and out of the stream channel. Their population has declined due to habitat fragmentation and degradation resulting from urban development in riparian areas (USFWS 2004). Potential for PMJM to occur within the Project is unlikely. Aerial imagery and spatial data indicate that no perennial water courses exist within the Project. Further, the Project is not located within a CPW designated Riparian Conservation Zone (RCZ) for the species (CPW 2011). State Sensitive Species CPW spatial data, species profiles (CPW 2016), and aerial imagery were reviewed to determine potential for occurrence of any ST, SE, or SC (Table 2.). Black-tailed prairie dog (Cynonyms ludovicianus) colonies are evident from review of aerial imagery and indicate the potential for the burrowing owl (Athene cunicularia), a ST species, and ferruginous hawk (Buteo regalis). Aerial imagery indicates that some water features may

COMMON NAME SCIENTIFIC NAME STATUS LIKELIHOOD OF OCCURENCE

Complete Effects Analysis

Preble’s meadow jumping mouse

Zapus hudsonius preblei

FT Unlikely to occur; see discussion below.

Conditional Effects Analysis

Least tern

Sternula antillarum

(interior population)

FE Project is located outside of species’ range; Project would not affect water within the U.S. Platte river shed; therefore, impacts to this species would not occur.

Pallid sturgeon Scaphirynchus albus (entire population)

FE Project is located outside of species’ range; Project would not affect water within the U.S. Platte river shed; therefore, impacts to this species would not occur.

Piping plover Charadrius melodus

(except Great

Lakes watershed)

FT Project is located outside of species’ range; Project would not affect water within the U.S. Platte river shed; therefore, impacts to this species would not occur.

Western prairie fringed orchid

Platanthera praeclara FT Project is located outside of species’ range; Project would not affect water within the U.S. Platte river shed; therefore, impacts to this species would not occur.

Whooping crane Grus americana FE Project is located outside of species’ range; Project would not affect water within the U.S. Platte river shed; therefore, impacts to this species would not occur.

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CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com

congregate northern leopard frog (Rana pipiens), a SC species (NWI 2015; USGS 2015). Specifically, stock ponds and the unnamed tributary to Henderson Gulch may provide suitable habitat for northern leopard frog in the form of small ponds or riparian habitat.

Table 2. SE, ST, SC WITH THE POTENTIAL FOR OCCURRENCE WITHIN THE PROJECT AREA (CPW 2016)

COMMON NAME SCIENTIFIC NAME STATUS LIKELIHOOD OF OCCURENCE Black-tailed prairie dog Cynonyms ludovicianus SC Likely

Burrowing owl Athene Cunicularia ST Likely

Ferruginous hawk Buteo regalis SC Likely

Northern leopard frog Rana pipiens SC Likely

SC=State Species of Special Concern, ST=State Threatened

Black-tailed prairie dog The black-tailed prairie dog is a highly social burrowing rodent distributed across the eastern portion of Colorado. The animal is listed as a SC in Colorado. Unlike most rodents in the family Cynonyms, prairie dogs do not hibernate during winter. The species may remain underground when temperatures drop, but otherwise remain active. While still ubiquitous in parts of Colorado, the population has suffered decline from habitat fragmentation, sylvatic plague, conversion of rangeland to agriculture, and inadequate regulatory mechanisms (CPW 2015). Complex burrow systems in healthy prairie dog colonies provide high quality breeding and nesting habitat for burrowing owls since multiple burrows are often used during breeding (Poulin et al. 2011). A review of aerial imagery indicated the potential presence of active prairie dog colonies. A site reconnaissance would confirm the presence or absence of active prairie dog colonies. Burrowing Owl The burrowing owl is a small ground-dwelling bird distributed across the western U.S., Mexico, Florida, the Caribbean, and parts of Canada. The bird receives statutory protection under the Migratory Bird Treaty Act (MBTA) and is listed as ST. The species is migratory in Colorado, typically arriving on breeding grounds in late March to early April. Juveniles typically fledge by late August, but may remain on breeding grounds until winter migration. Burrowing owls in Colorado begin their winter migration in early autumn; the owl is not expected to be present in Colorado between November 1 and March 14 (CPW 2007). Winter grounds are distributed across southern states including Arkansas, Oklahoma, Texas, and Mexico (Haug et al. 2011). The owl most often utilizes unoccupied black-tailed prairie dog burrows in Colorado (CPW 2007). Active burrowing owl nests are recognizable by feathers and pellets scattered around the entrance.

A site reconnaissance and species specific surveys would confirm the presence or absence of nesting burrowing owls within the Project during the owl nesting season. Ferruginous Hawk The ferruginous hawk is a SC in Colorado. The hawk occurs throughout the western United States and is a year-round resident in Colorado. It is typically associated with open plains, prairies, and grasslands. Breeding occurs in large, well-developed riparian woodland trees or well-developed desert mounds (Bechard and

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CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com

Schmutz 1995). Nest substrates vary widely and may include cliffs, trees, and utility structures. Foraging habitat is present within the Project, and is likely associated with the potentially active prairie dog colonies. Small clusters of ponderosa pines within the southern portion of the Project and distribution lines along Hilltop Road may provide suitable nesting substrates. A site reconnaissance and nesting raptor survey would confirm the presence or absence of active nests on or adjacent to the Project. Northern Leopard Frog The Northern leopard frog is a medium-sized SC amphibian with an extensive range throughout the mountains and lowlands of Colorado. Although locally common, the frog is nearly extirpated in much of the Republican drainage and southeastern Colorado. Suitable habitat consists of emergent wetlands, banks of low velocity streams, ponds, lakes, and marshes. Northern leopard frogs will breed in shallow perennial bodies of water or shallow wetlands adjacent to perennial streams and lakes. Females deposit egg masses in shallows where vegetation is used as a substrate and protection (CPW 2014). Vegetated stock ponds and the unnamed tributary to Henderson Gulch may provide suitable habitat for the northern leopard frog. A site reconnaissance would confirm the presence or absence of potentially suitable habitat. SITE RECONNAISSANCE

A site reconnaissance of the Project was conducted on June 29, 2016. Dominant vegetation consists of noxious and non-noxious weedy species, likely an effect of prior ground disturbance due to homestead and agricultural development. Noxious weed species observed included Canada thistle (Cirsium arvense), bull thistle (Cirsium vulgare), musk thistle (Carduus nutans), diffuse knapweed (Centaurea diffusa), common mullein (Verbascum Thapsus), and downy brome (Bromus tectorum). Native plant species included yellow sweet clover (Melilotus officinalis), curly dock (Rumex crispus), Jim Hill mustard (Sisymbrium altissimum), fringed sage (Artemesia frigida), yellowspine thistle (Cirsium ochrocentrum), soapweed yucca (Yucca glauca), orchard grass (Dactylis glomerata), locoweed (Oxytropis lambertii), and fescues (Festuca spp). Tree species included narrowleaf cottonwood (Populus angustifolia), New Mexican locust (Robinia neomexicana), and ponderosa pine. Attachment III: Independence Community Site Photo Log presents typical vegetation throughout the Project. Suitable raptor nesting substrates are present in the form of mature ponderosa pines, which are distributed across the southern portion of the Project, and mature cottonwoods, which are present along the southernmost unnamed tributary to Henderson Gulch. A pair of adult Swainson’s hawks (Buteo swainsonii) was observed in a mature pine tree north of the homestead area (Attachment II). No nests were identified at the time of the site reconnaissance, however a raptor-specific survey during the breeding season (March through June) would confirm the presence or absence of active raptor nests within or adjacent to the Project. A single active prairie dog colony (±94 acres) is located in the south-central portion of the Project. Activity is greatest within the western portion of the colony, where prairie dogs were observed above-ground (Attachment II). Much of the eastern portion of the colony is currently inactive; signs of recent activity were not observed and no prairie dogs were observed at the time of the site reconnaissance. Black-tailed prairie dog does not receive statutory protection. However, humane treatment of active colonies prior to

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construction is an accepted practice and what is preferred by CPW. Since the site reconnaissance confirmed the presence of a prairie dog colony (historic and active), the potential for the presence of nesting burrowing owls and foraging ferruginous hawks does exist. No burrowing owls were observed during the site reconnaissance; however, absence of burrowing owls would need to be confirmed by following the recommended CPW burrowing owl survey protocols (CPW 2007). The site assessment determined a high potential for the presence of potentially-jurisdictional wetlands and WOUS within the Project. The site reconnaissance confirmed the presence of an unnamed tributary to Cool Creek along the western border of the Project. A defined bed and bank and wetland vegetation within the channel were observed. The northern two unnamed tributaries to Cool Creek did not exhibit a defined bed and bank, and are unlikely to be determined jurisdictional. Wetland vegetation was observed within multiple NWI wetlands within the Project; however, wetlands were determined to be isolated and are therefore unlikely to exhibit characteristics of jurisdictional wetlands. Wetland vegetation, surface water, and a defined bed and bank were observed along the unnamed tributary to Henderson Gulch. A formal wetland delineation would determine the exact size and extents of jurisdictional wetlands or WOUS within the Project. Any impacts to jurisdictional WOUS or wetlands would trigger permitting through the U.S. Army Corps of Engineers (USACE) under Section 404 of the Clean Water Act (CWA). Impacts to jurisdictional waters or wetlands not exceeding 300 linear feet or 0.5 acre would require the submittal of an application for a Nationwide Permit (NWP) to the USACE. Impacts to jurisdictional waters exceeding 300 linear feet or 0.5 acre would trigger the submittal of an application for an Individual Permit (IP) to the USACE. Issuance of an IP requires a 30-day public comment period and additional Water Quality Certification (WQC) process through the Colorado Department of Public Health (CDPHE). Impacts to jurisdictional wetlands exceeding 0.10 acre would likely require mitigation. A formal wetland delineation would determine and quantify Project impacts to jurisdictional waters, if any. Elbert County discourages development within significant riparian zones along stream corridors within the County. A healthy riparian corridor is defined by surface water seasonally or perennially and dense shrubby vegetation presence that creates sufficient wildlife cover (Lorne Fitch et al. 2003). Coordination with the County indicated that Elbert County does not map significant riparian zones. The site reconnaissance did identify the presence of potentially significant riparian habitat along the eastern portion of the unnamed tributary and its confluence with Henderson Gulch, which could provide potentially suitable habitat for the northern leopard frog. Dense riparian vegetation observed included willows, sedges (Carex ssp.), and rushes (Juncus ssp.). Riparian corridors do not receive statutory protection.

CONCLUSIONS AND RECOMMENDATIONS

The site reconnaissance indicated some biological constraints may be present within the Project. Black-tailed prairie dogs were observed within a contained colony at the south-central portion of the Project. Black-tailed prairie dogs are a state SC and are associated with burrowing owls (ST) and foraging ferruginous hawk (SC). A pair of adult Swainson’s hawk were observed north of the homestead area; however, no active nest was located during the site reconnaissance. Nesting burrowing owls and raptors are protected under the Migratory Bird Treaty Act (MBTA). Noxious weed populations were detected during the survey and would require management (Attachment IV: Independence Community Noxious Weed Management Memo); coordination with Elbert County on noxious weed management protocols is advised. Jurisdictional waters and wetlands are likely present within the unnamed tributary to Henderson Gulch and the unnamed tributary to Cool Creek on the western boundary of the Project. Impacts to jurisdictional waters would trigger permitting under Section

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404 of the CWA. CORE recommends the following:

• Black-tailed prairie dog treatment should occur no less than two weeks prior to construction to allow for a follow-up survey following treatment. Treatment options would include toxic bait (zinc-phosphide treated oats) or fumigants (aluminum phosphide tablets). Treatment selection would depend on the time of year, size of colony, and cost restrictions.

• Should construction occur within the burrowing owl nesting season (March 15 through October 31),

CORE recommends that surveys be completed in accordance with CPW Recommended Survey Protocol and Actions to Protect Nesting Burrowing Owls (CPW 2007) prior to any ground disturbing activities.

• Should active burrowing owl nests be identified within the property during project construction, 150-

foot buffers should be established around the active nest (burrow), per CPW burrowing owl survey protocols, until a qualified biologist has determined that the nest has failed or that juveniles have fledged.

• Raptor nest surveys should be conducted prior to the start of construction. If construction is to occur

during the raptor nesting season (February 1 through July 15), CORE recommends that surveys be conducted prior to construction activities and buffers be established around active raptor nests, in accordance with CPW Recommended Buffer Zones and Seasonal Restrictions for Colorado Raptors (CPW 2008). CORE recommends that Craft Bandera Acquisition Company, LLC remove any raptor nests within the Project prior to the nesting season to remove any potential conflict in Project construction with the spacing and timing restrictions identified in CPW (2008).

• A formal wetland delineation should be conducted in accordance with the USACE 1987 Wetland

Delineation Manual if impacts to potentially jurisdictional waters are necessary. Should results of the delineation determine the presence of potentially jurisdictional wetlands or waters within the Project, CORE will provide the wetland boundaries to the project civil engineering/design team so that project design can avoid impacts to regulated features. If impacts to jurisdictional waters are unavoidable, permitting under Section 404 of the CWA would be required.

• Floodplain boundaries will be provided to the project civil engineering/design team so that Project

design can avoid impacts to these regulated features. If impacts to floodplains are unavoidable, the Project should commence with the necessary floodplain permitting requirements through Elbert County.

• The County does not regulate management of noxious weeds. However, the County does recommend

treatment of noxious weeds prior to ground disturbing activities. CORE recommends the treatment of any noxious weeds identified within the construction easement (Attachment IV).

• Coordinate with Elbert County to solicit recommendations regarding the potential designation of the

unnamed tributary and its confluence with Henderson Gulch as significant riparian habitat.

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CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com

If you have any questions, concerns or require additional information, please feel free to contact me at 303.703.4444 or by email at [email protected]. Sincerely, CORE Consultants, Inc.

Chris Haas Tina Brazil Vice President Environmental Consultant

ATTACHMENTS I. INDEPENDENCE COMMUNITY SITE LOCATION MAP II. INDEPENDENCE COMMUNITY HABITAT ASSESMENT MAP III. INDEPENDENCE COMMUNITY SITE PHOTO LOG IV. INDEPENDENCE COMMUNITY NOXIOUS WEED MANAGEMENT MEMO

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REFERENCES

Bechard, Marc J. and Josef K. Schmutz. (1995). Ferruginous Hawk (Buteo regalis), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/172

doi:10.2173/bna.172 Chapman, S. S., Griffith, G. E., Omernik, J. M., Price, A. B., Freeouf, J., and Schrupp, D. L. (2006).

Ecoregions of Colorado (color poster with map, descriptive text, summary tables, and photographs): Reston, Virginia, U.S. Geological Survey (map scale 1: 1,950,000).

Colorado Parks and Wildlife (CPW). (2007). CPW Recommended Survey Protocol and Actions

to Protect Nesting Burrowing Owls. Accessed online: https://cpw.state.co.us/Documents/WildlifeSpecies/LivingWithWildlife/RecommendedSurveyOwls.pdf

_____ (2008). Recommended Buffer Zones and Seasonal Restrictions for Colorado Raptors.

Accessed online: https://cpw.state.co.us/Documents/WildlifeSpecies/LivingWithWildlife/RaptorBufferGuidelines2008.pdf

_____ (2016). Colorado Parks & Wildlife - Species Profiles. Species Profiles. [Online.] Available at http://cpw.state.co.us/learn/Pages/SpeciesProfiles.aspx. Haug, E. A., B. A. Millsap, and M. S. Martell (2011). Burrowing Owl (Athene cunicularia). The

Birds of North America Online. doi: 10.2173/bna.61 Lorne Fitch, Barry Adams, and Kerri O’Shaughnessy (2003). Caring for the Green Zone-Riparian

Areas and Grazing Management. Third Edition. United States Fish and Wildlife Service (USFWS). (2004). Preble’s Meadow Jumping Mouse

(Zapus hudsonius preblei) Survey Guidelines. Available Online. http://www.fws.gov/mountain-prairie/species/mammals/ preble/CONSULTANTS/pmjm2004guidelines.pdf. Accessed August 2014.

_____(2016). Information, Planning, and Conservation System. Available online:

https://ecos.fws.gov/ipac/ Accessed June 28, 2016. US Geological Survey, Gap Analysis Program (GAP). (August 2011). National Land Cover, Version

2.

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ATTACHMENT I INDEPENDENCE COMMUNITY SITE LOCATION MAP

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Date: 12/19/2016CORE Project #: 16-007

Independence CommunitySite Location Map

Elbert County, Colorado

0 2,000 4,000Feet

q

Project Boundary (±1,011 ac)

Vicinity Map

Project Area

Reference:USGS 7.5 Minute Topographic Quadrangle

Ponderosa Park, CO Quad

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ATTACHMENT II INDEPENDENCE COMMUNITY HABITAT ASSESSMENT MAP

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[b2 ADULT SWHA

Cool

Cree

k

Coyote TrlHilltop Rd Co Rd 158

Delbe

rt Rd

Co R

d 5Lafayette Trl

Date: 12/19/2016CORE Project #: 16-XXX

Independence CommunityHabitat Assessment Map

Elbert County, Colorado

0 1,000 2,000Feet

q

BoundaryNHD WatercourseNHD WaterbodyNWI Wetland100-year Floodplain

[b SWHA ObservationPrairie Dog Colony

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ATTACHMENT III INDEPENDENCE COMMUNITY SITE PHOTO LOG

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Independence Community Habitat Assessment Report Elbert County, CO July 15, 2016 Page 1 of 3

Attachment III – PHOTOGRAPHIC LOG

Elbert County, Colorado

Central portion of site facing north

East boundary of the site facing west

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Independence Community Habitat Assessment Report Elbert County, CO July 15, 2016 Page 2 of 3

Northwest corner facing southeast

East boundary of the site facing southwest

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Independence Community Habitat Assessment Report Elbert County, CO July 15, 2016 Page 3 of 3

Stock pond east side of Project, facing southeast

Unnamed tributary to Henderson Gulch facing northwest (upstream)

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CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com

ATTACHMENT IV INDEPENDENCE COMMUNITY NOXIOUS WEED MANAGEMENT MEMO

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CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com

March 21, 2017 Randy Roberts Craft Bandera Acquisition Company, LLC 1787 South Broadway, Suite 200 Denver, CO 80210 CORE Consultants Project Number 15-054 Re: Noxious Weed Management Memo

Independence Community Elbert County, Colorado Dear Mr. Roberts CORE Consultants, Inc. (CORE) presents this memo summarizing a noxious weed management plan for the Independence Community Residential Project (Project) in Elbert County, Colorado. The Project encompasses approximately 1,011 acres located at the northeast corner of the intersection of Hilltop Road (CO 158) and Delbert Road (Attachment I: Independence Community Site Location Map). Low-density residential development borders the Project to the north. Agricultural and undeveloped lands border the site to the west, south, and east. Proposed preliminary Project components include single family residential units, community trail systems, access roads, utilities, a school site, stormwater management facilities, and wastewater management facilities.

NOXIOUS WEED MANAGEMENT

The spread of invasive species roughly mirrors the rise in human travel and commerce (Mack et al., 2000; Sheley et al., 1996). Many noxious weeds have been identified as aggressive, weather resistant escaped ornamentals from residential landscapes (Westbrooks, 1998). The Federal Noxious Weed Act (7 U.S.C. 2801 et seq.; 88 Stat. 2148) was enacted in 1975 in an effort to stanch the spread of noxious weeds across the country. Following guidelines set forth by the Federal Noxious Weed Act, Colorado passed the Colorado Noxious Weed Act (Act) (C.R.S. 35-5.5-103) in 1990. The Act identified noxious weeds specific to the landscape of Colorado. The Act defines noxious weeds as any non-native plant that:

• Aggressively invades or is detrimental to economic crops or native plant communities; • Is poisonous to livestock; • Is a carrier of detrimental insects, diseases, or parasites; • Is detrimental, either by direct or indirect effects, to the environmentally sound management of natural

or agricultural ecosystems. The Act identifies three levels of priority for control of noxious weeds throughout the state of Colorado (State). The Colorado Weed Management Association (CWMA) maintains an updated list of noxious weeds known to occur in the State. CWMA also maintains a “watch list” of noxious weeds that occur in proximity to State borders and/or those species with a distribution that is not yet understood (Appendix II: Colorado State Noxious Weed List [CWMA, 2015]). List A noxious weeds are those species targeted for eradication.

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CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com

And are typically isolated in nature or extremely rare throughout much of the State (Colorado Revised Statutes 35-5.5-103). Eradication and reporting of List A populations is required by law (Colorado Department of Agriculture [CDA], 2006). List B species are discretely distributed throughout the State and must be eradicated, contained, or suppressed (Colorado Revised Statutes 35-5.5-103). List C noxious weed populations are widespread and well established. The Act was amended in 2002 to require counties to establish individual management plans relevant to local municipalities. Elbert County does not regulate the treatment of noxious weeds on private properties. However, the County does request that noxious weeds are treated prior to construction and that Project protocols are in place to control the spread of noxious weeds. CORE recommends treatment of all List A, B, and C noxious weed species identified in the Project construction easement prior to commencement of grading activities.

PROJECT PROTOCOLS

Project protocols would include surveys and treatment prior to construction to prevent the spread of noxious weeds during construction activities that would include ground disturbance. Surveys Noxious weed surveys would be conducted within all construction easements prior to construction; i.e., prior to any ground disturbing activities. Surveyors would use GPS units to collect data pertaining to identified noxious weed populations. Data collected will include coordinates for the approximate center of each identified population, approximate radius of infestation, and approximate density (measured in percent coverage within the estimated extent of a population). Noxious weed populations will be mapped; the locations of noxious weed populations would be communicated to a licensed herbicide applicator. Should surveyors identify List A species, a plant sample would be collected for positive identification and reported to the County. Treatment Treatment type would be selected depending on the priority rank of the noxious weed species (List A, B, C), the location and density of the infestation, and through coordination with the licensed herbicide applicator. Should surveyors identify List A species, hand pulling and/or chemical treatment would be utilized to ensure eradication of the Project population. All herbicide application will occur a minimum of two weeks prior to scheduled ground disturbing activities. If you have any questions, concerns or require additional information, please feel free to contact me at 303.703.4444 or by email at [email protected]. Sincerely, CORE Consultants, Inc.

Tina Brazil Environmental Consultant

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CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com

ATTACHMENTS ATTACHMENT I. SITE LOCATION MAP ATTACHMENT II. COLORADO STATE NOXIOUS WEED LIST

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CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com

REFERENCES

Colorado Department of Agriculture. (2006). 8 CCR 1206-2 – Rules Pertaining to the Administration and Enforcement of the Colorado Noxious Weed Act.

Colorado Weed Management Association. (CWMA). 2015. Colorado State Noxious Weed List Mack, R. N., Simberloff, D., Mark Lonsdale, W., Evans, H., Clout, M., & Bazzaz, F. A. (2000). Biotic invasions:

causes, epidemiology, global consequences, and control. Ecological applications, 10(3), 689-710. Sheley, R., Manoukian, M., & Marks, G. (1996). Preventing Noxious Weed Invasion. Rangelands,18, 100-101. State of Colorado. (2003). Colorado Revised Statutes, Title 35 Agriculture, Article 5.5 Colorado Noxious

Weed Act. Westbrooks, R. G. (1998). Invasive plants: changing the landscape of America. US Government Documents

(Utah Regional Depository), 490.

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CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com

ATTACHMENT I

SITE LOCATION MAP

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Date: 12/19/2016CORE Project #: 16-007

Independence CommunitySite Location Map

Elbert County, Colorado

0 2,000 4,000Feet

q

Project Boundary (±1,011 ac)

Vicinity Map

Project Area

Reference:USGS 7.5 Minute Topographic Quadrangle

Ponderosa Park, CO Quad

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CORE Consultants, Inc. | 1950 W. Littleton Boulevard, Suite 109 | Littleton, CO 80120 | 303.703.4444 | www.CoreCivil.com

ATTACHMENT II

COLORADO STATE NOXIOUS WEED LIST

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CORE Consultants Inc.

1950 W Littleton Blvd Suite 109 | Littleton CO 80120

303.703.4444

COMMON NAME SCIENTIFIC NAME LIST

African rue Peganum harmala A

camelthorn Alhagi pseudalhagi A

Cypress spurge Euphorbia cyparissias A

Dyer's woad Isatis tinctoria A

elongated mustard Brassica elongata A

flowering rush Butomus umbellatus A

giant reed Arubdo donax A

giant salvinia Salvinia molesta A

hairy willow-herb Epilobium hirsutum A

hydrilla Hydrilla verticillata A

Japanese, giant and bohemian knotweed

Polygonum cuspidatum, P. sachalinense and P. bohemicum

A

meadow knapweed Centaurea pratensis A

Mediterranean sage Salvia aethiopis A

medusahead Taeniatherum caput-medusae A

myrtle spurge Euphorbia myrsinites A

orange hawkweed Hieracium aurantiacum A

parrot feather Myriophyllum aquaticum A

purple loosestrife Lythrum salicaria A

rush skeletonweed Chondrilla juncea A

squarrose knapweed Centaurea virgata A

tansy ragwort Senecio jacobaea A

yellow starthistle Centaurea solstitialis A

absinth wormwood Artemesia absinthium B

black henbane Hyoscyamus niger B

bouncingbet Saponaria officinalis B

bull thistle Cirsium vulgare B

Canada thistle Cirsium arvense B

Chinese clematis Clematis orientalis B

common tansy Tanacetum vulgare B

common teasel Dipsacus fullonum B

corn chamomile Anthemis arvensis B

cutleaf teasel Dipsacus laciniatus B

dalmatian toadflax (broad leaved) Linaria dalmatica B

dalmatian toadflax (narrow leaved) Linaria genistifolia B

dame's rocket Hesperis matronalis B

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CORE Consultants Inc.

1950 W Littleton Blvd Suite 109 | Littleton CO 80120

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diffuse knapweed Centaurea diffusa B

Eurasian watermilfoil Myriophyllum spicatum B

hoary cress Cardaria draba B

houndstongue Cynoglossum officinale B

jointed goatgrass Aegilops cylindrica B

leafy spurge Euphorbia esula B

mayweed chamomile Anthemis cotula B

moth mullein Verbascum blattaria B

musk thistle Carduus nutans B

oxeye daisy Leucanthemum vulgare B

perennial pepperweed Lepidium latifolium B

plumeless thistle Carduus acanthoides B

Russian knapweed Acroptilon repens B

Russian-olive Eleagnus angustifolia B

salt cedar Tamarix chinensis, T. parviflora, and T. ramosissima

B

scentless chamomile Tripleurospermum perforatum B

scotch thistle Onopordum acanthium and O. tauricum B

sulfur cinquefoil Potentilla recta B

wild caraway Carum carvi B

yellow nutsedge Cyperus esculentus B

yellow toadflax Linaria vulgaris B

bulbous bluegrass Poa bulbosa C

chicory Cichorium intybus C

common burdock Arctium minus C

common mullein Verbascum thapsus C

common St. Johnswort Hypericum perforatum C

downy brome Bromus tectorum C

field bindweed Convolvulus arvensis C

halogeton Halogeton glomeratus C

johnsongrass Sorghum halepense C

perennial sowthistle Sonchus arvensis C

poison hemlock Conium maculatum C

puncturevine Tribulus terrestris C

quackgrass Elymus repens C

redstem filaree Erodium cicutarium C

velvetleaf Abutilon theophrasti C

wild proso millet Panicum miliaceum C

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CORE Consultants Inc.

1950 W Littleton Blvd Suite 109 | Littleton CO 80120

303.703.4444

Asian mustard Brassica tournefortii WATCH

baby's breath Gypsophila paniculata WATCH

bathurst burr Xanthium spinosum WATCH

Brazilian egeria Egeria densa WATCH

common bugloss Anchusa officinalis WATCH

common reed Phragmites australis WATCH

garden loosestrife Lysimachia vulgaris WATCH

garlic mustard Alliaria petiolata WATCH

Himalayan blackberry Rubus armeniacus WATCH

Japanese blood grass Imperata cylindrica WATCH

meadow hawkweed Hieracium caespitosum WATCH

onionweed Asphodelus fistulosus WATCH

purple pampas grass Cortaderia jubata WATCH

scotch broom Cytisus scoparius WATCH

sericea lespedeza Lespedeza cuneata WATCH

Swainson pea Sphaerophysa salsula WATCH

Syrian beancaper Zygophyllum fabago WATCH

water hyacinth Eichhornia crassipes WATCH

water lettuce Pistia stratiotes WATCH

white bryony Bryonia alba WATCH

woolly distaff thistle Carthamus lanatus WATCH

yellow flag iris Iris pseudacorus WATCH

yellow floatingheart Nymphoides peltata WATCH

yellowtuft Alyssum, A. corsicum WATCH