Proposed Larimer County Radio Communications Facility

Summary of Scoping Comments and Issues

December 2006 thru January 2007

Prepared by Mangi Environmental Group, Inc. February 2, 2007

Larimer County Larimer Communications Facility U.S. Forest Service Scoping Report

TABLE OF CONTENTS

1.0 INTRODUCTION...... 1 2.0 THE SCOPING PROCESS ...... 2 2.1 Direct Mail...... 2 2.2 Email ...... 2 2.3 News Media Press Releases...... 2 2.4 Distribution of Posters in the Nearby Communities...... 3 2.5 Incoming Comments...... 3 2.6 Additional Contacts ...... 3 2.7 Site Prospectus ...... 3 3.0 SCOPING COMMENTS ...... 5 3.1 Comment Letters Received ...... 5 3.2 Summary of Comments...... 6 3.3 Issues that May Be Considered “Significant” ...... 10 4.0 ADDITIONAL SCOPING RESULTS ...... 11 4.1 Media Coverage Received ...... 11 4.2 Site Prospectus – Interested Electronic Communication Providers ...... 11

APPENDIX I A. Scoping Letter B. Scoping Letter Contact List C. Press Release D. Press Release Contact List E. Revised Press Release F. Poster G. Additional Contacts H. Comment Codes Per Comment Letter I. Comment Letters Per Comment J. Media Coverage Received

APPENDIX II Actual Comment Letters

Larimer County Larimer Communications Facility U.S. Forest Service Scoping Report

1.0 INTRODUCTION

Larimer County, Colorado, filed an application with the Arapaho & Roosevelt National Forests and Pawnee National Grassland, Canyon Lakes Ranger District, to construct an 800MHz radio communication site atop Middle Bald Mountain (Sect. 9, T9N, R74W, 6th PM; 40-45-57.8n latitude, 105-42-27.8w longitude; 10,867-foot altitude). There is currently no communication facility at the proposed location. Radio communication in the upper regions of the Cache la Poudre Canyon is spotty, and it is becoming increasingly essential because of increased recreational use and residential development in and around the canyon. The County wants to improve its radio coverage so that government agencies such as the Sheriff’s Department, local fire departments, and other emergency responders can more effectively communicate. The purpose of the Proposed Action is to provide first-responders and other agencies with reliable, all-weather communications capabilities that would allow emergency service providers to assist residents and recreational visitors as quickly and safely as possible during both routine and large- scale incidents.

The Proposed Action would involve construction, operation and maintenance of a tower, a building, and overhead lines. An approximately 40 to 60 foot, three-legged, lattice-style, non- reflective tower would be fixed on top of the rock outcrop at the Middle Bald Mountain summit. There would be no guy wires. That tower would carry two microwave dishes approximately six feet in diameter with grey covers. A 360-square foot building to house the radio equipment and emergency generator would be located on a nearly-level area of alpine tundra below the rock outcrop of the summit. It would be constructed of a concrete slab floor and pre-formed, exposed-aggregate walls. Electrical power for the facility would be provided by overhead lines to be constructed along the north side of the NFSR 517 from the Elkhorn Creek trailhead at County Road 162 to tree line on Middle Bald Mountain. The power line would then be cabled underground across the alpine tundra meadow and above the tree line to the building. In addition, an existing access road from NFSR 517 to the summit would need to be upgraded.

A Forest Plan amendment may be required because Middle Bald Mountain is not designated in the 1997 Forest Plan Revision as a communication site.

In order to process the Larimer County application, the United States Forest Service (USFS) must fulfill the requirements of the National Environmental Policy Act (NEPA). The NEPA planning process helps the public and responsible officials consider the environmental impact of proposed actions as well as reasonable alternatives to those actions. The public is engaged early in the process to help define the issues and the scope of the environmental analysis. The analysis will address the estimated impacts of the County’s proposed facility, the estimated impacts of alternative actions that would meet the need, the No Action alternative, and the estimated impacts of any connected actions.

This Scoping Report summarizes and categorizes the input received during the scoping period. It does not include recommendations or conclusions about the scope of the EA.

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2.0 THE SCOPING PROCESS

The public scoping period was designed to help the USFS determine the appropriate scope of its environmental study of the facility proposed by Larimer County by identifying concerns the public has with the proposed project:

• What alternatives should be considered? • What other actions should be considered? • What environmental effects should be considered? • What steps to reduce potential adverse impacts should be considered?

The period for public input, normally 30 days, began on December 1, 2006. It was originally slated to extend until January 12, 2007, to accommodate the holiday season and was then extended even further. The final deadline for comments to be fully considered in the project analysis was January 22, 2007.

A website was made available to provide pertinent information throughout the scoping process: http://www.fs.fed.us/r2/arnf/projects/ea-projects/clrd/commsite/index.shtml.

2.1 Direct Mail

A scoping letter (Attachment A) was mailed to the 66 contacts provided by USFS (Table 1) as well as 38 additional agencies, organizations and individuals (Table 2). It was also mailed to 13 communications organizations (Table 3), as provided by the subcontractor Pericle (Attachment B).

2.2 Email

An email version of the scoping letter was sent to 17 email addresses, including 2 for organizations that did not receive a hard copy. Two contacts from the County were able to forward the email version of the letter to 2 lists maintained by the County: the Commissioner Rennels’ Citizens Meeting Group and the Red Feather Lakes Plan Advisory Commission (Attachment B).

2.3 News Media Press Releases

A press release (Attachment C) was sent via email to 25 media (i.e. newspaper and radio) contacts in the Denver area, 58 media contacts in the Fort Collins area, and 13 internal contacts (i.e. public affairs and visitor information specialists). All contacts were provided by the Canyon Lakes Ranger District, Arapaho and Roosevelt National Forest & Pawnee National Grassland.

In addition, the press release was sent to 4 local newspapers and newsletters by email, to one newsletter by fax, and to one newspaper by mail (Attachment D).

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A second press release (Attachment E) was distributed on January 3, 2007, to the contacts listed in Attachment D to inform the public of the deadline extension.

2.4 Distribution of Posters in the Nearby Communities

At least 35 copies of a poster/flier about the project (Attachment F) were sent to Deni LaRue, the Larimer County Information Officer. She arranged for Mr. Bud Thomas to distribute them at key locations in the Red Feather Lakes community.

2.5 Incoming Comments

Both a postal mail address and an email address were established for accepting comments:

Communications Site Mangi Environmental Group 7915 Jones Branch Drive McLean, VA 22102 [email protected]

A toll-free telephone comment line was offered for set-up but was not employed.

2.6 Additional Contacts

As the comment period proceeded, 6 additional scoping letters were mailed to individuals, and 3 individuals who submitted comments by email (Attachment G) were added to the email list in Attachment D.

In total, 244 individuals, organizations, agencies, and members of the news media were contacted about the scoping process.

Scoping Letter Sent by Mail 123 Scoping Letter Sent by Email 19 Press Release Sent 102 by Email, Mail or Fax TOTAL CONTACTS MADE: 244

2.7 Site Prospectus

Forest Plan direction and USFS policy are to maximize utilization of communication sites. During scoping, the Canyon Lakes Ranger District also sought input from electronic communications providers who would be interested in locating at this site, if it were designated. Facility options could include: 1) Public safety facility (restricted to government and emergency service providers), or

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2) Low-power commercial facility (government and emergency service providers + non- government low-power radio providers like ham radio, AM radio, commercial wireless voice, data carriers, etc.), or 3) High-power commercial facility (the above + high-power telecommunication providers like FM radio, television, cellular, etc.).

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3.0 SCOPING COMMENTS

For the purposes of this report, a “comment” is defined as an opinion, issue, concern, question, or suggestion made within a comment letter. There may be several comments within one comment letter. See Attachment H for a list of comments per comment letter.

A “comment letter” is defined as any single piece of correspondence sent in the form of a mailed letter or as an emailed, faxed, or phoned message. See Attachment I for a list of comment letters per comment.

3.1 Comment Letters Received

A total of 79 comment letters were received. (See Appendix II to review actual letters.)

Individuals 71 Organizations 6 Agencies 2 Communications Providers 1 TOTAL COMMENT LETTERS 79 Individuals

There were 71 comment letters received from individual members of the public. Numerous letters from one person or more than one person per letter were typically counted once.

Organizations

One petition was sent in an envelope from the Larimer County Sheriff’s Office to the Canyon Lakes Ranger District with 34 signatures of people in support of the public safety communication facility on Middle Bald Mountain: “Reliable communications are essential for the effectiveness and safety of our emergency responders. We believe this facility will greatly enhance emergency response in our community.”

Similarly, the Lower Poudre Canyon Association, which represents 250 residents and property owners, wrote a letter in support of the project: “The proposed facility would improve the communication capabilities for emergency services in our area. We view this as a worthwhile benefit to our residents.”

The board of directors of the Poudre Canyon Fire Protection District wrote in support of the project. They referred to a County report that claims that coverage would be “greatly” improved: “This would be a vast improvement for all agencies and improve communications in the event of emergencies.”

The board of directors of the Crystal Lake Road & Recreation Association and the Crystal Lakes Water & Sewer Association wrote a joint letter in support for the Middle Bald Mountain tower.

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However, they stated their concern about potential environmental degradation and requested that a gate be built to restrict access. Additionally, they stated their opposition against the additional towers and against installation of any lighting.

Chris Pague from The Nature Conservancy in Colorado recommended that the location be inventoried prior to construction, especially for butterflies and rare plant species. He also suggested that the tower be placed in a different location on Middle Bald Mountain.

Agencies

The Fort Collins District Colorado State Forest Service supports the proposal. They believe that the benefits of increased communication outweigh site impacts. They request that a VHF repeater be included to help in the transition to 800 MHz.

Norm Keally from the City of Fort Collins made an inquiry but did not submit comments.

No other agency comments have been received at this time.

3.2 Summary of Comments

The comment letters contained roughly 400 comments. Below is a tally of comment letters per comment (see Attachment I for details).

Some individuals who commented expressed conceptual opinions about the Proposed Action:

• 20 expressed general support for the project or for certain aspects of the project: • 17 feel there is a demonstrated need to improve communications • 15 value safety • 5 feel the costs of not having communications are too high • 3 support use of the tower for commercial interests

• 27 expressed general opposition to the project or to certain aspects of the project: • 20 questioned the need to improve communications and/or the ability to improve communications effectively i. 3 questioned the accuracy of modeling ii. 3 questioned the adequacy of funding and/or follow-through • 11 value rural lifestyles and/or the area i. 4 said the tower is not wanted by the community ii. 12 said that lack of communication should be assumed when living in or traveling to rural and/or mountainous areas • 24 say the costs of the project outweigh any communication benefits i. 6 believe that radio technology will quickly become outdated; the structure will outlast its function ii. 3 oppose using tax dollars for the project • 15 oppose use of the area by commercial interests • 16 believe the area should be conserved; the USFS should be protecting the forest

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i. 7 said for future generations ii. 4 said for learning and educational purposes iii. 9 said for the serenity, solitude, and/or sentimental value of the place iv. 21 said because the area is unique (i.e. it currently lacks development; the environment defines the area) • 4 fear the project would set a precedent for other towers and/or development in the area and/or on other nearby mountains

Several people expressed concerns about specific impacts:

Comment Letter(s) Issue or Concern Per Code Concern about environmental damage in general 20 Concern about damage caused by equipment/ 11 construction and/or maintenance activities Physical Impacts: Potential Land Use Issues 3 Impacts due to power lines, poles, fencing, etc. 12 Impacts to FR 517 3 Impacts due to access road upgrade 7 Potential Soil Impacts 2 Irreparable damage to alpine tundra 13 Potential Waste Management/Spill Impacts 1 Biological Impacts Potential Wildlife Impacts 10 Elk, moose, etc. (i.e. large animals) 7 Birds 6 T&E species 1 Noise 1 Potential Vegetation Impacts 5 Socioeconomic Impacts: Potential Visual/Aesthetic Impacts 29 Light impacts 5 View at the peak would be disturbed 3 View of tower as part of landscape 13 Potential Recreational Impacts 15 Concern by OHV users (i.e. Killpecker Trail; 4 Elkhorn Baldy Road) Concern for/by hikers; about roadless areas 8 Potential Economic 0 Tourism impacts/ concerns about property values 5 Potential Transportation Impacts 2 Potential Cultural/Historic Resource Impacts 2 Potential Noise Impacts 1

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Comment Letter(s) Issue or Concern Per Code Potential Human Health/Safety Impacts 3 Mention “Homeland Security” 4

Others who commented offered alternatives to the Proposed Action:

Comment Letter(s) Alternative Per Code Explore other alternatives/ lower impact and/or 12 cost options Provided specific suggestions 1 Wait for better conditions (i.e. final decision on 3 roadless rules; funding; just because) Place facility in a different location: Use sites that are already degraded or are less visible (i.e. existing roads or powerlines; different 10 part of mountain) Deadman's Mountain/Road 7 South Bald 4 Buckhorn Mountain 1 Sleeping Elephant 1 Another Bald 1 Use land of person who commented 1 Modify certain aspect of the project: Install a gate for the access road 5 Develop a “commercial partnership” (i.e. a partnership with cell phone companies) to offset 2 costs to taxpayers Use an alternate road for powerline 1 Replace one big tower with a series of smaller 3 towers Use other towers as a "stop-gap" until better 2 technology is developed Add VHF repeater to transition into use of new 1 technology Change/limit the size of the project (i.e. height of 3 towers) Technology: Consider using satellite technology 8 Use other technologies with less impact (i.e. 8 helicopters, etc.) Utilize solar or wind power; generator backup 5

There were several comments about the scoping process itself:

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Comment Letter(s) Issue or Concern Per Code Request EIS 15 Request deadline extension 12 Request public meetings 11 Request appropriate representative at 2 public meetings Require further study; want more data or information to support need, cost, etc.; want more 15 public involvement Lives saved if tower built 4 Environmental impacts 2 General concern about comment period timing 9 and/or length Inadequate amount of time to educate 3 selves about project Public wasn’t told about project for 10 8 Years Process was inadequate 4 No alternatives were suggested 3 No public meeting was originally planned 3 Did not sufficiently inform public 8 There were inaccuracies in the scoping letter 4 Include need for second site (i.e. Glacier View 3 tower) in proposed action Coordinate with existing planning efforts and/or agreements in area (i.e. Red Feather Lakes Area 8 plan, Larimer County master plan) Reference documents were not made easily 1 accessible Want to be informed of future input opportunities; want process to be open; want to be contacted; 9 want more information

Finally, a few comments addressed mitigation:

Mitigation Comment Letter(s) Per Code Provided specific suggestions 4

Comments that were made in 15 letters of more were: • General support for the project or for certain aspects of the project: • A demonstrated need for the project • Value safety • General opposition to the project or to certain aspects of the project:

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• Questioned the need to improve communications and/or the ability to improve communications effectively • The costs of the project outweigh any communication benefits • Oppose use of the area by commercial interests • Believe the area should be conserved; the USFS should be protecting the forest • The area is unique (i.e. it lacks development; the environment defines the area) • Concern about environmental damage (i.e. impacts) in general • Potential Visual/Aesthetic Impacts • Potential Recreational Impacts • Request EIS • Require further study; want more data or information to support need, cost, etc.; want more public involvement

3.3 Issues that May Be Considered “Significant”

Based on the scoping comments, there is a considerable list of impacts that may be considered significant upon further study. These include but are not limited to:

• Tribal cultural impacts – The “Baldies” (including Middle Bald Mountain) may be historically sacred & significant to the Ute Mountain Tribe; there may be artifacts there. • Destruction/disturbance of tundra – The Laramie Mountains are a unique geological feature supporting two or three small but pristine pockets of alpine tundra and adjacent tundra-forest ecotone. Middle Bald Mountain is one of these pockets. Alpine tundra is considered by many to be rare and fragile. Some people who commented claim that it would take 300 years to produce 1/4 inch of tundra topsoil lost during project construction, operation, and maintenance activities. If 30 percent of the tundra is affected, the impact would be significant. • Conflict with local land use plans – The proposal may violate the Larimer County Master Plan and Red Feather Lakes Area Plan (adopted by the Larimer County Commissioners), which preserve the viewshed. • Recreation impacts – Middle Bald Mountain is a central feature of the recreational area; it is one of the most easily accessible places for residents and visitors to experience nature. Many people visit or live in the area specifically because of the wilderness, the views, and the recreational opportunities. One of the trails that leads to the peak of Middle Bald Mountain is the only alpine trail in the area. Some OHV users consider the NFSR 517 route to be “historical;” construction may impact property values, tourism, and the like. • Endangered species impacts – Rare and important species may include the Calliope Hummingbird, Common Raven, Bald Eagle, migrating raptors and passerine species, migrating butterflies, rare plants and/or wildflowers, Bull Moose, Elk, etc. • Precedential impacts – The project could set a precedent for other projects proposed at Horsetooth Mountain, Long’s Peak, and Mummy Range. • Light pollution impacts – Flashing lights on the tower could be considered a nuisance.

An environmental analysis must be conducted in order to determine the actual significance of these or other impacts.

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4.0 ADDITIONAL SCOPING RESULTS

4.1 Media Coverage Received

The following press was collected during the scoping period for the public record:

Date Source Title of Article Author Forest Service Studies Impact of Radio Tower: Larimer County Wants Associated 5-Dec-06 cbs4denver.com Tower Near Red Feather Lakes Press article EDITORIAL: Radio tower on Middle Linda Bell, Jan-07 North 40 News Bald Mountain draws fire Correspondent IN BRIEF: Tower input deadline Coloradoan 4-Jan-07 The Coloradoan extends staff SOAPBOX: Bald Mountain proposal 5-Jan-07 The Coloradoan strips rural sanity Ben Myers Middle Bald Mountain Tower is bad 7-Jan North 40 News idea Ben Myers LETTER TO THE EDITOR: Radio Maj. Justin 12-Jan The Coloradoan tower needed for public safety Smith LETTER TO THE EDITOR: Tower 14-Jan-07 The Coloradoan is a necessity Bill Sears Larry and LETTER TO THE EDITOR: Don't Margie 18-Jan-07 The Coloradoan degrade mountain Caswell SOAPBOX: Radio tower would spoil Susannah 19-Jan-07 The Coloradoan essence of mountain Wright LETTER TO THE EDITOR: Safety 1/26/2007 The Coloradoan should come first Jim Schroeder

See Attachment J for additional information about the articles.

4.2 Site Prospectus – Interested Electronic Communication Providers

Rick Sullivan from Cingular Wireless asked for details about the site in case it is possible for them to relocate their existing communications facility from Deadman Mountain.

No other inquiries have been received at this time.

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