Final Comment Opportunity! County Commissioners Public Comment and Approval: East Boulder Creek Site Management Plan
By BCAS Conservation Committee
Boulder County Parks and Open Space (BCPOS) has created a management plan for the East Boulder Creek (EBC) site. The site has experienced limited human access, and therefore species diversity is quite high on portions of the area, particularly Kenosha Wetlands and along Coal Creek. The EBC site consists of 1,377 acres and contains five miles of stream along Boulder and Coal Creeks (including one mile of restored floodplain), a dozen ponds, wetlands, reclaimed grasslands, grazing lands, and irrigated pasture lands. The location is along Boulder Creek from just west of CO Highway 287 at the site’s southwest corner, to County Line Road at the northeast corner.
The East Boulder Management Plan site is 1,377-acres, composed of five individual open space properties that contain a dozen ponds and five miles of perennial stream along Boulder Creek and Coal Creek. To read the management plan, appendices, public survey results and more visit the EBC website. For an interactive map, visit this BCPOS website.
The EBC site includes Great Blue Heron heronry.
This special site needs your voice! The EBC site presents an opportunity to continue to protect and restore native prairie, riparian corridors, and other important habitats. Over 140 bird species and a variety of native mammals, amphibians, and other organisms have been observed using the site. To maintain this diversity, human access needs to be carefully planned. The County Commissioners are seeking public feedback and it is important for them to hear from people who value our local wildlife and habitats.
How Can You Help?
Submit written comments to the Boulder County Commissioners online prior by noon on Wednesday January 24. Also consider commenting in person or on Zoom at the upcoming Commissioners meeting at 9:30 on Thursday January 25.
Content to Consider for Your Comments
BCAS is providing the following comments to the County Commissioners. Please consider including the points most relevant for you. Your comments may be more effective if revised to use your own words.
These comments reference the Management Plan and Appendix A, which are linked under Proposed Management Plan heading here.
Boulder County Audubon Society (BCAS) is submitting these comments on the proposed management plan for the Prairie Run Open Space, previously referred to as the East Boulder Creek (EBC) site. We have previously submitted comments to BCPOS and POSAC throughout the phases of plan development over the last year. BCAS’s mission is to be “a voice for birds and wildlife conservation through habitat protection, advocacy, and nature education.”
As we have previously stated, we consider it of the utmost importance to prioritize protection, restoration, and enhancement of wildlife and habitats when determining how and where human access will be allowed at the EBC site.
BCAS appreciates county staff’s hard work on this plan. We expect that the planned restoration of stream corridors and native grasslands will improve wildlife habitat on the site, and we support strictly limiting access to East Boulder Creek to specific areas on the south side of the creek. We appreciate some changes made between early and later plan drafts, including moving the play area and shelter further west and away from the Kenosha Wetlands Critical Wildlife Habitat (CWH), and consolidating several trails on the east side of the stacked ponds, leaving the remaining accessible trail adjacent to the stacked ponds and further from Kenosha Wetlands CWH. The Kenosha Wetlands CWH, located near the confluence of East Boulder Creek and Coal Creek, is one of several CWH’s in the Prairie Run area designated in the Environmental Resources Element (ERE) of the Boulder County Comprehensive Plan.
In our July comments to Survey 2, we expressed concerns about providing urban amenities at EBC and about the proximity of facilities, including the parking lot and fishing pier, to the Kenosha Wetlands CWH. Kenosha Wetlands CWH contains important cattail marsh nesting habitat where bird Species of Special Concern have been observed. We still have these concerns, and other concerns as explained below,
The Prairie Run area has a high level of species diversity, as noted in Plan Appendix A, which lists over 170 wildlife species, including over 140 bird species and a variety of native mammals, fish, and reptiles, that have been documented on the property. At least 20 of these species are Species of Special Concern designated in the ERE. Much of this diversity is concentrated around the Kenosha Wetlands CWH. The area is home to at least five nesting raptor species and a heronry. At least fourteen raptor species have been documented using the site, according to Plan Appendix A, including hawks, falcons, eagles, owls, Osprey, and Northern Harrier. Several of these have been designated as Species of Special Concern. Bald Eagles nesting nearby frequent the area for feeding, courting, and raising their young.
In addition, the Prairie Run area has been designated in the ERE as Suitable, Contiguous Habitat for the federally threatened Preble’s meadow jumping mouse and the species has been documented upstream, per Plan Appendix B.
To maintain the diversity of species observed on the site, human access needs to be carefully planned and implemented, with consideration given to seasons of wildlife use for breeding, migration, and wintering habitat as well as maintaining undisturbed open creek corridors for the movement, nesting, and foraging of birds and mammals.
The plan concentrates the most intensive recreational use in the northeast portion of Prairie Run, which includes the Kenosha Wetlands CWH, several raptor nests, and a heronry. Planned facilities in this part of the area include a parking lot, trails adjacent to the CWH and along Boulder and Coal Creeks, picnic shelters, playground, and a fishing pier and potential paddle boarding on the stacked ponds east of the CWH.
BCAS has previously expressed concern about the proximity of facilities to the Kenosha Wetlands CWH. As mentioned above, moving the playground and shelter further west and consolidating trails on the east side of the stacked ponds are welcome improvements.
However we are still particularly concerned about the trails on the north side of Kenosha Wetlands CWH and the east side of Coal Creek. As we have previously commented to BCPOS, these areas provide some of the most valuable wildlife habitat on the site, and the trails are not needed in order to provide a future connection for Erie. We consider it important to avoid further fragmenting these areas. Eliminating these trails would contribute greatly to fulfilling Goal 2, Action: Protect Sensitive Wildlife Areas on p. 21 of the plan. We are also still concerned about the proximity of the parking lot and fishing pier to the Kenosha Wetlands CWH.
We would like to highlight several important points from pages 5-10 of Plan Appendix A (updated November 2023), which clearly lays out both the habitat values of the EBC and the risks of increased access.
Appendix A states that the EBC “provides habitat for a diverse array of species due to its riparian corridors, water bodies, low level of human presence and limited adjacent development.…..the wildlife-supporting elements of the CWH and adjacent riparian corridors would likely be diminished without maintaining human impacts at low intensity”. Specifically mentioned are the Boulder and Coal Creek corridors that host nesting Bald Eagles, Red-tailed Hawks, Swainson’s Hawk’s, Great-horned Owls, and American Kestrels as well as the fact that the EBC site serves as foraging area and home range territory for two pairs of nesting bald eagles.
The Appendix goes on to caution that “Public access and a network of trails could irreversibly diminish the regular, long-term use of this location by eagles.” The Appendix references the reduced availability of suitable riparian habitat to sustain nest sites along the creeks, including for herons, which “warrants elevated concern for protecting current nest sites and promoting future ones”.
Regarding the Kenosha Wetlands CWH, Appendix A states that “The wetland serves as a densely occupied nesting area for migratory songbirds and secretive marsh birds, a migratory stopover during fall and spring migration, and it is utilized by a broad range of avian species but especially waterfowl. Protection of CWH #65 and adjacent upland habitat is imperative to preserve the breeding, foraging, and seasonal migratory bird activity and habitat that supports over 142 species of birds including 20 avian Species of Special Concern.”
Based on the above points from Plan Appendix A, and our previous comments to BCPOS, we are still concerned about the urban recreational amenities that would bring in large numbers of people to the most sensitive habitats in the northeast area of Prairie Run. Nearby towns provide many of these amenities in their parks - for example, Erie lists thirteen parks on their website that provide playgrounds and other amenities.
Additionally, we still believe the loop trail along the north side of the Kenosha Wetlands CWH and the east side of Coal Creek should be eliminated, as mentioned above. One reason is the raptor nesting along Coal Creek, shown on plan maps. As we have previously commented, we believe that planning trails close to raptor nests where months-long seasonal closures may be needed during nesting season seems like a setup for management headaches and visitor frustration.
In our Survey 2 comments, we stated that we believe dogs, if allowed, should be leashed and strictly limited to specific areas where wildlife impacts would be minimized. In view of the Kenosha Wetlands CWH, wildlife species diversity, and Species of Special Concern in the northeast section, it is our considered opinion that this means prohibiting dogs in the northeast section of the area, as we recommended in our December comments to POSAC. Even one dog encroaching on the Kenosha Wetlands CWH could cause nesting failure for birds nesting on the ground or in cattails, including bird Species of Special Concern. There is a substantial body of research that shows that the presence of dogs, even on leash, has been shown to result in disturbance of wildlife feeding patterns, dispersal, and reduction in species presence - for example, this 2016 literature review of impacts of dogs on wildlife and water quality https://www.researchgate.net/publication/301800852 with its extensive list of references, including a local study on Boulder County Open Space (Miller SG, Knight RL, Miller CK. 2001. Wildlife responses to pedestrians and dogs. Wildlife Society Bulletin 29:124-132.)
We believe that incorporating these changes would still provide excellent recreation and educational experiences with mountain views and wildlife observations, while minimizing the risk of losing the wildlife that visitors enjoy observing. Once recreational facilities are built, it will be very difficult, and expensive to remove or move them if adverse impacts are found. It will be critical to use baseline wildlife data, and to continue surveys and monitoring while stream restoration is ongoing and before facilities are built. This will allow any adverse impacts to wildlife or habitats to be detected early and addressed immediately, through modifications of facilities locations, seasonal closures, or other measures, before changes become irreversible.
We hope and expect that as the plan is implemented, BCPOS will prioritize protecting the integrity of the CWH’s, Environmental Conservation Areas, and other areas designated in the ERE as well as protecting nesting raptors and herons and other Species of Special Concern who use the area in different seasons.
We have previously commented about invasives prevention measures. Several policies incorporated into the plan address invasive plants; however, we are unable to find mention of aquatic invasive species in the plan, Appendix A, or incorporated policies. Aquatic invasive species can be spread by equipment during stream restoration, and by any type of watercraft. We consider it very important to add invasives prevention measures, such as boot cleaning stations (including regular maintenance), and thorough inspection of all equipment to be used for restoration, construction or maintenance, especially including prevention measures for aquatic invasive species such as New Zealand mudsnails, which already occur in several locations upstream of the East Boulder Creek site. This content could be added as a Priority under Goal 2, as it is relevant to all of the Priorities under this goal.
There are many places in Boulder County, on the plains and in foothills and mountains, for humans and dogs to recreate, but the areas remaining where wildlife can retreat without these disturbances, especially in diminishing riparian prairie habitats, are shrinking. Prairie Run has the potential to be a model of restored prairie grassland and healthy streams hosting rich wildlife populations, including habitat for many of our grassland species whose populations have declined precipitously due to habitat loss.
Swainson’s Hawk