When I called Therese Glowacki, Boulder County's Manager of Resource Management, to express my concern about the wildlife at Rainbow, she told me that Boulder County's wildlife was not on 287 and that I shouldn't "go down that road." Wildlife experts disagreed.
"Restoration and conservation activity should be considered which promotes prairie and riparian habitats, or which increases connectivity with the adjacent ECA and riparian corridors. All efforts to limit or reverse habitat fragmentation should be pursued."
East County Conservation Area description
Boulder County Comprehensive Plan
“What we found is that mostly, it’s just birds out in that canopy out there.”
Andrew Barth, Boulder County Public Information Officer
Boulder County Comprehensive Plan
Environmental Conservation Area #13
"This ECA along with the White Rocks and Gunbarrel Hill ECA work together to protect critical resources in the east part of the County. Each contains a multitude of significant plants, plant communities, and wildlife. And together they total 15,000 acres, providing an important movement corridor along Boulder Creek and between Boulder and St. Vrain Creeks.
The East County ECA spans north to south between St. Vrain and Boulder Creek, and west to east between Highway 287 and the county line. Much of this area is irrigated farmland, which has been acquired by the County as Open Space or conservation easement. The farmland provides a level of seclusion necessary for several nesting raptors. Some of the ecological features of this ECA include Boulder Creek, Panama Reservoir, Lefthand Creek, and St. Vrain Creek. Great blue herons have a small rookery in this area. Restoration has occurred along some of the riparian corridors and continues to be a conservation priority. The area provides a movement corridor for white-tailed deer between Boulder and St. Vrain Creeks."
The County's Special Use Review Application - to itself for its own approval - contained a substantial ecology report by Birch Ecology. It was surprising that an ecology group would conclude that Rainbow's wildlife and habitat were worthless. The Wildlife Chair of the National Sierra Club's Colorado Chapter graciously offered to read over the report. She found the conclusions quite lacking.
Next, Steve Jones, a well-regarded wildlife expert who has spent many years advocating on behalf of Boulder County's wildlife, generously offered to visit our farm. It was apparent to him also that Rainbow was well worth saving.
Delia Malone, Wildlife Committee Chair of the Sierra Club’s Colorado Chapter, reviewed the Ecological Assessment and Wildlife Impact Report of the Special Use Review application. The issues she raises underscore that the Rainbow Nursery should be preserved and its conservation easement restored. If not, these issues must be addressed before approval can be considered.
4.4. Wildlife Habitat
* As required by the Migratory Bird Treaty Act, breeding bird surveys must be conducted.
* "Additionally, the lack of mowing of grasses/weeds below the nursery rows has resulted in thick cover capable of supporting common wildlife including the ubiquitous deer mouse” - and potentially Preble’s jumping mouse, a Federally listed species, for which surveys should be conducted.
4.4.1 Preble’s Jumping Mouse
* "Based on field reconnaissance conducted by Jerry Powell on August 25th, 2020, the proposed building site and adjacent area of Leggett Ditch do not provide suitable habitat for the Preble’s meadow jumping mouse (PMJM - Zapus hudsonius preblei).” This conclusion is not supported by the evidence provided.
* "Habitat for active and hibernating periods are not present within or near the project site and there is no connectivity with other locations where these are available.” Given the near proximity to other Preble's populations what should occur are live-trapping surveys for Preble's jumping mouse.
4.4.2 Birds of Conservative Concern
* "No other USFWS identified Migratory Birds of Conservation Concern (Table 5) have suitable habitat within the location of the proposed facility.” The Migratory Bird Treaty Act protects all neotropical migrant songbird species - regardless of their inclusion on the list of Birds of Conservation Concern. What should occur are breeding bird surveys - the presumption by the survey team is unsupported and antiquated. Given that in North America we have 3 billion fewer birds than we did in 1970, and given that many once-common birds are experiencing dramatic declines, all habitat is important as is every native songbird.
* "Similarly, the areas of Preble’s meadow jumping mouse habitat identified in the 2013 ERE Update (Figure 5) are at least a half mile from the site.” Although no listed wildlife or plant species may currently occupy the site, the site does provide potential habitat for numerous sensitive species and thus should be protected for future potential expansion of sensitive species.
8.0 Summary and Recommendations
* "Construction of the proposed compost facility would be compatible with the surrounding area in terms of the ecological resources addressed in this report.” This statement is not supported. The ecological resources addressed in this report are incomplete and thus are an inaccurate representation of the ecological resources of the area.
* "The project would not result in an over-intensive use of the land or excessive depletion of natural resources since it is already a highly disturbed site with few areas of native plant communities and no sensitive wildlife resources within the footprint of disturbance.” Impacts of the proposed development extend well beyond the footprint of the developed area. These impacts that extend beyond the footprint of the development (edge effects) must also be considered in the development proposal. These edge effect impacts, , likely extend from a minimum of hundreds of meters, up to 1/2 mile beyond the footprint of the development. These edge effect impacts must be evaluated to understand the actual and full extent of the proposed development.
* "Considering the opportunistic nesting and forage that the tree canopy provides for wildlife, a nest survey is recommended prior to tree removal if completed during nesting season.” . . . and must be conducted during nesting season.
Please read Steve Jones' outstanding and influential report here: