Rocky Flats

National Wildlife Refuge

Final

Comprehensive Conservation Plan

and

Environmental Impact Statement

September 2004

Prepared for:

U.S Fish & Wildlife Service

Rocky Flats National Wildlife Refuge

Rocky Mountain Arsenal – Building 121

Commerce City, CO 80022

Prepared by:

ERO Resources Corp.

1842 Clarkson Street

Denver, CO 80218

And:

Shapins Associates

1738 Pearl Street, Ste. 220

Boulder, CO 80302

Approved: _________________________________ __________________

Ralph Morgenweck Date

Regional Director, Region 6, USFWS

Final Comprehensive Conservation Plan & EIS iii

SUBMITTED BY:

_________________________________ __________________

Laurie Shannon Date

Planning Team Leader

Rocky Flats National Wildlife Refuge

_________________________________ __________________

Dean Rundle Date

Refuge Manager

Rocky Flats National Wildlife Refuge

CONCUR:

_________________________________ __________________

David Weisman Date

Refuge Program Supervisor

_________________________________ __________________

Richard A. Coleman, Ph.D. Date

Regional Chief

National Wildlife Refuge System

ROCKY FLATS NATIONAL WILDLIFE REFUGE

COMPREHENSIVE CONSERVATION PLAN/

ENVIRONMENTAL IMPACT STATEMENT APPROVAL

U.S. FISH AND WILDLIFE SERVICE, REGION 6

Final Comprehensive Conservation Plan & EIS v

Abstract

The Rocky Flats site is a 6,240-acre former nuclear defense facility operated by the U.S. Department of Energy

(DOE). The DOE is completing cleanup of the site under oversight by the U.S. Environmental Protection

Agency (EPA) and the Colorado Department of Public Health and Environment. Under the Rocky Flats

National Wildlife Refuge Act of 2001, the site will become the Rocky Flats National Wildlife Refuge following

certification from the EPA that cleanup and closure have been completed. The Rocky Flats site is located at the

interface of the Great Plains and Rocky Mountains, where it supports a diverse mosaic of vegetation

communities. Many areas of the Rocky Flats site have remained relatively undisturbed for the past 30 to 50

years, allowing them to retain diverse natural habitat and associated wildlife. Important vegetation communities

on the site include the rare xeric tallgrass grassland and the tall upland shrubland communities. Rocky Flats

also supports populations of the threatened Preble’s meadow jumping mouse, as well as a herd of about 160 deer.

The U.S. Fish and Wildlife Service has prepared this Final Comprehensive Conservation Plan and

Environmental Impact Statement (CCP/EIS). It describes and analyzes four management alternatives for the

site: Alternative A - No Action, Alternative B – Wildlife, Habitat and Public Use (Preferred Alternative),

Alternative C – Ecological Restoration, and Alternative D – Public Use. Wildlife-dependent public uses are

considered to be appropriate uses on National Wildlife Refuges, and were considered in the development of the

alternatives. Some of the greatest benefits would come from road removal and revegetation, weed management,

and Preble’s habitat management. The greatest impacts to Refuge resources would be the result of reduced

resource management in Alternative A, and increased visitor use in Alternatives B and D. The Final CCP/EIS

provides responses to comments received on the Draft CCP/EIS.

The Final CCP/EIS is available for review at http://rockyflats.fws.gov. The U.S. Fish and Wildlife Service will

issue a Record of Decision on the CCP no sooner than 30 days after the Notice of Availability for the Final

CCP/EIS is published in the Federal Register. Comments concerning this Final CCP/EIS should be sent to:

Laurie Shannon, Planning Team Leader

U.S. Fish and Wildlife Service

Rocky Mountain Arsenal – Building 121

Commerce City, CO 80022

Phone: (303) 289-0980

Fax: (303) 289-0579

Email: rockyflats@fws.gov

Final Comprehensive Conservation Plan & EIS vii

Contents

Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .S1

Chapter 1 Purpose and Need . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

1.1. Legal and Policy Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4

U.S. Fish & Wildlife Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5

National Wildlife Refuge System Mission and Goals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5

Compatibility Policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5

1.2. Refuge Significance, Purpose, Vision and Goals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6

Significance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6

Purpose and Direction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6

Vision . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

Goals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

1.3. Proposed Action/Preferred Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

1.4. Planning Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

1.5. Planning Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

1.6. Decision to be Made . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

1.7. Adjacent Land Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

1.8. Activities Outside the Scope of this EIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11

1.9. Future Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13

1.10. References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14

Chapter 2 Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15

2.1. Development of Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17

Significant Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17

Resource Management Zones . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17

2.2. Description of Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18

Alternative A: No Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18

Alternative B: Wildlife, Habitat and Public Use (Preferred Alternative) . . . . . . . . . . . . . . . . . . . .18

Alternative C: Ecological Restoration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18

Alternative D: Public Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19

2.3. Wildlife Habitat and Public Use Management Descriptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26

Wildlife and Habitat Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26

Public Use Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28

2.4. Objective and Strategy Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .37

Goal 1. Wildlife and Habitat Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .39

Goal 2. Public Use, Education and Interpretation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .51

Goal 3. Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .63

Goal 4. Effective and Open Communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .65

Goal 5. Working With Others . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .66

Goal 6. Refuge Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .68

Alternative A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .74

Alternative B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .74

Alternative C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .74

Alternative D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .74

2.7. Partnership Opportunities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .74

2.8. Monitoring and Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .75

2.9. Alternative Considered but Eliminated . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .76

2.10. Reasonably Foreseeable Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .76

Urban Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .76

Regional Transportation Improvements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .76

Resource Development and Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .77

Open Space and Trails . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .79

Cold War Museum . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .80

2.11. References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .80
viii Rocky Flats National Wildlife Refuge 

Chapter 3 Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .101

3.1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .103

3.2. Geology and Soils . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .103

Surficial and Bedrock Geology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .103

Geologic Hazards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .103

Mineral Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .103

Soils . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .105

Soil Contamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .105

3.3. Water Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .105

Surface Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .105

Ground Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .108

Future Hydrological Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .110

3.4. Vegetation Communities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .110

Xeric Tallgrass Grassland Management Zone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .111

Wetland and Riparian Corridors Management Zone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .112

Mixed Prairie Grasslands Management Zone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .115

Noxious Weeds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .115

Rare Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .117

Fire History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .117

3.5. Wildlife Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .117

Mammals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .119

Birds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .123

Reptiles and Amphibians . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .123

Aquatic Species . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .124

Wildlife Species of Special Concern . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .125

Wildlife Corridors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .125

Potential Contamination Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .126

3.6. Federal Threatened and Endangered Species . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .126

Preble’s Meadow Jumping Mouse . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .126

Bald Eagle . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .127

Plant Species . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .127

3.7. Cultural Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .127

Prehistoric Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .127

Historic Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .127

3.8. Infrastructure, Easements, and Utilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .129

Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .129

Utilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .132

Mineral Rights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .132

Water Rights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .133

3.9. Surrounding Land Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .133

Municipalities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .133

Woman Creek Reservoir Authority . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .134

Open Space . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .134

Other Nearby Land Uses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .134

3.10. Open Space, Recreation and Trails . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .134

City of Boulder Open Space and Mountain Parks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .134

Boulder County Open Space . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .137

Jefferson County Open Space . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .137

City of Arvada Open Space . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .137

City of Westminster Open Space . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .138

City and County of Broomfield Open Space . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .138

Town of Superior Open Space . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .138

3.11. Visual Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .138

Views From Surrounding Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .138

Views From Rocky Flats . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .138

Internal Views . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .139

Disturbed Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .139

3.12. Noise . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .139

3.13. Air Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .139

3.14. Socioeconomics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .139

Population and Demographics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .139

Employment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .140

Income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .140

Rocky Flats National Wildlife Refuge 
Final Comprehensive Conservation Plan & EIS ix

Chapter 4 Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .145

4.1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .147

Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .147

4.2. Geology and Soils . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .148

Wildlife and Habitat Management Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .148

Public Use, Education, and Interpretation Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .150

Refuge Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .151

Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .152

4.3. Water Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .152

Wildlife and Habitat Management Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .152

Public Use, Education and Interpretation Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .153

Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .153

4.4. Vegetation Communities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .154

Wildlife and Habitat Management Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .154

Public Use, Education and Interpretation Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .159

Refuge Operations, Safety and Partnerships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .165

Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .166

4.5. Wildlife Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .167

Wildlife and Habitat Management Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .167

Public Use, Education, and Interpretation Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .173

Refuge Operations, Safety and Partnerships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .176

Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .176

Wildlife and Habitat Management Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .177

Public Use, Education and Interpretation Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .178

Refuge Operations, Safety and Partnership Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .179

Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .180

4.7. Cultural Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .180

Wildlife and Habitat Management Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .180

Refuge Operations, Safety and Partnerships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .180

Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .181

4.8. Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .181

Visitation/Access . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .181

Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .183

4.9. Open Space, Recreation and Trails . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .183

Wildlife and Habitat Management Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .183

Public Use, Education and Interpretation Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .184

Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .185

4.10. Visual Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .185

Wildlife and Habitat Management Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .185

Public Use, Education and Interpretation Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .186

Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .186

4.11. Noise . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .188

Wildlife and Habitat Management Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .188

Public Use, Education and Interpretation Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .188

Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .188

4.12. Air Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .188

Dust and Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .188

Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .189

4.13. Socioeconomics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .189

Employment, Income, and Housing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .189

Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .190

4.14. Wilderness Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .190

4.15. Fencing Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .190

4.16. Possible Transportation Improvements Near the Refuge . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .191

Lands Within 300 Feet of Indiana Street . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .191

Potential Impacts from Transportation Improvements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .191

4.17. Adherence to Planning Goals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .194

4.18. Resource Commitments Common to All Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .195

4.19. Short-term Uses of the Environment and Maintenance of Long-term Productivity . . . . . . . . . . . . . . . . .195

4.20. Unavoidable Adverse Environmental Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .195

4.21. Summary of Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .195

4.22. References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .196
x Rocky Flats National Wildlife Refuge 

Chapter 5 Preparers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .213

U.S. Fish and Wildlife Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .215

Shapins Associates, Inc. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .215

Resolve . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .216

ERO Resources Corp. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .216

Additional Contributors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .216

U.S. Fish and Wildlife Service, Region 6 Regional Office . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .216

U.S. Fish and Wildlife Service, Region 6 Ecological Services . . . . . . . . . . . . . . . . . . . . . . . . . . . .217

U.S. Fish and Wildlife Service, Colorado Fish and Wildlife Assistance Office . . . . . . . . . . . . . . .217

U.S. Fish and Wildlife Service, Private Lands . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .217

U.S. Fish and Wildlife Service, Washington Office . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .217

U.S. Fish and Wildlife Service, Rocky Mountain Arsenal NWR Staff . . . . . . . . . . . . . . . . . . . . .217

U.S. Department of Energy, Rocky Flats Field Office . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .217

Kaiser-Hill/Labat-Anderson . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .218

Colorado Division of Wildlife . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .218

Chapter 6 Consultation and Coordination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .219

6.1. Project Scoping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .221

Public Scoping Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .221

Project Website . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .221

Public Agency Meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .221

Focus Groups . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .222

Native American Tribes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .222

6.2. Results from Scoping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .222

6.3. Alternative Workshops . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .223

Issues to Reconsider . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .223

Public Preferences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .223

6.4. Comments on Draft EIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .223

Changes from the Draft CCP/EIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .223

6.5. Draft CCP/EIS Recipients . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .225

Federal, State and Local Agencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .225

Government Representatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .226

Organizations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .226

Native American Tribes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .227

Individuals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .227

Public Libraries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .228

Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .229

Appendices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .237

Appendix A. Refuge Legislation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .239

Appendix B. Compatibility Determination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .251

Appendix C. Laws and Executive Orders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .269

Appendix D. Regulatory Letters about Future Refuge Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .275

Appendix E. Letter to RFCA Parties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .281

Appendix F. Cost Details . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .285

Appendix G. Species Lists . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .295

Appendix H. Comments and Responses on the 

Draft Environmental Impact Statement . . . . . . . . . . . . . . . . . . . . . . .(See Companion Document)

Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .307

Rocky Flats National Wildlife Refuge 
Final Comprehensive Conservation Plan & EIS xi

Figures

Figure 1. Regional Location. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3

Figure 2. Comprehensive Conservation Planning Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8

Figure 3. Rocky Flats Industrial Area and DOE Retained Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11

Figure 4. Pre-Cleanup Plutonium Concentrations in Surface Soils . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12

Figure 5. Rock Creek Reserve Boundary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18

Figure 6. Alternative A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22

Figure 7. Alternative B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23

Figure 8. Alternative C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24

Figure 9. Alternative D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25

Figure 10. Prescribed Fire and Grazing Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .43

Figure 11. Reasonably Foreseeable Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .78

Figure 12. Surficial Geology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .104

Figure 13. Soils . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .106

Figure 14. Water Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .109

Figure 15. Vegetation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .113

Figure 16. Noxious Weeds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .116

Figure 17. Recent Fire History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .118

Figure 18. Wildlife Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .121

Figure 19. Potential Prairie Dog Habitat . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .122

Figure 20. Cultural Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .128

Figure 21. Infrastructure, Easements, and Utilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .130

Figure 22. Regional Open Space . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .135

Figure 23. Regional Trails . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .136

Figure 24. Alternative A Roads and Trails . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .160

Figure 25. Alternative B Roads and Trails . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .161

Figure 26. Alternative C Roads and Trails . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .162

Figure 27. Alternative D Roads and Trails . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .163

Tables

Table 1. Estimated Increased Cancer Risk from Exposure to Residual Contamination . . . . . . . . . . . . . .13

Table 2: Summary of Proposed Management Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20

Table 3. Interpretive Themes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .29

Table 4. Objective and Strategy Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Table 5. Estimated Costs of Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .74

Table 6. Summary of Objectives and Strategies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .82

Table 7. Vegetation Communities at Rocky Flats . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .111

Table 8. Major Noxious Weeds at Rocky Flats . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .117

Table 9. Wildlife Species of State Special Concern at Rocky Flats . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .126

Table 10. Daily and Peak Hour Traffic Volume Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .131

Table 11. Road Restoration and Average Vegetation Patch Size Following Revegetation . . . . . . . . . . . . .156

Table 12. Vegetation Disturbance Associated With New Trail Construction . . . . . . . . . . . . . . . . . . . . . . . .164

Table 13. Vegetation Impacts from Public Use Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .164

Table 14. Comparison of Proposed Trail Density to Other Open Space Areas . . . . . . . . . . . . . . . . . . . . . . .175

Table 15. Trail Lengths Within Preble’s Habitat . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .179

Table 16. Estimated Visitation and Associated Vehicles Per Day . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .181

Table 17. Daily and Peak Hour Traffic Volume for Access and Trailheads Proposed in Alternatives B and D . .182

Table 18. Potential Resource Impacts Within Various Right-of-Way Widths . . . . . . . . . . . . . . . . . . . . . . . .192

Table 19. Adherence to Planning Goals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .194

Table 20. Impact Threshold Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .198

Table 21. Summary of Environmental Consequences . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .202

Table 22. Percentage of Scoping Comments by Topic . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .222
xii Rocky Flats National Wildlife Refuge 
xiii Final Comprehensive Conservation Plan & EIS xiii

Acronym List

BOSMP City of Boulder Open Space and Mountain Parks Department

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CCP Comprehensive Conservation Plan

CDOW Colorado Division of Wildlife

CDOT Colorado Department of Transportation

CDPHE Colorado Department of Public Health and Environment

CNHP Colorado Natural Heritage Program

DOE Department of Energy

DRCOG Denver Regional Council of Governments

EIS Environmental Impact Statement

ESA Endangered Species Act

EPA Environmental Protection Agency

FTE Full-time employee

GPS Global Positioning System

IPM Integrated Pest Management

MMS Maintenance Management System (database)

MOU Memorandum of Understanding

NEPA National Environmental Policy Act

NWR National Wildlife Refuge

NWRS National Wildlife Refuge System

NWTC National Wind Technology Center

O&M Operations and maintenance

RFCA Rocky Flats Cleanup Agreement

RFCAB Rocky Flats Citizen Advisory Board

RFCLOG Rocky Flats Coalition of Local Governments

RMA Rocky Mountain Arsenal National Wildlife Refuge

ROD Record of Decision

RONS Refuge Operations Needs System

Summary

Final Comprehensive Conservation Plan & EIS S1

Summary

THE ROCKY FLATS NATIONAL WILDLIFE REFUGE

This document is a Final Comprehensive Conservation

Plan (CCP) and Environmental Impact Statement

(EIS) for the Rocky Flats National Wildlife Refuge

(Rocky Flats NWR). The CCP will guide

management of Refuge operations, habitat restoration

and visitor services for the next 15 years. The EIS

evaluates and compares four alternatives to managing

wildlife, habitats and human use of the proposed

Refuge. It also discloses effects of restoration and

visitor use on important physical, biological, social and

cultural resources.

The Rocky Flats site is a 6,240-acre former nuclear

defense facility operated by the U.S. Department of

Energy (DOE). All weapons manufacturing was

performed in a 600-acre area in the middle of the site

known as the Industrial Area. In 1992, the mission of

the Rocky Flats site changed from weapons production

to environmental cleanup and closure. The DOE is

completing the cleanup in accordance with the Rocky

Flats Cleanup Agreement (RFCA) under oversight by

the U.S. Environmental Protection Agency (EPA) and

the Colorado Department of Public Health and

Environment (CDPHE).

Under the Rocky Flats National Wildlife Refuge Act of

2001 (Refuge Act), the 6,240-acre Rocky Flats

Environmental Technology Site will become the Rocky

Flats NWR following certification from the EPA that

cleanup and closure have been completed. At that

time, the U.S Fish & Wildlife Service (Service) will

assume management responsibility for most of the site.

Five sequential steps must be completed before Rocky

Flats becomes a Refuge. These steps are:

1. Service completes final CCP/EIS and issues

a Record of Decision

2. DOE completes site cleanup except for

operations and maintenance of cleanup

monitoring facilities

3. EPA certifies completion of the cleanup

4. DOE transfers land to Department of the

Interior

5. Department of the Interior establishes the

Refuge and Service begins management and

implementation of the CCP

Big Bluestem in the xeric tallgrass prairie.

© RFETS

The Refuge provides habitat for elk.

© Mauro

Summary
Summary

S2 Rocky Flats National Wildlife Refuge 

The Service understands that some members of the

public remain apprehensive about potential public use

at Rocky Flats NWR due to the site’s history. In all

alternatives, the Service would brief visitors about the

site’s transformation from a nuclear weapons

production facility to a National Wildlife Refuge. In

the alternatives that allow for expanded public use, the

Service would address public concerns about the

safety of the Refuge by providing clear information

that educates visitors about access restrictions and

public use opportunities. This information would be

available at all trailheads. The Service also would

work with the DOE to develop signage and fencing or

another means of boundary demarcation to clearly

identify all areas that would be retained by DOE and

are closed to public access.

REFUGE SIGNIFICANCE

In the Refuge Act, Congress identified the following

significant qualities about the Rocky Flats site:

• The majority of the site has generally

remained undisturbed since its acquisition

by the government.

• The site preserves valuable open space

and striking vistas of the Front Range

mountain backdrop.

• The site provides habitat for many wildlife

species, including a number of threatened

and endangered species, and is marked by 

the presence of rare xeric tallgrass prairie

plant communities.

REFUGE PURPOSE

The Refuge Act identified four purposes of the Rocky

Flats NWR:

• Restoring and preserving native ecosystems.

• Providing habitat for, and population

management of native plants and migratory

and resident wildlife.

• Conserving threatened and 

endangered species.

• Providing opportunities for compatible

scientific research.

The Refuge Act also provided some direction for

managing the Refuge. The Service is to manage the

Refuge to ensure that wildlife-dependent public uses

and environmental education and interpretation are the

priority public uses of the Refuge.

VISION

During the initial planning process, the Service

developed the following vision statement to describe

what will be different in the future as a result of the

CCP and to capture the essence of what the Service is

trying to accomplish at the Refuge:

Rocky Flats National Wildlife Refuge is a

healthy expanse of grasslands, shrublands

and wetlands, including rare xeric tallgrass

prairie, where natural processes support a

broad range of native wildlife. The Refuge

provides striking mountain and prairie views

© Mauro

The Service would conserve the diversity of native fauna.
Final Comprehensive Conservation Plan & EIS S3

Summary

and opportunities to appreciate the Refuge

resources in an urbanized area through

compatible wildlife-dependent public uses

and education. Working with others, the

Refuge conserves the unique biotic

communities and sustains wildlife

populations at the interface of mountains

and prairies on Colorado’s Front Range.

GOALS

The Service also developed a set of goals to guide the

planning effort and Refuge management:

Wildlife and Habitat Management

Conserve, restore and sustain the biological diversity

of the native flora and fauna of the mountain/prairie

interface with particular consideration given to

threatened and endangered species.

Public Use, Education and Interpretation

Provide visitors and students high quality

recreational, educational and interpretive

opportunities and foster an understanding and

appreciation of: the Refuge’s xeric tallgrass prairie;

upland shrub and wetland habitats; native wildlife;

the history of the site; and the National Wildlife

Refuge System (NWRS).

Safety

Conduct operations and manage public access in

accordance with the final Rocky Flats’ cleanup

decision documents to ensure the safety of the Refuge

visitors, staff and neighbors.

Effective and Open Communication

Conduct a variety of communication outreach efforts to

raise public awareness about the Refuge programs,

management decisions, and the mission of the Service

and the NWRS.

Working with Others

Foster beneficial partnerships with individuals,

government agencies, non-governmental organizations,

and others to promote resource conservation,

compatible wildlife-related research, public use, site

history, and infrastructure.

Refuge Operations

Based on available funds, provide facilities and staff to

fulfill the Refuge vision and purpose.

PUBLIC INVOLVEMENT

Throughout the CCP/EIS development process, the

Service has solicited input from the public. Public

involvement in the planning process ensured that

interested and affected individuals, organizations,

agencies and governmental entities were consulted and

provided opportunities to participate. Public

involvement has:

• Informed the public about Rocky Flats

NWR (planning updates, website, public

meetings, presentations).

• Provided public input on key issues.

• Provided help in determining management

direction of Rocky Flats NWR.

© Mauro

Goldfinch and a variety of bird species present 

opportunities for wildlife observation.
Summary

S4 Rocky Flats National Wildlife Refuge 

THE REFUGE’S RESOURCES

The Rocky Flats site is located at the interface of the

Great Plains and Rocky Mountains. The western half

of the site is characterized by the relatively level Rocky

Flats pediment, which gives way to several finger-like

drainages that slope down to the rolling plains in the

eastern portion of the site. 

A diverse mosaic of vegetation communities is found at

Rocky Flats. Two of these vegetation communities, the

xeric tallgrass prairie and the tall upland shrubland,

are considered to be rare in the region. Other

vegetation communities include riparian woodland,

riparian shrubland, wetlands, mesic mixed grassland,

xeric needle and thread grassland, reclaimed mixed

grassland, and ponderosa pine woodland.

Many areas of the Rocky Flats site have remained

relatively undisturbed for the last 30 to 50 years,

allowing them to retain diverse habitat and associated

wildlife. These wildlife communities are supported by

the regional network of protected open space that

surrounds Rocky Flats on three sides and buffers

wildlife habitat from urban development. Preble’s

meadow jumping mouse (Preble’s), a threatened

species, occurs in every major drainage on the Refuge,

as well as wetlands and shrubland communities

adjacent to the Rock Creek and Woman Creek

drainages. A resident herd of about 160 deer inhabit

the site and elk are occasionally present. 

Cultural resource surveys have identified and recorded

45 cultural sites or isolated artifacts at Rocky Flats.

None of the identified cultural resources are

recommended as eligible for listing in the National

Register of Historic Places. However, the Lindsay

Ranch within the Rock Creek drainage provides

opportunities to interpret the early history of

settlement and ranching on the prairie.

The Rocky Flats site is located at the intersection of

Jefferson, Boulder and Broomfield counties. The site 

is surrounded by open space to the north, east and

west, and urban development to the northeast and

southeast. Other nearby land uses include mining

operations, wind energy research, and water collection

and storage facilities.

ACTIVITIES OUTSIDE THE SCOPE OF THIS EIS

The legislation establishing Rocky Flats NWR requires

that the Department of Energy (DOE) retain

jurisdiction, authority and control over portions of the

Rocky Flats site necessary for cleanup response

actions. DOE anticipates that it will need to retain land

in and around the current Industrial Area in order to

maintain institutional controls and protect cleanup and

monitoring systems. 

Management alternatives for the DOE-retained lands

are not considered in this CCP because the lands will

not be part of the Refuge and the Service will not have

authority to decide how those lands should be managed.

The Service is recommending a fence that allows

wildlife movement be built around the retained area to

Research on wildlife populations would be a component distinguish Refuge lands from DOE jurisdiction. The of most alternatives.

A field of wildflowers.

© Mauro

© Mauro
Final Comprehensive Conservation Plan & EIS S5

Summary

DOE does not anticipate transferring any lands that

would require additional safety requirements for either

the Refuge worker or the visitor. 

DESCRIPTION OF ALTERNATIVES

Four alternatives were developed following the public

scoping process and a workshop involving the planning

team and Service staff. The alternatives are analyzed in

detail in this CCP/EIS and summarized briefly below.

ALTERNATIVE A: NO ACTION

In the No Action Alternative, the Service would not

develop any public use facilities and would not

implement any new management, restoration, or

education programs at Rocky Flats. In this

alternative, the Service would continue to manage the

1,800-acre Rock Creek Reserve in accordance with the

Rock Creek Reserve Integrated Natural Resources

Management Plan (DOE 2001). 

Management activities within the Rock Creek Reserve

would include ongoing resource inventories and

monitoring, habitat restoration, weed control, and road

removal and revegetation. Public use opportunities

would be limited to guided tours.

ALTERNATIVE B: WILDLIFE, HABITAT AND PUBLIC USE

(PREFERRED ALTERNATIVE)

Alternative B, the Service’s Preferred Alternative,

emphasizes both wildlife and habitat conservation

along with a moderate level of wildlife-dependent

public use. Refuge-wide habitat conservation would

include management of native plant communities,

removal and revegetation of unused roads and stream

crossings, management of deer and elk populations, 

and protection of Preble’s meadow jumping mouse

habitat. Restoration would strive to replicate presettlement conditions.

Visitor use facilities would include about 16 miles of

trails, a seasonally staffed visitor contact station,

trailheads with parking, and developed overlooks. One

trail down to the Lindsay Ranch would be open soon

after Refuge establishment, while the remainder of the

public use facilities would open after 5 years, when

restoration is well underway. Most of the trails would

use existing roads. Public access would be by foot,

bicycle, horse, or car. A limited public hunting program

would be developed in collaboration with Colorado

Division of Wildlife (CDOW). 

On- and off-site environmental education programs

would focus on the prairie ecosystem and would

primarily target high school and college students.

The Service would provide compatible scientific

research opportunities that focus on wildlife habitat

and interactions between wildlife and human use.

Partnerships would be sought from federal, state and

municipal agencies and private entities to help achieve

Refuge goals and to conserve contiguous lands. 

ALTERNATIVE C: ECOLOGICAL RESTORATION

Alternative C emphasizes Refuge-wide conservation

and restoration of large areas of wildlife habitat.

Restoration and management activities would strive to

replicate pre-settlement conditions. Restoration efforts

would focus on disturbed areas such as road corridors,

stream crossings, cultivated fields and developed areas.

The Lindsay Ranch

barn would be an

interpretive site in

Alternative B. 

© Mauro
Summary

S6 Rocky Flats National Wildlife Refuge 

Limited public use and minimal facility development

would occur in this alternative. Any facilities on the

Refuge would be built for specific resource protection

and management purposes. A single, 3,700-foot long

trail would provide access to the Rock Creek drainage,

but access would be limited to guided tours only.

Environmental education programs would be limited to

local distribution of educational materials about the

Refuge and its ecological resources.

In Alternative C, the Service would facilitate increased

opportunities for applied research relating to long-term

habitat changes and species of special concern.

Partnerships would be expanded with governmental

agencies, educational institutions and others to assist in

wildlife and habitat protection, resource stewardship

and the preservation of contiguous lands.

ALTERNATIVE D: PUBLIC USE

In Alternative D, the Service would emphasize wildlifedependent public uses. Wildlife and habitat

management would focus on the restoration of select

plant communities and ongoing conservation and

management of existing native plant and wildlife

species. Certain roads and other disturbed areas not

used for trails or public use facilities would be restored

with native vegetation.

A broad range of public use opportunities would be

provided, including wildlife observation and

photography, interpretation, environmental education

and a limited hunting program. Access through the

Refuge would be provided by a 21-mile trail system that

would accommodate hiking, bicycling and equestrian

use. Most of the trails would be constructed along

existing roads. A visitor center would be constructed at

the Refuge. Environmental education efforts would

include on- and off-site programs for kindergarten

through college age students.

Research opportunities would focus on the integration

of public use into the Refuge environment and

interactions between wildlife and visitors. Partnerships

would be sought with various public agencies to help

sustain Refuge goals and preserve contiguous lands.

The Service also would work with local communities

and tourism organizations to promote wildlifedependent public uses on the Refuge.

OBJECTIVES AND STRATEGIES

The Service has developed objectives and strategies for

each alternative. An objective is a general statement

about what the Service wants to achieve on the Refuge,

while a strategy is a specific action, tool, technique or

combination of the above used to meet objectives.

Because each alternative has a different emphasis, the

objectives and strategies vary by alternative. The

following summarizes key objective topics addressed

for each alternative in the CCP/EIS:

© Mauro

Resident deer populations are found at the Refuge.
Final Comprehensive Conservation Plan & EIS S7

Summary

WILDLIFE AND HABITAT MANAGEMENT

• Preble’s habitat management

• Xeric tallgrass management

• Mixed grassland prairie management

• Road restoration and revegetation

• Weed management

• Deer and elk management

• Prairie dog management

• Species reintroduction

PUBLIC USE, EDUCATION AND INTERPRETATION

• Public access

• Visitor experience 

• Interpretation

• Environmental education

• Hunting

• Recreation facilities

SAFETY

• Staff safety

• Visitor safety

OPEN AND EFFECTIVE COMMUNICATION

• Outreach efforts

WORKING WITH OTHERS

• Emergency response partnerships

• Conservation partnerships

• Research partnerships

• Volunteer partnerships

REFUGE OPERATIONS

• Staffing

• Operations and management facilities 

• Cultural resource management

ENVIRONMENTAL CONSEQUENCES

The proposed Refuge management alternatives would

pose a variety of benefits and impacts to resources at

Rocky Flats. Some of the greatest benefits would

come from road removal and revegetation, weed

management, and Preble’s habitat management

activities. The greatest impacts to Refuge resources

would be the result of reduced resource management in

Alternative A and increased visitor use in Alternatives

B and D. These and other effects are summarized

below and described in detail in the CCP/EIS.

© USFWS

Sharp-tailed grouse is a likely candidate for reintroduction.

Lupine and

many other

wildflowers

can be found

on the Refuge.

© Mauro
Summary

S8 Rocky Flats National Wildlife Refuge 

Preble’s Habitat Management. All of the alternatives

include protection and maintenance of the Refuge’s

Preble’s habitat. This would result in moderate, longterm benefits to Preble’s and other species that depend

on riparian habitat. 

Pond Restoration. Alternative C would remove the

Lindsay Ponds and restore those areas to a native

wetland. This would result in a major impact to

existing native fish populations that use the ponds and

also would impact future fish reintroductions.

Grassland Management. Tallgrass and mixed

grassland management strategies, along with weed and

fire management and road removal and revegetation in

all alternatives, would benefit grassland communities

on the Refuge. However, many of the benefits would

be limited to the Rock Creek Reserve in Alternative A

and would be reduced overall in Alternatives A and D

because prescribed fire and grazing would not be

available as Refuge-wide grassland restoration tools. 

In Alternatives B and C, the planned restoration of

non-native grasses in the hay meadow and other areas

to native prairie would benefit the overall quality and

diversity of mixed grassland habitat on the Refuge. 

Road Restoration and Revegetation. In all of the

alternatives, the removal and revegetation of unused

roads and stream crossings would provide a major

long-term benefit to a variety of vegetation

communities and related wildlife species. These

benefits would be greatest in Alternative C and the

least in Alternative A.

Weed Management. In all of the alternatives,

implementation of Integrated Pest Management (IPM)

practices would benefit a variety of wildlife habitat

types on the Refuge. These benefits, however, would

be greatly reduced in Alternative A where proactive

weed control would only be applied to the Rock Creek

Reserve and an IPM plan would not be completed. 

Deer and Elk Management. The establishment and

achievement of population targets for deer and elk in

Alternatives B, C and D would benefit both those

species and the habitat on which they depend.

However, proposed monitoring levels in Alternatives A

and D may not be sufficient to develop effective

population targets.

In Alternative A, the Service would not actively pursue

population targets, which could result in long-term

impacts to ungulate populations and their habitat and

adverse impacts on habitat quality for Preble’s and

other species due to overbrowsing or overgrazing.

Trail Development and Use. While the impacts of new

trail construction in Alternatives B and D would be

negligible, public use of some trails could result in

moderate long-term adverse impacts to wildlife species

due to an increased human presence that may alter

wildlife movement and foraging patterns. These

impacts would be more pronounced in Alternative D,

where several trails run adjacent to riparian areas and

could disturb potential raptor nesting habitat. The

combination of trails in the Rock Creek drainage in

Alternative D could result in a moderate to major

impact to wildlife and habitat in that area. Some trail

impacts could be reduced by the enforcement of

seasonal trail closures.
PURPOSE AND NEED

chapter 1

Chapter 1. Purpose and Need 

The Rocky Flats Environmental Technology Site is a

6,240-acre former nuclear defense facility operated by

the U.S. Department of Energy (DOE). The site is 16

miles northwest of Denver, Colorado on the borders of

Boulder, Broomfield, and Jefferson counties (Figure

1). The DOE acquired 2,519 acres in 1951, and an

additional 4,027 acres in 1974 and 1975. Of these

acres, 305 acres have been conveyed to the DOE's

Wind Technology Site northwest of the site. All

weapons manufacturing was performed in a 600-acre

area in the middle of the site known as the Industrial

Area. The area surrounding the Industrial Area is

known as the Buffer Zone.

In 1992, the mission of the Rocky Flats site changed

from weapons production to environmental cleanup

and closure. The DOE is completing the cleanup in

accordance with the Rocky Flats Cleanup Agreement

(RFCA) under oversight by the U.S. Environmental

Protection Agency (EPA) and the Colorado

Department of Public Health and Environment

(CDPHE). The RFCA is a legally binding agreement

between the EPA, CDPHE, and DOE that establishes

the regulatory guidelines and framework for site

cleanup. Because the EPA, CDPHE, and DOE signed

the Rocky Flats Cleanup Agreement, these three

agencies are known as the RFCA Parties.

During the comment period on the Draft CCP and EIS,

numerous commentors had questions or concerns about

the process of becoming a Refuge. Five sequential

steps must be completed before Rocky Flats becomes a

Refuge. The steps, discussed in more detail in the

following sections, are:

1. Service completes final CCP/EIS and issues

a Record of Decision

2. DOE completes site cleanup except for

operations and maintenance of cleanup

monitoring facilities

3. EPA certifies completion of the cleanup

4. DOE transfers land to Department of the

Interior

5. Department of the Interior establishes the

Refuge and Service begins management and

implementation of the CCP

DOE is currently completing a wide range of interim

cleanup actions. When these activities are completed,

expected sometime between 2005 and 2006, the DOE

will prepare a Remedial Investigation/ Feasibility

Study (RI/FS) report describing any remaining

contamination at the site. The report also will describe

any additional cleanup actions that DOE may need to

take. The report will be summarized in a document

known as the Proposed Plan, which will be released for

public comment before being finalized. After public

comment has been incorporated, the Proposed Plan

Chapter 1: Purpose and Need

Final Comprehensive Conservation Plan & EIS 3

The Refuge site was a former nuclear defense facility

operated by the DOE.

© RFETS

Figure 1. Regional Location.
Chapter 1: Purpose and Need

4 Rocky Flats National Wildlife Refuge 

will become the basis for a Corrective Action

Decision/Record of Decision (CAD/ROD), which the

RFCA Parties will sign. The CAD/ROD will

determine the need for any additional cleanup, longterm monitoring, and land use controls necessary for

the site. 

Under the Rocky Flats National Wildlife Refuge Act of

2001 (P. L. 107-107) (Refuge Act - Appendix A), the site

will become the Rocky Flats National Wildlife Refuge

and be managed by the U.S. Fish and Wildlife Service

(Service) when the EPA certifies that cleanup and

closure at Rocky Flats have been completed and that

all response actions are operating properly and

successfully. O&M associated with response actions

will be ongoing. "Response actions" are cleanup

activities currently being undertaken or monitoring

and maintenance activities following cleanup by the

DOE at the Rocky Flats site. The EPA will not certify

that cleanup and closure at Rocky Flats has been

completed until after the RFCA Parties sign the

CAD/ROD. After EPA certification, DOE will transfer

much of Rocky Flats to the Department of the Interior

and the Service will manage it as a National Wildlife

Refuge. DOE will be required to conduct post-closure

environmental monitoring and remedy maintenance in

accordance with a post-closure, long-term stewardship

agreement approved by EPA and CDPHE. DOE will

also review the cleanup remedy at least every 5 years

with the EPA and CDPHE. The EPA and CDPHE

can require DOE to undertake additional actions if

post-cleanup monitoring indicates the cleanup is not

protective of human health and the environment.

The majority of the site has remained undisturbed

since its acquisition, and provides habitat for many

wildlife species, including two species that are

federally listed as threatened (bald eagle and

Preble’s meadow jumping mouse). Establishing the

site as a unit of the National Wildlife Refuge System

(NWRS) will promote the preservation and

enhancement of its natural resources for present

and future generations.

This document is a Final Comprehensive

Conservation Plan (CCP) and Environmental Impact

Statement (EIS) for the Rocky Flats National

Wildlife Refuge. Once finalized, the CCP will guide

management of Refuge operations, habitat

restoration, and visitor services for the next 15 years.

Guidance will be provided in the form of goals,

objectives, strategies (Chapter 2) and compatibility

determinations (Appendix B). Compatibility is

discussed in more detail in a following Compatibility

Policy section. The Final CCP will be based on a

Record of Decision (ROD) that will identify a selected

alternative. The selected alternative can be one of the

alternatives in this final CCP/EIS or it can be a new

alternative developed from a combination of the draft

alternatives. This final EIS evaluates and compares

four alternatives for managing wildlife, habitats, and

human use of the proposed Refuge. It also describes the

effects of restoration and visitor use on important

physical, biological, social, and cultural resources.

1.1. LEGAL AND POLICY GUIDANCE

Refuges are managed to achieve the mission and goals

of the NWRS and the designated purpose of the

Refuge unit as described in establishing legislation or

executive orders, or other establishing documents. Key

concepts and guidance of the NWRS are provided in

the Refuge System Administration Act of 1966 (P.L. 89-

669), the Refuge Recreation Act of 1962 (P.L. 87-714),

Title 50 of the Code of Federal Regulations, the Fish

and Wildlife Service Manual and, most recently, the

National Wildlife Refuge System Improvement Act of

1997 (P.L. 105-57) (Improvement Act). The

Improvement Act amends the Refuge System

Administration Act by providing a unifying mission for

the NWRS, a new process for determining compatible

public uses on refuges, and a requirement that each

refuge be managed under a CCP. The Improvement

Act states that wildlife conservation is the priority of

NWRS lands and that the Secretary of the Interior will

ensure the biological integrity, diversity and

environmental health of refuge lands are maintained.

The Improvement Act requires the Service to monitor

the status and trends of fish, wildlife and plants in each

National Wildlife Refuge System.
Chapter 1: Purpose and Need

Final Comprehensive Conservation Plan & EIS 5

refuge. A list of other laws and executive orders that

may affect the CCP for Rocky Flats NWR or the

Service’s implementation of the CCP is provided in

Appendix C.

U.S. FISH & WILDLIFE SERVICE

The Service, an agency within the Department of the

Interior, will manage the Rocky Flats NWR. The

Service is the primary federal agency responsible for

conserving and enhancing the nation’s fish and wildlife

populations and their habitats. Although the Service

shares this responsibility with other federal, state,

tribal, local and private entities, the Service has specific

trust responsibilities for migratory birds, threatened

and endangered species, and certain anadromous fish

and marine mammals. The Service also has similar

trust responsibilities for the lands and waters it

administers to support the conservation and

enhancement of fish and wildlife.

NATIONAL WILDLIFE REFUGE SYSTEM

MISSION AND GOALS

The mission of the NWRS is: 

“To administer a national network of lands

and waters for the conservation,

management and where appropriate,

restoration of the fish, wildlife and plant

resources and their habitats within the

United States for the benefit of present and

future generations of Americans.”

(National Wildlife Refuge System Improvement

Act of 1997.)

Since the first refuge was established in 1903, the

NWRS has grown to more than 92 million acres in size.

It includes more than 500 refuges, with at least one in

every state and over 3,000 Waterfowl Production

Areas. The needs of wildlife and their habitats come

first on refuges, in contrast to other public lands

managed for multiple uses.

Administration, management and growth of the NWRS

are guided by the following goals:

• To fulfill the Service’s statutory duty to

achieve refuge purpose(s) and further the

System mission

• To conserve, restore where appropriate, and

enhance all species of fish, wildlife and

plants that are endangered or threatened

with becoming endangered

• To perpetuate migratory bird, 

interjurisdictional fish, and marine 

mammal populations

• To conserve a diversity of fish, wildlife 

and plants

• To conserve and restore as appropriate

representative ecosystems of the United

States, including the ecological processes

characteristic of those ecosystems

• To foster understanding and instill

appreciation of native fish, wildlife and

plants and their conservation, by providing

the public with safe, high quality and

compatible wildlife-dependent public use.

Such use includes hunting, fishing, wildlife

observation and photography and

environmental education and interpretation

COMPATIBILITY POLICY

Lands within the NWRS are different from federal

multiple-use public lands, such as National Forest

System lands, because they are closed to all public

uses unless specifically and legally opened. A refuge

use is not allowed unless it is determined to be

compatible. Recreational uses, including all actions

associated with a recreational use, refuge management

economic activities, or other use by the public, are

considered to be a refuge use. A compatible use is a

use that, in the sound professional judgment of the

Refuge Manager, will not materially interfere with or

detract from the fulfillment of the mission of the

NWRS or the purposes of the Refuge. Sound

professional judgment is defined as a decision that is

consistent with principles of fish and wildlife

management and administration, available science and

resources, and adherence with law. The Improvement

Act also states that compatible wildlife-dependent

recreation uses are legitimate and appropriate priority

general public uses. Six uses, hunting, fishing, wildlife

observation, wildlife photography, environmental

education, and interpretation, are to receive enhanced

consideration in planning and management over all

other general public uses of the NWRS. Whenever

they are determined to be compatible, and consistent

with public safety, these uses are to be provided on

units of the NWRS.

Compatibility determinations are written

determinations signed and dated by the Refuge
Chapter 1: Purpose and Need

6 Rocky Flats National Wildlife Refuge 

Manager with concurrence of the Regional Chief,

National Wildlife Refuge System, stating that a

proposed or existing use of a national wildlife refuge

is or is not a compatible use. Compatibility

determinations are typically completed as part of the

CCP or step-down management plan process. Draft

compatibility determinations are open to public input

and comment. Once a final compatibility

determination is made by the Refuge Manager, with

Regional Chief concurrence, it is not subject to

administrative appeal.

Facilities and activities associated with recreational

public uses, or where there is an economic benefit

associated with a use, require compatibility

determinations. Refuge management activities such

as invasive species control, prescribed fire, scientific

monitoring and facilities for managing a refuge do not

require compatibility determinations.

Four compatibility determinations for public

recreational activities proposed in Alternative B (the

Preferred Alternative) can be found in Appendix B.

Drafts of these compatibility determinations were

available for public review and comment as part of the

Draft CCP/EIS. Additional draft compatibility

determinations are likely to be prepared and issued for

public comment during the life of the plan in response

to step-down management plans that may call for

implementation of a refuge economic use (e.g. grazing),

for specific research projects, or in response to third

party requests for other refuge uses not addressed in

this plan.

1.2. REFUGE SIGNIFICANCE, PURPOSE, 

VISION AND GOALS

SIGNIFICANCE

In the Refuge Act, Congress found that the Rocky

Flats site had several significant qualities:

• The majority of the Rocky Flats site has

generally remained undisturbed since its

acquisition by the federal government.

• The State of Colorado is experiencing

increasing growth and development,

especially in the metropolitan Denver Front

Range area in the vicinity of the Rocky

Flats site. That growth and development

reduces the amount of open space and

thereby diminishes for many metropolitan

Denver communities the vistas of the

striking Front Range mountain backdrop.

• The Rocky Flats site provides habitat for

many wildlife species, including a number of

threatened and endangered species, and is

marked by the presence of rare xeric

tallgrass prairie plant communities.

Establishing the site as a unit of the NWRS

will promote the preservation and

enhancement of those resources for present

and future generations.

PURPOSE AND DIRECTION

As discussed previously, the Rocky Flats NWR was

established by the Refuge Act. The Refuge Act

identified four purposes of the Rocky Flats NWR:

• Restoring and preserving native ecosystems

• Providing habitat for and population

Deer with fawn.

© Mauro
Chapter 1: Purpose and Need

Final Comprehensive Conservation Plan & EIS 7

management of native plants and migratory

and resident wildlife

• Conserving threatened and endangered

species (including species that are

candidates for listing under the Endangered

Species Act)

• Providing opportunities for compatible

scientific research

The Refuge Act also provided some direction for

managing the Refuge. The Service is to manage the

Refuge to ensure that wildlife-dependent public uses

and environmental education and interpretation are the

priority public uses of the Refuge and to comply with

all response actions.

VISION

At the beginning of the planning process, the Service

developed a vision for the Refuge. A vision describes

what will be different in the future as a result of the

CCP and is the essence of what the Service is trying to

accomplish at the Refuge. The vision is a futureoriented statement designed to be achieved through

Refuge management by the end of the 15-year CCP

planning horizon. The vision for the Refuge is:

Rocky Flats National Wildlife Refuge is a

healthy expanse of grasslands, shrublands

and wetlands, including rare xeric

tallgrass prairie, where natural processes

support a broad range of native wildlife.

The Refuge provides striking mountain

and prairie views and opportunities to

appreciate the Refuge resources in an

urbanized area through compatible

wildlife-dependent public uses and

education. Working with others, the Refuge

conserves the unique biotic communities

and sustains wildlife populations at the

interface of mountains and prairies on

Colorado’s Front Range.

GOALS

The Service also developed a set of goals based on the

Refuge Act and information developed during project

planning. The Service established six goals for

Refuge management.

Goal 1. Wildlife and Habitat Management. Conserve,

restore and sustain biological diversity of the native

flora and fauna of the mountain/prairie interface with

particular consideration given to threatened and

endangered species.

Goal 2. Public Use, Education and Interpretation.

Provide visitors and students high quality

recreational, educational and interpretive

opportunities and foster an understanding and

appreciation of the Refuge’s xeric tallgrass prairie,

upland shrub and wetland habitats; native wildlife; the

history of the site; and the NWRS.

Goal 3. Safety. Conduct operations and manage public

access in accordance with the final Rocky Flats’

cleanup decision documents to ensure the safety of the

Refuge visitors, staff and neighbors.

Goal 4. Effective and Open Communication. Conduct

communication outreach efforts to raise public

awareness about the Refuge programs, management

decisions and the mission of the Service and the

NWRS among visitors, students and nearby residents.

Goal 5. Working with Others. Foster beneficial

partnerships with individuals, government agencies,

non-governmental organizations, and others to

promote resource conservation, compatible wildliferelated research, public use, site history and

infrastructure.

Goal 6. Refuge Operations. Based on available funds,

provide facilities and staff to fulfill the Refuge vision

and purpose.

1.3. PROPOSED ACTION/PREFERRED

ALTERNATIVE

The Service will adopt and implement a CCP for the

Rocky Flats National Wildlife Refuge. Alternative B,

which addresses the major issues identified during

public scoping and is consistent with sound fish and

wildlife management, was identified as the Service’s

proposed action for the Draft CCP/EIS. For this Final

CCP/EIS, the Alternative B is identified as the

“Preferred Alternative”.

1.4. PLANNING PROCESS

The Final CCP and EIS for the Rocky Flats NWR is

intended to comply with the Improvement Act, and the

National Environmental Policy Act (NEPA), and their

implementing regulations. The Service issued a final

refuge planning policy in 2000 that established
Chapter 1: Purpose and Need

8 Rocky Flats National Wildlife Refuge 

requirements and guidance for NWRS planning,

including CCPs and step-down management plans, and

ensured that planning efforts comply with the

provisions of the Improvement Act (U.S Fish &

Wildlife Service 2000). The planning policy identified

several steps of the CCP and EIS process (Figure 2):

• Form a planning team and conduct 

pre-planning

• Initiate public involvement and scoping

• Review Draft Vision Statement and Goals

and determine significant issues

• Develop and analyze alternatives, including

the Preferred Alternative

• Prepare Draft CCP and EIS

• Prepare and adopt Final CCP and EIS and

issue a ROD

• Implement plan, monitor and evaluate

• Review and revise plan

The Service began the pre-planning process after the

Refuge Act was passed in December 2001. A planning

team composed of Service staff and outside consultants

was formed in May 2002. The planning team held an

interagency workshop to identify a draft Refuge vision

and goals in July 2002. 

The planning team also developed a public

involvement/outreach plan that described how

agencies and the public could participate in the

planning process (U.S Fish & Wildlife Service 2002).

Public involvement in the planning process ensured

that interested and affected individuals, organizations,

agencies and governmental entities were consulted

and provided opportunities to participate. Public

involvement in the Refuge CCP/EIS process served

the following functions:

• Informed public about Rocky Flats NWR

• Collected public input on key issues and

concerns and 

• Provided help in determining management

direction of Rocky Flats NWR

Several communication tools were used to engage the

public, including “planning updates” to provide periodic

reports to stakeholders, workshops to solicit public

input, and a webpage for posting general information

The

Comprehensive 

Conservation 

Planning Process and 

NEPA Compliance

B. INITIATE PUBLIC

INVOLVEMENT AND SCOPING

- Involve the public

C. REVIEW VISION

STATEMENT AND GOALS AND

DETERMINE SIGNIFICANT

ISSUES

D. DEVELOP AND ANALYZE

ALTERNATIVES

- Reasonable range of

alternatives and a No Action

alternative

E. PREPARE DRAFT PLAN

AND NEPA 

DOCUMENT (EIS)

- Public comment and review

F. PREPARE AND ADOPT

FINAL PLAN

- Respond to public comment

- Select preferred alternative

G. IMPLEMENT PLAN,

MONITOR AND EVALUATE

- Public involvement when

applicable

H. REVIEW AND REVISE

PLAN

- Public involvement when

applicable

A. PREPLANNING: 

PLAN THE PLAN

Figure 2. Comprehensive Conservation

Planning Process. 
Chapter 1: Purpose and Need

Final Comprehensive Conservation Plan & EIS 9

and planning documents. In addition, notifications of

public meetings and document availability were

distributed through Federal Register notices and

media press releases. Furthermore, presentations and

briefings of project status were made to key

stakeholder groups.

After the Service published a Notice of Intent to

prepare an EIS in August 2002, the Service held

scoping meetings in Broomfield, Arvada, Westminster

and Boulder, Colorado. The scoping period ended on

October 31, 2002. Public involvement with the planning

process is described in more detail in Chapter 6. Based

on the qualities, issues and recommendations identified

in the scoping process, as well as guidance from the

Improvement Act, NEPA and the Service’s planning

policy, the planning team identified the significant

issues that are the focus of the CCP/EIS:

• Vegetation Management

• Wildlife Management

• Public Use

• Cultural Resources

• Property

• Infrastructure

• Refuge Operations

These issues are discussed in greater detail in Section

1.5. The Service prepared a scoping report that

describes in detail the scoping process and results (U.S

Fish & Wildlife Service 2003a). After scoping was

completed, the planning team collected available

information about the resources of Rocky Flats and the

surrounding area. This information is summarized in a

resource inventory report for the site (U.S Fish &

Wildlife Service 2003b). The resource inventory

provides the basis for Chapter 3.

This CCP provides long-term guidance for

management decisions; sets forth goals, objectives and

strategies needed to accomplish Refuge purposes; and

identifies the Service’s best estimate of future needs.

This CCP details program planning levels that are

sometimes substantially above current budget

allocations and, as such, are primarily for Service

strategic planning and program prioritization purposes.

This CCP does not constitute a commitment for

staffing increases, operational and maintenance

increases, or funding for future land acquisition.

The Improvement Act requires that a CCP be in place

for each refuge by 2012 and the public has an

opportunity for active involvement in plan development

and revision. The Service is committed to securing

public input throughout the CCP development process.

1.5. PLANNING ISSUES

Several significant issues were identified following the

analysis of all comments collected through the various

public scoping activities and a review of the

requirements of the Improvement Act and NEPA.

These issues, as well as the many other substantive

issues identified during scoping, were considered

during the formulation of alternatives for future

Refuge management. The significant issues are

summarized in the following sections.

Vegetation Management: Native plant community

preservation and restoration, fire management and 

weed control.

The amount and type of public use was a significant

scoping issue.

© Mauro
Chapter 1: Purpose and Need

10 Rocky Flats National Wildlife Refuge 

Wildlife Management: Wildlife species protection

and management, including strategies to address

species reintroduction, population management,

migration corridors and coordination with regional

wildlife managers.

Public Use: Policies and facility options to address

several scenarios, from no access to multiple

recreational and educational uses. This includes a

range of facility development to accommodate

these scenarios.

Cultural Resources: Preservation and recognition of

elements related to site history, including Lindsay

Ranch structures and Cold War heritage.

Property: Privately owned mineral rights,

transportation right of way, and adjacent land

owner relationships.

Infrastructure: Facilities, such as roads, fences, signs

and water systems, that accommodate Refuge needs

and user comfort/safety. Also includes surface water

hydrology and maintenance of water quality.

Refuge Operations: Staffing requirements and

management strategies to preserve significant

resources and coordinate with surrounding

communities and landowners.

1.6. DECISION TO BE MADE

The decision to be made by the Mountain and Prairie

Regional Director of the Service is the selection of an

alternative that will be implemented as the Rocky Flats

National Wildlife Refuge CCP. This decision will be

made in recognition of the environmental effects of

each of the alternatives considered. The decision will

be disclosed in a ROD no sooner than 30 days after the

Final EIS is filed with the EPA and made available to

the public. Implementation of the CCP will begin after

the DOE transfers primary administrative jurisdiction

of Rocky Flats lands to the Service and the Refuge is

formally established.

1.7. ADJACENT LAND PROTECTION

While the CCP/EIS does not constitute a commitment

for funding the protection of lands outside the Refuge’s

boundary, the Service may pursue habitat-protection

partnerships, conservation easements and/or

acquisition of lands west of the Refuge. The protection

of the grassland habitat that buffers the Refuge’s

western boundary (east of Highway 93) is important

for the health of ungulate populations that migrate

from the foothills down to the prairie. The protection

of wildlife corridors was raised as an issue in public

scoping and was frequently reiterated in subsequent

public meetings. Degradation of this habitat may deter

The Service has recommended a barbed-wire fence to demarcate the boundary between the Refuge and

DOE retained lands.

© Shapins Associates
Chapter 1: Purpose and Need

Final Comprehensive Conservation Plan & EIS 11

wildlife from migrating to the Refuge and threaten

existing ungulate populations that reside and/or calve

within the Refuge. 

The Service is currently working on a new national

land conservation policy and strategic policy and

growth initiative. This policy will develop a decisionmaking process for the growth of the NWRS and guide

individual refuges in evaluating lands suitable for

addition to the NWRS. The process will help ensure

that lands the Service protects are of national and

regional importance and meet certain nationwide

standards and goals.

The Service’s land acquisition policy is to obtain the

minimum interest necessary to satisfy refuge

objectives. Conservation easements can sometimes

be used in this context, when they are proven to be a

cost-effective habitat protection measure. In general,

conservation easements must preclude the

destruction or degradation of habitat and allow refuge

staff to adequately manage uses of the area for the

benefit of wildlife. 

1.8. ACTIVITIES OUTSIDE THE SCOPE OF THIS EIS

The Rocky Flats site is undergoing cleanup by the

DOE with oversight of CDPHE and EPA. The

Service will not accept transfer of administrative

jurisdiction, or as discussed previously, assume full

responsibility for managing the Refuge until the EPA

has deemed the cleanup complete. It is not known

exactly how long cleanup might take, or what effect

cleanup activities might have on Refuge resources and

uses. The DOE currently anticipates portions of the

site will be transferred to the Service sometime

between 2006 and 2008.

The legislation establishing Rocky Flats NWR requires

that the DOE retain jurisdiction, authority, and control

over portions of Rocky Flats necessary for cleanup

response actions. DOE anticipates that it will retain

land in and around the Industrial Area to maintain

institutional controls, and to protect cleanup facilities

and monitoring systems. The DOE-retained area may

be up to 1,200 acres, but the area's final size and

configuration will not be determined until the final

cleanup is completed and the retained area is agreed to

by the RFCA Parties. The DOE retained area

tentatively identified is shown in Figure 3; it is subject

to change before DOE transfers lands to the Service.

Management alternatives for the DOE retained area

are not considered in this CCP because the lands will

not be part of the Refuge and the Service will not have

authority to decide how those lands are managed.

However, RFCA requires that the entire site,

including the area retained by DOE, be cleaned up to a

level that will protect human health and the

environment as well as ecological receptors.

Specifically, the cleanup will protect the Refuge

worker and the less exposed Refuge visitor. Existing

concentrations of plutonium, a contaminant found in

soils inside and outside the anticipated DOE retained

area, are very low in surface soils in the lands to be

transferred to the Service. Further characterization of

the future Refuge area is ongoing. Pursuant to

Attachment 5 of RFCA, which was approved by EPA

and CDPHE, DOE removed surface soils with a

plutonium level of 50 picocuries per gram (pCi/g) or

more (Figure 4). A curie is a unit of measurement for

plutonium, and a picocurie is a trillionth of a curie.

Fifty pCi/g will be protective of a Refuge worker who

is exposed to this level on a full-time basis at Rocky

Flats. DOE anticipates retaining certain lands

containing less than 50 pCi/g of plutonium for remedyrelated purposes. An example boundary for DOE

retained lands is shown in Figure 4. However, no

decisions have been made regarding the specific

boundary and acreage of the DOE retained lands.

These decisions will be made during the RI/FSCAD/ROD process described earlier. The majority of

land that will become the Refuge will contain less than

1 pCi/g of plutonium. 

Some areas within the DOE retained area had a

plutonium concentration of more than 50 pCi/g. As

discussed in Chapter 3, elevated plutonium

concentrations are associated with an area known as

the 903 pad. As part of cleanup, DOE removed all

surface soils with a plutonium concentration of more

than 50 pCi/g around the 903 pad.

Figure 3. Rocky Flats Industrial Area and 

DOE Retained Area. 
Chapter 1: Purpose and Need

Final Comprehensive Conservation Plan & EIS 13

The Service believes that the health risk from

working on or visiting Refuge lands would be low.

As shown in Table 1, the estimated increased cancer

risk from exposure to residual soil contamination of

7 pCi/g is 1 in 1 million for the Refuge worker, and

0.6 in 1 million (or 6 in 10 million) for the Refuge

visitor. As shown in Figure 4, the majority of the

public use facilities would be located in areas where

the residual contamination is much lower (less than

1 pCi/g).

Lands that would require additional safety

requirements or restrictions for either the refuge

worker or visitor will not be transferred to the

Service for the Refuge. The risk assessment efforts

that resulted in the 50 pCi/g surface soil cleanup

action level were inclusive of Refuge management

activities such as trail building, fence construction

and prescribed fire, and visitor use activities such as

hiking, biking, and horseback riding. The risk

assessment and cleanup protections were designed

to be safe for the Refuge worker, Refuge visitor, and

the greater community. 

A Memorandum of Understanding (MOU) between

the Department of the Interior and DOE will guide

the transition of Rocky Flats to its status as a

National Wildlife Refuge. The Service does not

intend to accept transfer of primary administrative

jurisdiction for any land at Rocky Flats until the

MOU is finalized. Following cleanup and closure,

future agreements may provide for Service

involvement in managing the wildlife and habitat

resources on the retained area, under DOE

supervision. Because DOE will retain

administrative jurisdiction and manage the retained

area, which will be surrounded by the Refuge, the

Service is recommending a 4-strand, barbed-wire

fence that allows wildlife movement be built around

the retained area. The Service is also

recommending that appropriate signs be placed

near the boundary to distinguish Refuge lands from

DOE lands (see Appendix E, letter to RFCA

parties). Although no public access to the DOE

retained area is proposed in this CCP, and the

Service has recommended that the DOE retained

lands be posted with signs that prohibit public

entry, the cleanup levels being implemented will

result in a landscape that is safe for human entry.

The Service will not use the land at Rocky Flats for

residential or “bunkhouse” facilities during the life

of this CCP. If such a use is considered in the

future, the Service will obtain approval from the

CDPHE and the EPA, and will notify the public

during the planning process.

This EIS does not analyze different scenarios for

the cleanup activities because they are outside the

scope of Refuge management activities considered

in the CCP. A cleaned-up site provides the baseline

for analysis. Detailed information describing the

remaining contamination at the site will be

presented in DOE’s RI/FS Report to be published

prior to EPA’s certification of completion of the

cleanup. Readers interested in additional

information on cleanup activities should contact the

DOE at (303) 966-4546, the EPA at (303) 312-6251,

or the Colorado Department of Public Health and

Environment at (303) 692-3300.

1.9. FUTURE PLANNING

The CCP will be adjusted to include new and

improved information as it becomes available over

the course of the CCP’s 15-year duration.

Soil Plutonium Concentration 

50 pCi/g 7 pCi/g 1 pCi/g 0.1 pCi/g 

Area retained by DOE Areas to become the Refuge 

Refuge Worker* 1 in 

133.3 thousand 

1 in

1 million 

1 in

6.7 million 

1 in

66.7 million 

Refuge Visitor* 1 in 

227.3 thousand 

1 in

1.7 million 

1 in

11.1 million 

1 in

125 million 

Source: Point estimations from the Remedial Soil Action Level Model 

*Exposure Assumptions: 

 Refuge Worker – 4 hours indoors and 4 hours outside for 250 days a year for 18.7 years 

 Refuge Visitor – 2.5 hours outside for 100 days a year for 6 years (child) or 24 years (adult)

Table 1. Estimated Increased Cancer Risk from Exposure to Residual Contamination
Chapter 1: Purpose and Need

14 Rocky Flats National Wildlife Refuge 

Implementation of the CCP will be monitored and

reviewed regularly during inspections and

programmatic evaluations. Budget requests and

annual work plans will be tied directly to the CCP.

Fifteen years after the Refuge has been established,

the CCP will be formally revised, following the process

used on this CCP. Any substantive changes to the CCP

before the 15-year period will involve a public process.

However, the Refuge Manager has the authority under

Title 50 CFR, to take immediate actions outside this

plan as necessary to respond to emergencies and

protect wildlife and public safety.

The CCP describes the desired future conditions of the

Refuge and provides long-range guidance and

management direction. Chapter 2 describes objectives

and strategies that the Service would use to achieve

the desired future conditions. During the 15-year life

of this plan, the Service would prepare additional

plans, called step-down management plans. A stepdown management plan provides specific guidance for

the Service to follow to achieve objectives or

implement management strategies related to specific

management topics such as habitat, fire and public

use. Step-down plans will be developed as the need

arises. The preparation of new step-down plans

typically will require further compliance with Service

planning policies and procedures, including

opportunities for public review and comment. The

Service anticipates the following plans would be

needed at the Refuge:

• Vegetation and Wildlife Management Plan

• Integrated Pest Management Plan

• Fire Management Plan

• Hunting Plan

• Visitor Services Plan

• Health and Safety Plan

• Historic Preservation Plan

A Visitor Services Plan would be an umbrella

document that would include interpretation,

environmental education, hunting management and

research protocols. 

1.10. REFERENCES

U.S. Fish & Wildlife Service. 2000. National

Wildlife Refuge System Administration Act

as Amended by the National Wildlife

Refuge System Improvement Act of 1997,

Refuge Planning Policy; Notice. Federal

Register 65:33891-33919. May 25.

U.S. Fish & Wildlife Service. 2002. Public

involvement process. Denver, CO. August.

U.S. Fish & Wildlife Service. 2003a. Scoping

report–Rocky Flats National Wildlife

Refuge. Denver, CO. January.

U.S. Fish & Wildlife Service. 2003b. Resource

Inventory–Rocky Flats National Wildlife

Refuge. Denver, CO. April. Available at

http://rocky flats. fws.gov/index.htm. 
ALTERNATIVES

chapter 2

Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 17

This chapter describes the four alternatives analyzed

in detail in this EIS, including the Preferred

Alternative and the No Action Alternative. The

following sections describe how the alternatives were

developed, how they address the significant issues

identified during the scoping process, and how each

alternative would achieve the objectives and

strategies identified for the Refuge. The chapter’s

last two sections describe options considered but

dismissed from detailed analysis, and activities that

could result in cumulative effects when combined

with the effects of the Preferred Alternative.

2.1. DEVELOPMENT OF ALTERNATIVES

SIGNIFICANT ISSUES

In 2002, the Service held several meetings with the

public and agencies to identify the issues and

concerns that were associated with the

establishment and management of the Rocky Flats

NWR. The public involvement process is

summarized in greater detail in Chapter 6. Based on

input from the public scoping process, as well as

guidance from the Improvement Act, the NEPA and

the Service’s planning policy, the planning team

selected seven significant issues that will be addressed

in the alternatives:

1. Vegetation Management

2. Wildlife Management

3. Public Use

4. Cultural Resources

5. Property

6. Infrastructure

7. Refuge Operations

RESOURCE MANAGEMENT ZONES

Early in the planning process, the planning team

identified three management zones that correspond to

general vegetation communities at Rocky Flats. These

management zones are xeric tallgrass prairie, wetlands

and riparian corridors, and mixed prairie grasslands.

These management zones were developed to organize

management concepts and provide direction to the

objectives and strategies under each alternative. 

Xeric Tallgrass Prairie

Rocky Flats supports an example of the rare xeric

tallgrass prairie community, which is generally found on

cobbly soils in the western portions of the site. While

the quality and species composition of this community

vary, all of the xeric tallgrass management area has

similar characteristics and management needs.

Wetlands and Riparian Corridors

Located primarily along the drainages at Rocky Flats,

the wetlands and riparian corridors management zone

is generally composed of plant communities that

depend on moist conditions. While the vegetation

communities in this management zone range from

various wetlands to riparian woodland, they all share

similar characteristics and management needs.

Mixed Prairie Grasslands

The eastern portions of Rocky Flats largely are

composed of short and mixed-grass prairie

communities. The various grassland communities in

this grassland management zone share similar

characteristics and management needs.

Chapter 2. Alternatives

Prairie coneflower in the mixed prairie grassland.

© Nelson, RFETS
Chapter 2: Alternatives 

18 Rocky Flats National Wildlife Refuge 

2.2. DESCRIPTION OF ALTERNATIVES

Development of the alternatives was based on the

public scoping process and workshops involving the

planning team and Service staff. The public scoping

process identified the significant issues to be addressed

by the alternatives. The planning workshops allowed

the Service to develop a range of possible alternatives

and specific objectives and strategies for those

alternatives. The workshops resulted in four

alternatives that are analyzed in detail in this EIS. A

fifth alternative was considered early in the process,

but was eliminated from consideration (this alternative

is discussed Section 2.9). The four alternatives are:

• Alternative A: No Action

• Alternative B: Wildlife, Habitat and Public

Use (Preferred Alternative)

• Alternative C: Ecological Restoration

• Alternative D: Public Use 

ALTERNATIVE A: NO ACTION

In the No Action Alternative, the Service would not

develop any public use facilities and would not

implement any new management, restoration, or

education programs at the Refuge. In this alternative,

the Service would continue to manage the Rock Creek

Reserve in accordance with the Rock Creek Reserve

Integrated Natural Resources Management Plan

(DOE 2001). The Rock Creek Reserve is 1,800 acres

surrounding Rock Creek in the northern part of the

Refuge (Figure 5). 

Management activities within the Rock Creek

Reserve would include ongoing resource inventories

and monitoring, use of prescribed fire, habitat

restoration, weed control, and road removal and

revegetation. As “caretakers” of remaining portions of

the site, the Service would emphasize minimal

resource stewardship (such as weed control) outside

of the Rock Creek Reserve. Public use opportunities

would be limited to guided tours to the Rock Creek

Reserve (Figure 5). 

ALTERNATIVE B: WILDLIFE, HABITAT AND PUBLIC USE

(PREFERRED ALTERNATIVE)

Alternative B, the Service’s Preferred Alternative,

emphasizes both wildlife and habitat conservation

along with a moderate level of wildlife-dependent

public use. Refuge-wide habitat conservation includes

management of native plant communities, restoration

of disturbed areas, removal and revegetation of

unnecessary roads and stream crossings, management

of deer and elk populations, and protection of Preble’s

meadow jumping mouse habitat. Restoration would

strive to replicate pre-settlement conditions and would

use a variety of integrated pest management (IPM)

tools including prescribed fire and grazing. 

Visitor use facilities would include about 16 miles of

trails, a seasonally staffed visitor contact station,

trailheads with parking, and developed overlooks

(Figure 7). With the exception of one trail opened

immediately, restoration would begin before other trails

are opened. Most trails would use existing road

corridors. Public access would be by foot, bicycle, or

horse, with limited car access to two parking areas on

the Refuge. A limited public hunting program would be

developed in collaboration with the Colorado Division of

Wildlife (CDOW). On- and off-site environmental

education programs would focus on the prairie

ecosystem and would target primarily high school and

college students. 

The Service would provide compatible scientific

research opportunities focused on wildlife habitat and

interactions between wildlife and human use.

Partnerships would be sought with federal, state and

municipal agencies and private entities to help achieve

Refuge goals and conserve contiguous lands.

ALTERNATIVE C: ECOLOGICAL RESTORATION

Alternative C emphasizes Refuge-wide conservation

and restoration of large areas of wildlife habitat.

Restoration and management activities would strive to

replicate pre-settlement conditions. Restoration efforts

Figure 5. Rock Creek Reserve Boundary.
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 19

would focus on disturbed areas such as road corridors,

stream crossings, cultivated fields and developed areas

and would use a variety of IPM tools including

prescribed fire and grazing.

Limited public use and minimal facility development

would occur in this alternative (Figure 8). Any

facilities on the Refuge would be built for specific

resource protection and management purposes.

Because of this, office space would be leased off-site.

One trail would provide access to the Rock Creek

drainage. Access would be limited to pre-arranged,

guided tours only. Environmental education programs

would be limited to publication and local distribution of

educational materials about the Refuge and its

ecological resources.

In Alternative C, the Service would facilitate increased

opportunities for applied research relating to long-term

habitat changes and species of special concern.

Partnerships would be expanded with governmental

agencies, educational institutions and others to assist in

wildlife and habitat protection, resource stewardship

and the preservation of contiguous lands.

ALTERNATIVE D: PUBLIC USE

In Alternative D, the Service would emphasize

wildlife-dependent public uses. Wildlife and habitat

management would focus on the restoration of select

plant communities and ongoing conservation and

management of existing native plant and wildlife

species. A variety of IPM tools would be used,

although prescribed fire and grazing would not be

used. Some roads and other disturbed areas not used

for trails or public use facilities would be restored

with native vegetation.

A broad range of public use opportunities would be

provided, including wildlife observation and

photography, interpretation, environmental education

and a limited hunting program (Figure 9). Access

through the Refuge would be provided by a 21-mile

trail system that would accommodate hiking, bicycling

and equestrian use. Most trails would be constructed

along existing roads. A visitor center would be

constructed on the Refuge or at a nearby location.

Environmental education efforts would include onand off-site programs for kindergarten through

college age students.

Research opportunities would focus on the integration

of public use into the Refuge environment and

interactions between wildlife and visitors. Partnerships

would be sought with various public agencies to help

sustain Refuge goals and preserve contiguous lands.

The Service also would work with local communities

and tourism organizations to promote wildlifedependent public uses on the Refuge.

The Front Range mountain backdrop provides a beautiful setting for wildlife observation.

© Shapins Associates
Chapter 2: Alternatives 

20 Rocky Flats National Wildlife Refuge 

Table 2: Summary of Proposed Management Actions

Throughout the site, use a variety of techniques

(including prescribed burning) to restore disturbed

areas, conserve native plant communities and wildlife

populations, and reduce coverage of invasive weeds.

Programs – Access limited to a trail down to Lindsay

Ranch during years 1-5. Following year 5, open Refuge

to general public and provides interpretation and an

organized youth/disabled hunting program. 

Environmental education programs for high school and

college-level students.

Facilities – Hiking, biking and limited equestrian trails

(16.5 miles total). Wildlife viewing blind, overlooks,

interpretive signage, kiosk, visitor contact station and

restrooms.

Same as A plus:

Visitors – Staff and outreach materials would inform

visitors about opportunities and restrictions for access,

and any safety hazards. 

Programs and materials developed to inform the public

about the Refuge’s resources, the NWR System, the

Service’s stewardship role, risk and management issues

and to recruit visitors and support for the Refuge.

Partnerships – More extensive partnerships to address

the conservation of habitat across boundaries, to

interpret cultural resources and to recruit more

compatible scientific research.

Volunteers – Develop a volunteer program to assist

Refuge staff with public use programming and other

refuge operations.

4 full-time employees.

Construct a storage/maintenance building and a contact

station with office space. Maintain the existing stock fence.

Wildlife &

Habitat

Public Use,

Education,

Interpretation

Safety

Open & Effective

Communication

Working with

Others

Refuge

Operations

ALTERNATIVE A — No Action

Continue current habitat and wildlife

management practices that focus on the Rock

Creek drainage. Limit habitat and wildlife

management in other areas to the protection of

existing conditions. Restrict general public

use. Continue limited compatible scientific

research opportunities.

Maintain current conservation and restoration

approaches. Increase weed control and restoration

in the Rock Creek drainage only. 

Programs – Public access permitted by organized

guided tours only. Public use programming limited

to the distribution of a Refuge fact sheet that

outlines the Refuge’s history and its natural and

cultural resources.

No environmental education programming.

Facilities – Public use facility development limited to

a restroom facility.

Staff – Trained staff knowledgeable about the site’s

institutional controls, requirements, and resources.

Visitors – All visitors would remain under the

supervision of Refuge staff. 

Outreach limited to the distribution of a Refuge fact

sheet to interested parties that request information.

Partnership – Maintain relationships with CDOW

and surrounding open space agencies and

landowners.

2 full-time employees.

Renovate existing shed to house tractors and a small

office space. Maintain the existing stock fence.

GOALS ALTERNATIVE B — Wildlife, Habitat, & Public Use

Implement extensive habitat and wildlife

management and conservation focused on the

restoration to pre-settlement conditions.

Accommodate wildlife-dependent public use.

Facilitate compatible scientific research that

focuses on habitats, wildlife, and public use. 

*Preferred Alternative
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 21

Same as B plus:

Institute more extensive restoration and monitoring.

Programs – Access limited by organized guided tours only.

Public use programming limited to the distribution of a

Refuge fact sheet habitat types, wildlife populations and the

Service’s restoration practices and the development of

simple learning materials for high school college educators. 

No environmental education programming.

Facilities – Limited facility development including a hiking

trail (0.6 miles), an overlook with an interpretive sign panel

and a restroom.

Same as A

Same as B

Same as B plus:

Partnerships – Partnerships and research emphasis is on

habitat and wildlife conservation.

Volunteers – Volunteers would assist with restoration and

conservation operations rather than public use

programming.

5 full-time employees.

Construct a storage/maintenance building and lease office

space. Maintain the existing stock fence.

Throughout the site, restore some disturbed areas (no

burning or grazing), conserve native plant communities and

wildlife species, and limit the spread of invasive weeds.

Accept prairie dogs from off-site.

Programs – Greatest amount of public use opportunities

including increased natural and cultural interpretation

programs.

Environmental education programs expanded to serve

kindergarten - college-level students.

Facilities – Extensive facility development including hiking,

biking and equestrian trails (21.2 miles total), wildlife

viewing blinds, interpretive signage, kiosk, outdoor

classroom, visitor center and restrooms.

Same as B

Same as B

Same as B

8 full-time employees.

Construct a larger storage/maintenance building and a visitor

center with office space. Maintain the existing stock fence.

ALTERNATIVE C — Ecological Restoration

Maximize habitat and wildlife management and

conservation focused on the restoration to presettlement conditions. Limit general public use.

Implement compatible scientific research that focuses

on habitat and wildlife.

ALTERNATIVE D — Public Use

Focus habitat and wildlife management on the

restoration of select plant communities and the

conservation of existing native plant communities and

wildlife species. Provide opportunities for a diversity

of compatible public uses. Facilitate compatible

scientific research focused on habitats, wildlife, and

the related impacts of public use.
Chapter 2: Alternatives 

26 Rocky Flats National Wildlife Refuge 

2.3. WILDLIFE AND HABITAT AND PUBLIC USE

MANAGEMENT DESCRIPTIONS

With many miles of trail, thousands of acres of

grassland habitat and a beautiful mountain backdrop,

the Refuge could become a popular destination for

wildlife enthusiasts, naturalists and students within the

Denver metropolitan area. The visitor experience at

the Refuge would be characterized by the Service’s

commitment to providing visitors with an

understanding and appreciation of the flora and fauna

of the prairie ecosystem. The Service’s efforts to

connect visitors to their natural resource heritage

would build upon regional efforts to promote an

appreciation for the grassland environments. 

Given the current cleanup of the Rocky Flats

Environmental Technology Site and the Service’s

commitment to habitat conservation and enhancement,

the Refuge would provide an excellent opportunity to

educate the public about the processes of grassland

restoration and to actively involve them in the

rehabilitation of the landscape. 

WILDLIFE AND HABITAT MANAGEMENT

Preble’s Habitat Management

Riparian and wetland communities at the Refuge

support habitat for a variety of wildlife species,

including the threatened Preble’s meadow jumping

mouse. In all alternatives, the Service would protect

and maintain Preble’s habitat throughout the Refuge.

While meeting the Service’s obligations under the

Endangered Species Act, the protection of Preble’s

habitat also would serve other species that depend on

riparian and wetland communities for survival. 

Alternative A would protect and maintain Preble’s

habitat; Alternatives B, C and D also would direct the

Service to improve habitat for the mouse (and other

riparian species). Part of the riparian habitat

enhancement efforts in Alternatives B, C and D would

be the removal and revegetation of unused roads and

stream crossings. In Alternative A, this revegetation

would only occur within the Rock Creek Reserve.

In all alternatives, the Service would conduct surveys

of Preble’s habitat every 2 to 3 years to detect changes

in size and location of existing populations.

Alternatives B, C and D would expand the surveys to

include monitoring plant diversity in riparian areas.

In Alternatives B and D, where there would be trail

use through some riparian habitat areas, the Service

would seek funding and partnerships to assist in

monitoring the impacts of recreational use on Preble’s

and its habitat.

Xeric Tallgrass Management

The rare xeric tallgrass grassland community, which

dominates the pediment tops in the western portion of

the Refuge, is an important natural resource that needs

special consideration and management. In all

alternatives, the Service would manage the xeric

tallgrass to maintain the extent and improve the native

species composition of this community. The Service

would develop a vegetation management plan to direct

management efforts (including herbicide application,

biological controls, prescribed fire, grazing and

mowing) and would monitor species composition and

weed infestations every few years to ascertain the

effectiveness of management efforts. In Alternative A,

no grazing would be used and prescribed fire would be

limited to the Rock Creek Reserve. Prescribed fire

and grazing would not be used in Alternative D.

Mixed Grassland Prairie Management

Nearly half of the Refuge consists of mixed grassland

prairie communities. While these communities are

relatively common along the Colorado Front Range,

they play an important role in providing habitat for

various wildlife species. Management strategies for the

mixed grassland prairie include the use of prescribed

fire in Alternatives A, B and C and the use of managed

grazing in Alternatives B and C. In the southeast

corner of the Refuge, a former agricultural field has

been planted with non-native grasses. In Alternatives

B and C, the Service would revegetate this and other

disturbed areas with native grassland species that

would improve the extent and diversity of grassland

habitat. In all alternatives, additional management

strategies would be implemented in the mixed

grassland prairie communities according to the

objectives and strategies outlined under weed

management, prairie dog management, habitat

restoration and species reintroduction.

Road Restoration and Revegetation

Rocky Flats currently has over 70 miles of roads, of

which about 50 miles will be under Service jurisdiction.

All of the alternatives call for the removal and

revegetation of roads and stream crossings that would

not be used for maintenance access, fire control, trails,

or other Refuge purposes. The extent of restoration

efforts would be:

• Alternative A (in the Rock Creek Reserve): 12

miles of road; 7 stream crossings
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 27

• Alternative B: 26 miles of road; 13 stream

crossings

• Alternative C: 26 miles of road; 13 stream

crossings

• Alternative D: 24 miles of road; 6 stream

crossings

While Alternative C would have fewer roads and trails

overall, the length of road to be revegetated in

Alternative B is the same as Alternative C because in

Alternative B, a new trail segment would replace the

existing road in the Woman Creek drainage. See

Figures 25 and 26. 

Weed Management

Noxious weeds present a tremendous challenge to the

health and diversity of native plants and wildlife habitat

on the Refuge. Under Alternatives B, C and D, the

Service would control the spread and reduce the

density of diffuse knapweed, Dalmatian toadflax and

Canada thistle during the 15-year timeframe of the

CCP. In Alternative A, this reduction would only occur

within the Rock Creek Reserve; outside of Rock Creek,

the Service would control the spread of weeds, but

would not commit resources to weed reduction. 

Under Alternatives B and C weed management

scenarios would employ a comprehensive IPM

approach, including the use of herbicides, biological

controls, mechanical removal, prescribed fire and

controlled grazing. Weed infestations would be mapped

annually. Prescribed fire and grazing would not be used

in Alternative D and no grazing would occur in

Alternative A. In Alternative A, however, limited

prescribed fire would be used in the Rock Creek

Reserve. Additional methods used in Alternatives B and

C would include informal surveys along roads and trails

and temporary fences to collect tumbleweeds which

disperse seeds with the wind.

Deer and Elk Management

While the sizes and locations of deer and elk

populations at the Refuge are well known, the carrying

capacity of the habitat at the Refuge relative to

population size has not been determined. In all

alternatives, the Service and/or CDOW would

determine a target population for deer and elk on the

Refuge and would seek to manage those levels. Tools to

attain these population goals include culling by Service

and/or CDOW staff. In Alternatives B and D, a limited

public hunting program also would be used.

Managing deer and elk within target population levels

for the Refuge would minimize the potential for

overgrazing and overbrowsing of sensitive riparian

habitat. In all alternatives, the Service would monitor

sensitive areas for such impacts. 

Prairie Dog Management

The short and mixed grassland communities in the

eastern portions of the Refuge provide up to 2,460

acres of habitat for black-tailed prairie dog. About 113

acres of prairie dog colonies were mapped at the

Refuge in 2000. Due to recent plague outbreaks, about

10 of those acres are currently occupied. In all

alternatives, prairie dog populations would be allowed

to expand naturally within their primary habitat areas.

In Alternative A, this expansion would not be limited.

In Alternative B colonies would be limited to 750 acres,

in Alternative C colonies would be limited to 500 acres

and in Alternative D colonies would be limited to 1,000

acres. Alternative D would allow the Service to

evaluate the suitability of accepting unwanted prairie

dogs that are relocated from other jurisdictions; the

other alternatives would not allow prairie dog

relocation onto the Refuge.

Species Reintroduction

The task of restoring native species to the Refuge has

already begun. In 2003, two native fish species that

have been decreasing regionally were introduced into

Rock Creek. Additionally, the CDOW, the City of

Boulder, and Boulder County introduced a population

of sharp-tailed grouse onto their open space properties

north of the Refuge. In all alternatives, the Service

would continue to work with CDOW to facilitate

Prairie dogs would be managed differently under each

alternative.

© Mauro
Chapter 2: Alternatives 

28 Rocky Flats National Wildlife Refuge 

species reintroduction at the Refuge. In Alternatives B,

C and D, the Service would take active steps to

evaluate the suitability of additional species

reintroductions and to complete a management plan for

sharp-tailed grouse reintroduction on the Refuge.

Alternative C would promote the overall goal of

restoring the Refuge environment to pre-settlement

conditions. In Alternative C, the Lindsay Ponds on

Rock Creek, which currently provide habitat for the

reintroduced fish species, would be removed and Rock

Creek restored. 

PUBLIC USE MANAGEMENT

This section offers a preview of the visitor experience

of the Refuge in each alternative. Alternatives A and C

would have limited and controlled access with few

visitors; for Alternatives B and D, the Refuge would be

open to the public for a variety of uses. The three

primary components that will shape the visitor’s

Refuge experience would be public outreach,

interpretation, and public use activities and facilities.

These components are described to illustrate how a

visitor would experience the Refuge. 

The public outreach component describes methods

used to educate the potential visitor about the Refuge,

pique their interest, and recruit them to participate in

public use programs. The interpretation component

identifies critical stories to be told and the natural and

cultural resources that will become the basis for

educational and interpretive activities. How visitors

access the site, what activities they enjoy, where they

travel and what facilities they encounter are outlined in

the public use activities and facilities component. 

Public Outreach

Improving public perception of the Refuge by

informing visitors about the site’s natural resources

and addressing safety concerns is essential to the

development of successful public use programs. Past

concerns about contamination, radiation exposure and

other environmental risks have fostered apprehension

about visiting the Refuge. The Rocky Flats site has

been closed to the general public for over 50 years and

the lack of access opportunities has also contributed to

fearful speculation about the site’s condition. 

In an effort to assuage public safety concerns, the

Service would develop public outreach programs in all

alternatives. The Service would attempt to build a

stronger base of public understanding, support and

stewardship within the Denver metropolitan area

through a variety of outreach methods.

Communication

The “Open and Effective Communication” goal

(described in Chapter 1) is driven by the Service’s

commitment to provide the public with clear

information about the safety of the site, instill

confidence in the Service’s ability to provide safe visitor

experiences and to develop community support for the

Service’s programs and management policies. In

response to the concerns raised during public scoping

regarding the site’s history and contamination, the

Service sees the value in developing a communication

goal to guide public outreach efforts. The goal clearly

emphasizes the importance of educating the public

about the Refuge, the Service and the NWRS.

With the exception of Alternative A (only limited public

outreach), all alternatives would include the

development of a variety of public outreach methods to

inform the public about environmental stewardship,

risk communication, CCP implementation, and the

mission of the Service and the NWRS. For example, a

visitor may learn about the Refuge and opportunities to

visit the site through media coverage, newsletters and

flyers, or by attending community events. To reach a

broad range of people, the Service would coordinate

with local partners to participate in community events

and provide input on local environmental issues. The

outreach efforts would be instituted during the first

year of the Refuge’s establishment and would be

ongoing throughout the life of the CCP. Public outreach

efforts in Alternative A would be limited to the

distribution of a Refuge fact sheet to interested parties

that request information.

Alternatives B and D would have environmental 

education programs.

© USFWS
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 29

Interpretation

The goal of the interpretive programs at the Refuge is

to inform the public about the Rocky Flats site,

educate about resident wildlife and their habitats, and

cultivate a stewardship ethic. Committed to fostering

an appreciation of the Refuge’s natural resources, the

Service developed interpretive themes that focus on

wildlife, wildlife habitat and the site’s history. Providing

the public with interpretive information would enhance

the public’s understanding of their surrounding natural

environment and increase support for the Service’s

habitat conservation efforts. Alternatives B and D

would include substantial interpretive programming

and signage. Alternative C would contain minimal

signage. Alternative A would not include interpretive

programs or facilities.

Interpretive Themes 

Interpretive themes would provide a basis for the

development of public use activities and facilities in

Alternatives B, C and D. The themes capture the

essence and importance of ideas, concepts and features

that emerged from the Service’s review of the Refuge’s

natural and cultural resources. 

The four themes represent the central messages that

the Service wants to convey to visitors. The themes

provide the foundation for all interpretive

programming and facility development. Each theme is

summarized by a simple statement and supported by

several subthemes. Linked specifically to certain

resources, the subthemes further define the stories

about Refuge resources and the Service’s role in

transforming the site (Table 3). 

Interpretive Facilities

In Alternatives B and D, a variety of facilities would

be developed to help the visitor better understand the

interpretive themes. The primary interpretive

facilities would be signage, displays and a Refuge

website. Facility development in Alternative C would

be limited to an interpretive sign panel at the Rock

Creek overlook. 

Table 3. Interpretive Themes

Theme: Habitat Restoration: “Diverse wildlife populations require healthy plant communities.”

Theme: Wildlife: “Wildlife take refuge at Rocky Flats.”

Theme: Wildlife and People: “Wildlife comes first.”

Theme: History: “Native Americans, settlers and the DOE all used Rocky Flats. Today, it is protected for wildlife.”

Plants for Wildlife: Riparian and prairie plant communities including the rare

xeric tallgrass and tall upland shrublands provide shelter and food for wildlife.

Battling Invasive Weeds: Invasive weeds crowd native plants and degrade habitat

at the Refuge and throughout the West.

Restoring the Prairie: Restoring and maintaining the native prairie requires a

variety of tools and techniques. 

Subthemes: Explore the various types of

habitat at the Refuge and promote

visitors’ awareness, understanding and

appreciation of both the prairie ecosystem

and the Service’s restoration efforts.

Home to Wildlife: Refuge wildlife forage and nest in the grasslands, occupy the

riparian areas and migrate to and from adjacent open space lands.

Threatened and Endangered Species: Preble’s meadow jumping mouse, a

threatened species, resides in the riparian habitat found at the Refuge.

Returning to the Prairie: Reintroducing prairie species to the Refuge boosts

biodiversity and creates unique viewing opportunities.

Subthemes: Explore the relationships

between habitat types and the kinds of

wildlife they support.

Watchable Wildlife: Viewing wildlife in a natural setting.

Respecting Wildlife: While an enjoyable activity, wildlife observation requires

respect and consideration for wildlife. 

Subthemes: Explore how wildlife and

people co-exist and how both will benefit

from habitat restoration and conservation.

Prehistoric Prairie Settlement: Native American activity on the plains – describing

settlements, hunting and day-to-day survival on the prairie.

Settling the Frontier: Homesteading on the Great Plains and the establishment of

the Lindsay Ranch.

Plutonium Trigger Production: DOE’s development and management of a nuclear

weapons production site and the cold war history. The Service will work in

collaboration with the Cold War Museum to tell the story of the site as a nuclear

production site.

A Renewed Purpose: DOE’s cleanup and closure of the production site and the

Service’s ongoing efforts to restore and conserve the prairie in order to provide

habitat for wildlife and wildlife-dependent public uses.

Subthemes: Interpret the historical

periods that have shaped the site and

how generations have managed to

survive in the harsh climactic conditions

of the prairie landscape.
Chapter 2: Alternatives 

30 Rocky Flats National Wildlife Refuge 

Signage/Displays: Signs and displays varying in

design would help illustrate the historical and natural

stories of the Refuge. Listed below are the types of

signage a visitor would find upon entering and

exploring the Refuge:

• Roadside and Boundary Signs: Signage is

needed to notify people of the Refuge’s

location and direct visitors to the Refuge. In

all alternatives, a refuge entrance sign

would be placed outside the main entrance

along Highway 93, and the exterior

boundary would be posted with standard

NWR boundary signs. All alternatives also

would include small, metal boundary signs

along the fence line.

• Interpretive Signs: Located at all trailheads

and in selected spots along trails, small

signs would display a map and/or

interpretive facts about a specific location or

topic. Trailhead signs would include

information about the site’s history, clean up

and access restrictions.

• Interpretive Sign Panels: Larger signs at

the Rock Creek and Highway 128

(Alternative D only) overlooks, the contact

station/visitor center, and Lindsay Ranch

would display interpretive information about

the Refuge’s resources and/or visitor

orientation information.

• Directional Signs: Located at select trail

intersections, signs would provide visitors

direction and announce trail rules 

and regulations.

• Visitor Kiosk: Located outside the contact

station/visitor center in Alternatives B and

D, the kiosk would consist of three panels

fastened to a wooden structure. The kiosk

would provide orientation, regulatory and

interpretative information for visitors

entering the Refuge. 

• Interpretive Displays: Within the contact

station/visitor center, Alternatives B and D would

have both permanent and changing displays that

highlight the Refuge’s natural resources.

Website: In Alternatives B and D, a Refuge website

would provide a reference resource for students and the

general public to learn from their classroom and/or home

computer fun facts about the Refuge as well as scientific

data related to the grassland ecosystem and its wildlife.

The website would serve several education levels.

Interpretive and Environmental Education Programs

Outlined below are general descriptions of the types of

interactive and field-based interpretation and

educational activities for each alternative. Directly tied

to the interpretive themes, the programs would bolster

environmental awareness and appreciation by

highlighting the natural features and history of the

Refuge. Refuge staff would develop and run the

programs with the assistance of volunteers. Programs

would be tailored to attract a diversity of visitors and

the types of programs and their topics would change

seasonally. The programs listed below apply to

Alternatives B and D except where noted. 

• Guided Tours: Included in all alternatives

although tours in Alternatives A and C

would be very limited and would be prearranged with Service staff. Refuge staff or

a volunteer would lead interpretive walks

that focus on wildlife, habitat needs, or the

site’s other natural and cultural resources.

Tours would highlight unique characteristics

of the site and identify the interrelationship

Under Alternatives B and D, volunteers would have

an opportunity to be involved in many aspects of

refuge operations.

© USFWS
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 31

between prairie plant communities and

wildlife populations. 

• Nature Programs/Presentations:

Conducted either in the field, in surrounding

communities, or in the visitor center,

presentations would offer an in-depth

explanation of a specific topic. To the extent

possible, Refuge volunteers and/or partners

would lead these programs/presentations.

• Hands-On Work: Programs developed to

recruit volunteer participation in prairie

restoration may include seed collection,

weed removal, or seeding. The work

activities would include information sessions

on restoration techniques and the benefits of

restoring prairie habitat. Volunteers also

may be involved with Refuge enhancement

projects such as trail construction and

general maintenance.

• Teacher Resource Guides and Workshops:

Refuge staff would develop teacher

resource guides that present the necessary

information for teachers to conduct their

own environmental education programs at

the Refuge. The guides would meet

Colorado’s model content standards and

would likely include pre-visit activities, onsite activities, post-visit activities and

assessment activities. Additionally, the

Service would sponsor teacher training

workshops to familiarize local educators

with the Refuge’s resources. 

Public Use Activities and Facilities

Although guided by a “Wildlife First” mission that

promotes the “conservation, management and where

appropriate, restoration of the fish, wildlife and plant

resources and their habitats,” the Refuge System is

also committed to investing in public use facilities and

programs that foster an appreciation of the Refuge’s

natural resources. By raising public awareness and

understanding of the prairie habitat and wildlife, the

Service hopes to cultivate a land stewardship ethic

among visitors.

Access

In all alternatives, access to the site would be obtained

via a two-lane road off of Highway 93. In Alternatives

A and C, access would be pre-arranged with the

Service and the visitor experience would be limited to a

guided tour with Refuge staff. In Alternatives B and D,

the access road would direct visitors to orientation

information, trailheads and parking areas. 

To tie into surrounding existing and proposed trail

systems, Alternatives B and D would include additional

access points located on the north, east and south

boundaries of the Refuge. Strategically located to

provide links to proposed trail networks, the secondary

access points along the Refuge boundary would permit

visitors to enter the site on foot, bike and in some cases

by horse. In these two alternatives, the Refuge would

remain open from sunrise to sunset.

Because visitors in Alternatives B and D would be able

to enter the site from a number of access points, each

entry would serve as a “use portal” where signage would

inform users about the distinction between where they

came from (e.g., municipal open space) and where they

are going (a National Wildlife Refuge). In addition to

clarifying access opportunities and restrictions and

information on the site’s history and cleanup, the

signage would inform visitors to the conservation

practices and priorities that may differ from

surrounding open space areas. 

Wildlife-Dependent Public Uses

The four alternatives would present a spectrum of

wildlife recreation opportunities ranging from guided

tours, to hiking, to interactive interpretation programs.

While visitors in Alternatives A and C would be guided

through the site, visitors in Alternatives B and D would

explore and learn about the site independently with the

aid of interpretive facilities including signage, kiosks

and printed materials. Through the careful siting of

trails and the design of visitor use facilities, it would be

Wildlife observation is a priority wildlife-dependent possible to shape the Refuge environment so that it

public use.

© Mauro
Chapter 2: Alternatives 

32 Rocky Flats National Wildlife Refuge 

invites exploration and reveals natural processes while

minimizing impact to sensitive areas. Interpretive and

educational programs would promote appreciation of

the ecology of the prairie environment and inspire a

greater appreciation for the Front Range’s remaining

grassland habitat. Dogs and other pets would not be

permitted on the Refuge in any of the alternatives. 

Wildlife-dependent public uses that would be made

available to visitors in each alternative are as follows.

Alternative A

All public access would be pre-arranged with the

Service prior to entering the Refuge. In Alternative A,

the visitor experience would be restricted to a guided

driving and/or walking site tour and opportunities to

view or photograph wildlife would be incidental. The

Service tour guide would interpret the Refuge’s

resources throughout the site tour. 

Alternative B 

The visitor experience in Alternative B would include

opportunities for the public to engage in hunting,

wildlife observation, photography, interpretation and

environmental education. The public use activities

would be carefully managed to avoid harmful impacts

to wildlife and their habitat. Because the Service would

focus on restoration and facility development during

the first 5 years of Refuge operation, most of these

activities would not be instituted until the Refuge is

fully open to the general public (by year 6).

• Hunting: A highly controlled youth and/or

disabled hunting program would be held a

few weekends a year. This program would

allow youth and disabled individuals to hunt

deer and elk with the assistance of Service

staff (and Refuge partners) in a safe

environment where they would have

reasonable harvest opportunities. If

necessary, the Service could consider

expanding the hunting program to include

the general public (depending on wildlife

management needs). During special hunting

weekends, the Refuge would be closed to all

other visitors.

Limited hunting, wildlife observation and photography would be included in Alternatives B and D.

© Mauro
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 33

• Wildlife Observation and Photography:

Trails, blinds and overlooks would provide

numerous vantage points for observing

wildlife. Naturalists, photographers and

other wildlife enthusiasts would also enjoy

opportunities to view and photograph

wildlife off-trail (between October and May

in areas south of Woman Creek). 

• Interpretation: Upon entering the Refuge,

visitors would find signage, maps and

interpretive panels outside a visitor contact

station. Interpretive and informational

materials at trailheads, overlooks, and the

contact station would educate visitors about

specific site resources such as grassland

restoration, early settlement of the prairie

and wetland ecology.

• Volunteers: A volunteer program would be

developed to provide support for Refuge

staff. Volunteers would assist with orienting

and educating visitors. Any visitor

interested in learning more about the

Refuge and, in turn, improving the Refuge

experience for others would have the

opportunity to volunteer. 

• Environmental Education: Throughout the

life of the CCP, the target audience for onand off-site environmental education

programs would be high school and

college-level students. During the initial

years of Refuge establishment (years 1

through 5), students would be encouraged

to engage in research-oriented and

independent study. Following year 5,

guided tours and other nature programs

would be designed to explore the site’s

natural and cultural resources and foster

an understanding and lasting appreciation

for the prairie environment.

Alternative C

In Alternative C, the Refuge staff would lead visitors

on guided walking tours along a trail leading to the

Rock Creek overlook. Upon request, the Refuge staff

also could conduct guided auto tours that would provide

opportunities to observe a diversity of habitat types.

Limited public access opportunities would be made

available upon Refuge establishment. Wildlife

observation, photography and interpretation would be

incorporated into the tour at the discretion of the

Service guide. No hunting or environmental programs

would be developed. 

Public access would be restricted in Alternative C;

however, guided tours would seek to enhance a visitor’s

appreciation of the Refuge’s resources. The Rock

Creek overlook offers views of a variety of habitats

including riparian, wetland, xeric tallgrass and upland

shrub. The overlook and hike also would reveal the

Service’s ongoing restoration efforts including road

removal, stream crossing restoration, and re-seeding of

the historic Lindsay Ranch landscape. The overlook’s

elevated perch on the pediment above Rock Creek

would provide impressive distant views to the Rocky

Mountain foothills and the Indian Peaks. 

Alternative D

Among the alternatives, Alternative D would offer the

greatest amount of wildlife-dependent public uses.

The Refuge would be open to the general public about

6 months to 1 year after Refuge establishment,

although it is likely that some of the facility

development and programming would be phased in

over the course of the CCP. Public use activities that

would be offered in addition to those described above

in Alternative B include:

• Wildlife Observation and Photography: A

more extensive trail system in concert with

additional wildlife blinds and overlooks

would increase opportunities for visitors to

view and photograph wildlife. 

• Volunteers: A larger volunteer force

would allow for the development of

additional interpretive programming. The

Most of the trails would be converted from existing roads.

© Shapins Associates
Chapter 2: Alternatives 

34 Rocky Flats National Wildlife Refuge 

volunteers would be available to educate

visitors and host workshops, tours or

lectures. Enrollment in the volunteer

naturalist program would be open to the

public and would entail training by

Service staff on how to interpret the site’s

natural resources. 

• Interpretation: Alternative D would have

the same programming as Alternative B,

but would have more facilities including a

visitor’s center and an outdoor education

facility. Located just inside the Refuge

entrance, a visitor center would attract

visitors, provide a central location for

visitor orientation and display

interpretive exhibits. 

• Environmental Education: The audience

for educational programming in this

alternative would be expanded to include

K-8th graders as well as high school and

college level students.

Other Public Uses

In Alternatives B and D, visitors would have the

opportunity to bike and ride horses on some of the

Refuge’s multi-use trails. Although biking and

equestrian uses are not priority public uses, they

would provide means for visitors to access the

Refuge’s interior to observe wildlife and explore the

prairie landscape. 

Alternative B

Biking would be allowed on all multi-use trails, but

equestrian use would be limited to the multi-use trails

in the southern half of the site. The southern multi-use

trails would provide equestrians with links to adjacent

trail systems in Westminster, Broomfield and Arvada.

Off-trail use would be permitted seasonally in the

southern half of the Refuge. Off-trail use would provide

visitors with increased opportunities to view wildlife

and to explore the grasslands.

Alternative D

All multi-use trails would be open to equestrian and

biking use. Off-trail use would be permitted seasonally

in the southern half of the Refuge. Off-trail use would

provide visitors with increased opportunities to view

wildlife and to explore the grasslands.

A future trail would follow the road corridor down to the Lindsay Ranch barn in Alternatives B and D.

© Shapins Associates

A pedestrian trail would overlook the Rock Creek drainage.

© Shapins Associates
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 35

Facilities 

The types and scale of public use facilities would vary

considerably in the four alternatives. Alternatives B

and D contain the greatest amount of facility

development. Facility development in Alternative A

would be limited to a portable restroom. In Alternative

C, facility development would consist of one trail, an

overlook and a restroom. The trail system in

Alternatives B and D would be planned to provide

access to a variety of habitat types and to facilitate

wildlife observation. 

Alternative A

Other than providing a portable restroom, no public

use facilities would be developed. Visitation to the

Refuge would be by arrangement only and visitors

would most likely be taken on auto tours along the

access roads. 

Alternative B 

Facility development within Alternative B would

carefully balance opportunities for visitors to explore

the prairie with habitat conservation. Facility

development would include trails, trailheads, overlooks,

information kiosks, viewing blinds, contact station (with

restrooms) and parking areas. 

For the first 5 years of Refuge establishment, the site

would only be open to the general public at scheduled

times and one trail (1.75 miles) to Lindsay Ranch would

be open to pedestrians. The initial trail would extend

from the parking area to the Rock Creek overlook and

make a loop within the Rock Creek drainage. 

Outlined below are all facilities that would be 

developed and open to the public 5 years after the

Refuge is established:

• Trails: Approximately 12.8 miles of multi-use

trails and 3.8 miles of pedestrian-only trails

would be developed. The majority of the

trails would follow converted road corridors

away from riparian areas. Trails within the

Rock Creek drainage and other sensitive

areas would be subject to seasonal closures

as needed to protect wildlife. Looped

pedestrian-only and multi-use trails as well

as connections to adjacent trail systems

would accommodate a variety of trail users. 

• Kiosk: Within a kiosk located outside the

contact station, visitors would find maps of

the trail system, rules and regulations, and

information on Refuge wildlife and habitat.

The kiosk would consist of three sign panels

hung on a wooden structure. The kiosk

would be accessible to all visitors when the

contact station is closed. During the early

years of refuge establishment when access

is limited and before development of the

contact station, the kiosk will provide

information on current and future public

use opportunities.

• Equestrian Uses: Only multi-use trails in

the southern portion of the site would be

open to equestrian uses. Hitching posts

would be located near the contact station,

allowing equestrian users to hike to

Lindsay Ranch.

• Trailheads: All entries to the Refuge trail

system would be posted with signage that

clearly demarcates the visitor’s entry into a

National Wildlife Refuge. 

• Overlook: Three overlooks would provide

views of the site and the outlying landscape.

The overlooks would be simple and

designed to fit into the prairie landscape.

They would likely entail a graded, gravel

area sited for its nearby and distant views.

The Rock Creek and Highway 128

overlooks would feature interpretive sign

panels. Benches at the Woman Creek and

Rock Creek overlooks would provide a

resting point for visitors.

• Blinds: Wildlife viewing blinds would be sited

to optimize observation opportunities. The

blinds would be designed to blend in with

the surrounding landscape and minimize

disturbances to wildlife. 

Future trail corridor leading to the Woman Creek overlook.

© Shapins Associates
Chapter 2: Alternatives 

36 Rocky Flats National Wildlife Refuge 

• Parking: Four parking areas (spaces for about

54 cars and one bus) would be constructed. The

largest parking lot (30 spaces) would be located

at the entry drive terminus and adjacent to the

contact station. This main parking area would

be designed to accommodate horse trailers. An

additional parking lot (20 spaces) would be

situated on the site’s northern edge with

convenient access from Highway 128. Pull-offs

along the main access road, south of the visitor

contact station, and along Indiana Street would

provide additional parking spaces (3 to 4

spaces each) for visitors using trails in the

southern portion of the Refuge. All parking

areas would be gravel and enclosed by a post

and beam fence. 

• Restrooms: Restrooms would be located near

and/or within the visitor contact station.

• Contact Station: A small structure

(approximately 750 to 1,000 square feet)

would house an interpretive display and staff

office space. The contact station would be the

primary orientation point for visitors where

they would collect information about the

Refuge. The station also would serve as the

meeting ground for guided tours and other

Refuge programs. Located outside the main

parking area, the contact station would be

staffed seasonally (e.g., weekends from May

through October), to provide visitor contact

with Refuge staff. 

Alternative C

Public access would also be “by arrangement only”

and facility development would be minimal. There

would be no designated parking areas, blinds or visitor

contact station. 

• Trails: Under the supervision of a tour guide,

visitors would be able to experience the

Refuge on foot. The approximately 0.75 mile

soft surface pedestrian trail would lead

visitors to an overlook on top of the

pediment. The trail would be built along a

converted road.

• Overlook: One overlook would be located

above the Rock Creek drainage. 

• Restroom: Toilets would be located at

the trailhead. 

Alternative D

Alternative D would involve the greatest degree of

public use facility development. This alternative would

build on the facilities included in Alternative B and

include a more extensive trail system, more

parking/trailheads, facility development, a visitor

center and additional blinds and overlooks. Listed

below are facilities that would be built in addition to

those included in Alternative B:

• Trails: The trail system would expand

slightly on the trail routes planned for

Alternative B with the addition of 3.8 miles

of trails (21.2 total – 14.9 multi-use and 6.3

pedestrian-only).

• Equestrian Trails: All multi-use trails would

be open to equestrian use. Hitching posts

would be located at the parking areas

designed to accommodate horse trailers and

at the Rock Creek overlook.

• Trailheads: With trailheads on the east,

west and north sides of the Refuge and a

trail connection with Arvada trails to the

south, Alternative D would provide several

access points and trail linkages. All entries

to the Refuge trail system would be posted

with signs that clearly demarcate entry

into a National Wildlife Refuge. 

• Overlooks: An additional overlook (four

total) would be located in the northwest

corner of the Refuge along Highway 128.

This roadside overlook would allow

potential visitors to pull over and view the

Rock Creek drainage from the Refuge’s

northern boundary. All overlooks would be

identical in design to those in Alternative

B and would include interpretive sign

panels and benches. 

• Blinds: A second wildlife

observation/photography facility would be

located in an optimal viewing location. 

• Outdoor Classroom: A “living classroom” would be

designed to accommodate up to 60 students. The

structure would comprise a 1,000-square foot,

primitive shelter over a hard surface, with tables and

benches to accommodate students. Also included

would be 100-square feet of enclosed storage for

education materials and moveable furniture. Programs

conducted at the classroom would actively engage

students in the exploration and study of the prairie.
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 37

A

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GOAL 1: WILDLIFE AND HABITAT MANAGEMENT

PREBLE’S HABITAT MANAGEMENT

Preble’s surveys

As needed, exclude ungulates from Preble’s habitat

Monitor effects of recreation on Preble’s

XERIC TALLGRASS MANAGEMENT

Vegetation Management Plan

Monitor species composition

Use restoration tools to stimulate growth

- Potential use of prescribed fire

- Potential use of grazing (cattle)

MIXED GRASSLAND PRAIRIE MANAGEMENT

Restore hay meadow to native prairie

ROAD RESTORATION AND REVEGETATION

Revegetate unused roads 

Monitor restoration success

WEED MANAGEMENT

Develop Integrated Pest Management Plan

Control weeds with biological controls and herbicides

Potential use of grazing to control weeds

Potential use of prescribed fire to control weeds

Interior fencing to collect tumbleweeds

DEER AND ELK MANAGEMENT

Establish target populations

Use population control methods 

- Culling

- Public hunting

Monitor for effects of overpopulation

Protect movement corridors

Monitor fawns

PRAIRIE DOG MANAGEMENT

Limit expansion of colonies

Monitor size and location of colonies

Exclude from Preble’s habitat

Consider relocations from off-Refuge

Monitor for plague

SPECIES REINTRODUCTION

Introduce/monitor sharp-tailed grouse

Complete grouse management plan

Monitor native fish reintroduction

Table 4. Objective and Strategy Overview z = Activity is proposed for that alternative

 = Magnitude of activity varies

A L T E R N A T I V E S

2.4 OBJECTIVE AND STRATEGY OVERVIEW

The following table provide a general overview of the

activities that are proposed in the CCP alternatives.

The table does not include all of the Refuge

management activities and does not represent all of

the objectives and strategies. Detailed descriptions of

all of the proposed management actions are presented

in this chapter. 
Chapter 2: Alternatives 

38 Rocky Flats National Wildlife Refuge 

D

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A L T E R N A T I V E S

GOAL 2: PUBLIC USE, EDUCATION AND EDUCATION

PUBLIC ACCESS

Guided tours by arrangement

Open public access

Hiking trails

Allow bicycles and horses on some trails

INTERPRETATION AND ENVIRONMENTAL EDUCATION

Implement on-site interpretive programs

Education programs for school students

Construct outdoor classroom

HUNTING

Allow youth/disabled hunting

RECREATION FACILITIES

Trails

Overlooks

Wildlife viewing blinds

Visitor contact station

Visitor center

GOALS 3, 4 and 5: SAFETY, COMMUNICATION, 

AND PARTNERSHIPS

STAFF AND VISITOR SAFETY

Staff orientation/first aid training

Develop a Health and Safety Plan

Brief all visitors on safety issues

Provide safety information

OUTREACH AND EMERGENCY RESPONSE

Distribute Refuge fact sheet

Use several hands-on outreach methods

Coordinate with other agencies

CONSERVATION AND RESEARCH

Coordinate with other agencies 

Partner to maintain wildlife corridors

Prioritize research needs

VOLUNTEERS

Create and implement volunteer program

GOAL 6: REFUGE OPERATIONS

STAFFING

Share staff with Rocky Mountain Arsenal

Biological staff 

Public use staff

Fire staffing

Law enforcement staff

MANAGEMENT FACILITIES

Storage/maintenance facility

Small office space on-site

Prepare fire cache

CULTURAL RESOURCE MANAGEMENT

Develop Historic Preservation Plan

Stabilize Lindsay Ranch barn

Survey following prescribed fire
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 39

2.5. OBJECTIVES AND STRATEGIES

The objectives and strategies are the specific actions

that the Service would implement to achieve the goals

of the Refuge. An objective is a general statement

about what the Service wants to achieve on the

Refuge, while a strategy is a specific action, tool,

technique or combination of the above used to meet

objectives. Because each alternative has a different

emphasis, the objectives and strategies would vary by

alternative. The following sections provide the

objectives and strategies for each alternative. In

each alternative, the objectives and strategies are

arranged by the six goals discussed under the Goals

section in Chapter 1. Several goals were subdivided

into topics. For example, Goal 1 addresses wildlife and

habitat management. Objectives and strategies within

this goal were developed for species reintroduction,

deer and elk management, prairie dog management

and other topics. 

An overview of the management activities that would

occur under each alternative is illustrated in Table 4. A

detailed summary of the objectives and strategies for

each alternative are summarized in Table 6 and the end

of Chapter 2. 

Detailed descriptions of all the proposed management

actions are located in the text that follows. 

GOAL 1. WILDLIFE AND HABITAT MANAGEMENT

Conserve, restore and sustain biological diversity of

the native flora and fauna of the mountain/prairie

interface with particular consideration given to

threatened and endangered species.

The Refuge supports about 250 species of wildlife and

several rare or sensitive plant communities. While

some of these species and communities have specific

management requirements that are directly addressed

in the following objectives, there are many others that

are not specifically addressed. These include animals

such as the short-horned lizard and red-tailed hawk

and rare plants such as the tall upland shrubland

community and forktip three awn. The Service will

address these species and communities by focusing on

sustaining and improving the habitat conditions that

support their life processes. For example, the

protection and improvement of Preble’s meadow

jumping mouse habitat (Objective 1.1) would benefit

many other species that depend on riparian areas for

survival, as well as wetlands and the tall upland

shrubland community. Weed management strategies

(Objective 1.5) would improve habitat conditions for

numerous grassland-dependent species, including the

short-horned lizard, various ground nesting birds and

small mammals, and some rare plants such as the

forktip three awn.

While it is not outlined specifically in the objectives,

the Service would continue to informally monitor

general wildlife populations and rare plant

communities on the Refuge. In addition, the Service

would work with CDOW, the Colorado Natural

Heritage Program, area universities and other

partners to ensure that general wildlife and rare

plants that are not directly addressed in the objectives

are protected and managed on the Refuge.

Objective 1.1—Preble’s Habitat Management

Background

As the only known federally listed species that resides

on the Refuge, it is the Service’s responsibility to

protect and conserve the threatened Preble’s meadow

jumping mouse and its habitat. The life history of this

species has not been studied thoroughly. What has

been gleaned from habitat studies is that the species is

a habitat specialist relying on well-developed shrubdominated riparian vegetation. Not only riparian areas

are utilized; upland shrub and grasslands provide

travel corridors, nest sites and forage. The

replacement of native vegetation by noxious weeds and

excessive grazing is shown to reduce the quality and

quantity of suitable Preble’s habitat (Compton and

Hugie 1993).

Alternative A

Beginning in the first year and throughout the life of

the CCP, protect about 1,000 acres of Preble’s habitat

on the Refuge. 

Rationale: The Service is obligated by law and agency

policy to protect Preble’s habitat where it exists

Preble’s meadow jumping mouse is a threatened species

found on the Refuge.

© Mauro
Chapter 2: Alternatives 

40 Rocky Flats National Wildlife Refuge 

throughout the Refuge. Currently, about 1,000 acres of

riparian, wetland and adjacent grassland habitat areas

have the potential to support Preble’s. In Alternative

A, the Service would manage these areas to prevent

the degradation of Preble’s habitat on the Refuge. 

Strategies:

1.1.1 – Every 2 to 3 years, survey each drainage for

the presence/absence and abundance of Preble’s using

live-traps in randomly selected linear transects

parallel to the stream, recording dominant vegetation

type at trap locations (Kaiser-Hill 2001).

1.1.2 – Allow natural revegetation of native species on

lightly used roads in Preble’s habitat including

unimproved stream crossings.

1.1.3 – While the species is under the consideration of

the ESA, consult with the Service’s Ecological

Services field office on actions potentially adversely

affecting Preble’s. 

1.1.4 – Develop habitat-sensitive weed management

strategies for use in Preble’s habitat areas. 

1.1.5 – Control noxious weeds in Preble’s habitat to

prevent an increase in weed distribution and density

using IPM tools (biological, mechanical, chemical

applications and limited prescribed fire).

Alternative B

Beginning in the first year and throughout the life of

the CCP, protect Preble’s habitat, maintaining and

improving approximately 1,000 acres of Preble’s

habitat on the Refuge.

Rationale: In Alternative B, the Service would place a

priority on the protection and improvement of riparian,

wetland and adjacent grassland habitat that have the

potential to support Preble’s. Preble’s have evolved

with grazing and browsing by ungulates, especially

deer, and under normal circumstances should not be

impacted by ungulate behavior. If, however, Refuge

deer become overpopulated, over grazing/browsing

within riparian areas has the potential to adversely

affect Preble’s habitat in isolated areas.

Strategies:

1.1.1 – Establish permanent transects in each stream

drainage and survey these transects every 2 to 3

years for the presence/absence and abundance of

Preble’s using live-traps in linear transects parallel to

the stream, recording dominant vegetation type at

trap locations (Kaiser-Hill 2001; Burnham et al. 1980).

Establish exclosures to determine a baseline level of

browsing and grazing.

1.1.2-1.1.5 – Same as A.

1.1.6 – If necessary, protect Preble’s habitat by using

fencing and ungulate population control to exclude

grazing/browsing animals if the quality of the habitat

is threatened.

1.1.7 – Seek partnerships and funding for the

performance of biannual surveys for the presence and

distribution of Preble’s in areas where existing and

proposed Refuge recreational trails cross Preble’s

habitat using live-trapping in grid patterns that

encompass the stream and uplands. Record level and

type of recreation use in the Preble’s survey areas. 

1.1.8 – Manage for species recovery as indicated in the

Service Recovery Plan (in draft 2003).

Alternative C

Same as B.

Rationale: Same as B.

Strategies:

1.1.1 – Every 3 years survey established trapping

transects using line intercept method for foliage

density, foliage height diversity and plant species

diversity (Kaiser-Hill 2001; Burnham et al. 1980) in

the riparian woodlands, riparian and tall upland shrub

communities in Preble’s habitat. Record dominant

vegetation type at trap locations.

1.1.2-1.1.5 – Same as A.

1.1.6 – Same as B.

1.1.8 – Same as B.

Alternative D

Same as B.

Rationale: Same as B.

Strategies:

1.1.1– Same as B.

1.1.2-1.1.4 – Same as A.

1.1.5 – Control weeds by biological control and spot

mechanical and chemical application each growing

season to prevent an increase and density of

infestation in Preble’s habitat. 

1.1.6 – Same as B.

1.1.7 – Establish a monitoring plan to determine the

effect of trails and recreation activity on Preble’s.
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 41

Objective 1.2—Xeric Tallgrass Management

Background

Xeric tallgrass prairie is a rare vegetation community

type that would be protected, maintained and

restored in suitable locations. Tallgrass prairie

evolved with the natural processes of fire and grazing,

which are important in supporting and invigorating

the prairie ecosystem. The disruption of these natural

processes renders the prairie community prone to the

establishment of noxious weeds that often outcompete native plants. Infested native plant

communities are reduced in their capacity to support

native wildlife populations. A variety of techniques are

needed to restore healthy, balanced native

communities. IPM involves using techniques that

simulate natural processes and could include:

prescribed fire; revegetation with native species;

mechanical control methods such as mowing, root

grubbing and hand pulling; chemical applications;

grazing; and biological agents. 

As IPM tools, prescribed fire and grazing are useful in

helping to control weeds, reduce plant litter, recycle

nutrients and improve the overall health and vigor of

the native grasslands. Prescribed fire would be

conducted considering state air quality regulations,

ecological timing (to maximize benefits to desirable

species and effectiveness in controlling weed species),

weather conditions and operational logistics. Grazing

for ecological restoration purposes would likely consist

of managed cattle for short periods of time to simulate

natural processes and invigorate native grasses

(grazing for the specific purpose of weed control is

typically conducted using goats). Monitoring of these

treatments and their effectiveness would allow the

Service to adapt and alter techniques to improve longterm effectiveness.

Alternative A

Manage the existing extent (about 1,000 acres) of the

xeric tallgrass prairie within the Rock Creek Reserve

using IPM strategies (as described in Objective 1.5 -

Weed Management).

Rationale: In Alternative A, the focus would be on

controlling weeds throughout the 1,000 acres of xeric

tallgrass within the Rock Creek Reserve. In other

parts of the Refuge, xeric tallgrass management would

be limited to general weed management, as described

in Objective 1.5 - Weed Management. Prescribed fire

within the Rock Creek Reserve would be conducted to

stimulate native plant growth, reduce plant litter, and

help control weeds in the xeric tallgrass community. 

Strategies:

1.2.1 – Within 2 years, produce a long-term vegetation

management plan that identifies detailed strategies

for weed management, restoration and xeric tallgrass

prairie species composition to be attained by the end

of the CCP.

1.2.2 – Throughout the growing season, conduct

informal monitoring of grasslands for noxious weeds.

1.2.3 – At a minimum, every 3 years survey selected

vegetation point intercept transects to determine

ground cover, vegetation density, species and species

richness, document effectiveness of weed control,

assess impacts of disturbance on plant communities,

track ratio of warm season to cool season species and

provide overall assessment of the status of the

tallgrass community (Kaiser-Hill 1997; Owensby

1973). Detailed surveys would be limited to the Rock

Creek Reserve.

1.2.4 – Use prescribed fire (in Rock Creek Reserve

only), mowing and other restoration tools to stimulate

the growth of native plants in the xeric tallgrass

community and reduce fuel for wildfire. Grazing

would not be used.

1.2.5 – Participate in regional efforts to implement

tallgrass prairie conservation measures.

1.2.6 – Suppress all wildfires.

Alternative B

By year 15, manage the existing extent (about 1,500

acres) of the xeric tallgrass prairie across the Refuge

to achieve an average relative cover of no less than

60 percent (± 4 percent) native grasses and 10

percent (± 5 percent) forbs, with no more than 10

percent of the average cover to be invasive nonnative species. Maintain the total number of native

species to be at least 80 percent of the about 285

plant species that have been identified in the

tallgrass community prior to Refuge establishment.

Rationale: Under Alternative B, the focus would be

on maintaining and improving the 1,500 acres of xeric

tallgrass across the site from the conditions that

existed at the time of Refuge establishment. IPM

techniques, as described in Objective 1.5 - Weed

Management, would be used to maintain the native

composition of species in the xeric tallgrass

communities. While the number of plant species within

the community fluctuates annually according to

climactic conditions, a total of about 285 species are

consistently found within this community. Not meeting

the objective as stated above does not necessarily
Chapter 2: Alternatives 

42 Rocky Flats National Wildlife Refuge 

indicate the xeric tallgrass is critically imperiled but

would warrant a more thorough investigation.

Prescribed fire would be conducted Refuge-wide to

stimulate native plant growth, reduce plant litter and

help control weeds in the xeric tallgrass community.

Strategies:

1.2.1-1.2.2 – Same as A.

1.2.3 – Same as A, except: Surveys would be

conducted in xeric tallgrass areas Refuge-wide.

1.2.4 – Use prescribed fire in conjunction with other

restoration tools such as grazing, mowing, herbicides

and biological controls to simulate natural processes

that once existed at Rocky Flats. 

1.2.5 -1.2.6– Same as A.

1.2.7 – Use prescribed fire in areas identified in

Figure 10. Prescribed fire may be used in grassland

areas at a average frequency of 5 to 7 years (riparian

areas 5 to 10 years). These can occur for two years in

a row but not less frequently than once every 10 to12

years. Burn areas would average about 200 to 500

acres per year of both xeric and mixed grasslands and

portions of riparian communities across the site. 

1.2.8 – Use grazing in areas identified in Figure 10.

Grazing on a specific grassland area would be limited

to short duration with high animal numbers (flash

grazing for an average of 2 weeks) as identified in the

Vegetation and Wildlife Management Plan.

Temporary paddocks with electric fencing would be

used to contain livestock in specific areas. 

1.2.9 – Monitor ecological conditions before and after

the application of any specific restoration tool.

1.2.10 – In accordance with Objective 3.2 - Visitor

Safety, close the Refuge to all public use prior to and

during the use of prescribed fire on the Refuge.

Alternative C

Same as B.

Rationale: Same as B.

Strategies:

1.2.1 -1.2.2 – Same as A. 

1.2.3 –1.2.4 – Same as B.

1.2.5 - 1.2.6 – Same as A.

1.2.7 -1.2.9 – Same as B. 

Alternative D

Same as B.

Rationale: Same as B.

Strategies:

1.2.1-1.2.2 – Same as A.

1.2.3 – Same as B.

1.2.4 – Do not use prescribed fire or grazing. Use

other restoration tools such as mowing, herbicides and

biological controls.

1.2.5 -1.2.6 – Same as A.

Objective 1.3—Mixed Grassland Prairie Management 

Background

Nearly one half of the Refuge is vegetated with

shortgrass prairie communities, including mesic mixed

grassland, xeric needle and thread grassland, short

grassland, and reclaimed mixed grassland. While these

communities are habitat for a variety of wildlife species

on the Refuge, the Service has not outlined very many

specific management strategies for the mixed

grassland prairie at the Refuge. Instead, management

strategies that are important to these prairie

communities, including managing weeds, managing

prairie dogs, restoring unused roads and sustaining

habitat for introduced species, are covered under other

wildlife and habitat management objectives. However,

because many native wildlife species rely on diverse

habitat components that are not present in agricultural

fields, hay meadows, or a monoculture of plant species,

the Service has outlined specific management

strategies related to restoration of these areas.

Maintenance and enhancement of these mixed

grassland prairie communities is integral to other, more

specific objectives. 

As outlined in Objective 1.5 - Weed Management, a

variety of IPM tools, including managed grazing and

prescribed fire, would be used to maintain the health

and integrity of the mixed grassland prairie

communities. Prescribed fire would be conducted

considering state air quality regulations, ecological

timing (to maximize benefits to desirable species and

effectiveness in controlling weed species), weather

conditions and operational logistics. Grazing for

ecological restoration purposes would likely consist of

managed cattle for short periods of time to simulate

natural processes and invigorate native grasses

(grazing for the specific purpose of weed control is

typically conducted using goats). Monitoring of these
Chapter 2: Alternatives 

44 Rocky Flats National Wildlife Refuge 

treatments and their effectiveness allows for

adaptation and alteration of techniques to improve

long-term effectiveness.

Alternative A

Through the life of the CCP, maintain and improve the

vigor and native species composition of short and mesic

mixed grassland habitat according to the management

objectives for weed management, prairie dog

management, habitat restoration and species

reintroduction.

Rationale: The mixed grassland prairie communities

at the Refuge provide habitat for a variety of wildlife

species. In Alternative A, these communities would be

managed according to the specific purposes of other

objectives. Prescribed fire would be conducted in the

Rock Creek Reserve to stimulate native plant growth,

reduce plant litter and help control weeds in the mixed

grassland prairie communities. 

Strategies:

1.3.1 – Use IPM strategies to control or reduce

noxious weed infestations and maintain or improve

the vigor of native short and mesic grassland

according to Objective - 1.5 Weed Management and

Objective 1.4 - Road Restoration and Revegetation.

1.3.2 – Allow short and mesic grassland communities

to support prairie dog expansion, according to

Objective 1.7 - Prairie Dog Management.

1.3.3 – Maintain short and mesic grassland

communities as needed to support the reintroduction

of sharp-tailed grouse or other species, as directed

under Objective 1.8 - Species Reintroduction.

1.3.4 – Suppress all wildfires.

1.3.5 – Use prescribed fire (in Rock Creek Reserve

only), mowing and other restoration tools to stimulate

the growth of native plants in the mixed grassland

prairie communities and reduce fuel for wildfire.

Grazing would not be used.

Alternative B

Same as A, except restore 300 acres of non-native

grassland in the southeast corner of the Refuge (hay

meadow), as well as other reclaimed grassland areas, to

a native mixed grassland community.

Rationale: The mixed grassland prairie communities

at the Refuge provide habitat for a variety of wildlife

species. In Alternative B, the Service would restore

non-native grassland areas, including the hay meadow,

to improve the diversity of habitat for a variety of

species. In addition, the mixed grassland prairie

communities would be managed according to the

specific purposes of other objectives. Prescribed fire

would be conducted Refuge-wide to stimulate native

plant growth, reduce plant litter and help control

weeds in the mixed grassland prairie communities.

Strategies:

1.3.1-1.3.4 – Same as A.

1.3.5 – Use prescribed fire in conjunction with other

restoration tools such as grazing, mowing, herbicides

and biological controls to simulate natural processes

that once existed at Rocky Flats.

1.3.6 – Restore non-native reclaimed grasslands in the

hay meadow and other areas to a native mixed

grassland community.

1.3.7 – Use prescribed fire in areas identified in

Figure 10. Prescribed fire may be used in grassland

areas at a average frequency of 5 to 7 years (riparian

areas 5 to 10 years). These can occur for two years in

a row but not less frequently than once every 10 to 12

years. Burn areas would average about 200 to 500

acres per year of both xeric and mixed grasslands and

portions of riparian communities, across the site. 

1.3.8 – Use grazing in areas identified in Figure 10.

Grazing on a specific area would be limited to short

duration with high animal numbers (flash grazing for

an average of 2 weeks) as identified in the Vegetation

Management Plan. Temporary paddocks with electric

fencing would contain the livestock in specific areas. 

1.3.9 – Monitor ecological conditions before and after

the application of any specific restoration tool.

1.3.10 – In accordance with Objective 3.2 - Visitor

Safety, close the Refuge to all public use prior to and

during the use of prescribed fire on the Refuge.

Alternative C

Same as B. 

Rationale: Same as B.

Strategies:

1.3.1-1.3.4 – Same as A.

1.3.5 -1.3.10– Same as B.

Alternative D

Same as A.

Rationale: Same as A.
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 45

Strategies:

1.3.1-1.3.4 – Same as A.

Objective 1.4—Road Restoration and Revegetation

Background

Currently about 70 miles of roads occur at the Refuge

(of which about 20 miles will remain under DOE’s

jurisdiction). The removal and revegetation of

extraneous roads would provide more wildlife habitat

and reduce the effects of fragmentation. Fragmentation

results from roads, trails and other disturbances

interrupting continuous habitat with unsuitable and

possibly hostile environments. Fragmentation can

affect plants and animals, resulting in the isolation of

populations or individuals, reduction of genetic

diversity, reduction of carrying capacity and other

effects. Roads provide corridors for predators and are

prone to weed infestations. Abrupt vegetation changes

at road edges alter light, temperature and wind

exposure. Revegetation and the restoration of natural

contours, either by natural succession or mechanical

grading, would increase the quality and quantity of

native wildlife and plant habitats.

In all alternatives, the Service would retain about 25

miles of roads for maintenance, fire control, utility

and ecological monitoring access. In some cases, the

roads would also be used as trails. Unless designated

otherwise, access roads would be closed to public use. 

Alternative A

Beginning in the first 3 years and completed during

the life of the CCP, revegetate—in the Rock Creek

Reserve—12 miles of unused roads with seven

stream crossings.

Rationale: The 2001 Rock Creek Reserve Integrated

Natural Resources Management Plan (DOE 2001) calls

for the removal and revegetation of unused roads

within the Rock Creek Reserve. In Alternative A, the

roads in the Rock Creek Reserve would be restored

and revegetated, while the roads in the remainder of

the Refuge would be left in place. 

Strategies:

1.4.1 – Allow natural revegetation of native species on

lightly used roads and unimproved stream crossings,

in areas not dominated by weeds.

1.4.2 – In select locations, prepare (including soil prep,

culvert removal, fill, regrading to match original

contours, herbicide application) and seed roadways

and uplands with native species appropriate to soil

type, slope and aspect.

1.4.3 – Where suitable, revegetate stream crossings

with woody riparian species.

1.4.4 – Informally survey roadways for noxious weeds

during the growing season and apply IPM techniques.

1.4.5 – Work with the Service’s Ecological Services

office and other agencies for ESA consultation and

necessary permits in Preble’s habitat and wetlands

and adjacent buffer zones.

Alternative B

Beginning in the first year and completed within the

life of the CCP, revegetate approximately 26 miles of

unused roads with 13 stream crossings. This would

include about 7 miles of xeric tallgrass habitat and

about 11 miles of mixed grassland prairie. 

Rationale: In Alternative B, roads across the Refuge

that are not being used for public use, fire protection,

or maintenance access, would be restored and

revegetated, while others would be narrowed to the

width of a trail.

Strategies:

1.4.1-1.4.5 – Same as A.

1.4.6 – Every 3 years survey restored habitat areas

along selected vegetation point intercept transects

to determine ground cover, vegetation density,

species and species richness; document effectiveness

of weed control; assess impacts of disturbance on

plant communities; and provide overall assessment

of the vegetation community and restoration success

(Kaiser-Hill 1997; Owensby 1973).

Prescribed fire would be used as a management tool in

Alternatives A, B and C.

© Nelson, RFETS
Chapter 2: Alternatives 

46 Rocky Flats National Wildlife Refuge 

Alternative C

Beginning in the first year and within the first 10

years, revegetate about 26 miles of unused roads with

13 stream crossings. This would include about 8 miles

of xeric tallgrass habitat and about 11 miles of mixed

grassland prairie.

Rationale: In Alternative C, restore and

revegetate to a pre-settlement condition almost

all roads not needed for fire or Refuge access.

Strategies:

1.4.1-1.4.5 – Same as A.

1.4.6 – Same as B.

Alternative D

Beginning by year 3 and completed within the life of

the CCP, revegetate approximately 24 miles of unused

roads with 6 stream crossings. This would include

about 7 miles of xeric tallgrass habitat and about 12

miles of mixed grassland prairie. 

Rationale: Same as B. 

Strategies:

1.4.1-1.4.5 – Same as A.

1.4.6 – Same as B.

Objective 1.5—Weed Management

Background

Noxious weeds are nonnative plant species that invade

an area that has been disturbed or where vegetation is

stressed. Noxious weed infestations reduce the capacity

of native plant communities to support wildlife

populations and a diversity of organisms. Soil

disturbances and cessation of the natural processes

such as fire and grazing have resulted in a proliferation

of noxious weed species at Rocky Flats. 

IPM involves techniques that simulate the processes

that contribute to the integrity of the ecosystems and

can be applied when conditions are optimum for

greatest effectiveness: prescribed fire; revegetation

with native species; mechanical methods of mowing,

root grubbing and hand collection; chemical

applications; and biological agents. Depending on the

location and treatment, controlled grazing by goats or

cattle can be used as ecological restoration tools (as

discussed in Objective 1.2 - Xeric Tallgrass

Management) or for weed management purposes.

Monitoring the effectiveness of treatment allows

adaptation and alterations of techniques to improve

long-term effectiveness. Diffuse knapweed and

Dalmatian toadflax are the principal threats to the

grasslands, while Canada thistle threatens wetlands

and riparian areas. Weed management efforts will seek

to prevent the spread of existing infestations and the

establishment of new ones.

In accordance with the Colorado Noxious Weed Act,

the control of “list B” noxious weed species such as

Diffuse knapweed, Dalmatian toadflax, and Canada

thistle would be prioritized over the control of “list C”

species such as field bindweed and jointed goatgrass.

Biological controls would be planned to minimize

potential impacts to native species. 

Alternative A

In the Rock Creek Reserve, reduce the density of

diffuse knapweed and Dalmatian toadflax populations

by 15 percent within the first 5 years, 25 percent within

10 years and 50 percent within 15 years (as described

in Kaiser-Hill 2002). Reduce the density and control

the spread of other noxious weed species, especially

Canada thistle by 50 percent within 15 years. Prevent

the establishment of weed species (Jefferson County,

Boulder County and State of Colorado weed lists) not

yet observed on the Refuge. For the Refuge outside of

Rock Creek, limit and control the spread and density of

existing weed infestations beginning in the first year. 

Rationale: In Alternative A, staff resources would

concentrate weed reduction efforts in the Rock Creek

Reserve while attempting to limit the expansion of

weeds over the rest of the Refuge. Although the Rock

Creek Reserve management plan (DOE 2001) did not

specify weed reduction targets, the Service has

established targets for the Rock Creek Reserve.

Strategies:

1.5.1 – Employ an IPM approach to include the

application of herbicides to perimeters of knapweed

and toadflax patches to prevent their spread.

Redistribute established biological control agents

across the Rock Creek drainage and continue

releases. Rake along fence lines and dispose of all

tumbleweeds. Grub and handpull where needed. 

1.5.2 – Annually identify and map weed patches using

a Global Positioning System (GPS) to demarcate the

areal extent and relative severity of infestations. Map

treatment sites and monitor for efficacy in subsequent

growing season.

1.5.3 - Correlate weed management with prairie dog

management to minimize weed infestations in prairie

dog expansion areas.
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 47

Alternative B

Reduce the density of diffuse knapweed and

Dalmatian toadflax populations by 15 percent within

the first 5 years, 30 percent within 10 years and 60

percent within 15 years (as described in Kaiser-Hill

2002). Reduce the density and spread of other

noxious weed species, especially Canada thistle by

50 percent within 15 years. Limit and control the

establishment of weed species (Jefferson County,

Boulder County and State of Colorado weed lists)

not yet observed on the Refuge. 

Rationale: In Alternative B, the full range of IPM

tools, including chemical, biological and mechanical

control, prescribed fire and grazing, would be

available to reduce noxious weed concentrations

throughout the Refuge. Prescribed fire would be

subject to an approved fire management plan and

state air quality regulations. Grazing also would be

subject to an approved plan. Burning along fence

lines would reduce seed spread of noxious weeds,

and the removal of plant litter would reduce the

amount of herbicide that would be required to

control weed infestations in that area.

Strategies:

1.5.1-1.5.3 – Same as A.

1.5.4 – Develop a comprehensive IPM plan.

1.5.5 – Conduct annual informal survey for new

infestations during the growing season, focusing

on roadways, trails, restoration areas and

disturbed sites. 

1.5.6 – If necessary, establish temporary interior

fencing in areas where weeds are wind dispersed

to collect weeds and limit dispersal. Burn along

fence lines and dispose of all tumbleweeds. 

1.5.7 – Use managed grazing of goats, or other

livestock as appropriate for short periods to

control weed infestations and simulate natural

grassland processes.

Alternative C

Same as B.

Rationale: Same as B.

Strategies:

1.5.1-1.5.3 – Same as A.

1.5.4 -1.5.7 – Same as B.

Alternative D

Same as B, except reduce diffuse knapweed and

Dalmatian toadflax by 10, 15 and 30 percent within 5,

10 and 15 years, respectively (instead of 15, 30 and 60

percent).

Rationale: Same as B, except prescribed fire and

grazing would not be used.

Strategies:

1.5.1-1.5.3 – Same as A.

1.5.4 – Same as B.

Objective 1.6— Deer and Elk Management

Background

CDOW has primary responsibility for the management

of deer and elk herds throughout the state and

cooperated with the DOE for wildlife management at

Rocky Flats before Refuge establishment. CDOW

strives to set population levels at 80 percent carrying

capacity, but the Service believes that setting a target

population level for the Refuge will provide for better

management of the ungulate population and would

present fewer difficulties in determining what the

carrying capacity should be. The resulting target

population level may be lowered if degradation is

occurring in Preble’s habitat (riparian and upland

shrubs). Continued cooperation with the CDOW will

provide continuity in management, sharing of resources

and provide larger habitat areas for deer and elk.

Management of deer and elk populations is necessary to

maintain the health of the herds and prevent the

degradation of sensitive habitats such as riparian

woodlands and shrublands and tallgrass prairie. 

Alternative A

Work with CDOW to establish target populations and

manage deer and elk populations as needed to prevent

overpopulation, the spread of disease and adverse

impacts to Preble’s habitat. 

Rationale: In Alternative A, due to limited resources,

the Service would cooperate with CDOW’s population

management efforts on the Refuge. The Service would

seek the assistance of CDOW in the event that deer

populations excessively degrade Preble’s habitat, or if

chronic wasting disease or any other wildlife concern is

suspected on the Refuge. 

Strategies:

1.6.1 – Work with CDOW in population monitoring

and control through culling and other methods.

1.6.2 – Assist CDOW in establishing target

populations for deer and elk on the Refuge.

1.6.3 – Every 2 years monitor for ungulate induced

degradation using multiple methods for foliage
Chapter 2: Alternatives 

48 Rocky Flats National Wildlife Refuge 

density, foliage height diversity and plant species

diversity (Anderson and Ohmart 1986) in the riparian

woodlands, riparian and tall upland shrub

communities in Preble’s habitat.

Alternative B

Within 3 years, establish deer and elk population

targets to be achieved by year five. Adverse effects to

Preble’s or other federally endangered or threatened

species and their habitats may necessitate reduced

population target levels.

Rationale: In Alternative B, a public hunting

program may be all that is necessary to control the

herd size; however, additional culling by Refuge staff

and CDOW, or keeping the herd away from sensitive

habitat areas with exclosures or temporary fencing

may be required. The Service would correlate the

establishment of population targets with the public

hunting program to maximize the utility of hunting

as a management tool and to ensure that it does not

adversely impact populations. 

Strategies:

1.6.1 – Coordinate and assist CDOW to monitor and

manage populations through a public hunting

program, culling by Refuge or CDOW personnel, or

temporary exclosures. 

1.6.2-1.6.3 – Same as A.

1.6.4 – Perform annual deer and elk relative

abundance or relative density study by direct count.

1.6.5 – Establish permanent vegetation photo

points in riparian and upland shrubs and use them

to monitor for excessive habitat degradation by

ungulates every 2 years. Establish exclosure plots

to determine the extent of browsing. 

1.6.6 – Work with other agencies to protect

movement corridors between the Refuge and 

nearby habitat areas.

Alternative C

Same as B. 

Rationale: In Alternative C, no public hunting

or culling of the herd would be permitted. 

Other strategies including temporary fencing

may be required. 

Strategies:

1.6.1 – Same as B, except coordinate and assist

CDOW to manage populations using culling and other

strategies (public hunting would not be used). 

1.6.2- 1.6.3 – Same as A.

1.6.4 – Seasonally monitor ungulate distribution and

movement patterns by direct count.

1.6.5- 1.6.6 – Same as B.

1.6.7 – Annually survey by direct count population

number, composition, fawning rate and fawn survival. 

Alternative D

Same as B. 

Rationale: A public hunting program may be all that

is necessary to control the herd size, but additional

culling by Refuge staff may be required to keep herd

size within target population limits. Due to the number

of resources being used to accomplish public use and

restoration objectives, it may take longer to establish

and achieve population targets. The Service would

correlate the establishment of population targets with

the public hunting program to maximize the utility of

hunting as a management tool and to ensure that it

does not adversely impact populations. 

Strategies:

1.6.1 – Same as B.

1.6.2 – Same as A.

1.6.3 – Same as A, except monitor every 3 years

(instead of every 2 years). 

1.6.4 – Same as B.

Objective 1.7—Prairie Dog Management

Background

Prairie dogs are important components in the short

and mesic grasslands systems. They are commonly

considered a “keystone” species because their activities

(burrowing and intense grazing) provide food and

shelter for many other grassland species. While blacktailed prairie dogs are no longer a candidate species for

threatened status listing under the ESA (as of August

2004) the Service still has a strong interest in

conserving the species and habitat where appropriate.

Rocky Flats contains about 2,460 acres of potential

prairie dog habitat, based on an analysis of suitable

soils, vegetation, and slope. While about 113 acres of

prairie dog colonies have been identified in recent

years, active prairie dog colonies at Rocky Flats

currently comprise an area of about 10 acres.

Thresholds for prairie dog expansion in the various

alternatives are based on these existing conditions and

the extent of potential habitat.
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 49

Alternative A

Allow prairie dog populations to expand naturally across

the Refuge outside of recognized Preble’s habitat.

Rationale: In Alternative A, the Service would

depend on natural habitat conditions and predation to

regulate the size and location of prairie dog colonies. If

prairie dogs colonize and degrade Preble’s habitat

areas (such as wetlands and riparian grasslands), the

Service would consider relocation to more suitable

habitat areas on the Refuge.

Strategies:

1.7.1 – Trap and relocate on site, or use other methods

to exclude prairie dogs from Preble’s habitat in the

Rock Creek Reserve.

1.7.2 – Use intra-Refuge relocation as required.

1.7.3 – Do not accept prairie dogs from off-Refuge

relocation projects. 

1.7.4 – Cooperate with DOE’s stewardship designee to

manage prairie dogs on DOE retained lands through

visual and vegetative barriers where necessary. 

1.7.5 - Correlate prairie dog management with weed

management efforts to minimize weed infestations in

prairie dog expansion areas.

Alternative B

Allow prairie dog populations to expand up to 750 acres

in areas of non-native grassland as well as short and

mixed native grasslands outside of recognized Preble’s

habitat across the Refuge

Rationale: Restoration is a key component of

Alternative B. The Service would manage for a

sustainable prairie dog population that contributes to

the overall function and integrity of the grassland

communities and does not degrade other sensitive

resources (such as wetlands, shrublands and xeric

tallgrass prairie). With limited staff resources, it

could be difficult to limit prairie dog expansion if they

populate large areas, so it is important that the

Service maintain a manageable prairie dog population

on the Refuge. If necessary, the Service would try to

limit the expansion of prairie dogs into sensitive areas

that do not provide primary habitat for prairie dogs.

Because human recreation is a significant component

of Alternative B, plague control methods may be

needed in prairie dog management to protect prairie

dog colonies as well as Refuge visitors. 

Strategies:

1.7.1 – If necessary, trap and relocate within the

Refuge, or use other methods to exclude prairie dogs

from Preble’s habitat and xeric tallgrass throughout

the Refuge. 

1.7.2-1.7.5 – Same as A.

1.7.6 – Annually monitor and map the location, extent

and distribution of prairie dog populations including

densities and vegetation characteristics within prairie

dog towns. 

1.7.7 – Annually monitor for plague and respond with

flea control if appropriate.

Alternative C

Same as B, except allow prairie dog populations to

expand up to 500 acres.

Rationale: With the limited staff resources in

Alternative C, it could be difficult to limit prairie dog

expansion if they populate large areas. Because of the

emphasis on ecological restoration of the site to a presettlement condition in this alternative, large expansion

of prairie dogs would be limited to the extent possible

until restoration is completed. The integrity of the xeric

tallgrass and riparian woodland, riparian shrublands

and uplands considered Preble’s habitat across the site

would be protected. 

Strategies:

1.7.1 – Same as B.

1.7.2-1.7.5 – Same as A.

1.7.6 – Same as B.

1.7.7 – Informally monitor for the presence of plague

and consult with local public health officials.

Alternative D

Same as B, except allow prairie dog populations to

expand up to 1,000 acres.

Rationale: With the emphasis on providing more

public use opportunities in Alternative D, prairie dogs

would be allowed to populate larger areas than in

Alternatives B and C recognizing that it could be

difficult to limit prairie dog expansion if they populate

large areas. To the extent possible, the integrity of the

xeric tallgrass and riparian woodland, riparian

shrublands and uplands considered Preble’s habitat

across the site would be protected. Because human

recreation is a significant part of Alternative D, plague

control methods would be used in prairie dog

management to protect prairie dogs and visitors.

Strategies:

1.7.1 – Same as B.
Chapter 2: Alternatives 

50 Rocky Flats National Wildlife Refuge 

1.7.2 – Same as A.

1.7.3 – Evaluate the suitability of accepting prairie

dogs from off-site locations.

1.7.4 -1.7.6 – Same as A.

1.7.7 – Same as B, except annually monitor and

quantify prairie dog populations, but do not

monitor densities and vegetation characteristics

within prairie dog towns.

1.7.8 – Same as B.

Objective 1.8—Species Reintroduction

Background

CDOW holds the primary responsibility for wildlife

management in Colorado and cooperated with the

DOE for wildlife management on Rocky Flats before

Refuge establishment. CDOW, through a cooperative

effort with City of Boulder, introduced a small number

of plains sharp-tailed grouse just north of the Refuge

on Boulder’s open space land during spring 2003 and is

interested in expanding the introduction of the grouse

onto the Refuge. The Service worked with CDOW to

introduce northern redbelly dace and the common

shiner in Rock Creek during summer 2003. 

Alternative A

During the 15-year life of the CCP, facilitate and assist

reintroduction of native extirpated species by, or in

coordination with, the CDOW. Implement population

monitoring of existing reintroductions (redbelly dace,

common shiner) and any new reintroductions until

successfully established.

Rationale: In Alternative A, Service cooperation

with CDOW on introductions/reintroductions would

provide continuity in management, sharing of

resources and benefit the ecosystems and native

communities present on the Refuge. The Service,

however, would not take a leading role in species

reintroduction. An alternating year monitoring

program would enable the limited staff resources to

rotate population monitoring.

Strategies:

1.8.1 – Coordinate with CDOW to introduce and

monitor plains sharp-tailed grouse.

1.8.2 – Coordinate with CDOW in species release,

monitoring and habitat maintenance needs on the

Refuge.

1.8.3 – Coordinate with CDOW on monitoring native

fish reintroduction (northern redbelly dace and

common shiner) in Rock Creek, until they are

successfully established.

Alternative B 

Within 3 years of Refuge establishment, evaluate the

suitability for introducing/reintroducing plains sharptailed grouse and other native species, prioritize the

species that could be introduced/reintroduced during

the life of the CCP and implement population

monitoring of reintroduced species at least annually

until populations are established.

Rationale: In Alternative B, a full evaluation of

Refuge habitat suitability is needed before

introductions/ reintroductions are planned. Service

staff would play an active role in evaluating the

suitability of reintroduction efforts and would partner

with CDOW to manage implementation. Population

monitoring by Service staff would be implemented as

necessary.

Strategies:

1.8.1 – Coordinate with and assist CDOW in

evaluating the suitability of the Refuge for plains

sharp-tailed grouse and other native species. 

1.8.2 – Oversee and assist CDOW with species release,

monitoring and habitat maintenance on the Refuge. 

1.8.3 – Annually monitor native fish (northern

redbelly dace and common shiner) in Rock Creek. If

needed, reintroduce them in the Walnut Creek

drainage and Woman Creek (provided suitable

habitat exists), until successful establishment.

1.8.4 – If found suitable for introduction, during the

first 2 years of the CCP, complete a management plan

for the plains sharp-tailed grouse.

Alternative C 

Same as B, except within 3 years, remove the

introduced common shiner and redbelly dace from the

Lindsay Ranch ponds and determine if they can be

relocated elsewhere on the Refuge (in order to restore

the ponds to native wetlands). 

Rationale: Similar to Alternative B, Service staff

would partner with CDOW to evaluate the suitability of

reintroduction efforts and implement and monitor

those efforts. With the focus on ecological restoration

of the site to pre-settlement conditions under

Alternative C, stocked native fish populations in the

Lindsay Ranch ponds would need to be transplanted to

the other drainages (on site, if possible) and the ponds

restored to a native wetland condition.
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 51

Strategies:

1.8.1-1.8.4 – Same as B.

Alternative D

During the first 3 years of the 15-year CCP, complete

an evaluation of the Refuge’s suitability for the

reintroduction of plains sharp-tailed grouse and

implement population monitoring.

Rationale: In Alternative D, additional resources

would be focused on providing a full range of public

use opportunities and aside from the grouse and

native fish, no other reintroductions/introductions

would be proposed.

Strategies:

1.8.1 – Same as B.

1.8.2 – Same as B, except coordinate with and assist

CDOW (but not oversee CDOW). 

1.8.3 – Same as B.

GOAL 2. PUBLIC USE, EDUCATION AND INTERPRETATION

Provide visitors and students high quality

recreational, educational and interpretive

opportunities and foster an understanding and

appreciation of the Refuge’s xeric tallgrass prairie,

upland shrub and wetland habitats; native wildlife;

the history of the site; and the NWRS.

Objective 2.1—Visitor Experience 

Alternative A

For the life of the CCP, provide guided interpretive

tours for less than 300 visitors annually (less than 2

tours a month). During their visit, 90 percent of site

visitors would be informed about the safety steps that

were taken prior to Refuge establishment. 

Rationale: In this alternative general public access

is restricted. The only public use permitted would be

organized guided tours of the Refuge. Because

Service staff would accompany all visitors, all visitors

would enjoy a safe, informative tour of select highquality resource areas within the Refuge. In an

effort to make visitors feel safe, all tours would

include information about the steps that were taken

to ensure safety prior to Refuge establishment. One

survey would be developed to measure all visitor

experiences and would include questions related to

use patterns, satisfaction and understanding of the

resource (as referred to in objectives 2.1, 2.2, 2.3, 2.4

and 2.5).

Strategies:

2.1.1 – Develop a guideline and reservation system to

manage public use and arrange tours. 

2.1.2 – Provide a staff contact for every tour to explain

the site’s history and resources as well as the Refuge

System’s mission and help ensure that visitors feel

safe during their visit.

2.1.3 – Develop a survey to measure the quality of the

visitor experience. 

Alternative B

Within the first 5 years of the Refuge’s establishment,

the Service would initiate efforts to make Refuge

visitors feel safe and would ensure that at least 75

percent of visitors would be informed about the safety

steps that were taken prior to Refuge establishment.

Rationale: Access to the Rocky Flats site has been

highly restricted during both the nuclear production

and the cleanup phases of the site’s history. A

substantial amount of public skepticism about the site’s

safety and a lack of familiarity with the site’s resources

are likely to hamper visitation. To ease public

apprehension about the site, it would be crucial to

ensure that visitors feel welcome, safe and comfortable.

During focus groups about visitor use and outreach

programs, specialists emphasized the importance of

communicating with the public and explaining cleanup

results and ongoing safety measures. One survey would

be developed to measure all visitor experiences and

would include questions related to use patterns,

satisfaction and understanding of the resource (as

referred to in objectives 2.1, 2.2, 2.3, 2.4 and 2.5).

Refuge tours, open visits and interpretive programs would

increase public awareness of the Refuge system.

© Mauro
Chapter 2: Alternatives 

52 Rocky Flats National Wildlife Refuge 

Strategies:

2.1.2 – Provide a staff contact during peak seasons to

welcome visitors and address safety concerns.

2.1.3 – Develop a survey designed to measure how

safe visitors feel during their visit.

2.1.4 – Develop an outreach program that reaches

beyond the site’s boundaries and educates

surrounding communities about the Refuge’s safety

and amenities.

2.1.5 – Use signage, staff contact, brochures, website

and other means to convey safety information.

2.1.6 – Implement a volunteer program focused on

helping the public and site visitors understand efforts

that have been made to ensure the safety of site

users.

2.1.7 – Keep surrounding communities including, but

not limited to, Jefferson, Boulder and Broomfield

counties, the cities of Westminster, Arvada, Boulder,

Golden and Broomfield and nearby school districts

informed about Refuge events and the progress of the

CCP’s implementation.

Alternative C

For the life of the CCP, provide guided interpretive

tours for less than 1,000 visitors annually. During their

visit, 90 percent of site visitors would be informed

about the safety steps that were taken prior to Refuge

establishment.

Rationale: The primary emphasis for this alternative

is ecological restoration and protection with limited

public use. All public use would be through arranged

tours including classes and other research groups.

Visitor numbers would be low because Refuge’s

funding would be directed primarily toward resource

preservation and restoration rather than visitor use.

Because Service staff would accompany all visitors,

they would enjoy a safe, informative tour of select high

quality resource areas within the Refuge. In an effort

to make visitors feel safe, all tours would include

information about the steps that were taken to ensure

safety prior to Refuge establishment. One survey

would be developed to measure all visitor experiences,

using questions related to use patterns, satisfaction and

understanding of the resource (as referred to in

objectives 2.1, 2.2, 2.3, 2.4 and 2.5).

Strategies: Same as A.

Alternative D 

Same as B.

Rationale: Same as B.

Strategies: Same as B.

Objective 2.2—Public Access

Alternative A

Initiate limited guided tours (fewer than 300 visitors

annually) of the Refuge within the first year of the

Refuge’s establishment and provide opportunities for

wildlife observation, photography and limited

interpretation. The tours would be conducted

throughout the life of the CCP. About 75 percent of

visitors would report satisfaction with their guided

Refuge experience.

Rationale: Visitor access and wildlife-dependent uses

would only be permitted on a guided tour. Site tours

would provide visitors the opportunity to view unique

xeric tallgrass prairie, upland shrub and wetland

habitats and to understand the site’s history and the

NWRS. Hunting, equestrian and bicycling uses would

not be permitted. In all alternatives, dogs would be

prohibited on the Refuge because they pose a threat to

the wildlife resources on the Refuge. In order to

minimize disturbances to the natural environment,

visitors would be restricted to designated areas. 

Strategies:

2.2.1 – Develop and implement a survey that

measures visitor satisfaction and use patterns.

2.2.2 – Do not permit dogs on the Refuge.

2.2.3 – Use existing roads as routes for the tour. No

trail or other visitor use facilities would be developed. 

Alternative B

By the end of 15 years, visitors would have

opportunities to observe and photograph wildlife and

to experience the Refuge’s unique habitats, mountain

and prairie views on foot, bike and horse. Satisfaction

with their Refuge experience would be reported by 75

percent of visitors.

Rationale: One of the goals of the Refuge System is to

foster an understanding of wildlife and its habitat by

providing the public with safe, high quality, wildlifedependent public uses. The Refuge provides

opportunities for the public to experience the unique

xeric tallgrass prairie, upland shrub, wetland habitats

and learn about the site’s history and the NWRS.

Trails and overlooks would be designed to allow visitors

to experience the diverse areas of the site and

expansive views of the mountain backdrop and the

Denver/Boulder metropolitan area. 
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 53

Off trail use would be allowed on a seasonal basis for

pedestrian access only in the southern portion of the

Refuge during specific times of the year (OctoberApril). Limiting off trail use to the late fall and winter

would limit impacts to ground nesting birds and deer

fawning in the uplands. Off trail use would provide

opportunities for amateur naturalists, wildlife

photographers and others to access their subjects.

To protect Preble’s and other wildlife habitat, closures in

the Rock Creek area and other drainages would be

instituted on an as needed basis. Overlooks, however,

would remain open and provide views into the riparian

areas. Dogs would be prohibited on the Refuge because

they are permitted on nearby open spaces and pose a

threat to wildlife resources.

Strategies: 

2.2.1-2.2.2 – Same as A.

2.2.3 – Develop trails to provide multiple

opportunities for viewing and photographing wildlife. 

2.2.4 – Allow off-trail use in the southern portion of

the Refuge (south of Woman Creek) between

October and April.

2.2.5 – Establish seasonal trail closures in Rock Creek

and other drainages as necessary to minimize impacts

to wildlife. Keep portions of the rim trails open for

viewing the riparian areas.

2.2.6 – Provide a seasonally staffed visitor contact

station to inform visitors about the Refuge’s

resources and how to best experience the Refuge

during different seasons.

2.2.7 - Open the Refuge to the public from sunrise 

to sunset.

2.2.8 - Maintain public access on the main access

road only. Close all other roads to public access.

2.2.9 - Do not permit motorized vehicles on the

Refuge except in designated parking/access areas,

refuge maintenance access and access to utility

easements, ditches, and private mineral rights.

Alternative C

Initiate limited guided tours (limited to 1,000 visitors

annually) of the Refuge within the first year of the

Refuge’s establishment and provide limited

opportunities for wildlife observation, photography and

interpretation. The tours would be conducted

throughout the life of the CCP. About 75 percent of

visitors would report satisfaction with their guided

Refuge experience.

Rationale: Same as A. 

Strategies: 

2.2.1-2.2.2 – Same as A.

2.2.10 – Provide the minimum amount of public use

facilities, including trails and overlooks, to allow

visitors to obtain views of key resource areas while

minimizing impacts to wildlife. 

2.2.11 – Minimize the scale of all facilities, where

appropriate, place them in previously disturbed areas.

Alternative D

Throughout the life of the CCP, visitors would have

opportunities to observe and photograph wildlife and to

experience the Refuge’s unique habitats and mountain

and prairie views. About 75 percent of visitors would

report satisfaction with participation in a wide range of

wildlife dependent recreational uses.

Rationale: Same as B.

Strategies:

2.2.1-2.2.2 – Same as A.

2.2.3-2.2.5 – Same as B.

2.2.6 – Provide a staffed visitor center to inform

visitors about the Refuge’s resources and

opportunities for experiencing the Refuge.

2.2.7-2.2.9 – Same as B.

Refuge access would be limited to guided tours in

Alternatives A and C.

© Shapins Associates
Chapter 2: Alternatives 

54 Rocky Flats National Wildlife Refuge 

Objective 2.3—Appreciation of the National Wildlife

Refuge System 

Alternative A

For the life of the CCP, 90 percent of the visitors who

are allowed site access would understand and

appreciate the NWRS mission, the purpose of the

Refuge and most importantly, the natural and cultural

resources of the Refuge. 

Rationale: All visitors would be on guided tours with

knowledgeable staff that would explain the NWRS

mission, the purpose of the Refuge and the resources of

the Refuge.

Strategies:

2.3.1 – Keep Refuge visitation very low and provide

staff contact on all tours. Adjust visitation limits as

needed to minimize impacts on Refuge resources. 

2.3.2 – Develop a visitor use tracking system to

measure the number of visitors. Use it in conjunction

with the visitor experience survey to identify changes

needed to improve the visitor’s experience. 

2.3.3 – Distribute a survey to tour participants every 7

years (twice during the life of the CCP). Distribute the

survey over the course of a year to ensure that

feedback is collected during all four seasons.

Alternative B

By the end of the CCP, 65 percent of visitors would

understand and appreciate the NWRS, the purpose of

the Refuge and the natural and cultural resources of

the Refuge.

Rationale: Given the drastic shift in the use of Rocky

Flats from nuclear weapons production to a wildlife

refuge, the public is unfamiliar with the site’s new

mission and its natural resources. As people begin to

feel safe and comfortable with accessing the Refuge,

the Service would strive to foster public awareness and

appreciation of the Refuge System and the purpose of

the Refuge. The Refuge’s proximity to urban areas

presents a good opportunity to educate a large number

of people about the NWRS and its role in conservation

across the country. 

Strategies: 

2.3.1 – Include questions in the visitor surveys and

questionnaires (strategy 2.2.1) that measure visitors’

understanding of the NWRS and the Refuge’s

resources.

2.3.2 – Create the interpretive media and programs

identified in the environmental education component

of the Visitor Services Plan, a step-down plan that will

outline visitor services in more detail than the CCP.

2.3.3 – Work with outside partners to ensure visitors

understand the Refuge’s natural and cultural

resources. Potential partners include the CDOW,

surrounding city and county environmental education

entities (government, non-profit and profit), Cold War

Museum, Boulder and Jefferson County high schools

and the State Historic Preservation Office. 

2.3.4 – During peak seasons, provide adequate

personnel to ensure that staff contact is available

to visitors.

2.3.5 – Develop an interpretive signage system that

educates visitors about the natural and cultural

resources at the Refuge.

2.3.6 - Educate visitors about the National Wildlife

Refuge System.

Alternative C

For the life of the CCP, 90 percent of the visitors who

are allowed Refuge access would understand and

appreciate the NWRS mission, the purpose of the

Refuge and most importantly, the natural and cultural

resources of the Refuge.

Rationale: Same as A.

Strategies: 

2.3.1-2.3.2 – Same as A.

2.3.3 – Same as A, except: distribute a survey to

tour participants every 5 years (three surveys

during the life of the CCP). Distribute the survey

over the course of a year to ensure that feedback is

collected during all four seasons.

Alternative D

By the end of the CCP, 50 percent of visitors would

understand and appreciate the NWRS mission, the

purpose of the Refuge and the natural and cultural

resources of the Refuge.

Rationale: Same as B, except. Alternative D would

offer the greatest amount of public use programs and

likely attract the most visitors. Given the increased

number of visitors, Refuge staff would not be able to

communicate personally with as many people;

therefore, the percentage of visitors who develop an

understanding and appreciation of the Refuge System

and the Refuge’s legislated purpose would be lower

than in Alternatives B and C. 

Strategies: Same as B.
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 55

Objective 2.4—Public Use Tracking

Alternative A 

Not applicable to Alternative A.

Alternative B

Within the first year of the Refuge’s establishment, open

a pedestrian-only trail to Lindsay Ranch and monitor

the number of visitors to the Refuge. During years 5

through 7, as more trails are opened, develop baseline

data for numbers of visitors and their use patterns.

Rationale: The Refuge has not been open to the

public; therefore, no visitor use data exists.

Establishing quality baseline data is needed for future

management decisions. A quantitative understanding of

visitor activity (numbers of visitors, trail and use

patterns) combined with an analysis of the quality of

their experience would allow Service staff to enhance

or limit visitor use opportunities. 

Strategies: 

2.4.1 – Develop a visitor use tracking system to

measure the number of visitors. Use it in conjunction

with a visitor experience survey to identify changes

needed to improve the visitor’s experience. 

2.4.2 – Use trail or vehicle counters to record Refuge

visitor numbers.

2.4.3 - Use the results of tracking to guide the design

and planning of public use facilities and programs.

Alternative C 

Not applicable to Alternative C.

Alternative D

Within the first 2 years of establishment, determine

baseline data for numbers of visitors and their use

patterns.

Rationale: Same as B.

Strategies: Same as B.

Objective 2.5—Public Use Assessments

Alternative A 

Not applicable to Alternative A.

Alternative B

By the end of the CCP, 25 percent of visitors would

demonstrate an appreciation of the Service’s

stewardship mission and would have the desire to apply

the conservation ethic to their own lives and share it

with others. 

Rationale: The goal of interpretation and

environmental education is to foster an understanding

and appreciation for natural processes that inspires

people to behave in a more environmentally conscious

manner. In addition to providing on-site recreation and

education opportunities, the public use program would

strive to inspire citizens to become better land

stewards in their own communities and stronger

advocates for the Refuge system. This objective is in

keeping with the goals of the System that promote

establishment of a greater appreciation of fish, wildlife

and plants and their conservation.

Strategies:

2.5.1 – Develop survey questions that gauge visitors

understanding and appreciation of natural resources,

stewardship and environmentally sensitive ethics. 

2.5.2 – Distribute the survey, on and off-site, every 5

years (twice during the life of the CCP). Distribute

the survey over the course of a year to ensure that

feedback is collected during all four seasons.

2.5.3 – Design simple, low cost methods of gathering

change of behavior data (e.g., web, volunteers,

environmental education students).

2.5.4 - Use survey data to guide interpretive and

educational program development as well as public

outreach.

Alternative C 

By the end of the CCP, 50 percent of visitors would

demonstrate an appreciation of the Service’s

stewardship mission and would have the desire to apply

the conservation ethic to their own lives and share it

with others.

Rationale: Given Alternative C’s emphasis on

restoration and conservation, it would be important for

tour guides to communicate the Service’s mission and

ongoing efforts to protect and enhance habitat on the

Refuge. Although Alternative C does not involve

formal public use programming, Refuge staff would

accompany all visitors during their guided tours. Tour

guides would have opportunities to educate visitors

about the Service’s mission and promote the value of a

stewardship ethic. This objective is in keeping with the

goals of the System that promote the establishment of

a greater appreciation of fish, wildlife and plants and

their conservation.

Strategies: Same as B.

Alternative D

By the end of the CCP, 10 percent of visitors would

express an understanding of the land stewardship

mission of the Service and would express the desire to

apply this conservation ethic to their own lives. 
Chapter 2: Alternatives 

56 Rocky Flats National Wildlife Refuge 

Rationale: This objective is in line with NWRS goals

that promote the establishment of a greater

appreciation of fish, wildlife and plants and their

conservation. However, the increased number of

visitors in Alternative D would hamper efforts to

personally communicate with visitors and, as a

consequence, a lower percentage of visitors are likely

to adopt environmental ethics.

Strategies: Same as B.

Objective 2.6—Interpretative Planning

Alternative A

Within 1 year of the Refuge’s establishment, develop

a fact sheet on the Refuge’s history and its natural

and cultural resources. The fact sheet would be

updated annually and would also outline ongoing

scientific research.

Rationale: Because visitor use would be limited

and highly controlled, the purpose of the fact

sheet would be to provide staff with a basis for

presenting information to visitors on guided tours.

The content of the fact sheet would be broad and

cover topics ranging from the Refuge’s Cold War

history to descriptions of habitats to ongoing

scientific research. The fact sheet would also be

used as a mailer to interested parties that request

information on the Refuge. 

Strategies:

2.6.1 – Use the fact sheet to develop guides for

staff who are leading visitor tours.

Alternative B

Within 4 years of the Refuge’s establishment, develop

the interpretive component of a Visitor Services Plan

outlining interpretive facilities and programs. 

Rationale: An interpretive plan would be prepared as

a component of an umbrella Visitor Services Plan. The

interpretive plan would focus on creatively and

accurately informing visitors and students about the

new Refuge. The first step would be to communicate

about the site’s history and safe opportunities for

access. During the early years of the Refuge’s

establishment, it also would be important to inform the

public about the Refuge’s wildlife, natural resources

and scenic values and encourage people to visit the site.

Gradually, the Service would need to develop and

implement comprehensive interpretation programs

that build an appreciation for the intricacies of the

site’s natural systems. 

Strategies:

2.6.1 – Work with outside partners to develop the

interpretive component of the Visitor Services Plan.

Potential partners include CDOW, surrounding city and

county environmental education entities (government,

non-profit and private), Cold War Museum, Boulder

and Jefferson county high schools and the State

Historic Preservation Office. 

Alternative C

Within 1 year of the Refuge’s establishment develop a

fact sheet on the Refuge’s habitat types, wildlife

populations and the Service’s restoration practices.

The fact sheet would be updated annually and would

also outline ongoing scientific research. Following year

3, Refuge staff would use the fact sheet as a basis for

creating simple learning materials about the Refuge’s

natural resources that would be distributed to high

school and college educators.

Rationale: The fact sheet is intended to provide staff

with a basis for presenting information to visitors on

guided tours and for developing simple learning

materials that focus on the Refuge’s ecology. Given

Alternative C’s emphasis on ecological restoration,

the fact sheet would describe the Refuge’s habitats,

wildlife populations as well as the Service’s

management techniques for restoring and maintaining

the grassland ecosystem. The fact sheet would also be

used as a mailer to parties that request information

on the Refuge. 

Strategies: 

2.6.1 – Same as A.

2.6.2 – Work with local educators to determine what

resource learning materials would best supplement

their curriculum. 

Alternative D

Within 2 years of the Refuge’s establishment, develop

the interpretive component of a Visitor Services Plan

outlining interpretive facilities and programs. 

Rationale: Same as B, plus: The interpretive

component of the Visitor Services Plan would be

developed in the early CCP implementation stages

because this alternative has a strong focus on

providing a diversity of compatible public uses. 

Strategies: Same as B.

Objective 2.7—Interpretative Programs

Alternative A 

Not applicable to Alternative A.

Alternative B

Within 15 years of the Refuge’s establishment,

implement the interpretive component of the Visitor
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 57

Services Plan. Implementation would include the

development of a wide range of interpretive programs

and facilities. 

Rationale: An interpretive plan would be prepared as a

component of an umbrella Visitor Services Plan. The

interpretive plan would be developed by Refuge staff

and would describe interpretive as well as environmental

education programs and related facilities. Initially,

interpretation efforts would focus on providing

information related to visitor comfort and safety. During

later years of the CCP implementation, the focus would

shift to the development of site-related interpretive

programs and facilities. The range of programs and

facilities would include guided tours about native flora

and fauna, interpretive signage with both cultural and

natural themes and overlook structures.

Strategies:

2.7.1 – Develop interpretive programs that explore

the site’s natural and cultural resources and are

accessible to children and adults. 

2.7.2 – Distribute interpretive media (newsletter,

flyers, website) in accordance with outreach

techniques outlined in the Visitor Services Plan.

2.7.3 - Develop interpretive facilities including

interpretive signage and interpretive displays.

Alternative C 

Not applicable to Alternative C.

Alternative D

Within 15 years of the Refuge’s establishment,

implement the interpretive component of the Visitor

Services Plan. Implementation would include the

development of a wide range of interpretive

programs and facilities including a visitor center. 

Rationale: Same as B.

Strategies:

2.7.1-2.7.2 – Same as B.

2.7.3 – Design and build (or retrofit) a visitor’s

center and interpretive/orientation exhibits. 

2.7.4 – Develop an interpretive naturalist program.

Objective 2.8—Environmental Education Planning

Alternative A 

No educational programs in Alternative A.

Alternative B

Within 5 years of the Refuge’s establishment,

develop a plan outlining on- and off-site

environmental education programs for high school

and college-level students as well as training for

educators. Environmental education programs

would meet state standards for learning,

accommodate independent studies and tie to the

mission of the NWRS and the site’s natural

resources and history. 

Rationale: In the Denver Metropolitan area, natural

resource study sites are needed to accommodate high

school and college level research. This need was

identified by educators and interpretive specialists at

an environmental education focus group in the fall of

2002 and is based on the Refuge’s proximity to the

Colorado School of Mines and University of Colorado. 

Specialists noted that there are several

environmental programs for elementary and middle

school children in communities surrounding the

Refuge, but programs that provide opportunities for

high school students to develop research skills

through field study are limited. Since high school and

college students are more independent, the costs and

staffing resources needed to develop these types of

programs would be less than they would be for

programs for younger students. Environmental

education programs at the Refuge would be research

oriented and would involve independent study and

would therefore require only limited assistance and

supervision from Refuge staff. The Service would,

however, sponsor teacher workshops for local

educators so they could effectively lead

environmental education programs on the Refuge.

Given current public apprehension about the site’s

safety, an independent and off-site approach to

environmental education is appropriate during the

first 5 years of the Refuge’s establishment. Although

the educational program would focus on high school

and college level students, limited on and off-site

activities for visitors of all ages would also be included.

Strategies:

2.8.1 – Partner with area universities, high schools,

the Cold War Museum and other educational

institutions to develop the environmental education

components of the Visitor Services Plan. 

2.8.2 – Pursue environmental education grants in

collaboration with area universities, high schools, the

Cold War Museum and other educational institutions.

2.8.3 – Use website, email and other media to

distribute information on refuge resources and data

for student use.
Chapter 2: Alternatives 

58 Rocky Flats National Wildlife Refuge 

Alternative C 

No educational programs in Alternative C.

Alternative D 

Within 3 years of the Refuge’s establishment, develop

a plan outlining environmental education programs

for on- and off-site programs for kindergarten (K)-

eighth graders, high school and college level students,

as well as training for educators. Environmental

education programs would meet state standards for

learning and accommodate independent studies and

would be tied to the mission of the NWRS and the

site’s natural resources and history.

Rationale: Same as B, plus programs for younger

students (K-eighth) also would be provided and would

distinguish themselves from other youth programs by

focusing on the prairie ecosystem. The environmental

education programs would include both teacher-led and

staff-led programs as well as independent research. 

Outdoor classrooms and educational signage would

enhance the educational programs.

Strategies: Same as Alternative B.

Objective 2.9—Environmental Education

Implementation

Alternative A

No educational programs in Alternative A.

Alternative B

Within 8 years of the Refuge’s establishment

implement the environmental education components of

the Visitor Services Plan and the program it outlines

for high school and college level students. 

Rationale: Once the Refuge becomes established and

the public becomes more comfortable with site

visitation through public education and outreach

efforts, the Refuge staff would begin implementing the

plan. Education programs would adopt the state’s

model content curriculum standards and focus on the

Refuge’s natural resources. Implementation of the

program would include teacher workshops in which

Service staff train local educators about the Refuge’s

resources. Educators would be required to attend a

Service-sponsored workshop prior to leading

environmental education programs on the Refuge.

Strategies:

2.9.1 – Work with area universities, high schools, the

Cold War Museum and other educational institutions

to implement environmental education programs. 

2.9.2 – Collaborate with area universities, high

schools, the Cold War Museum and other educational

institutions and pursue grants to support

environmental education programs.

2.9.3 – Use a variety of media to distribute a wide

range of data that can be used by high school and

college students.

2.9.4 - Sponsor teacher workshops in order to inform

educators about the Refuge’s resources and facilitate

teacher-led environmental education programs.

Alternative C 

No educational programs in Alternative C.

Alternative D

By year 15, implement the environmental education

components of the Visitor Services Plan and the

program it outlines for K-8th, high school and college

level students. 

Rationale: Same as B.

Strategies: 

2.9.1-2.9.4 – Same as B.

2.9.5 – Construct educational facilities including an

outdoor classroom.

2.9.6 – Use a variety of tools to provide educational

opportunities, including an interactive website that

provides students with current Refuge data on

Refuge happenings.

Objective 2.10 – Hunting Program

Alternative A 

No hunting programs in Alternative A.

Alternative B

Within the first 2 years of the Refuge’s establishment,

institute a controlled youth and/or disabled person’s

deer and/or elk hunting program 2 weekends a year.

After 2 years, annually modify the extent of the hunting

program (number of permits and frequency) in order to

ensure that target level ungulate populations are

maintained. If appropriate for wildlife management,

expand the hunting program to include able-bodied

hunters.

Rationale: Hunting is consistent with the Refuge

System's mission and is identified as a priority wildlife

dependent use on refuges (outlined in the

Improvement Act). Hunting allowed on the Refuge

would be subject to state regulations and safety

requirements. Hunting would be highly controlled in

terms of number of users, user populations, time
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 59

frame and allowable weapons. Hunting would be

limited to short-range weapons such as archery and

shotguns and only open during designated weekends

to youth and disabled hunters. There are very few

hunting opportunities for these special populations in

the region and they would benefit from the tightly

managed program at the Refuge. 

There have been concerns expressed from the public

about the consumption of deer at Rocky Flats if a public

hunting program is implemented. Tissue samples,

including meat tissues, of deer harvested at Rocky

Flats in 2002 have been analyzed for contaminants. The

results of the analysis indicate that there is no

significant uptake of contaminants by deer or other

wildlife species at Rocky Flats. Risk-based calculations

based on these measurements indicate very low health

risks (less than 1x10-6 increased cancer risk).

Hunting would also be an important management tool

for maintaining target ungulate populations and

optimal habitat conditions. If the Service, in

consultation with CDOW determines that a larger

hunting program is needed to control ungulate

populations, the program would be opened to the

general public and not limited to youth and disabled

hunters. A step-down hunting plan would be prepared

as a component of an umbrella Visitor Services Plan. 

Strategies:

2.10.1 – By year 1, develop a hunting plan with public

involvement.

2.10.2 – Work with the CDOW and other interested

entities to develop and implement the hunting plan.

2.10.3 – During the hunting weekends, close the

Refuge to other public use.

2.10.4 – Allow hunters with proof of completion of a

certified hunter safety course to hunt using archery

and shotguns.

Alternative C 

No hunting programs in Alternative C.

Alternative D 

Same as B.

Objective 2.11—Hunting Program Assessment

Alternative A 

No hunting programs in Alternative A.

Alternative B

Following each hunting season, assess the success of

the hunting program and adjust hunting opportunities

as appropriate.

Rationale: Refuge management would need to

monitor and evaluate the newly instituted hunting

program and adjust the program based on ungulate

population sizes, safety, adjacent communities support

and hunter satisfaction (one survey would be developed

to address objectives 2.11 and 2.12).

Strategies:

2.11.1 – Develop a survey for hunters, adjacent

landowners and surrounding communities to measure

their interest and support for the hunting program. 

2.11.2 – Monitor deer populations and habitat

conditions to understand the effects of the hunting

program on wildlife and Refuge resources.

Alternative C 

No hunting programs in Alternative C.

Alternative D 

Same as B.

Rationale: Same as B.

Strategies: Same as B.

Objective 2.12—Hunting Program Benchmarks

Alternative A

No hunting programs in Alternative A.

Alternative B 

About 95 percent of hunters would report no conflicts

with other users, a reasonable harvest opportunity and

overall satisfaction with their Refuge experience.

Rationale: Due to the limited number of hunters and

the healthy resident deer population at the Refuge, it is

likely that youth and disabled individuals would be

afforded a quality hunting experience.

Strategies:

2.12.1 – Develop a brief survey for hunters in order to

evaluate their Refuge experience (combined with

survey used to measure objective 2.11).

2.12.2 – Staff interaction on a one-on-one with

hunters.

Alternative C 

No hunting programs in Alternative C.

Alternative D 

Same as B.

Rationale: Same as B.

Strategies: Same as B.
Chapter 2: Alternatives 

60 Rocky Flats National Wildlife Refuge 

Objective 2.13—Recreation Facilities

Alternative A 

Within 1 year of Refuge establishment, provide a

portable restroom facility to accommodate visitors on

guided tours.

Rationale: No facility development, other than a

restroom, would be required because visitation would

be very limited.

Strategies:

2.13.1 – Install a portable restroom facility.

Alternative B

Within 1 year of the Refuge’s establishment, begin

development of the hiking trail to the Lindsay Ranch

and build an un-staffed welcome kiosk and simple

restroom facilities at the open access point. By year 5,

additional trails would be open to public use. By year

7, 75 percent of all recreation facilities including trails,

and interpretive signage at key locations would be

established. Parking (4 parking areas ranging in size

from 3 to 30 spaces with the largest parking area at the

main entrance accommodating horse trailers) would

also be developed during this period. By year 15,

develop 100 percent of the trail system, including

connections to adjacent areas for pedestrians, cyclists

and equestrians. 

Rationale: Recreational facilities would provide

public access to the Refuge’s many natural and

cultural resources. During the early years of the

CCP implementation, the Service would focus

staffing and budgetary resources on habitat

restoration including revegetating unnecessary roads,

weed management, and restoring stream crossings.

This focus would allow the Service to reduce the

severity of noxious weed infestations and gain a

foothold on road restoration before public trail use

introduces new disturbances onto the landscape. The

Service would also need to conduct baseline Preble’s

surveys before opening the site to public use.

Therefore, with the exception of the immediate

opening of the Lindsay Ranch hiking trail and

welcome kiosk, development of the recreation

facilities would need to be postponed until year 5.

The un-staffed welcome kiosk positioned nearby the

Lindsay Ranch trailhead would inform visitors about

current access opportunities and future public use

facility development.

If early restoration efforts are effective and

budgetary and staffing resources are available, the

Service may initiate construction of new trails and

the conversion of selected roads to trails before year

5 and, if feasible, may open some trails or portions of

trails ahead of schedule. 

Bicycles and horses would be permitted on multiple use

trails in order to facilitate regional trail linkages and to

serve as a mode of transportation for wildlife viewing

and accessing the Refuge from surrounding

communities. Certain trails would be designated for

pedestrian use only. Trails would be designed to

provide connections, use existing road corridors and

minimize impacts to sensitive wildlife resources. 

The unstaffed welcome kiosk would serve as a central

information dissemination point at the main entrance

to the Refuge. The simple structure would include

orientation and interpretive panels to explain Refuge Viewing blinds and overlooks would facilitate wildlife

observation and photography.

© USFWS
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 61

resources and public use opportunities. Eventually, the

structure would be augmented with a seasonally

staffed visitor contact station that would include

permanent displays, administrative offices, Refuge

orientation information and educational materials.

Strategies:

2.13.1 – Construct an unstaffed welcome kiosk and

portable restroom facilities within disturbed areas

at the main parking lot and trailhead.

2.13.2 – Develop a universally accessible trail that links

the main parking area to the Rock Creek overlook.

Also provide an accessible mounting ramp for

equestrian use.

2.13.3 – To provide a quality trail user experience,

reduce reclaimed road widths to single lane, unpaved

trails. However, maintain adequate width of trail

corridors to allow them to also serve as access routes

for maintenance or fire protection vehicles.

2.13.4 – Clearly mark all trails with signage indicating

permitted uses.

2.13.5 - Prior to opening the Lindsay Ranch 

trail improve the trail corridor and conduct a 

Preble’s survey.

2.13.6 – Where appropriate, use existing road corridors

for trails to reduce negative impacts on site resources

and site trails so they minimally impact habitat and

provide a quality visitor experience.

2.13.7 – Realign road/trail corridors in specific areas

with excessive slopes and/or sensitive wildlife habitat,

or where wildlife viewing could be greatly enhanced.

2.13.8 – Designate some sections of the trail for

pedestrian use only and create multi-use trails that

permit bicycles and horses (equestrian use would be

limited to the southern half of the Refuge).

2.13.9 – Implement seasonal trail closures as needed to

protect wildlife and their habitats.

2.13.10 – Use existing roads to provide motorized

access to parking and trailheads. Make all motorized

access and parking areas unpaved.

2.13.11 – Work with adjacent landowners on issues

related to trail linkages to trail systems north, south,

east and west of the Refuge.

2.13.12 – Work with neighboring landowners,

agencies and the Colorado Department of

Transportation (CDOT) to develop safe pedestrian

crossings at all trailheads. 

2.13.13 – Work with others to develop an underpass

under Indiana Street if it is deemed necessary for safe

pedestrian connections to trails and open space east of

the Refuge.

2.13.14 - Post signage at all trailheads that clearly

communicates access opportunities as well as

information about the site’s history, recent clean up

efforts, and differences in management between the

Refuge and neighboring open space properties.

2.13.15 - Educate equestrian users on the importance of

using weed-free hay and removing manure from trails.

2.13.16 - Work with equestrian groups and ensure

that they remove horse manure from trails on a

volunteer basis.

Alternative C 

Within 7 years of the Refuge’s establishment,

develop all recreational facilities. Facilities would

include a short (approximately 1.25 miles) access

road, limited parking with turn around space

(approximately 10 spaces, which can also be used by

a small bus), a pedestrian trail with an overlook,

portable toilets and information/ interpretive panels.

Rationale: Limited recreation facilities would be

provided to visitors to minimize site disturbance and

provide visual access to the Rock Creek drainage. As

one of the least disturbed and most diverse portions of

the Refuge, Rock Creek is a desirable destination. All

facilities would be sited in previously disturbed areas.

Facility development would not be completed until year

7 because management resources would be directed

toward conservation and restoration efforts during the

early years of the CCP.

The Service would continue to partner with CDOW.

© USFWS
Chapter 2: Alternatives 

62 Rocky Flats National Wildlife Refuge 

Strategies:

2.13.1 – Provide portable toilets for both staff and

visitor use.

2.13.2 – Design and construct the unpaved access,

circulation and parking and trail facilities.

2.13.3 – Reclaim disturbed areas within these

corridors by removing paving and reducing 2-track

roads to single track trails. 

2.13.4 – Place an interpretative panel at the Rock

Creek overlook. Post added trail signage to explain

limited access opportunities.

Alternative D 

Within the first 5 years of the Refuge’s establishment,

develop 100 percent of the trail system along with

simple orientation and interpretive signage at key

locations. The trail network would provide pedestrians,

cyclists and equestrian users opportunities to access

the site’s key resource areas and to connect to

adjacent trails and communities. During this period,

develop an unstaffed welcome kiosk and simple

restroom, access and parking facilities (five parking

areas ranging in size from 10 to 30 spaces, designed to

accommodate horse trailers).

Rationale: Same as Alternative B, except parking

areas in this alternative would be larger than in B

to accept a greater diversity of users. In Alternative

D, the simple welcome kiosk would be

supplemented with a staffed visitor center that

would include permanent displays, administrative

offices, Refuge orientation information and

educational materials.

Strategies: Same as B. 

Objective 2.14—Enhanced Recreation Facilities

Alternative A 

Not applicable to Alternative A.

Alternative B

Within 10 years of the Refuge’s establishment, enhance

trails, construct a seasonally staffed contact station

with upgraded restrooms, develop maintenance

facilities and create additional interpretive panels.

Rationale: To bolster the quality of the visitor

experience, additional resources would be expended on

visitor use facilities in the later years of the CCP. A

seasonally staffed contact station would be located in

an existing disturbed area where it would not fragment

wildlife habitat. The facility would allow for more

visitor contact and provide a central location for

information dissemination and interpretation. 

Trail-related improvements would include upgrading

trail surfaces, overlooks and interpretive signage.

These improvements would reduce maintenance costs,

enhance the quality of the visitor experience and

reduce resource damage. Viewing blinds could be

constructed to enhance photographic and wildlife

observation opportunities.

Strategies: 

2.14.1 – Build additional interpretive signs.

2.14.2 – Improve trail alignments, surfaces and

overlooks to minimize resource impacts and

improve the visitor experience.

2.14.3 – Routinely evaluate trail and public facility

impacts and establish measures to minimize

impacts on wildlife from trails and other visitor

facilities and uses.

2.14.4 – Build a viewing blind to enhance wildlife

observation opportunities.

2.14.5 – Construct a small (approximately 750 to 1,000

square feet), seasonally staffed contact station.

2.14.6 - If trail conflicts arise, use signage and

expanded trail corridors on sections of trail where site

lines are limited to divide equestrians from other trail

users.

2.14.7 - If funding is available, position benches at

strategic locations along certain trails and construct a

limited number of shade structures.

Alternative C 

Not applicable to Alternative C.

Alternative D

By the end of the CCP, enhance trails, construct 

a visitor center with upgraded restrooms and 

build additional photography and wildlife 

observation facilities.

Rationale: Same as Alternative B plus; a staffed

visitor center would be located in an existing

disturbed area where it would not fragment wildlife

habitat. The facility would allow for more visitor

contact and provide a central location for information

dissemination and interpretation. 

Strategies: 

2.14.1-2.14.3 – Same as B.

2.14.4 – Construct additional wildlife observation and

photography facilities called for in the interpretation

component of the Visitor Services Plan.

2.14.5 – Develop a visitor center. 
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 63

2.14.6 - 2.14.7 - Same as B

2.14.8 – Develop an outdoor classroom outlined in the

interpretive component of the Visitor Services Plan. 

Objective 2.15— Cold War Museum 

Alternative A 

Not applicable to Alternative A.

Alternative B

If the Cold War Museum secures a site adjacent to

the Refuge and funds to develop a museum within

the life of the plan, the Service would partner to colocate interpretive and other public use facilities

with the organization. 

Rationale: The Refuge Act (P.L. 107-107,sec.3181)

(Refuge Act - Appendix A) states that the Secretary

may establish a Rocky Flats Museum to commemorate

the contribution that Rocky Flats and its work force

provided to winning the Cold War. The legislation

states that the museum shall be located in the City of

Arvada unless the Secretary determines otherwise.

Therefore, there is a possibility that the facility would

be constructed on land adjacent to the Refuge should it

become available and be deemed appropriate.

Partnering with the Cold War Museum on the

development of a museum presents an excellent

opportunity for the Service to reduce the footprint of

public use facilities on the Refuge. The shared facility

would house the simple interpretive displays and staff

office space originally intended for the contact station.

The Cold War Museum would also be staffed

seasonally by Refuge staff and serve as a meeting area

for guided tours and other Refuge programs.

Additionally, the Cold War Museum facility would

present increased opportunities to interpret the the

history of the site as ranchland and a nuclear weapons

production facility.

Strategies:

2.15.1 - Continue working with the Cold War Museum

to explore potential museum sites adjacent to the

Refuge.

Alternative C 

Not applicable to Alternative C.

Alternative D

Same as B.

Rationale: Same as Alternative B, plus; The Cold

War Museum, if located adjacent to the Refuge, would

substitute for the visitor center. The shared facility

would house the interpretive displays and staff office

space originally intended for the visitor center.

Strategies: Same as B

GOAL 3. SAFETY

Conduct operations and manage public access in

accordance with the final Rocky Flats’ cleanup

decision documents to ensure the safety of the Refuge

visitors, staff and neighbors.

Objective 3.1—Staff Safety

Alternative A

Throughout the life of the CCP, all Service staff working

at the Refuge would participate in a Refuge orientation

and training that would introduce them to the site itself,

the institutional controls, CERCLA remedy

requirements, safety procedures (both workers and

public), biological hazards and physical hazards. The

orientation and training would be required prior to

beginning an assignment. 

Rationale: Rocky Flats National Wildlife Refuge is a

CERCLA site that has undergone cleanup. Specific

areas will remain under primary jurisdiction of the DOE

and may remain off limits to the public. It would be

important that Refuge staff receive specific training

regarding the site background, remediation actions,

CERCLA remedy requirements and institutional

controls. This training would help ensure the safety of

employees and visitors. Knowledgeable employees would

be instrumental in ensuring that visitors are kept

informed and feel safe during their visit to the Refuge.

Volunteers would help with restoration activities such as

seed collection.

© Shapins Associates
Chapter 2: Alternatives 

64 Rocky Flats National Wildlife Refuge 

Strategies:

3.1.1 – Develop an orientation training program

that clearly addresses key Refuge safety issues. 

3.1.2 – Provide first aid training to key staff who

may be required to assist the public and staff on

site should an accident occur.

3.1.3 – Develop a record keeping system to

document worker training.

3.1.4 – As appropriate, develop site-specific

appendixes to the Refuge Complex Safety Plan.

3.1.5 – Develop a health and safety plan, within a

year of plan approval, to cover all Refuge

operations.

3.1.6 – Implement a goal of zero incident performance.

Alternative B

Same as A.

Rationale: Same as A.

Strategies: Same as A.

Alternative C

Same as A.

Rationale: Same as A.

Strategies: Same as A.

Alternative D

Same as A.

Rationale: Same as A.

Strategies: Same as A.

Objective 3.2—Visitor Safety

Alternative A

Throughout the life of the CCP, 100 percent of the

visitors on the guided programs would be briefed on

the site’s history. All Refuge employees would be

responsible for ensuring that safety regulations and

other compliance policies are met. 

Rationale: The Rocky Flats site has been closed to

the general public for over 50 years; therefore, it

would be important for the Service to clearly report

the site’s history. The Service, when possible, would

work with the DOE to ensure that visitors understand

access restrictions. 

Strategies: 

3.2.1 – Ensure that every guided program

addresses the site’s history.

3.2.2 – Include safety-related questions in the

visitor survey. Surveys would be used to determine

the safety knowledge of the visitors and

understand how to adjust the safety awareness

program based on this information.

Alternative B

Within 5 years of Refuge establishment 75 percent

of visitors would be aware that the Refuge is safe

and open for public access before they arrive. Upon

arrival, these visitors would be informed of public

use opportunities and restrictions. 

Rationale: Both the EPA and the CDPHE have

concurred that the Refuge would be safe for public

access (Appendix D). However, given the Rocky

Flats site’s nuclear weapons production history, it

would be important for the Service to clearly inform

the public that it is safe to visit the Refuge and that

the site offers opportunities to experience unique

grassland habitat and many wildlife dependent

recreation programs and facilities. In addition to

promoting opportunities for accessing the Refuge,

the Service would communicate to visitors about the

site’s history and areas on-site where public access

is prohibited. Areas retained by DOE would most

likely be closed to public access and access to

sensitive habitats would be restricted at times.

Similarly, the dilapidated structures within the

Lindsay Ranch complex may be fenced off if they

pose a safety hazard. 

Outreach materials, signage and staff would

educate the public about the steps to becoming a

refuge, access restrictions and opportunities. DOE

would post signage and construct fencing or

another means of boundary demarcation to clearly

identify all restricted areas that are subject to

institutional controls. The Service would continue

to work with DOE to ensure that the boundary is

clearly visible to the public.

Strategies: 

3.2.1-3.2.2 – Same as A.

3.2.3 – Provide maps and interpretive signs at all

trailheads that inform visitors about the site’s history,

clean up, and access restrictions.

3.2.4 – Help potential users understand the site’s

restrictions and public use opportunities through a

diversity of media including TV and radio programs,

brochures, personal talks, website, public service

announcements, news releases and articles. Also work

with local school systems to educate teachers and
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 65

students about the Refuge’s recreational and

educational potential.

3.2.5 – Provide Refuge access information to

regional map and tour book publishers.

3.2.6 – Develop surveys that are implemented at

Refuge access points to determine the safety

knowledge of the visitors and understand how to

adjust the awareness program based on this

information. Data collection would be consolidated

into one public use survey encompassing survey

needs identified in other goals. 

3.2.7 – Maintain a law enforcement presence on-site

and ensure that Refuge employees are well informed

and can educate visitors on Refuge safety restrictions

and allowable uses.

3.2.8 – Document violations and measure the success

of the program by the reduction in violations.

3.2.9 – Close the Refuge to public use prior to and

during the use of prescribed fire on the Refuge.

3.2.10 - Work with DOE to clearly demarcate the

DOE retained land boundary with a barbed-wire

agricultural fence, permanent obelisks, signage or

other appropriate means.

3.2.11 - Address the site’s history in guided programs.

Alternative C

Same as A.

Rationale: Same as A.

Strategies: 

3.2.1-3.2.2 – Same as A.

Alternative D

Same as B.

Rationale: Same as B.

Strategies: 

3.2.1-3.2.2 – Same as A.

3.2.2-3.2.11 – Same as B.

GOAL 4. EFFECTIVE AND OPEN COMMUNICATION

Conduct communication outreach efforts to raise

public awareness about the Refuge programs,

management decisions and the mission of the U.S

Fish & Wildlife Service and the National Wildlife

Refuge System among visitors, students and

nearby residents.

Objective 4.1—Outreach

Alternative A

Throughout the life of the CCP, disseminate

information collected on the Refuge through a fact

sheet sent to interested parties upon request. 

Rationale: Historically, Rocky Flats has been a

controversial site with substantial public interest and

concern. The Service would respond to inquiries and

educate the public about the site’s transformation from

a nuclear weapons production facility to a National

Wildlife Refuge. In order to achieve the Refuge’s

purposes, vision and goals, the Service would need to

communicate with the public. 

Strategies: 

4.1.1 – Distribute the fact sheet developed in Objective

2.6 to individuals, communities, civic and educational

organizations, conservation groups and other

interested stakeholders upon request.

Alternative B

Within 5 years of the Refuge’s establishment, develop

and implement four outreach methods to inform the

public about environmental stewardship, safety issues,

CCP implementation and educate them on the missions

of the Service and NWRS. Once established in year 1,

outreach efforts would be ongoing throughout the life of

the CCP.

Rationale: Same as Alternative A, plus the Service

would work with stakeholders, interest groups and the

general public to inform them about the site’s resources

and the visitor programs and facilities. In order to

achieve the Refuge’s purposes, vision and goals, the

Service would need to maintain open and regular

communication with the public. 

Strategies:

4.1.1 – At a minimum conduct outreach opportunities in

Broomfield, Boulder, Arvada and Westminster and

recruit participation from the local municipal

governments, business communities, civic and

educational organizations, conservation groups,

recreational users and other interested stakeholders.

4.1.2 – Establish a monitoring system to measure the

diversity of groups in attendance at outreach events.

4.1.3 – Use a variety of outreach communication

methods such as a newsletter, website, news releases,

local newspaper column and TV and radio programs.

4.1.4 – Encourage Refuge staff to attend selected

government and organization meetings and participate

with DOE in communicating with the public about

long-term stewardship programs.
Chapter 2: Alternatives 

66 Rocky Flats National Wildlife Refuge 

Alternative C

Same as B. 

Rationale: Same as B. 

Strategies: Same as B.

Alternative D

Same as B.

Rationale: Same as B.

Strategies: Same as B.

GOAL 5. WORKING WITH OTHERS

Foster beneficial partnerships with individuals,

government agencies and non-governmental

organizations and others that promote resource

conservation, compatible wildlife-related research,

public use, site history and infrastructure.

Objective 5.1—Emergency

Alternative A

Within 1 year of the Refuge’s establishment,

emergency response agreements would be in place

with all adjacent fire districts for mutual aid in

responding to fire and other emergencies. Additional

emergency response and fire protection agreements

would be developed with state and local law

enforcement agencies as needed.

Rationale: The Refuge is small and in close proximity

to a number of communities. Given the Refuge’s

location and the other on-site safety issues, rapid

suppression of fire or response to other emergencies

would be essential.

Strategies:

5.1.1 – Meet annually, or as often as needed, with

partnering agencies including DOE, to coordinate fire

and emergency response plans.

5.1.2 – Coordinate all prescribed fires with all nearby

fire districts and other cooperating agencies.

Alternative B

Same as A.

Rationale: Same as A.

Strategies: Same as A.

Alternative C

Same as A.

Rationale: Same as A.

Strategies: Same as A.

Alternative D

Same as A.

Rationale: Same as A.

Strategies: Same as A.

Objective 5.2—Conservation

Alternative A

Within 1 year of the Refuge’s establishment, develop

an agreement with the CDOW to coordinate habitat

and wildlife management strategies related to habitat

and resource conservation. Maintain open dialogue

with adjacent landowners and local governments. 

Rationale: The Service would establish a partnership

with CDOW and afford the agency opportunities to

supplement the Service’s limited habitat and wildlife

conservation programs. The Service would cooperate

with CDOW on potential species reintroductions. The

Service would remain open to partnering with adjacent

landowners and local governments if opportunities

arise to conserve additional habitat. 

Strategies:

5.2.1 – Seek CDOW’s input on devising and

implementing wildlife management strategies and

conservation objectives.

5.2.2 – Work closely with surrounding landowners,

open space and natural resource entities such as

Jefferson County, City of Boulder, Boulder County,

City and County of Broomfield, City of Westminster,

Town of Superior and City of Arvada to develop

resource management approaches for issues that

cross Refuge boundaries.

Alternative B

Throughout the life of the CCP, Refuge staff would

meet annually (at a minimum) with local governments

and other adjacent landowners, to coordinate habitat

management and resource conservation strategies. 

Rationale: The Service would encourage a regional

management approach for the conservation and

restoration of natural resources, which would require

collaboration with surrounding landowners. Many

natural resource management issues such as invasive

weed control, wildlife corridors, recovery of declining

species and impacts to resources caused by visitors

would need to be coordinated across boundaries. 

Strategies:

5.2.1 – Work closely with surrounding open space and
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 67

natural resource entities such as Jefferson County,

City of Boulder, Boulder County, City and County of

Broomfield, City of Westminster, Town of Superior,

City of Arvada and CDOW to develop resource

management approaches for issues that cross

Refuge boundaries.

5.2.2 – Use volunteers to help with conservation and

restoration activities. 

5.2.3 – Work with adjacent landowners to maintain

corridors for ungulate populations and other wildlife

that migrate seasonally to and from the Refuge.

Alternative C

Same as B.

Rationale: Same as B.

Strategies: Same as B.

Alternative D

Same as B.

Rationale: Same as B.

Strategies: Same as B.

Objective 5.3—Research

Alternative A

Throughout the life of the CCP, maintain agreements

with universities and federal agencies for compatible

scientific research. 

Rationale: The Service would encourage ongoing

compatible research efforts to continue after closure

and transfer. Due to limited resources allocated to

partnerships and research, in particular, the Service

would rely on outside researchers from other agencies

and universities to broaden its data base. Research

having direct implications for Refuge management,

such as information gathering and analysis focused on

wildlife, habitat and public use would considerably help

the Refuge and surrounding entities.

Strategies: 

5.3.1 – Establish criteria to evaluate research

proposals. Each proposal would be subject to a

compatibility determination.

5.3.2 – Emphasize and support research focusing on

studies that directly affect Refuge management.

Alternative B

Within the first 5 years of the Refuge’s establishment,

develop a list of research needs to be addressed by

Refuge staff and external researchers and establish a

system to evaluate and approve proposals for

compatible scientific research that focuses on the

Refuge’s habitat, wildlife and public use.

Rationale: Because the Refuge would be a newly

established refuge with limited resources, it would be

important for Service staff to collaborate with outside

researchers. Research partnerships would allow the

Service to expand its baseline data and study

management techniques more efficiently. Research that

has direct implications for Refuge management, such

as information gathering and analysis focused on

wildlife, habitat and public use would be instrumental

in shaping the management direction of the Refuge and

similar prairie landscapes throughout the life of the

CCP and into the future.

Strategies 

5.3.1 – Establish criteria to evaluate research

proposals that would ensure research is compatible

with the Refuge mission, purpose and goals.

5.3.2 – Same as A..

5.3.3 – Partner with others to seek funding to address

identified research needs.

Alternative C

Within the first 5 years of the Refuge’s establishment,

develop a list of research needs to be addressed by

Refuge staff and external researchers and establish a

system to evaluate and approve proposals for

compatible scientific research that focuses on longterm habitat changes and species of concern.

Rationale: Same as B except: Research would not

address public use, but focus on habitat and wildlife. 

Strategies: Same as B.

Alternative D

Same as B.

Rationale: Same as B.

Strategies: Same as B.

Objective 5.4—Volunteer

Alternative A 

No volunteer program in Alternative A.

Alternative B

Within 3 years of the Refuge’s establishment, create a

volunteer program and support the establishment of a

Friends group for the Rocky Flats National 
Chapter 2: Alternatives 

68 Rocky Flats National Wildlife Refuge 

Wildlife Refuge.

Rationale: Volunteers are essential for the growth and

success of many refuges within the NWRS. Volunteers

can assist with both resource conservation activities

and visitor use programs. Support of a Friends groups

would play an important role in leveraging local private

resources and public support for Refuge programs.

Strategies

5.4.1 – Recruit volunteers from equestrian and bicycle

groups and others to help maintain trails.

5.4.2 – Develop and implement a volunteer program

that defines volunteer opportunities for participation

in wildlife habitat and public use programs.

5.4.3 – Work with interested individuals to establish

and maintain a nonprofit corporation who’s objective

is to positively support the Refuge.

Alternative C 

No volunteer program in Alternative C.

Alternative D

Same as B.

Rationale: Same as B.

Strategies: Same as B.

GOAL 6. REFUGE OPERATIONS

Based on available funds, provide facilities and staff

to fulfill the Refuge vision and purpose.

Objective 6.1—Staffing

Alternative A

Within 2 years of the Refuge’s establishment, obtain

base funding for one full-time employee (1.0 FTE) and

one seasonal (0.5 FTE) at the Refuge and assign

collateral duties for Rocky Mountain Arsenal NWR

staff. Fire management funding would be used for an

additional two full-time (2.0 FTE) and two seasonal (1.0

FTE) employees.

Rationale: Given restrictions on general public use

and the limited amount of habitat and wildlife

conservation programs, minimal on-site staff would be

required. Due to the use of prescribed fire within the

Rock Creek Reserve and the high probability and

frequency of wildfires in the grasslands of the Refuge,

fire personnel are included in the staffing. Refuge fire

staff (3.0 FTE) would be responsible for suppressing

wildfires, developing prescribed burn plans, overseeing

prescribed fires and developing and maintaining

mutual aid agreements. Service employees would be

available to lead a limited number of Refuge tours. 

Strategies:

6.1.1 – Follow Service protocols for budget

development and hiring of staff.

Alternative B

Within 2 years of the Refuge’s establishment, obtain

base funding for three employees (3.0 FTE) for the

Refuge and within 5 years, add one employee (1.0

FTE). Also assign collateral duties for Rocky Mountain

Arsenal NWR staff. Fire management funding would

be used for an additional two full-time (2.0 FTE) and

two seasonal (1.0 FTE) employees.

Rationale: Due to the site’s urban context, high public

interest and extensive restoration requirements, onsite staffing and facilities would be necessary from the

onset of the CCP’s implementation. Staffing needs

would be based on the current and projected NWRS’s

budgetary environment and the objectives of the CCP.

Three full-time employees (3.0 FTE) would be required

within 2 years of Refuge establishment to begin

instituting habitat and restoration management

practices. An increase in public use after year 5 would

require one additional employee (1.0 FTE). 

Due to the use of prescribed fire in this alternative and

the high probability and frequency of wildfires in the

grasslands of the Refuge, fire personnel are included in

the staffing. Refuge fire staff (3.0 FTE) would be

responsible for suppressing wildfires, developing

prescribed burn plans, overseeing prescribed fires and

developing and maintaining mutual aid agreements.

Because the Refuge would be managed as part of a

complex, in conjunction with Two Ponds NWR and the

RMA, some staffing resources would be shared between

the three refuges. Collateral duties for Two Ponds and

RMA staff at the Refuge would ensure that the new

Refuge benefits from the experience and expertise of

trained staff. 

Strategies: Same as A. 

Alternative C

Within 2 years of the Refuge’s establishment, obtain

base funding for five employees (5.0 FTE) for the

Refuge and assign collateral duties for Rocky Mountain

Arsenal NWR staff. Fire management funding would

be used for an additional two full-time (2.0 FTE) and

two seasonal (1.0 FTE) employees.

Rationale: The extensive site restoration, research,

monitoring and habitat management to be initiated

upon Refuge establishment would require five
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 69

employees (5.0 FTE). Staffing needs would be based

on the current and projected NWRS’s budgetary

environment and the objectives of the CCP. 

Staffing for suppressing both prescribed fire and

unplanned grassland fires has the same rationale as

Alternative B, as does the sharing of staff resources

between Two Ponds NWR and the RMA.

Strategies: Same as A. 

Alternative D

Within 2 years of the Refuge’s establishment, obtain

base funding for six employees (6.0 FTE) for the

Refuge and within 5 years add two additional

employees (2.0 FTE). Also assign collateral duties for

Rocky Mountain Arsenal NWR staff. Fire management

funding would be used for an additional two full-time

staff (2.0 FTE) and one seasonal employee (0.5 FTE).

Rationale: Due to the site’s urban context, high public

interest and attractive recreational resources, on-site

staffing and facilities would be necessary during the

early stages of plan implementation. Staffing needs

would be based on the current and projected NWRS’s

budgetary environment and the objectives of the CCP.

Six employees (6.0 FTE) would be required within 2

years of Refuge establishment to fulfill the diverse

habitat, wildlife and increased public use

responsibilities outlined in Alternative D. Two more

employees (2.0 FTE) would be needed by year 5, upon

implementing additional public use programs.

Dedicated visitor services staff would be included

among the Refuge staff. 

Staffing for suppressing unplanned grassland fires has

the same rationale as Alternative B, as does the sharing

of staff resources between Two Ponds NWR and the

RMA. However, one-half less FTE is needed because

prescribed fire is not included in this alternative.

Strategies: Same as A. 

Objective 6.2—Operations and Management Facilities

Alternative A

Operations and maintenance (O&M) facilities at RMA

would support all maintenance, conservation and

administrative activities at the Refuge. 

Rationale: Primary maintenance facilities and

equipment storage for the Refuge would be at the

RMA and no facility development would take place at

the Refuge. Refuge O&M funding may be required to

Prescribed burning would occur in designated areas outside of DOE-retained lands in Alternatives A, B, and C.

© USFWS
Chapter 2: Alternatives 

70 Rocky Flats National Wildlife Refuge 

support conservation and restoration projects in the

Rock Creek Reserve, however, projects would not

necessitate the support of onsite O&M facilities. 

Strategies:

6.2.1 – Prepare and submit projects for the Refuge

Operations Needs System and Maintenance

Management System database.

6.2.2 – Prepare a fire cache and install necessary

water storage systems (e.g., tanks).

6.2.3 – Coordinate equipment use with RMA staff.

6.2.4 – Install boundary and trailhead signs along the

Refuge boundary in order to identify access points

and ownership. 

6.2.5 – Renovate existing, on-site vehicle search

buildings to create a small office space and to use for

storage and other refuge operations.

Alternative B

Within 5 years of the Refuge’s establishment, develop

50 percent of administrative and visitor use facilities for

on-site presence and connectivity with regional trail

systems. Within 5 years of the Refuge’s establishment,

develop 50 percent of O&M facilities needed to support

public use and conservation objectives. By year 10,

complete all O&M facilities. 

Rationale: During the early years of CCP

implementation, management resources would be

focused on public outreach and education beyond the

site boundaries, developing partnerships and securing

funding. Habitat conservation and restoration would

be the primary management priority. Construction of

the trail system, signage and orientation and

interpretation facilities would follow the development

of restoration measures. 

During the first 5 years of the Refuge’s establishment,

the Service staff would rely on O&M facilities at RMA.

Due to public outreach events and word of mouth,

visitor numbers are likely to substantially increase

once the Refuge is fully open to the general public in

the fifth year of the Refuge’s establishment, therefore,

it would be important to establish on site staffing and

complete visitor facilities by year 10. Once visitor use

facilities are established, on-site maintenance facilities

would be constructed and interpretive signage and

trails would be upgraded. Throughout the life of the

CCP, RMA O&M facilities and staff would supplement

Refuge operations. The Service will not use the land

at Rocky Flats for residential or “bunkhouse” facilities

during the life of the CCP.

Strategies:

6.2.1- 6.2.5 – Same as A.

6.2.6 – Provide administrative offices for Refuge

employees within the contact station.

6.2.7 – Pursue partnerships and funding sources

including but not limited to challenge cost share

projects, Federal Highway Administration, CDOT and

other transportation entities, Great Outdoors Colorado,

CDOW, Mile High Youth Corps, Colorado Historical

Society and Volunteers for Outdoor Colorado.

6.2.8 – Where possible, screen maintenance facilities

from visitor use areas.

6.2.9 – Construct a small (1,750 to 2,250 square feet)

maintenance/storage facility.

6.2.10 - Install a cistern or other storage system to

provide water to the visitor contact station, offices,

and maintenance facilities.

6.2.11 - Co-locate O&M facilities with public use

facilities and construct facilities in areas that are

already disturbed or degraded and will not impact

important wildlife habitat.

Alternative C

Within 3 years of the Refuge’s establishment,

develop a satellite maintenance facility to support

Refuge operations.

Rationale: Given the emphasis on ecological

restoration in Alternative C, the construction of O&M

facilities would precede the development of public use

facilities. Primary maintenance facilities and equipment

storage for the Refuge would be at the RMA with only

a small facility at the Refuge. Limited facility

development at the Refuge would reduce O&M

expenses and ensure that the maximum amount of land

is conserved. The construction of the maintenance

facilities within the early years of the Refuge’s

establishment would also help the Service establish an

on-site presence.

Strategies: Same as B. 

Alternative D

Within 4 years of the Refuge’s establishment, develop

75 percent of the administrative and visitor use

facilities for on-site presence and connectivity with

regional trail systems. Within 5 years of the Refuge’s

establishment, develop 50 percent of O&M facilities

needed to support public use and conservation

objectives. By year 10, complete all O&M facilities. By

year 15, complete construction of the visitor center.
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 71

Rationale: Given the emphasis on public use in

Alternative D, development of administrative and

visitor use facilities would be accelerated and all trails

and preliminary visitor use facilities (e.g., welcome

kiosk, restrooms) would be developed early in the life

of the CCP. Extensive public outreach events and word

of mouth are likely to attract large numbers of visitors

in the early years of the Refuge’s establishment;

therefore, it would be important to establish on-site

staffing and visitor facilities early in the CCP. Initial

facility development is crucial orienting visitors and

educating them about the Refuge’s resources. The

facilities would be upgraded over the life of the CCP,

culminating in the construction of a visitor center by

year 15. 

During the first years of the Refuge’s establishment,

while management resources are focused on habitat

conservation and visitor use facility development, the

Service staff would rely on O&M facilities at RMA.

With the inclusion of equestrian trail uses, additional

O&M resources would be allocated to the development

of large parking areas (that can accommodate horse

trailers) and additional trail maintenance. Noxious

weed control along multi-use trails would be more

intensive. Once visitor use facilities are established, the

maintenance facilities would be constructed and

interpretive signage and trials would be upgraded.

Maintenance facilities would be sufficient in size so

that no satellite facilities at RMA would be required. 

Strategies: 

6.2.1-6.2.5 – Same as A.

6.2.6- 6.2.8 – Same as B.

6.2.9 – Construct a larger (approximately 2,500 to

3,000 square feet) maintenance/storage facility.

6.2.10-6.2.11 - Same as B.

Objective 6.3—Fencing

Alternative A 

Upon the Refuge’s establishment and throughout the

life of the CCP, maintain the existing barbed-wire stock

fence. The fence would line the entire perimeter and

would be suitable for excluding neighboring livestock

from trespassing on the Refuge.

Rationale: State law requires that a stock fence

enclose the Refuge to prevent livestock trespassing.

Visitor safety and wildlife habitat goals would be

accomplished through signage, staff contact with

visitors and internal fencing of off-limits areas. 

The Service would also work closely with DOE to

ensure that the DOE retained land boundary is 

clearly demarcated.

Strategies:

6.3.1 – Attach boundary signage to the perimeter fence

and any fencing delineating the DOE retained area.

6.3.2 - Advise DOE on the use of signage and fencing to

demarcate the boundary of lands subject to

institutional controls.

Alternative B

Same as A.

Rationale: Same as A.

Strategies: Same as A.

Alternative C

Same as B.

Rationale: Same as B.

Nuttal’s larkspur.

© Nelson, RFETS
Chapter 2: Alternatives 

72 Rocky Flats National Wildlife Refuge 

Strategies: Same as A. 

Alternative D

Same as B.

Rationale: Same as B.

Strategies: Same as A.

Objective 6.4—Cultural Resources - Lindsay Barn

Alternative A

Within 15 years of Refuge establishment, develop an

inventory of cultural resources found on the Refuge

and maintain the Lindsay Ranch barn.

Rationale: Although the Lindsay Ranch structures

are not eligible for listing in the National Register of

Historic Places, they are valued by the public and

present an opportunity to interpret the early ranching

era at the Refuge. The Lindsay Ranch structures

including a barn and house are not structurally sound

and are in varying states of decay. In order to preserve

the scenic value of the cultural resource, the Service

and DOE initiated a project to stabilize the barn in

2003. Since the ranch house is not structurally sound

and presents a safety concern, the Service chose to

concentrate its stabilization efforts on the barn. The

house would be fenced off or taken down to minimize

safety hazards. Should partners raise sufficient funds

to stabilize and interpret the ranch house, the Service

will be amenable to working with them to complete

such a project. Over time, additional cultural resources

may be uncovered on the Refuge. The Service would

maintain a record of identified cultural resources.

Strategies:

6.4.1 – Pursue partnerships to help fund the ongoing

stabilization of the Lindsay Ranch barn.

6.4.2 – Maintain an inventory of all cultural resources

found on site.

6.4.3 – Following all prescribed fires in the Rock

Creek Reserve, conduct limited surveys of burned

areas for archaeological or cultural resources or

artifacts.

Alternative B

By year five, develop a step-down plan for the

preservation of all cultural resources on the Refuge. By

the end of the CCP, interpret the Lindsay Ranch barn.

Rationale: Same as A, plus where appropriate,

provide interpretive signage to help visitors better

understand the history of the Lindsay Ranch.

Strategies:

6.4.1-6.4.2 – Same as A.

6.4.3 – Following all prescribed fires, survey burned

areas for archaeological or cultural resources or

artifacts.

6.4.4 – Work with interested parties and organizations

to interpret the Lindsay Ranch and the story of

homesteading on the Refuge.

6.4.5 – Use trail signage to identify the historic

stage-coach stop and apple orchard in the Woman

Creek drainage. 

Alternative C

By year five, develop a step-down plan for the

preservation of all cultural resources on the Refuge.

Remove the Lindsay Ranch structures and restore the

area to native vegetation.

Rationale: The Lindsay Ranch structures were

identified as “ineligible” for listing in the National

Register of Historic Places and stabilization and/or

preservation of the barn and house is not mandatory.

Given Alternative C’s emphasis on ecological

restoration, the Lindsay Ranch structures would be

removed and the site would be restored to presettlement conditions. Prior to demolition, the Ranch

structures be documented with photographs. Over

time, additional cultural resources may be uncovered

on the Refuge. The Service would maintain a record of

all identified cultural resources.

Strategies:

6.4.1-6.4.2 – Same as A.

6.4.3 – Same as B.

6.4.6 – Restore stream crossings and revegetate roads

within the Lindsay Ranch site.

6.4.7 – Use native vegetation to restore the area to

pre-settlement conditions.

Alternative D

Same as B.

Rationale: Same as B.

Strategies:

6.4.1-6.4.2 – Same as A.

6.4.3 – Following all wildfires, survey burned areas for

archaeological or cultural resources or artifacts.

6.4.4-6.4.5 – Same as A.
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 73

Objective 6.5—Cultural Resources - Site History

Alternative A 

Not applicable to Alternative A.

Alternative B

Within 5 years of the Refuge’s establishment, develop a

cooperative partnership with interested stakeholders,

including the Cold War Museum, to interpret the

history of the Refuge.

Rationale: The history of the Refuge represents

diverse periods of time and topics ranging from Native

American history to the settlement of the western

frontier and nuclear weapons production during the

Cold War. The history and cultural resources of the

Refuge are of interest to many groups and individuals.

Interested stakeholders, including the Cold War

Museum, would be key partners in interpreting the

site’s history and cultural resources and securing

funding for interpretation and stabilization efforts. 

Strategies:

6.5.1 – Work with a variety of interested entities to

manage and interpret the history of the site as it

evolved through time. Interpretation programs would

illuminate the historical evolution of the site including

Native Americans, early settlement, ranching and

Cold War histories. 

6.5.2 – Work with appropriate state and federal

agencies to manage the site’s cultural resources

appropriately.

Alternative C

Not applicable to Alternative C.

Alternative D

Same as B.

Rationale: Same as B.

Strategies: Same as B.

2.6. STAFFING AND BUDGETS

Refuge budgets generally include ongoing operations

funds for staffing, maintenance and utility needs.

Estimated staff for each alternative is the minimum

necessary to accomplish the goals of that alternative. A

detailed list of this staff along with the costs for each

alternative are provided in Appendix F. Maintenance

expenses would cover activities necessary to keep

facilities and equipment in good working order. Utilities

would vary by alternative and would include gas,

electrical, phone and cleaning. In addition, restoration

and implementation costs would be calculated for each

alternative based on estimated needs. These one-time

items associated with opening the Refuge would

include costs to restore habitat, build facilities and

purchase equipment. Fire management funds are

administered from a different funding source and are

listed separately.

Because the Refuge would be managed as part of a

complex that includes the RMA and Two Ponds, there

would be costs that could be shared between the

facilities. Therefore, both operations and restoration

and implementation costs have been broken out

between items that would require new funding for the

Refuge and items that would be covered from the

complex’s existing base funding. Furthermore, large

equipment needed for restoration activities is assumed

to be shared with the other refuges in the complex and

is included with existing base funding.

Estimated costs for alternatives are summarized in

Table 5. Costs are presented in 2003 dollars. Because

the Refuge would not be established for several years,

these numbers would need to be adjusted for inflation

when the Refuge’s funding request is made.

Staffing and budget would be allocated to protect and

restore native grasses such as forktip three-awn.

© Nelson, RFETS
Chapter 2: Alternatives 

74 Rocky Flats National Wildlife Refuge 

ALTERNATIVE A

In Alternative A, the currently planned management

approach described in the Rock Creek Reserve

Integrated Natural Resources Management Plan

(DOE 2000) would be maintained. This would require

two employees with an annual funding target of about

$164,000 for operations. Restoration and

implementation costs amount to about $275,000, most

of which is for maintenance equipment, facilities,

restoration of unused roads and stabilization of the

Lindsay Ranch barn. Fire management activities on

the Refuge will require the equivalent of three

employees (2 full-time and 2 seasonals) with annual

funding of $133,000, as well as an up-front expenditure

of $125,000 for equipment and supplies. Total costs over

the 15-year period for this alternative would amount to

about $3.7 million.

ALTERNATIVE B

Compared to Alternative A, Alternative B would

require higher funding levels. It would require the

equivalent of four employees with an annual funding

target of $543,000 for operations. In addition, this

alternative would require $1.2 million in restoration

and implementation costs, over a third of which is for

maintenance equipment and related storage.

Remaining funds requested are for habitat restoration

supplies and visitor-related facilities. Fire management

activities on the Refuge will require the equivalent of

three employees (2 full-time and 2 seasonals) with

annual funding of $133,000, as well as an up-front

expenditure of $125,000 for equipment and supplies.

Estimated costs in 2003 dollars over the 15-year period

for this alternative are $8.6 million.

ALTERNATIVE C

Alternative C would require more funding than

Alternatives A and B, but less than Alternative D. This

is mainly due to the addition of one employee - for a

total of five - and the use of leased off-site office space

rather than new construction on-site. Staff and their

funding would shift emphasis to habitat conservation

and restoration activities, with annual operations costs

estimated at about $824,000. One-time restoration and

implementation activities would require about $882,000,

primarily focused on restoration supplies, maintenance

equipment and related storage. Fire management

activities on the Refuge would require the equivalent of

three employees (2 full-time and 2 seasonals) with

annual funding of $133,000, as well as an up-front

expenditure of $125,000 for equipment and supplies.

Estimated costs in 2003 dollars over the 15-year period

for this alternative are $11.5 million.

ALTERNATIVE D

Alternative D would require the largest amount of

funding because of its facility development and staffing

requirements. Although some funding would be used

for habitat conservation and restoration, the staffing

and budget would be weighted toward public use.

Alternative D would require eight full-time employees.

Annual operations costs are estimated slightly over $1

million, due to both an increased public use staff and

increased facility maintenance costs. Restoration and

implementation costs would be $4.5 million, primarily

due to the addition of a $3 million visitor center. Fire

management activities on the Refuge would require the

equivalent of two employees with annual funding of

about $84,000, as well as an up-front expenditure of

$125,000 for equipment and supplies. Estimated costs

in 2003 dollars over the 15-year period for this

alternative are $16.6 million.

2.7. PARTNERSHIP OPPORTUNITIES

The Service would pursue opportunities to work with

federal, state and local agencies, conservation groups,

adjacent landowners and other interested parties to

advance the purpose of the Refuge and to benefit

Alternative

Cost over 

15 Years

(millions 2003$)

Annual 

Operations

(thousands)

Restoration and

Implementation

(millions)

Fire

Management

(millions)

Major Components of Costs

A $3.7 $164 $0.3 $1.6 Small staff, limited restoration

B $8.6 $543 $1.2 $1.6 Balances public-use and restoration efforts

C $11.5 $824 $0.9 $1.6 Restoration staff, off-site office lease

D $16.6 $1,037 $4.5 $1.1 Increased public use staff and facilities

Table 5. Estimated Costs of Alternatives
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 75

surrounding communities. Many natural resource

management issues such as invasive weed control,

wildfire management, wildlife corridors, recovery of

declining species and impacts to resources caused by

visitors would need to be coordinated across boundaries.

Collaboration with surrounding open space and natural

resource entities such as Jefferson County, City of

Boulder, Boulder County, City and County of

Broomfield, City of Westminster, City of Arvada and

CDOW would be instrumental in achieving the Service’s

ecosystem management goals. The Service would also

develop and maintain mutual aid agreements related to

fire control with adjacent jurisdictions.

The Service would encourage and support research and

management studies on Refuge lands that inform

natural resource management decisions. Scientific

research partnerships would give the Service

opportunities to analyze independently collected data

and use research results to develop adaptive

management strategies. As data-sharing partners,

university faculty, staff and students as well as

independent scientists would be instrumental in

helping the Service develop baseline biological data. 

In Alternatives B and D, the Service also would

collaborate with interested organizations such as the

Cold War Museum to interpret the history of the Rocky

Flats site and communicate its story to Refuge visitors.

Other potential partnerships related to hunting,

environmental education, trail use and interpretation

may involve local universities, school districts,

conservation and/or historical organizations, open space

agencies, recreation user groups and the CDOW. 

Volunteer partnerships in Alternatives B and D would

be cultivated with individuals interested in learning

more about the Refuge and assisting staff with various

aspects of Refuge operations. The Service also would

support the development of a “Friends” group for the

new Refuge. Such a group would play an important

role in leveraging private resources and public support

for Refuge programming. 

2.8. MONITORING AND EVALUATION

In all alternatives, the Service would adopt an adaptive

management approach to the implementation of the

proposed management objectives. Adaptive

management is “the rigorous application of

management, research and monitoring to gain

information and experience necessary to assess and

modify management activities...A process that uses

feedback from Refuge research and monitoring and

evaluation of management actions to support or modify

objectives and strategies at all planning levels” (U.S

Fish & Wildlife Service 2000). Because the Refuge is

new, ongoing monitoring of the effectiveness of habitat

restoration and conservation and public use is essential

for adapting and refining objectives and strategies to

ensure management goals are achieved. Monitoring

and evaluation has been integrated into many resource

management and public use objectives. 

The Service would establish biological monitoring

programs to assess the effect of restoration and

conservation measures on habitat condition. The

Service would monitor certain habitat conditions to

determine if the management strategies are serving

the needs of native wildlife species. For example,

periodic Preble’s surveys would help determine the

effects of riparian habitat protection and enhancement

efforts. To assist in the control of invasive species such

as Dalmatian toadflax and diffuse knapweed and to

restore native plant communities, the Service would

evaluate the use of different treatments and control

mechanisms for the most efficient forms of weed

suppression. The Service would evaluate the use of an

IPM approach and, depending on the alternative

selected, prescribed fire, managed grazing, or use of a

combination of these techniques. The monitoring of

vegetation transects would help gauge the long-term

effects of weed management and restoration efforts in

the xeric tallgrass community. 

Visitor use surveys in Alternatives B and D would

measure the extent to which visitors feel welcome,

safe and comfortable at the Refuge and the extent to

Orange paintbrush.

© Nelson, RFETS
Chapter 2: Alternatives 

76 Rocky Flats National Wildlife Refuge 

which they learned about the Refuge system, safety

issues and the Service’s stewardship role during their

visits. In addition to measuring visitor satisfaction,

the surveys would indicate the effectiveness of public

use programming in increasing visitors’

understanding and appreciation of natural resources

and promoting environmentally responsible behavior. 

This CCP is designed to be effective for 15 years. It

would undergo periodic review to evaluate whether

the established goals and objectives are being met

and strategies are being implemented. Throughout

the life of the CCP, the Service would monitor Refuge

resources, assess whether the goals and objectives for

the Refuge are being achieved and if necessary,

adjust specific management prescriptions to better

respond to the long-term needs of the Refuge.

2.9. ALTERNATIVE CONSIDERED BUT

ELIMINATED

During the initial alternatives development workshop,

Service staff considered a “custodial management”

alternative. In this alternative, the Service would have

taken a “hands-off” approach to Refuge stewardship,

limiting management to areas that the Service is

legally obligated to address. These areas would include

the containment of weeds, the maintenance of fencing

and the preservation of federally listed threatened and

endangered species. Unlike the No Action Alternative,

under this alternative the Service would not manage

the Rock Creek Reserve in accordance with the Rock

Creek Reserve Integrated Natural Resources

Management Plan. 

This alternative was eliminated from detailed analysis

in the EIS. The rationale for eliminating this

alternative included:

• This alternative is similar to the No Action

Alternative

• Custodial management would lead to increased

degradation of wildlife and habitat

• This alternative is not consistent with the purposes

of the Refuge and the mission of NWRS

2.10. REASONABLY FORESEEABLE ACTIVITIES

Reasonably foreseeable future activities are actions

and activities that are independent of the Proposed

Action for the Refuge, but could result in cumulative

effects when they are combined with the effects of the

proposed alternatives. They are anticipated to occur

regardless of which Refuge alternative is selected. The

effects of these activities are described in the

Cumulative Impacts sections under each resource in

Chapter 4.

Reasonably foreseeable future activities within or near

the Refuge are represented in Figure 11 and fall into

the following categories:

• Urban Development

• Regional Transportation Improvements

• Resource Development and Assessment

• Open Space and Trails

• DOE Monitoring and Maintenance

• Cold War Museum

URBAN DEVELOPMENT

According to urban growth projections by the Denver

Regional Council of Governments (DRCOG), the

following areas are anticipated to be developed by 2020

(Figure 11):

• A strip of private land along highway 93

along the west side of Rocky Flats

• Portions of Broomfield and Westminster

between Great Western Reservoir and the

Jefferson County Airport

• Southwestern portions of Superior near

Highway 128

• Portions of Arvada directly south of the

Refuge (Vauxmont development - see below)

For many years, the City of Arvada has envisioned

urban development in an area immediately south of the

Refuge. Arvada annexed the area in 1988 and zoned it

for mixed residential and commercial development.

More recently, plans have been underway for a mixed

residential and commercial development called

Vauxmont. Currently no construction date is

anticipated and no formal plans have been reviewed by

the City of Arvada; however, a metropolitan district has

been established to provide water and other utilities to

the future development. The Vauxmont development

will be immediately adjacent to the southern boundary

of the Refuge.

REGIONAL TRANSPORTATION IMPROVEMENTS

CDOT and the Federal Highway Administration are
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 77

studying long-range regional transportation needs in

the northwest quadrant of the Denver Metropolitan

area. The study area of the Northwest Corridor EIS is

approximately bounded by the foothills on the west,

Simms Street/96th Street on the east, the intersection

of the Northwest Parkway/Tape Drive/Carbon

Road/96th Street on the north and the intersection of

C-470/I-70 on the south.

The study is considering a full range of possible multimodal options, including possible general transit

options, possible improvement of existing roadways,

possible new highways and enhancements, possible

implementation of a tolling enterprise, as well as

transportation system management and transportation

demand management items. The study was initiated in

2003 and will likely take 3 to 4 years to complete.

As part of the environmental review process for the

Northwest Corridor Transportation Study, CDOT is

coordinating with federal, state, and local agencies,

including the Service. The Service has provided and

will continue to provide comments to CDOT regarding

the Northwest Corridor Transportation Study. CDOT

will consult with the Service on any improvement

associated with the study that may affect a threatened

or endangered species.

While the completion of the Northwest Corridor

Transportation Study, and its eventual

recommendations for transportation improvements in

the areas surrounding Rocky Flats are reasonably

foreseeable, the Service has determined that

transportation improvements in any specific location

are not reasonably foreseeable. A specific

improvement has not been funded, is not in the

DRCOG’s Regional Transportation Plan, and therefore

is speculative. "Reasonably foreseeable" actions are not

speculative-they have been approved, are included in

short- to medium-term planning and budget documents

prepared by government agencies or other entities, or

are likely given trends (EPA 1999).

The Refuge Act's §3174 prohibits the construction of a

public road through the Refuge. However, the DOE

can make available land along the eastern boundary of

the Refuge for the sole purpose of transportation

improvements along Indiana Street. Land made

available under §3174 may not extend more than 300

feet from the west edge of the existing Indiana Street

right of way. To be made available, DOE must receive

an application submitted by a county, city, or other

political subdivision of the State of Colorado that

includes documentation demonstrating that the

transportation improvements for which the land is to

be made available:

• Are carried out so as to minimize adverse

effects on the management of the Refuge as

a wildlife refuge

• Are included in the regional transportation

plan of the metropolitan planning

organization designated for the Denver

Metropolitan area

Additionally, §3178 of the Refuge Act requires that the

CCP address and make recommendations on the land to

be made available. In Section 4.16 of this CCP/EIS,

three possible alternative widths, 50 feet, 125 feet and

300 feet, are analyzed. A range of widths is analyzed to

provide information to the Service and the DOE

regarding lands that could be made available. The

DOE will be responsible for determining the width of

any transferred lands, but it is likely the width would

range between 50 and 300 feet. The transfer of a 50-

foot right of way would make the right of way along

Indiana Street 100 feet wide, wide enough for a fourlane, undivided road. Similarly, the transfer of a 100-

foot right of way would make the right of way along

Indiana Street 200 feet wide. A 100-foot or 200-foot

wide right of way would not be wide enough for a fourlane, divided highway. Typical right of way widths for a

four-lane, divided highway, are 300 to 400 feet. The

transfer of a 300-foot right of way would make the right

of way along Indiana Street 350 feet wide, wide enough

for a four-lane, divided highway. The transfer would be

designed to help meet regional transportation needs.

Section 4.16 discusses two issues related to potential

transportation improvements near the Refuge. The

first part of Section 4.16 discusses the lands up to 300

feet from the west edge of the Indiana Street right-ofway that could be made available. The second part of

Section 4.16 discusses potential concerns that the

Service would have related to any transportation

improvements along Indiana Street, Highway 128, and

Highway 93. Improvements to these roadways are

among the universe of alternatives currently being

considered by the Northwest Corridor Transportation

Study (CDOT 2004).

RESOURCE DEVELOPMENT AND ASSESSMENT

Mining

A geologic formation called the Rocky Flats Alluvium

is found in the western half of the Refuge and in

surrounding areas. It is valued as an aggregate source

and is currently being mined in the Refuge area. The
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 79

U.S. Government does not own all of the subsurface

mineral rights at the Refuge. Currently, three active

mining permits are within the Refuge: the Bluestone

sand and gravel quarry, the Lakewood Brick and Tile

mine, and the Church Ranch - Rocky Flats Pit

(Figure 11). 

The Service believes that the exercise of these existing

privately owned mineral rights, particularly surface

mining of gravel and other aggregate material, at

Rocky Flats will have an adverse impact on the

management of the Refuge. The Service does not

believe it can manage the Refuge for meeting the

purposes of §3177(e)(2) of the Refuge Act if certain

mineral rights are exercised. Accordingly, the Service

will not accept transfer of administrative jurisdiction

for lands subject to the mining of gravel and other

aggregate material at Rocky Flats from DOE until the

United States owns the mineral rights of the land to be

transferred to the Service, or until the lands that are

subject of mining have been reclaimed to a mixed

prairie grassland community. 

The permit for the Church Ranch- Rocky Flats Pit

includes stipulations that mining will not encounter

groundwater, and will stay a minimum of 2 feet above

groundwater (CDMG 2004; Church Ranch 2004). The

permits for the Bluestone Pit and the Lakewood Brick

and Tile operation do not have stipulations about

groundwater.

Several off-site mining areas are located northwest of

the Refuge along Highway 93. In the permits, mining

can continue until the resource within the mine permit

area is depleted.

Reservoir Expansion

The City and County of Broomfield owns and operates

Great Western Reservoir to store irrigation water.

Great Western Reservoir is located along Walnut

Creek, about 1⁄2 mile east of the Refuge. Broomfield

plans to increase the size of the reservoir from 2,370

acre-feet to 12,000 acre-feet. Broomfield currently has

sufficient water to fill the reservoir and plans to

complete the expansion within the next 10 to 20 years.

National Wind Technology Center

The DOE’s National Renewable Energy Laboratory

operates the National Wind Technology Center

(NWTC) immediately northwest of the Refuge. The

NWTC is primarily used for wind energy research,

development and testing and currently has between 12

and 15 wind turbines. While the number of wind

turbines at NWTC would vary in accordance with the

nature of future research, the facility is likely to

continue such operations into the foreseeable future

(DOE-NREL 2002).

Utility and Ditch Access

Several outside entities own easements for natural gas,

electrical, fiber optic and other utility lines across the

Refuge. In addition, several other outside entities own

water rights that are conveyed across the Refuge

through ditches such as the Smart Ditch, Upper

Church Ditch and McKay Ditch. The owners and

managers of these easements and water rights will

continue to access the Refuge to maintain their

respective utilities and water rights.

OPEN SPACE AND TRAILS

Recreational Trails

The Refuge is bounded on three sides by designated

open space land owned and managed by local

governments. Several new trails are planned in these

areas, including:

• A new trail on City of Boulder Open Space

land that parallels Highway 128, connecting

the Coalton Trail to the Greenbelt Plateau

trailhead near Highway 93

• A new trail across the City and County of

Broomfield’s Great Western Open Space to

access Indiana Street

The City of Arvada has planned several trails along the

Big Dry Creek drainage between the Refuge and

Highway 72 to the south. These trails are not

associated with currently designated open space, but

are within the planned Vauxmont development

described above.

Front Range Trail

In 2001, Colorado State Parks initiated a planning

project to designate a continuous trail route along the

Front Range of Colorado. As planned, the Front Range

Trail would parallel the east side of Highway 93

between the highway and the Refuge’s western

boundary. While the concept of this trail in this general

location is certain, the exact alignment has yet to be

determined.

Coal Creek Canyon Park

Jefferson County Open Space owns 2,807 acres of

land near the mouth of Coal Creek Canyon, about 2

miles west of the Refuge. Completed in 2001, the
Chapter 2: Alternatives 

80 Rocky Flats National Wildlife Refuge 

management plan for this property outlines

management unit designations, trails and facilities.

However, the management plan also recommends

postponing any trail or facility development until at

least 2006 so that development plans can be

consistent with surrounding land uses (JCOS 2001). 

U.S. Department of Energy Monitoring 

and Maintenance

The Rocky Flats site is currently undergoing cleanup

by the DOE. The Refuge would not be established

until cleanup and certification by EPA is complete

(currently scheduled for 2006). It is not known how

long cleanup might take, or what effects cleanup

activities might have on Refuge resources and uses

(see discussion in Section 1.8). The DOE will retain

primary jurisdiction over some of the lands

surrounding the Industrial Area and will require

ongoing access to the Refuge after cleanup for

monitoring and maintenance purposes.

COLD WAR MUSEUM

The Rocky Flats Cold War Museum was founded in

2001 as a non-profit organization with the intent of

establishing a museum that documents the historical,

scientific and environmental aspects of the former

nuclear weapons plant at Rocky Flats. The

organization has been working to establish a location

for a museum and funding to construct it. In August

2003, the Rocky Flats Cold War Museum released a

Museum Feasibility Study that investigated potential

sites, funding sources and program requirements for a

museum. The study recommended the consideration of

three sites for a museum:

• Existing Rocky Flats Visitor’s Center

(Buildings 60 and 61) at the west entrance to

Rocky Flats

• Location near the entrance of the National

Wind Technology Center off of Highway 128

• Location within the future Vauxmont

development off of Highway 72 south of

the Refuge

The study recommended a museum location at or near

the existing Rocky Flats Visitor’s Center because of its

proximity to the site. If the necessary funding is

secured, the organization hopes to open the Rocky

Flats Cold War Museum in 2006 (Informal Learning

Experiences 2003).

2.11. REFERENCES:

Anderson, B.W. and R.D. Ohmart. 1986.

Vegetation. in A.Y. Cooperrider, R.J. Boyd

and H.R. Stuart, eds. Inventory and

Monitoring of Wildlife Habitat. U.S.

Department of Interior, Bureau of 

Land Management Service Center. 

Denver, Colorado.

Burnham, K.P., D.R. Anderson and J.L. Laake.

1980. Estimation of density from line

transect sampling of biological populations.

Wildlife Monographs, 72. 202 pp. 

CDOT. 2004. Northwest Corridor EIS. Materials

Presented at Public Meetings in April 2004.

http://www.dot.state.co.us/northwestcorridoreis/

involvement/apr04boards.cfm. Accessed June

9, 2004.

Church Ranch. 2004. Technical Revision to Rocky

Flats Pit, Permit number M-1987-113.

Colorado Division of Minerals and Geology

(CDMG). 2004. Permit issuance, Rocky

Flats Pit, Permit number M-1987-113, with

rider. January 13, 2004.

Compton, S.A. and D.A. Hugie. 1993. Status

Report on Zapus hudsonius preblei, a

candidate Endangered Species. USDI Fish

and Wildlife Service, Denver, Colorado.

Department of Energy – National Renewable

Energy Laboratory. 2002. Final Site-Wide

Environmental Assessment of National

Renewable Energy Laboratory’s National

Wind Technology Center.

Department of Energy Rocky Flats

Environmental Technology Site and the

U.S Fish & Wildlife Service. 2001.

Integrated Natural Resources

Management Plan, Environmental

Assessment and Finding of No Significant

Impacts for Rock Creek Reserve, 2001-

Closure.

EPA. 1999. Consideration of Cumulative Impacts

in EPA Review of NEPA Documents. U.S.

Environmental Protection Agency, Office of

Federal Activities (2252A). EPA 315-R-99-

002/May 1999.
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 81

Jefferson County Open Space. 2001. Executive

Summary: Coal Creek Canyon Park

Management Plan.

Informal Learning Experiences, Inc. 2003. Final

Report: Rocky Flats Cold War Museum

Scoping Study. Washington, D.C.

http://www.rockyflatscoldwarmuseum.org/

feasreport.pdf.

Kaiser-Hill, 1997. High-value vegetation survey

plan for the Rocky Flats Environmental

Technology Site. Golden, Colorado.

Kaiser-Hill. 2001. Ecology Field Monitoring

Plans for the Rocky Flats Environmental

Technology Site. Golden, Colorado.

Kaiser-Hill. 2002. 2001 Annual Vegetation

Report for the Rocky Flats Environmental

Technology Site.

Owensby, C.E. 1973. Modified step-point system

for botanical composition and basal cover

estimates. Journal of Range Management

26:303-303.

U.S. Fish & Wildlife Service. 2000. Final Refuge

Planning Policy. FWM 355. Part 602

National Wildlife Refuge System Planning. 
Chapter 2: Alternatives 

82 Rocky Flats National Wildlife Refuge 

ALTERNATIVE A – No Action ALTERNATIVE B – Wildlife, Habitat, and Public Use 

(Preferred Alternative) 

WILDLIFE AND HABITAT MANAGEMENT 

Preble’s Habitat 

Management 

Objective:

x Protect and maintain Preble’s habitat throughout the Refuge. 

Strategies:

x Survey Preble’s locations and habitat every 2-3 years. 

Objective: 

x Protect, maintain, and improve Preble’s habitat throughout the 

Refuge.

Strategies:

x If necessary, exclude grazing/browsing animals to protect habitat. 

x Seek funding/partnerships to monitor impacts of recreation on 

Preble’s.

Xeric Tallgrass 

Management 

Objective:

x Maintain the existing extent of xeric tallgrass habitat (in 

Rock Creek Reserve).

Strategies:

x Within 2 years, develop vegetation management plan. 

x Monitor every 2-3 years to determine species composition, 

document the effectiveness of weed control applications, 

and assess impacts of disturbance on plant communities in 

the Rock Creek Reserve. 

x Use prescribed burning, and mowing to stimulate the growth 

of native plants in the Rock Creek Reserve. 

x Suppress all natural wildfires. 

x Participate in regional xeric tallgrass prairie conservation 

efforts.

Objective:

x Maintain xeric tallgrass habitat across the Refuge with a native 

species composition of 80%. 

Strategies:

x Monitor every 2-3 years to determine species composition, 

document effectiveness of weed control applications, assess 

impacts of disturbance on plant communities across Refuge. 

x Use prescribed fire, grazing, mowing and other tools to stimulate 

the growth of native plants. 

Mixed Grassland 

Prairie

Management 

Objective: 

x Maintain and improve the vigor and native species 

composition of short and mesic mixed grassland habitat (in 

Rock Creek Reserve).

Strategies:

x Allow short and mesic prairie to support sustainable prairie 

dog expansion.

x Maintain short and mesic prairie to support the 

reintroduction of sharp-tailed grouse or other species.

x Use prescribed fire, and mowing to stimulate the growth of 

native plants in the Rock Creek Reserve.

x Suppress all natural wildfires.

Objective: 

x Same as A, except: Restore hay meadow and other areas to 

a native mixed grassland community. 

Strategies:

x Use prescribed fire, grazing, mowing and other tools to stimulate 

the growth of native plants. 

x Restore hay meadow and other areas to native mixed grassland. 

Table 6. Summary of Objectives and Strategies
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 83

 ALTERNATIVE C – Ecological Restoration ALTERNATIVE D – Public Use 

Objective: 

Strategies:

x More extensive monitoring to include surveys of vegetation and 

plant diversity in Preble’s habitat every 2-3 years. 

Objective: 

Strategies:

x Monitor impacts of trails and recreation on Preble’s (with or 

without additional funding/partnerships). 

Objective: 

Strategies:

Objective: 

Strategies:

x Use mowing and other tools. Prescribed burning and grazing 

would not be used. 

Objective: 

Strategies:

Objective: 

Same as A: Maintain and improve the vigor and native species 

composition.

Strategies:
Chapter 2: Alternatives 

84 Rocky Flats National Wildlife Refuge 

ALTERNATIVE A – No Action ALTERNATIVE B – Wildlife, Habitat, and Public Use 

(Preferred Alternative) 

WILDLIFE AND HABITAT MANAGEMENT (continued)

Road Restoration 

and Revegetation 

Objective:

x Revegetate 12 miles of unused roads and 7 stream crossings 

in Rock Creek Reserve. (To be completed by the end of the 

plan).

Strategies:

x Allow natural revegetation of lightly used roads and stream 

crossings.

x In some locations, regrade and seed roads. 

x Survey for noxious weeds and apply IMP techniques to 

control noxious weeds in seeded road corridors. 

Objective:

x Revegetate 26.3 miles of unused roads and 13 stream crossings 

across the Refuge. (To be completed by the end of the plan). 

Strategies:

x Every 3 years survey to determine ground cover, vegetation 

density, species composition, and effectiveness of weed control 

and impact of disturbances. 

Weed

Management 

Objective: 

x Within Rock Creek Reserve: 

- Reduce the density of diffuse knapweed and Dalmation 

toadflax populations 15% within the first 5 years, 25% 

within 10 years, and 50% within 15 years. 

- Reduce the density and halt the spread of other noxious 

weed species, especially Canada thistle, by 50% within 

15 years. 

- Prevent the establishment of species on County and 

State weed lists not yet observed on the Refuge. 

x Outside the Rock Creek Reserve: 

- Limit and control the spread and density of existing 

weed infestation. 

Strategies:

x Employ an integrated pest management (IPM) approach to 

include herbicides, biological controls, grubbing/handpulling, collecting tumbleweeds, and limited use of 

prescribed fire (within Rock Creek Reserve only). 

x Annually map perimeters of weed infestations and treatment 

sites.

Objective: 

Same as A with the following changes: 

x Refuge Wide: 

- Reduce diffuse knapweed and Dalmation 

toadflax to 15%, 30%, and 60% for 5, 10 and 

15 years respectively. 

- Reduce the density and halt the spread of other 

noxious weed species, especially Canada thistle, 

by 50% within15 years. 

Strategies:

x Same as A, except: Add prescribed fire and managed grazing 

Refuge-wide to the list of weed management tools. 

x Develop comprehensive integrated pest management plan. 

x Informally survey for new infestations along roadways, trail, 

restoration areas and disturbed sites. 

x Establish interior fencing to collect wind dispersed weeds; burn 

along fence lines to dispose of collected weeds. 
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 85

 ALTERNATIVE C – Ecological Restoration ALTERNATIVE D – Public Use 

Objective: 

Same as B except: 

x Revegetate 25.7 miles of unused roads and 13 stream crossings. 

Strategies:

Objective: 

Same as B except: 

x Revegetate 24.3 miles of unused roads and 6 stream crossings. 

Strategies:

Objective: 

Same as B 

Strategies:

Objective: 

Same as B except: 

x Refuge Wide: 

- Reduce diffuse knapweed and Dalmation toadflax to 10%, 15%, 

and 300% for 5, 10 and 15 years respectively. 

Strategies:

x Same as A: Prescribed fire and grazing would not be a part of 

the IPM techniques. 

x No informal surveys. 

x No interior fencing for weed management. 
Chapter 2: Alternatives 

86 Rocky Flats National Wildlife Refuge 

ALTERNATIVE A – No Action ALTERNATIVE B – Wildlife, Habitat, and Public Use 

(Preferred Alternative) 

WILDLIFE AND HABITAT MANAGEMENT (continued)

Deer and Elk 

Management 

Objective:

x Allow CDOW to establish target populations and manage 

deer and elk as needed. 

Strategies:

x Use culling to control populations. 

x Cooperate with CDOW in monitoring and controlling 

populations.

x Monitor every 2 years to evaluate ungulate impacts on 

riparian and upland shrub communities in Preble’s habitat. 

Objective:

x Within 3 years, establish deer and elk population targets 

to be achieved by year 5. 

Strategies:

x Use public hunting, culling, temporary exclosures, or hazing to 

manage populations. 

x Compared to A, this alternative would have more extensive 

monitoring:

- Annual abundance and density counts. 

- Photo monitoring to document any habitat degradation. 

x Work with others to protect movement corridors. 

Prairie Dog 

Management 

Objective:

x Allow unlimited expansion of prairie dog populations 

outside of recognized Preble’s habitat. 

Strategies:

x Trap and relocate, or use other methods, to exclude 

prairie dogs from sensitive habitat areas. 

x Do not accept prairie dogs from off-site locations. 

Objective: 

x Limit prairie dog populations to 750 acres outside of recognized 

Preble’s habitat and xeric tallgrass habitat throughout the 

Refuge.

Strategies:

x Annually monitor distribution of prairie dog populations. 

x Monitor for plague. 

Species

Reintroduction 

Objective: 

x Facilitate reintroduction of native extirpated species by or in 

coordination with CDOW. 

x Monitor redbelly dace and common shiner populations 

(introduced 2003) until successfully established. 

Strategies:

x Coordinate with CDOW on species release, monitoring, and 

habitat maintenance. 

Objective: 

Same as A except: 

x Within 3 years, evaluate suitability for additional reintroduction 

of native extirpated species such as sharp-tailed grouse in 

coordination with CDOW. 

x Prioritize species to be reintroduced. 

Strategies:

x Oversee and assist CDOW on species release, monitoring, and 

habitat maintenance. 

x If suitable, complete management plan for sharp-tailed 

 grouse within first 2 years. 

x Annually monitor native fish in Rock Creek and introduce to 

other drainages. 
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 87

 ALTERNATIVE C – Ecological Restoration ALTERNATIVE D – Public Use 

Objective: 

Strategies:

x Use culling and other strategies. 

x Include more extensive monitoring compared to B: 

- Seasonal ungulate counts to determine abundance, density 

and movement patterns. 

- Annual survey of population size and composition, fawning 

rates and fawn survival. 

Objective:

Strategies:

x Use public hunting, culling, or other strategies. 

x Monitor every 3 years to evaluate ungulate impacts on riparian 

and upland shrub communities in Preble’s habitat. 

Objective: 

Same as B except: 

x Limit prairie dog populations to 500 acres. 

Strategies:

x Informally monitor for plague and consult with local public 

health officials. 

Objective: 

Same as B except: 

x Limit prairie dog populations to 1,000 acres. 

Strategies:

x Evaluate the suitability of accepting prairie dogs from off-site 

locations. 

x Same as B: Monitor for plague. 

Objective: 

Same as B except: 

x Within 5 years, remove reintroduced native fish species from 

Lindsay Pond and remove pond. Relocate fish to other drainages 

on Refuge. 

Strategies:

x Coordinate with and assist CDOW with species release, 

monitoring, and habitat maintenance. 

Objective:

x Within 3 years, evaluate the suitability of reintroducing the Plains 

sharp-tailed grouse only. 

Strategies:
Chapter 2: Alternatives 

88 Rocky Flats National Wildlife Refuge 

ALTERNATIVE A – No Action ALTERNATIVE B – Wildlife, Habitat, and Public Use 

(Preferred Alternative) 

PUBLIC USE, EDUCATION and INTERPRETATION 

Public Access 

Objectives: 

x Guided tours limited to 300 visitors annually. 

x On guided tours, provide opportunities for wildlife 

observation and photography. 

x Educate visitors about the National Wildlife Refuge 

System’s mission and the Refuge. 

Strategies:

x Grant access “by arrangement only” and limit to guided 

tours.

x Develop a guideline for managing visitor access. 

x Distribute a survey to measure quality of visitor experience. 

Objectives: 

x Within 5 years, 75% of visitors will feel welcome, safe and 

comfortable. 

x By plan’s end, visitors experience the Refuge on foot, bike and 

horse.

x In year 1, open a trail to Lindsay Ranch. By years 5-7 open more 

trails and create baseline visitor data. 

x By plan’s end, 25% of visitors appreciate Refuge stewardship and 

desire to adopt conservation ethics. 

Strategies:

x Allow self-guided public access to trails and facilities. 

x Develop an outreach program. 

x Develop surveys to measure visitor experience. 

x Provide a seasonally staffed visitor contact station, overlooks, 

trails, and other facilities. Site trails (pedestrian only and multiuse trails for equestrian and bike use) to provide opportunities for 

wildlife observation. Allow limited off-trail use. Seasonally 

close some trails to minimize wildlife impacts. 

x Use signage, staff contact, brochures, website and other means to 

inform visitors about the steps to becoming a refuge and access 

opportunities and restrictions. 

x Implement volunteer programs. 

x Keep surrounding communities informed about Refuge events 

and plan implementation. 

x Develop an interpretive signage system and interpretive 

programs.

Interpretation 

Objective: 

x Within 1 year, develop a fact sheet on the Refuge’s history 

and its natural and cultural resources. 

Strategies:

x Develop guides for staff who are leading tours. 

Objectives: 

x Within 4 years, develop a plan outlining interpretive 

facilities/programs. 

x Within 15 years, implement the interpretive component of the 

Visitor Services Plan. 

Strategies:

x Work with partners to develop the interpretive component of the 

Visitor Services Plan. 

x Develop programs that explore the site’s resources. 

x Distribute a variety of interpretive media. 
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 89

 ALTERNATIVE C – Ecological Restoration ALTERNATIVE D – Public Use 

Objectives: 

x Guided tours limited to 1000 visitors annually. 

x On guided tours, provide opportunities for wildlife observation 

and photography. 

x 90% of visitors appreciate Refuge stewardship and desire to 

adopt conservation ethics. 

Strategies:

x Same as A: guided tours “by arrangement only” 

x Develop strategy to manage public use, including a survey that 

measures visitor satisfaction and use patterns. 

x Provide small scale facilities placed in previously disturbed areas 

that allow visitors to view key resources while minimizing 

impacts to wildlife. Construct a short hiking trail on existing 

roads to access the Lindsay Ranch overlook. 

Objectives: 

x Within 5 years, 75% of visitors will feel welcome, safe and 

comfortable. 

x Beginning in year 1, visitors can experience the Refuge in a 

variety of ways. 

x By year 2, determine baseline visitor use data. 

x By plan’s end, 50% of visitors value Refuge stewardship; 10% 

want to adopt conservation ethics. 

Strategies:

 Same as B, except: 

x Provide a year-round staffed visitor center. 

Objective: 

x Within 1 year, develop a fact sheet Refuge’s habitat types, 

wildlife populations, and the Service’s restoration practices. 

Build on the fact sheet to create learning other materials for 

distribution. 

Strategies:

x Develop guides for staff who are leading tours. 

x Work with local educators to determine topics for simple learning 

materials. 

Objectives: 

x Within 2 years, develop a plan outlining interpretive facilities and 

programs.

x Within 15 years, implement the interpretive component of the 

Visitor Services Plan. 

Strategies:

Same as B, plus:

x Design and build (or retrofit) a Visitor Center. 
Chapter 2: Alternatives 

90 Rocky Flats National Wildlife Refuge 

ALTERNATIVE A – No Action ALTERNATIVE B – Wildlife, Habitat, and Public Use 

(Preferred Alternative) 

PUBLIC USE, EDUCATION and INTERPRETATION (continued)

Environmental

Education

Objective: 

x No environmental education programming. 

Objectives: 

x Within 5 years, develop an education plan for high school and 

college students. 

x Within eight years, implement the education component of the 

Visitor Services Plan. 

Strategies:

x Partner with educational institutions and the Cold War Museum. 

x Use electronic and other media to distribute data. 

Hunting 

Objective: 

x No hunting. 

Objectives: 

x Within 2 years, institute a controlled youth and/or disabled 

person’s deer and/or elk hunting program. Following year 3, 

consider expanding the hunting program to the general public. 

x Following each hunting season, assess the hunting program and 

adjust as appropriate. 

x 95% percent of hunters will report no conflicts with other users, 

and be satisfied with their experience. 

Strategies:

x Work with the Colorado Division of Wildlife and other entities to 

develop a hunting component of the Visitor Services Plan and to 

monitor deer populations and habitat condition. 

x Close the refuge to others during hunting weekends and 

encourage staff to interact one-on-one with the hunters. 

x Develop a survey for hunters, adjacent landowners and 

surrounding communities. 

Recreation

Facilities

Objective: 

x No recreation facility development. 

Strategies:

x Provide portable restrooms for staff and visitor (guided tour) 

use.

Objectives: 

x Within 1 year, develop Lindsay Ranch trail. By years 5-7 build 

75% of trails. By year 15, build all facilities including about 4 

miles of hiking trails and about 13 miles of multi-use trails. 

x Within 10 years, construct a seasonally staffed contact 

station/restrooms and maintenance facilities. 

Strategies:

x Develop a universal access trail to the Lindsay Ranch overlook 

and pedestrian only trails in the Rock Creek drainage. 

x Mark trails with way finding and interpretive signs and 

seasonally close trails to protect wildlife habitats. 

x Construct seasonally staffed contact station, un-staffed welcome 

kiosk, wildlife viewing blind, and portable restrooms at trailheads 

and partner to develop trail links and pedestrian crossings. 

Routinely evaluate facility impacts on wildlife. 
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 91

 ALTERNATIVE C – Ecological Restoration ALTERNATIVE D – Public Use 

Objective: 

Same as A. 

Objectives: 

x Within 3 years, develop an education plan for junior/high school 

and college students. 

x By year 15, implement the education component of the Visitor 

Services Plan. 

Strategies:

Same as B except: 

x Construct outdoor classroom. 

Objective: 

Same as A. 

Objectives: 

Same as B. 

Strategies:

Same as A. 

Objective: 

x Within 7 years, develop all recreational facilities. 

Strategies:

x Design and construct the unpaved access, circulation, parking and 

trail facilities. 

x Develop an interpretative panel at the Rock Creek overlook, and 

post additional trail. 

x Provide portable restrooms at trailheads for staff and visitor use. 

Objective: 

x Within the first 5 years, develop all trail facilities. By year 15, 

develop about 6 miles of hiking trails and about 15 miles of 

multi-use trails.

x By the plan’s end, enhance built trails and construct all facilities 

listed in plan. 

Strategies:

Same as B, except: 

x Develop universal access to Rock Creek overlook. 

x Construct year-round staffed visitor center, un-staffed welcome 

kiosk and wildlife viewing blind. 

x Build outdoor classroom and added viewing facilities. 
Chapter 2: Alternatives 

92 Rocky Flats National Wildlife Refuge 

ALTERNATIVE A – No Action ALTERNATIVE B – Wildlife, Habitat, and Public Use 

(Preferred Alternative) 

SAFETY

Staff Safety 

Objective: 

x All Refuge staff will receive orientation/training. 

Strategies:

x Develop orientation and first aid training that addresses key 

Refuge safety issues. 

x Develop site-specific appendices to the Refuge Complex 

Safety Plan. 

x Within 1 year, develop a health and safety plan to cover all 

Refuge operations 

x Implement a goal of zero incident performance 

Objective: 

Strategies:

Visitor Safety 

Objective: 

x Brief 100% percent of visitors on the site’s history.

Strategies:

x Include safety related questions in the visitor survey, and 

adjust safety program using results. 

Objective: 

x Within 5 years, 75% of visitors will be aware that the Refuge is 

safe and open for public access before they arrive. Upon arrival, 

these visitors will be informed of public use opportunities and 

restrictions.

x Brief all participants in guided programs about site history. 

Strategies:

x Provide maps and interpretive signage with restriction 

information at all access points/trailheads. 

x Help potential users understand site restrictions and public use 

opportunities through a diversity of media. 

x Provide information to map/ tour book publishers. 

x Survey visitors to check success of safety program. 

x Maintain law enforcement and ensure employees can educate 

visitors on safety issues. 

x Measure program success by a reduction in visitors who violate 

safety rules. 
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 93

 ALTERNATIVE C – Ecological Restoration ALTERNATIVE D – Public Use 

Objective: 

Strategies:

Objective: 

Strategies:

Objective: 

Same as A. 

Strategies:

Same as A. 

Objective: 

Same as B. 

Strategies:

Same as B. 
Chapter 2: Alternatives 

94 Rocky Flats National Wildlife Refuge 

ALTERNATIVE A – No Action ALTERNATIVE B – Wildlife, Habitat, and Public Use 

(Preferred Alternative) 

OPEN AND EFFECTIVE COMMUNICATION 

Outreach 

Objective: 

x Disseminate information collected on the Refuge through a 

fact sheet mailed upon request. 

Strategies:

x Distribute fact sheet upon request. 

Objective: 

x Within 5 years, implement 4 methods of informing the public. 

Strategies:

x Reach out to local communities and recruit participants. 

x Measure diversity of groups attending outreach events. 

x Utilize a variety of outreach communication methods. 

x Take part in stewardship programs and local meetings. 

WORKING WITH OTHERS 

Emergency 

Objective: 

x Within 1 year, create emergency response agreements with 

relevant parties. 

Strategies:

x Meet annually, or as often as needed, to coordinate fire and 

emergency response plans. 

x Coordinate all prescribed burning and other restoration 

practices with all nearby agencies. 

Objective: 

Strategies:

Conservation 

Objective: 

x Within 1 year, develop a management agreement with the 

Colorado Division of Wildlife 

x Maintain open dialogue with adjacent entities. 

Strategies:

x Seek input of Colorado Department of Wildlife on wildlife 

management strategies. 

x Work closely with surrounding landowners, open space and 

natural resource entities. 

Objective: 

x Meet annually (at minimum) with local entities to address 

conservation issues. 

Strategies:

x Work closely with surrounding open space and natural resource 

entities. 

x Use volunteers to help with conservation activities. 

x Partner to maintain wildlife corridors for wildlife that migrate 

seasonally to and from the Refuge 
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 95

 ALTERNATIVE C – Ecological Restoration ALTERNATIVE D – Public Use 

Objective: 

Strategies:

Objective: 

Strategies:

Objective: 

Strategies:

Objective: 

Strategies:

Same as A except: 

x No prescribed fire would be used. 

Objective: 

Strategies:

Objective: 

Strategies:

 Use volunteers to help with conservation and public use 

activities. 
Chapter 2: Alternatives 

96 Rocky Flats National Wildlife Refuge 

ALTERNATIVE A – No Action ALTERNATIVE B – Wildlife, Habitat, and Public Use 

(Preferred Alternative) 

WORKING WITH OTHERS (continued)

Research 

Objective: 

x Maintain agreements with university and federal agencies 

for radionuclide research. 

Strategies:

x Establish criteria to evaluate research proposals. 

x Emphasize research with implications for the Refuge 

Objective: 

x Make a list of habitat, wildlife and public use research needs; 

evaluate proposals for such research. 

Strategies:

x Partner with other for research funding and resources 

Volunteers

Objective: 

 No volunteer programs 

Objective: 

x Within 3 years, create a volunteer program. 

Strategies:

x Define volunteer opportunities, and recruit volunteers from horse 

and bike groups to help maintain trails. 

x Work to establish a Refuge “Friends” group. 

Staffing

Objective: 

x Within 2 years, fund two employees and assign collateral 

duties for Rocky Mountain Arsenal staff. 

x Fund two full-time and two seasonal employees from fire 

management funding. 

Strategies:

x Follow Service protocols hiring of FTEs. 

Objective: 

x Within 2 years, fund four employees and assign collateral duties 

for Rocky Mountain Arsenal staff. Within 5 years add 1 

additional employee. 

Strategies:
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 97

 ALTERNATIVE C – Ecological Restoration ALTERNATIVE D – Public Use 

Objective: 

Strategies:

Objective: 

Strategies:

Objective: 

Same as A. 

Objective: 

Same as B. 

Strategies:

Same as B. 

Objective: 

x Within 2 years, fund five employees and assign collateral duties 

for Rocky Mountain Arsenal staff. Within 5 years, add two 

additional employees 

Strategies:

Objective: 

x Within 2 years, fund 6 employees and assign collateral duties for 

Rocky Mountain Arsenal staff. Within 5 years add 2 additional 

employees. 

Strategies:
Chapter 2: Alternatives 

98 Rocky Flats National Wildlife Refuge 

ALTERNATIVE A – No Action ALTERNATIVE B – Wildlife, Habitat, and Public Use 

(Preferred Alternative) 

WORKING WITH OTHERS (continued)

Operation and 

Management 

Facilities

Objective: 

x Develop facilities to support maintenance, conservation and 

administrative activities. 

x Maintain the existing stock fence. 

Strategies:

x Submit proposals to the Refuge Operations Needs System 

and Maintenance Management System. 

x Renovate existing vehicle search buildings to serve as a 

small office space and to house refuge operations. 

x Prepare a fire cache and install necessary water storage 

systems and coordinate equipment sharing with RMA staff. 

x Attach boundary signage to the perimeter fence and install 

roadside signs along the site boundary in order to announce 

the Refuge’s presence. 

Objective: 

x Within 5 years, develop 50% of O&M facilities needed to 

support public use and conservation objectives. By year 10, 

complete all O&M facilities. 

Strategies:

x Renovate existing vehicle search buildings and provide additional 

administrative offices for Refuge employees within the contact 

station.

x Construct a small maintenance/storage facility (approximately 

1750 – 2250 square feet). 

Cultural

Resource 

Management 

Objective: 

x Develop a cultural resource preservation plan. 

x Stabilize the Lindsay Ranch barn 

Strategies:

x Maintain an inventory of all cultural resources and. 

x Pursue partnerships to fund barn stabilization and fence 

and/or take down the Lindsay Ranch house to prevent a 

safety hazard. 

x Survey burned areas for cultural artifacts 

Objective: 

x Stabilize and interpret the Lindsay Ranch barn. 

Strategies:

x Work with interested parties to interpret the story of 

homesteading at Rocky Flats. 
Chapter 2: Alternatives

Final Comprehensive Conservation Plan & EIS 99

 ALTERNATIVE C – Ecological Restoration ALTERNATIVE D – Public Use 

Objective:

x Within 3 years, develop a satellite maintenance facility to support 

refuge operations. 

Strategies:

x Renovate existing vehicle search buildings evaluate the costs and 

availability of leasing nearby office space for Refuge employees. 

Objective: 

x Within 5 years, develop 75% of O&M facilities needed to 

support public use and conservation objectives. By year 10, 

complete all O&M facilities. 

Strategies:

x Renovate existing vehicle search buildings and provide additional 

administrative offices for Refuge employees within the visitor 

center. 

x Construct a maintenance/storage facility (approximately 2500 – 

3000 square feet). 

Objective: 

x Remove Ranch structures and restore the area to native 

vegetation. 

Strategies:

x Restore stream crossings and re-vegetate roads within the 

Lindsay Ranch site 

x Restore vegetation to pre-settlement conditions. 

Objective: 

x Stabilize and interpret Lindsay Ranch barn 

Strategies:

Same as B. 

AFFECTED ENVIRONMENT

chapter 3

Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 103

3.1. INTRODUCTION

This chapter describes the environmental resources at

Rocky Flats that may be affected by the proposed

CCP alternatives described in Chapter 2. As

discussed in Chapters 1 and 2, DOE will retain

primary jurisdiction over an area in the center of the

Refuge that encompasses the former Industrial Area

and any cleanup, closure and monitoring facilities.

The resource descriptions and acreage

measurements in this chapter encompass the entire

Rocky Flats site and do not distinguish between

Refuge lands and land that will be retained by DOE

for long-term monitoring. 

3.2. GEOLOGY AND SOILS

The 6,240-acre Rocky Flats site is at the interface of

the Great Plains and Rocky Mountains, about 2 miles

east of the foothill escarpment in Jefferson County,

Colorado. Site elevation ranges from 5,500 feet in the

southeastern corner to 6,200 feet near the current west

entrance gate. The western half of the site is

characterized by the relatively flat Rocky Flats

pediment, which gives way to several finger-like

drainages that slope down to the rolling plains in the

eastern portion of the site.

SURFICIAL AND BEDROCK GEOLOGY

Geologic units at the Rocky Flats site range from

unconsolidated surficial deposits to various bedrock

layers. Surficial deposits in the western portions of the

site are characterized by the Rocky Flats Alluvium,

clayey and sandy gravels up to 100 feet thick (Figure

12). The steeper slopes below the Rocky Flats

Alluvium in the central portion of the site generally

consist of landslide deposits. Surficial deposits in the

eastern portion of the site consist of colluvium 3 to 15

feet thick and terrace alluvium 10 to 20 feet thick

(Shroba and Carrara 1996).

The Rocky Flats Alluvium is underlain by the Arapahoe

Formation, composed of sandstones, siltstones and

claystones that range from 0 to 50 feet thick. In several

locations, springs emerge at the contact of the Rocky

Flats Alluvium and the Arapahoe Formation. These

springs support the tall upland shrubland community

described in the Vegetation Communities section.

Beneath the Arapahoe Formation lies the Laramie

Formation, composed of 600 to 800 feet of silty to

clayey sandstones, clayey siltstones and claystones.

The Laramie Formation is underlain by the Fox Hills

Sandstone and Pierre Shale. 

GEOLOGIC HAZARDS

Landslides and landslide deposits are common

along the steep hillsides and incised drainages at

the base of the Rocky Flats Alluvium escarpment.

These deposits occur in areas where bedrock layers

such as the Arapahoe Formation are capped by

unconsolidated gravel formations such as the Rocky

Flats Alluvium. While most of the landslide

deposits are of Pleistocene origin, some, especially

those in the Rock Creek drainage, are likely more

recent. Many landslide areas have high swell

potential and are subject to sheet wash and soil

creep (Shroba and Carrara 1996). 

Seven geologic fault lines have been identified at Rocky

Flats, including a northeast-trending reverse fault that

extends across the western part of the Industrial Area.

These faults are not believed to be a concern associated

with current or future human activities or facilities at

the site (DOE 1997).

MINERAL RESOURCES

The Rocky Flats Alluvium is believed to be the only

mineral resource feasible for development at the

Refuge. Historically, uranium, coal, oil and natural gas

have been extracted near the Rocky Flats site. None of

Chapter 3. Affected Environment 

The gravelly soils of Rocky Flats have been mined

for decades.

© USFWS
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 105

these mineral resources, however, appear to be feasible

for development (DOE 1997). Mining rights and

permits at the site are described in the Infrastructure,

Easements and Utilities section.

SOILS

The soils at the site formed from alluvium (stream

deposited), colluvium (gravity deposited), or residuum

(exposed bedrock material). Soils in the western half of

the site formed from alluvium, while those in the eastern

half of the site formed from colluvium and residuum. 

Soils in the western half of the site are primarily the

Flatirons and Nederland soils that formed in the Rocky

Flats Alluvium (Figure 13). Flatirons soils consist of

very cobbly to very stony loamy surface soils and

clayey subsoils. These soils are deep and well drained.

Flatirons soils are located on western pediments and

ridgetops, as well as the upper portions of hillsides.

Nederland soils have very cobbly loamy surface and

subsoils. They are deep and well drained. Nederland

soils are located on steeper hillsides and valley slopes

in the western portion of Rocky Flats.

Soils in the eastern portion of the site consist primarily

of Denver, Kutch, Midway, Valmont, Haverson and

Nunn soils. The Denver-Kutch-Midway complex

consists of soils with loamy surfaces and clayey

subsoils. The Denver soils are deep and well drained,

the Kutch soils are moderately deep and well drained,

while Midway soils are shallow and well drained. The

Denver-Kutch-Midway complex is the dominant soil

map unit in the eastern portion of Rocky Flats,

although it also occurs in the western half along

hillsides. Denver and Kutch soils are found on side

slopes and the Midway soils occur on steeper slopes.

Valmont soils consist of deep, well-drained soils with

loamy surface soils and loamy to clayey subsoils. This

soil type is found in the northeast corner of Rocky

Flats on the eastward extension of the Rock

Creek/Walnut Creek drainage divide. Haverson soils

are loamy soils located in floodplains or low terraces.

Nunn soils consist of deep, well-drained soils on lower

slopes adjacent to drainage bottoms. They have loamy

surface soils and loamy to clayey subsoils.

SOIL CONTAMINATION

DOE Retained Area 

Elevated concentrations of plutonium and americium

are currently found in the eastern portion of the site.

Concentrations are highest within the DOE retained

area, adjacent to an area known as the 903 Pad (DOE

1997). The 903 Pad is an area where industrial oil

mixed with plutonium was stored in steel drums from

1958 to 1968. This mixture leaked onto the soils in the

storage area, and these contaminated soils were

subsequently blown by the wind and deposited to the

east and southeast. In 1968, the storage area was

capped with asphalt to prevent further release of

contaminated soils. Because the area near the 903 Pad

has plutonium concentrations greater than 50 pCi/g,

DOE plans to remove all surface soils with a plutonium

concentration greater than 50 pCi/g (as well as some

other areas) and replace them with uncontaminated

soils. It is anticipated that DOE will retain jurisdiction

over the area, which will not be open for public use.

Refuge Lands 

Existing concentrations of plutonium, the primary

contaminant found in soils outside the DOE retained

area, are very low (less than 7 pCi/g) in the surface

soils in the lands to be transferred to the Service.

Most of the Refuge surface soils have a plutonium

concentration less than 1 pCi/g (Figure 4). As

discussed in Chapter 1, DOE is anticipating retaining

management responsibility for all lands with surface

soils having a plutonium concentration more than

approximately 7 pCi/g, in order to minimize the

potential for erosion and surface water impacts (Figure

4). Some surface soils south of the east entrance road

have a plutonium concentration between 1 and 7 pCi/g

(Figure 4). Because plutonium was distributed east of

the 903 Pad by wind, and because of the environmental

characteristics of plutonium, elevated plutonium

concentrations are limited to surface soils on the

Refuge, and are not present in subsurface soils. 

The DOE does not anticipate transferring any lands for

use as a refuge that would require additional safety

requirements for either the refuge worker or the visitor.

Lands that would require use restrictions will not be

transferred to the Service for the Refuge. The risk

assessment efforts that resulted in the 50 pCi/g cleanup

action level were inclusive of Refuge management

activities such as trail building, fence construction and

maintenance, visitor use, and prescribed fire and were

designed to be safe for the Refuge worker, Refuge

visitors, including children, and the greater community. 

3.3. WATER RESOURCES

SURFACE WATER

Three drainages originate on or near Rocky Flats:

Rock Creek, Walnut Creek, and Woman Creek (Figure

14). Stream levels fluctuate depending on the season
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 107

and amount of precipitation. Most streamflow is

controlled by ground water discharge; streamflow is

higher when ground water levels are higher, such as in

the spring. Surface sheet flow is only a significant

contributor to stream flows during high precipitation

events (Kaiser-Hill 2002b). 

There are currently 16 ponds on the Rocky Flats site, 12

of which are within the area that will be retained by

DOE. The others are the two Lindsay Ponds on Rock

Creek and ponds D-1 and D-2 on the Smart Ditch. 

Rock Creek

The Rock Creek basin drains the northwest portion of

the site. This drainage has a relatively flat headwater

area to the west and steep gullies and channels to the

east where it cuts below the Rocky Flats Alluvium into

bedrock formations. Rock Creek is hydrologically

isolated from the rest of the site and receives no water

from the Industrial Area. Surface water generally

originates from precipitation and shallow ground water

discharge. Rock Creek continues off-site to the

northeast, where it joins Coal Creek in the Boulder

Creek basin (DOE 1997).

Walnut Creek

Walnut Creek consists of three tributaries that drain

the central portion of the site, including most of the

Industrial Area. The northernmost branch, No Name

Gulch, begins at the outfall of the East Landfill Pond.

The central branch, North Walnut Creek, begins at the

northern edge of the Industrial Area and flows through

the “A” series ponds. South Walnut Creek begins in the

Industrial Area and collects discharge from the Rocky

Flats Wastewater Treatment Plant before flowing

through the “B” series ponds. The three branches

converge near the eastern Rocky Flats boundary

before flowing off-site to the east. Walnut Creek is

typically dry during most of the year.

Woman Creek

The Woman Creek basin drains the southern portion of

the Rocky Flats site. The Woman Creek drainage

consists of two major branches that begin off of the

Rocky Flats site to the southwest. The main stem of

Woman Creek flows across the site, passing south of

the Industrial Area and flowing through the C-1 pond.

The Mower Ditch diverts most of the Woman Creek

flow into Mower Reservoir, east of Rocky Flats. 

Typically, Woman Creek has no streamflow in late

spring and summer. All surface flows are lost to

ground water in the warmer months. In the winter,

most of the baseflow is from Antelope Springs.

Woman Creek is largely unaffected by pond releases

(pond C-2 is discharged about once a year, with a

release of 38 acre-feet). 

Big Dry Creek

A small portion of Rocky Flats near its southern

boundary lies within the Big Dry Creek drainage,

although the creek itself does not flow onto the site. Big

Dry Creek flows into Standley Lake about 1 mile east

of Indiana Street.

Ditches

Besides the three principal drainages, several ditches

cross the site. The South Interceptor Ditch currently

collects runoff from south of the Industrial Area, which

channels surface runoff into the C-2 pond. The Smart

Ditch originates at Rocky Flats Lake to the southwest

of the site, enters Rocky Flats and flows through the

South Woman Creek drainage for almost 2 miles before

splitting off toward Standley Lake to the southeast.

The Mower Ditch diverts most of Woman Creek

toward Mower Reservoir to the east. The Upper

Church Ditch enters Rocky Flats from the west and

traverses the Rock Creek/Walnut Creek drainage

divide until it exits the site in the northeast corner. The

McKay Ditch runs from the west side of the Industrial

Area into the Walnut Creek drainage. The Kinnear

Ditch diverts water from Coal Creek west of Rocky

Flats and conveys it to the Woman Creek channel

(Advanced Sciences 1991).

Drainages such as Rock Creek are a prominent feature

of the Refuge.

© Shapins Associates
Chapter 3: Affected Environment

108 Rocky Flats National Wildlife Refuge 

Off-Site Surface Water

Standley Lake is a large water supply reservoir that

serves nearby communities. It is located about 1 mile

southeast of Rocky Flats on the mainstem of Big Dry

Creek (Figure 14). Upstream of Standley Lake just

east of the Rocky Flats site, the Woman Creek

Reservoir was constructed to intercept any Woman

Creek flows that are not diverted through the Mower

Ditch. This reservoir is intended to protect water

quality in Standley Lake. Mower Reservoir is located

north of Woman Creek Reservoir on the east side of

Indiana Street and receives Woman Creek water

through the Mower Ditch. 

Immediately east of the site lies Great Western

Reservoir, owned by the City and County of

Broomfield and used for irrigation. Rocky Flats Lake

lies to the south and west of the site on land owned by

the State of Colorado. Rocky Flats Lake provides

water to the Smart Ditch, which runs across the

southern end of the site toward the D-2 pond and

eventually, into Standley Lake.

GROUND WATER

Hydrogeology at the Rocky Flats site is characterized

by three distinct units: the upper alluvial aquifer, lower

aquitard, and the Laramie-Fox Hills aquifer. An aquifer

is a geologic formation that has sufficient permeability

to store and/or convey water. An aquitard is a confining

layer with low permeability that can store of water but

does not allow water to readily pass through it.

The upper alluvial aquifer is comprised of the

unconsolidated materials that can be as much as 100

feet thick in the western portions of Rocky Flats. This

aquifer is generally recharged from precipitation or

surface water. Ground water in the unconsolidated

alluvial aquifer is generally close to the land surface,

with an average depth of 11 feet below ground surface. 

Several springs have emerged in areas where the

contact of the upper aquifer and the lower aquitard is

exposed at the surface. While most of these springs

occur within the Rock Creek drainage, Antelope

Springs in the Woman Creek drainage has the largest

discharge at the site. Antelope Springs discharges

continuously over several acres. 

The lower aquitard is composed of the deeper

claystones and siltstones of the Laramie and Arapahoe

Formations. Combined, these formations combined are

up to 800 feet thick below Rocky Flats. Recharge of the

lower aquitard occurs from downward flow through the

upper aquifer, or directly through precipitation in areas

where the bedrock is exposed. Beneath the aquitard

lies the regional Laramie-Fox Hills aquifer. It is

Surface water is stored in small ponds in many places on the Refuge.

© RFETS
Chapter 3: Affected Environment

110 Rocky Flats National Wildlife Refuge 

composed of the lower sandstone unit of the Laramie

Formation and the Fox Hills Sandstone and is confined

by the overlying aquitard. Ground water levels in the

bedrock aquifers are generally greater than 100 feet

(DOE 1997).

Several portions of the upper alluvial aquifer east and

northeast of the Industrial Area are known or

suspected of being contaminated with radionuclides,

volatile organic compounds, and metals. The aquitard is

less contaminated than the upper alluvial aquifer. No

contaminant plumes have been identified in the

aquitard. The Laramie-Fox Hills aquifer beneath the

site is unlikely to be contaminated (IATTF 1998).

FUTURE HYDROLOGICAL CONDITIONS

During site closure, DOE will remove the buildings,

pavement and some of the subsurface utilities (to a

depth of 3 feet) from the Industrial Area and grade and

revegetate the area. Subsurface utilities below 3 feet

deep will be assessed individually and may be left in

place. Landfill areas will be covered and also will be

regraded. These changes will affect the surface and

ground water hydrology of the site. The following

changes that will alter the hydrology of the Rocky

Flats site are expected to occur (Kaiser-Hill 2002b):

• No more water will be imported to the site

• Two channels in the Industrial Area will

route water to the A- and B-series ponds

• Treatment plant discharge to pond B-3 will

be discontinued

• The upper reach of the South Interceptor

Ditch will be removed

• Subsurface drains in the Industrial Area will

be removed down to 3 feet

• Subsurface utilities within 3 feet of surface

will be removed and the area will be

backfilled with Rocky Flats Alluvium,

changing the hydraulic conductivity of the

subsurface in the Industrial Area

• Pavement and buildings will be removed in

the Industrial Area (some basement slabs

and walls will be left in place)

• The Industrial Area and landfill areas will be

regraded to match adjacent topography and

the sites will be vegetated

Expected changes in streamflow in Walnut and Woman

creeks are discussed in the following sections. Flow in

Rock Creek will not be affected. These changes will

occur during site cleanup and closure before Refuge

establishment. Any potential impacts from these

changes will occur while the site is under the DOE’s

jurisdiction and are outside of the scope of this

CCP/EIS.

Walnut Creek

Walnut Creek flows will change due to the elimination

of waste water treatment plant discharge to the creek,

the removal of impervious areas in the Industrial Area,

and the elimination of storm water drain discharges in

the Industrial Area. Terminal pond (A-4 and B-5)

discharges will decrease and Walnut Creek flows will

be dominated by pond discharge operations and any

pond routing or structural modifications. South Walnut

Creek east of the Industrial Area is estimated to lose

90% of its annual flow (Kaiser-Hill 2002b).

Woman Creek

Changes in the flow of Woman Creek will be

insignificant, except for the area south of the Original

Landfill where flows may decrease due to the possible

use of covers and slurry walls at the landfill site.

Drainage to the South Interceptor Ditch and baseflow

within the ditch would decrease because storm water

flows from the Industrial Area will be significantly

reduced. Changes in ditch flows, however, are not

likely to affect Woman Creek flows because water

from the ditch is detained in pond C-2 and the ditch

supplies less than 10% of the flow of Woman Creek at

the east boundary. 

3.4. VEGETATION COMMUNITIES

A diverse mosaic of vegetation communities is found at

Rocky Flats (Table 7). Two of these vegetation

communities, the xeric tallgrass grassland and the tall

upland shrubland, are considered to be rare in the

region. Other significant vegetation communities

include the riparian woodland, riparian shrubland,

wetlands, mesic mixed grassland, xeric needle and

thread grassland, reclaimed mixed grassland and

ponderosa pine woodland (Figure 15).

Vegetation communities at Rocky Flats have been

grouped into Resource Management Zones. These

zones generalize the Refuge into three categories with

similar wildlife habitat attributes and management

requirements. The three management zones are Xeric

Tallgrass Grassland, Wetlands and Riparian Corridors,

and Mixed Prairie Grasslands. 
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 111

XERIC TALLGRASS GRASSLAND MANAGEMENT ZONE

Xeric Tallgrass Grassland

This rare plant community is found on the rocky

plains in the western portions of the site, extending

eastward along several finger-like ridgelines.

Covering 1,568 acres, it contains several different

plant associations that include combinations of big

bluestem, little bluestem, mountain muhly, sun sedge,

Fendler’s sandwort and Porter’s aster. Other tallgrass

prairie species include Indian-grass, prairie dropseed,

switchgrass, and needle-and-thread grass. Species

richness is high; 285 species have been recorded

within the xeric tallgrass community at Rocky Flats,

of which about 80% are native. Differences in species

composition are attributable to annual variations in

climate and precipitation (Kaiser-Hill 2002c). 

The xeric tallgrass grassland is found primarily on

Flatirons and Nederland soils and is believed to be a

relict once connected to the tallgrass prairie hundreds

of miles to the east (Nelson 2003; Essington et al. 1996).

The Colorado Natural Heritage Program (CNHP) has

found that much of the xeric tallgrass grasslands along

the Colorado Front Range has been disturbed by urban

development and agricultural conversion over the last

century. In addition, aggressive weed species such as

cheatgrass, Japanese brome and diffuse knapweed have

degraded many areas of this community throughout the

region (Essington et al. 1996). The CNHP believes that

the xeric tallgrass grassland community exists in fewer

than 20 places globally and that Rocky Flats has the

largest example of this community remaining in

Colorado and perhaps North America. The CNHP

ranks this community as imperiled within the state

(Essington et al. 1996).

The xeric tallgrass grassland community is comprised of

several sub-communities (Nelson 2003). One of these

sub-communities was identified by ESCO during a fiveyear evaluation of bluestem-dominated grasslands in

the Rocky Flats area. This study found that the major

distinguishing feature of what ESCO calls the rare Big bluestem within the xeric tallgrass grassland.

© USFWS

Table 7. Vegetation Communities at Rocky Flats

Vegetation Community

Grasslands

Xeric Tallgrass Grassland

Mesic Mixed Grassland

Xeric Needle and Thread Grassland

Reclaimed Mixed Grassland

Short Grassland

Shrublands

Tall Upland Shrubland

Riparian Shrubland

Other Shrubland

Total

Acres

1,568

2,199

187

640

10

34

41

70

Vegetation Community

Woodlands

Riparian Woodland

Ponderosa Pine Woodland

Wetlands

Tall Marsh Wetland

Short Marsh Wetland

Wet Meadow

Open Water/Mudflats

Other

Disturbed and Developed Areas

Acres

28

9

31

121

254

51

997

6,240
Chapter 3: Affected Environment

112 Rocky Flats National Wildlife Refuge 

“Rocky Flats Bluestem Grassland” community is the

abundance of big bluestem with little bluestem,

mountain muhly and Porter’s aster. While big and little

bluestem are characteristic of Midwestern tallgrass

prairies, mountain muhly and Porter’s aster are

characteristic of mountain environments. This unusual

combination of mountain and plains grassland species

in a consistent and recurring pattern across the Rocky

Flats alluvial surface, along with evidence of

exceptional stability, makes this vegetation community

a rare, if not unique, resource (ESCO 2002).

In 2001, high winds deposited several inches of sand on

xeric tallgrass grassland areas adjacent to existing

gravel mines in the northwest corner of the Refuge.

This sand buried most of the native vegetation and was

soon colonized by sunflower, a native annual weedy

species, as well as noxious weeds such as diffuse

knapweed, Russian thistle and kochia. This area may

require ongoing weed management and possible

reseeding to re-establish the native vegetative cover

(Kaiser-Hill 2002c).

WETLAND AND RIPARIAN CORRIDORS

MANAGEMENT ZONE

Riparian Woodland

The riparian woodland community is characterized by

a diverse mixture of plains cottonwood, peachleaf

willow, Siberian elm and coyote willow, with an

understory of various shrubs such as leadplant and

snowberry. Covering 28 acres, it is found primarily

along the drainage bottoms of Rocky Flats, with the

most significant stand occurring in the Rock Creek

drainage (Kaiser-Hill 1997; PTI 1997; Essington et al.

1996).

The most significant threat to the riparian woodland

community is from exotic species such as Siberian elm,

Canada thistle, musk thistle, smooth brome and

Kentucky bluegrass. Preservation of this woodland

community depends on the preservation of associated

streamflow (PTI 1997; Essington et al. 1996). 

Riparian Shrubland

Riparian shrubland forms extensive, dense thickets

of shrubs along the stream bottoms. This

community covers 41 acres throughout the Rocky

Flats site. It is dominated by narrowleaf willow,

coyote willow, or indigo bush and generally has an

understory consisting of leadplant, Baltic rush and

© Mauro

Choke cherry within the upland shrub habitat.

© USFWS

Cottonwood fall foliage within the riparian woodland.
Chapter 3: Affected Environment

114 Rocky Flats National Wildlife Refuge 

various sedges (Kettler et al. 1994; USACE 1994;

Kaiser-Hill 1997).

Tall Upland Shrubland

Tall upland shrubland occurs on 34 acres of northfacing slopes above seeps and along streams,

primarily within the Rock Creek drainage. The tall

upland shrubland consists of a rare association of

hawthorn, chokecherry and occasionally wild plum.

This shrubland is associated with ground water seeps

that form at the contact of the Rocky Flats Alluvium

and the underlying, relatively impermeable Arapahoe

Formation. The herbaceous understory contains a

number of species that are restricted to the cool,

shaded microhabitat provided by the canopy.

Understory species include Fendler waterleaf,

spreading sweetroot, anise root, carrionflower

greenbriar, fragile fern, Colorado violet, Rydberg’s

violet and northern bedstraw. Although the tall

upland shrubland represents less than 1% of the total

area of Rocky Flats, it contains 55% of the plant

species on the site (DOE/Service 2001). This

shrubland community is believed to be rare and may

not occur anywhere else (DOE/Service 2001; Essington

et al. 1996).

Other Shrubland

Other shrubland communities include short upland

shrubland and savannah shrubland, covering 70 acres

primarily in the Rock Creek drainage. Short upland

shrubland is characterized by stands of snowberry and

occasional Wood’s rose and is often found in association

with wet meadows and other wetland or riparian

communities. Savanna shrubland occurs in dryer areas

where scattered shrubs are interspersed with

grasslands. Three-leaf sumac is the predominant shrub

in this community (Kaiser-Hill 1997). 

Wetland Communities

Wetland communities cover 406 acres of the Rocky

Flats site and play an important role in sustaining the

diverse vegetation and habitat types found on the site.

The most significant wetland complexes at Rocky Flats

are the seep-fed wetlands along the hillsides of the

Rock Creek drainage and the Antelope Springs

complex in the Woman Creek drainage. These wetlands

are significant because they have the largest

contiguous areas and the most complex plant

associations (PTI 1997).

Three wetland types, tall marsh, short marsh and wet

meadow, are found at the site. These wetland types

occur in streamside areas along the valley floors and

near the seeps and springs that occur along many of

the hillsides. Each wetland type is described below. 

Tall Marsh Wetland

Tall marsh wetlands generally occur along ponds,

ditches and in persistently saturated seeps. Covering

31 acres of the site, these wetlands are dominated by

cattails, bulrushes and associated forbs such as

watercress, showy milkweed, swamp milkweed and

Canada thistle (a noxious weed). Antelope Springs in

the Woman Creek drainage is the best example of a

saturated slope wetland and tall marsh community at

Rocky Flats (Figure 15).

Short Marsh Wetland

Covering 121 acres, this wetland type is commonly

associated with seasonally inundated or saturated

areas, such as hillside seeps. Prevalent species include

Nebraska sedge, Baltic rush and spike rush as well as

forbs such as watercress and speedwell. 

Wet Meadow Wetland

These seasonally saturated wetlands occupy 254 acres

on the perimeter of saturated wetlands and contain

elements of both the short marsh wetland and upland

mixed grassland communities. Prevalent species

include redtop, prairie cordgrass and solid stands of

Canada bluegrass and western wheatgrass. Other

species commonly found in this community include

common milkweed, wild iris, Canada thistle, dock and

occasionally arnica (Nelson 2003).

Wetlands and open water provide waterfowl habitat.

© Mauro
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 115

MIXED PRAIRIE GRASSLANDS MANAGEMENT ZONE

Mesic Mixed Grassland

The mesic mixed grassland community is the largest

vegetation community at Rocky Flats, covering 2,199

acres across the broad ridges, hillsides and valley floors

throughout the site and the rolling plains in the eastern

portions of Rocky Flats (Figure 15). This community is

characterized by western wheatgrass, blue grama,

side-oats grama, prairie junegrass, Canada bluegrass,

Kentucky bluegrass, green needlegrass and little

bluestem. This grassland occurs on clay loam soils

having relatively higher soil moisture content than

other upland areas. The higher moisture results from

subirrigation from the coarse alluvial soils, snow

accumulation, and protection from wind (DOE 1997).

The mesic mixed grassland is very important to wildlife

species including grassland birds, small mammals and

larger mammals such as mule deer.

The quality of mesic mixed grassland varies

considerably across the site. In the western parts of the

site, this community has been degraded by diffuse

knapweed, while some areas in the eastern portion of

the site have been degraded by weed species such as

Japanese brome, alyssum and musk thistle (PTI 1997).

Xeric Needle and Thread Grassland 

Several patches of xeric grassland dominated by

needle-and-thread grass occur in the eastern half of

Rocky Flats. These patches cover 187 acres. Other

dominant grass species include New Mexico

feathergrass, Canada bluegrass, Kentucky bluegrass

and Japanese brome (Nelson 2003). This grassland

occurs primarily on the eastern extensions of the

Rocky Flats pediment that is characterized by very

cobbly sandy loam soils. Although not quite as cobbly,

these soils are very similar to the soils that support the

xeric tallgrass grassland community (Kaiser-Hill 1997).

The largest expanse of needle-and-thread grassland at

Rocky Flats occurs along the ridgetop north of the east

access road. 

Reclaimed Mixed Grassland

Reclaimed mixed grassland covers 640 acres,

primarily in the southeastern portion of the site

which was formerly cultivated for agriculture. Most

of these areas have been re-seeded with a mixture of

smooth brome and intermediate wheatgrass, both

introduced species. Other common species include

crested wheatgrass, sweetclover and field bindweed

(Kaiser-Hill 1997). 

Short Grassland

This grassland is typified by buffalograss and

blue grama, both short grass prairie species. Ten

acres of this community are found on the site

(Kaiser-Hill 1997).

Ponderosa Pine Woodland

Isolated patches of ponderosa pine woodland cover 9

acres in the uppermost reaches of the Rock Creek and

Woman Creek drainages near the western edge of the

Refuge. These scattered pines represent an eastward

extension of the nearby foothills forests. While much of

the understory is similar to the adjacent grassland

communities, other associated plants are more likely to

occur in foothills environments (DOE 1997).

Disturbed and Developed Areas

Disturbed and developed areas consist of existing or

former facilities associated with the previous use of the

Rocky Flats site. They include roads, landfills, dams

and other facilities. They also include former facilities

that have been revegetated with native and introduced

grass species.

NOXIOUS WEEDS

Noxious weeds are exotic, aggressive plants that invade

native habitat and cause adverse economic or

environmental impacts. Since 1990, Rocky Flats has

experienced a large increase in noxious weeds (DOE

1997). At Rocky Flats, the noxious weed species with

the greatest potential to degrade the native plant

communities and that are the most difficult to control

include diffuse knapweed, musk thistle, Dalmatian

toadflax, and Canada thistle. Other increasingly

Dalmatian toadflax, a noxious weed, has moved into

large areas of the Refuge.

© Mauro
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 117

problematic weeds are downy brome (cheatgrass), field

bindweed, and jointed goatgrass (Lane 2004). Diffuse

knapweed, an aggressive tumbleweed, is currently

given highest control priority. Canada thistle is

common in and around most of the wetlands, musk

thistle is found across mesic grasslands, and Dalmatian

toadflax is common in xeric grasslands and other areas

(Figure 16). Sulfur cinquefoil is a new invader to the

area that may have already established populations on

the Refuge (Lane 2004). 

Prioritized noxious weed lists and selected weed control

measures are found in the 2002 Annual Vegetation

Management Plan. The three most abundant noxious

weeds identified in 2001 mapping were: Dalmatian

toadflax infesting 2,504 acres; diffuse knapweed

infesting 1,919 acres; and musk thistle infesting 869

acres (Table 8) (Kaiser-Hill 2002a; DOE/Service 2001).

RARE PLANTS

No federally listed plant species, such as the Ute

ladies’-tresses orchid or Colorado butterfly plant, are

known to occur at Rocky Flats. Aside from the rare

xeric tallgrass prairie and tall upland shrubland

communities, Rocky Flats also supports populations of

four rare plant species that are listed as rare or

imperiled by the CNHP. These species are the

mountain-loving sedge, forktip three-awn,

carrionflower greenbriar, and dwarf wild indigo.

Forktip three-awn primarily occurs in previously

disturbed sites near the western edge of the current

Industrial Area. The other three species occur

primarily along the pediment slopes in the Rock

Creek drainage (Kaiser-Hill 2002c).

FIRE HISTORY

Historical documentation indicates that the

grasslands in the Rocky Flats area have been

subjected to lightning and human-caused fires for

thousands of years (DOE 1999). These fires likely

played a major role in promoting native vegetation

growth and diversity (DOE 1999). Since 1972,

wildfires have not been allowed to burn and only one

controlled burn has been conducted in the grasslands

at Rocky Flats. As a result, a fuel load of dead

vegetation has been building up in the grasslands of

Rocky Flats for at least 30 years. This buildup of dead

vegetation has contributed to an invasion of noxious

weeds on the site, particularly in the last 10 years

(DOE 1999). 

Seven wildfires have been documented on the site

since 1993 (Figure 17). In 1994, the Spring Grassland

fire burned 70 acres between Highway 128 on the

north boundary and the north access road. In 1996,

the 104-acre Labor Day Grassland Fire burned much

of an area penned in by access roads in the southern

portion of the site. In February 2002, a 27-acre fire

burned through portions of the Rock Creek drainage

on the south side of Highway 128. A 48-acre

prescribed burn was conducted on April 6, 2000. The

prescribed burn took place in the same area as the

1996 wildfire (Kaiser-Hill 2002). 

3.5. WILDLIFE RESOURCES

Many areas of the Rocky Flats site have remained

relatively undisturbed for the last 30 to 50 years,

allowing them to retain diverse habitat and associated

wildlife. These wildlife communities are supported by

Mixed mesic grassland provides food and shelter for elk

and other wildlife.

© Mauro

Table 8. Major Noxious Weeds at Rocky Flats

Weed Name

Dalmatian toadflax

Diffuse knapweed

Musk thistle

High Density

(ac.)

341

380

9

Medium Density

(ac.)

389

525

84

Low Density

(ac.)

1,240

377

430

Scattered

Density (ac.)

537

377

346

Total Infested

Area (ac.)

1,207

1,956

869
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 119

the regional network of protected open space that

surrounds the site on three sides, buffering wildlife

habitat from the surrounding urban development.

MAMMALS

One of the most abundant and conspicuous mammal

species at Rocky Flats is the mule deer. A resident

herd of about 160 individuals inhabits the site. While

mule deer distribution varies by the season, they

appear to have a general preference for the following

areas (shown in Figure 18):

• The open grasslands of the upper Rock

Creek drainage 

• The shrublands of the lower Rock Creek

drainage

• The grasslands of the upper Walnut Creek

drainage

• The hillsides above lower Walnut Creek

• Riparian bottomlands around Woman Creek

and Antelope Springs

• The grasslands below the pediment in the

Smart Ditch drainage

In the spring, mule deer exhibit an affinity for woody

habitat and secondarily for grasslands. In the summer,

deer use is more generally divided among different

habitats. In the fall, mule deer primarily use woody

habitats, with grasslands also being important. In the

winter, mule deer are commonly observed in grasslands

and tall upland shrublands (Kaiser-Hill 2001). 

Whitetail deer have become more common at the site

and are often observed in company with mule deer.

The Refuge is in CDOW’s Game Management Unit

(GMU) #38 and is adjacent to GMU#29, which

collectively make up the Boulder deer herd. American

elk visit Rocky Flats, but are not resident (DOE

1997). In 2003, 11 cow elk were observed with nine

calves in the Rock Creek drainage (Wedermyer 2003). 

Other mammals observed at Rocky Flats include

desert cottontail, white-tailed jackrabbits, blacktailed jackrabbits, muskrat and porcupine. Muskrats

generally occur in and around the ponds, while

porcupine populations are limited to the shrubland

and ponderosa pine habitats in the upper Rock

Creek drainage (DOE 1997). Black-tailed prairie

dogs inhabit the Rocky Flats site in limited numbers

(Figure 18) and are discussed in greater detail below.

Numerous small mammal species, such as mice and

voles, inhabit all vegetation community types at

Rocky Flats. Preble’s meadow jumping mouse, a

threatened species, is described below under

Federal Threatened and Endangered Species.

Two commonly observed carnivore species at Rocky

Flats are the coyote, which occurs throughout the site,

and raccoon, which is often seen in the Industrial Area

and near watercourses. Typically at Rocky Flats, three

to six coyote dens support an estimated 14 to 16

individuals at any given time (Kaiser-Hill 2001).

Twenty-two coyote dens used between 1991 and 2002

have been identified at Rocky Flats. The coyote dens

generally occur on hillsides near watercourses. Six

dens were active in 2002. One active den was located in

the upper Rock Creek drainage, two were located on

the slopes above either side of Walnut Creek near

Indiana Street, one was near the D-1 pond, one near

Antelope Springs and one in the upper South Woman

Creek drainage (Nelson 2003). Other carnivores

The coyote is a commonly observed carnivore species on the Refuge.

© Mauro
Chapter 3: Affected Environment

120 Rocky Flats National Wildlife Refuge 

include striped skunk, gray fox, red fox, long-tailed

weasel, American badger and mink. Black bears and

mountain lion tracks are occasionally seen at the site

(Kaiser-Hill 2000, 2001).

Black-Tailed Prairie Dog

The black-tailed prairie dog is a controversial species on

the forefront of conservation in the U.S. (CDOW 2003).

The prairie dog is often described and disputed as a

“keystone species” because it has a large effect on

community structure or ecosystem function (Power et al.

1996; CDOW 2003).

In August 2004, the Service removed the prairie dog

from consideration as a candidate species under the

Endangered Species Act (Service 2004b). Candidate

species are plants and animals for which the Service has

sufficient information on their biological status to

propose them as endangered or threatened under the

ESA, but for which development of a proposed listing

regulation is precluded by other higher priority listing

activities. Candidate species receive no statutory

protection under the ESA (Service 2002).

Regardless of its status as a keystone species, prairie

dogs play an important role in grassland ecosystems.

Several studies found that prairie dogs alter plant

species composition and structure. Typically, areas

occupied by prairie dogs have greater cover and

abundance of perennial grasses and annual forbs

compared to non-occupied sites (Whicker and Detling

1988; Witmer et al. 2002). Prairie dogs can contribute to

overall landscape heterogeneity, affect nutrient cycling,

and provide nest sites and shelter for wildlife such as

rattlesnakes and burrowing owls (Whicker and Detling

1988). Prairie dogs can also denude the surface by

clipping above-ground vegetation and contributing to

exposed bare ground by digging up roots (Kuford 1958;

Smith 1967). Prairie dogs are susceptible to and can

spread Sylvatic plague.

Three black-tailed prairie dog colonies, comprising 112.8

acres of grasslands, were mapped at Rocky Flats in 2000.

Since 2000, plague outbreaks have reduced the active

colonies to an area of 10 acres (Stone 2003). These

colonies are shown on Figure 19. 

The Rocky Flats site contains about 2,460 acres of

potential prairie dog habitat (Figure 19). Delineations of

potential prairie dog habitat are based on soil,

vegetation, and slope attributes that prairie dogs are

known to prefer (Clippinger 1989):

• 30 to 90% herbaceous cover

• 2- to 10-inch vegetation height Swainson’s hawk.

© USFWS

Western meadowlark.

© Mauro

American goldfinch.

© Mauro
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 123

• Slopes less than 20% (prefer less than 10%)

• Rock-free soils with less than 70% 

sand content

BIRDS

The most commonly observed raptors at Rocky Flats

are red-tailed hawk, great horned owl and American

kestrel. Other less abundant raptors include

Swainson’s hawk, ferruginous hawk, prairie falcon and

long-eared owls. Most raptor species use riparian

woodlands or tall upland shrublands for nesting and

roosting habitat and forage in all habitats at the site.

Raptor nest sites observed between 1991 and 1998 are

shown on Figure 18.

Over 185 species of migratory birds have been

recorded at Rocky Flats, of which about 75 are

believed to breed at the site. Of the estimated 100

neotropical migrants (migratory birds that breed

north of the U.S./Mexico border and winter south of

the border (PTI 1997)) at Rocky Flats, about 45 are

confirmed or suspected breeders at the site. 

Commonly observed bird species in wetland habitats

include the red-winged blackbird, song sparrow,

common yellowthroat and common snipe. Common

birds in riparian woodland areas include the northern

oriole, American goldfinch, house finch and yellow

warbler. The tall upland shrubland habitat is

inhabited by the song sparrow, rufus-sided towhee,

black-billed magpie, yellow-breasted chat and blackcapped chickadee. Common grassland birds include

the vesper sparrow, western meadowlark,

grasshopper sparrow and mourning dove (DOE

1997). The reclaimed mixed grassland provides

habitat for birds such as the western meadowlark and

vesper sparrow (PTI 1997).

Several waterfowl species use the ponds at Rocky

Flats. The most common waterfowl are mallards and

Canada geese (DOE 1997). Great blue herons feed

in mudflats and short marshlands, while doublecrested cormorants are common summer residents.

Plains Sharp-tailed Grouse

The Rocky Flats site and surrounding areas contain

potential habitat for the plains sharp-tailed grouse.

The grouse is extirpated from the area and is not

known to occur at Rocky Flats prior to 2003 (DOE

1997). The City of Boulder Open Space and Mountain

Parks Department, along with Boulder County Parks

and Open Space and the CDOW, have initiated a

sharp-tailed grouse reintroduction program on joint

City-County owned open space land north of Rocky

Flats. About 25 individuals were transplanted to the

open space area in 2003, while several more are

planned to be reintroduced in the future (Brennan

2003). Several of the transplanted individuals are

believed to have used Rocky Flats’ grasslands

(Wedermyer 2003). 

According to the CDOW Plains Sharp-tailed Grouse

Recovery Plan (CDOW 1992), grouse use different

habitats seasonally with extensive use of grassland

and grassland-low shrub transition zones. Riparian

areas and wooded draws are important winter habitat.

Reasons for the decline of sharp-tailed grouse include

land cultivation, livestock grazing and fire control.

Other threats to grouse include urban development

and alteration of habitat by weed infestation

(Gershman 1992). 

REPTILES AND AMPHIBIANS

In general, reptiles and amphibians are found in small

numbers at Rocky Flats due to an absence of suitable

habitat. The most common reptiles are the bullsnake,

yellow-bellied racer, plains garter snake and prairie

rattlesnake. All of these species occur in the open

grassland habitats, although the plains garter snake

typically lives close to water bodies. Other reptiles

include the short-horned lizard in open grasslands, the

eastern fence lizard in rocky shrublands, and the

western painted turtle in ponds (DOE 1997).

The most abundant amphibian at Rocky Flats is the

boreal chorus frog, which breeds in water bodies

throughout the site. The northern leopard frog is less

common and is found only in permanent water bodies

such as ponds (DOE 1997). The boreal chorus frog is

relatively abundant in the streams and wetlands at

Rocky Flats (Kaiser-Hill 2000). Other amphibians Northern red-belly dace were introduced into the

Lindsay Pond in 2003.

© RFETS
Chapter 3: Affected Environment

124 Rocky Flats National Wildlife Refuge 

include the bullfrog, Woodhouse’s toad, the plains

spadefoot and the tiger salamander (DOE 1997). 

AQUATIC SPECIES

Aquatic species at Rocky Flats are limited in drainages

and ditches by low and irregular flows. The most

common aquatic macroinvertebrates (aquatic insects)

are the larvae of the blackfly, midge and mayfly (DOE

1997). Other species include caddisflies, craneflies,

damselfly larvae, as well as snails and amphipods.

Large macroinvertebrates such as crayfish and snails

are potentially important prey for other fish, waterfowl

and mammal species. 

Each of the three primary drainages at Rocky Flats

contains a variety of pond and stream habitats, varying

amounts of habitat modification, and seasonal water

flows. The Walnut Creek drainage has been highly

modified as part of the development of Rocky Flats.

The upper section of the drainage was filled and the

lower section modified into a series of small reservoirs

that can retain water released from the Industrial

Area. A variety of non-native fish species (rainbow

trout, carp, bass) were introduced into the Walnut

Creek reservoirs. Although all introductions did not

establish reproducing fish populations, carp, goldfish

and fathead minnows are present in these reservoirs.

Woman Creek retains a significant amount of stream

habitat and holds the majority of Rocky Flats fish

species. Native fish species that reproduce within

Woman Creek include white suckers, fathead minnows,

green sunfish, stonerollers and creek chubs. Two nonnative fish species, golden shiners and largemouth

bass, also are found in the drainage. 

According to the Colorado Vertebrate Ranking System

(CDOW 2001), the Iowa darter and common shiner

rank high enough to merit re-evaluation and the

redbelly dace is potentially imperiled. Threats to these

species include extirpation through habitat degradation

(e.g., siltation, pollution and/or bank destabilization, the

effects of urbanization and predation by introduced

non-native fish.

Native Fish Restoration

The 2001 Rock Creek Reserve Integrated Natural

Resources Management Plan (DOE/Service 2001)

called for the establishment of native fish populations

within the Rock Creek drainage. Rock Creek supports

favorable habitat for native fish such as the common

Mule deer are one of several wildlife species that regularly move between the Refuge and adjoining lands.

© Mauro
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 125

shiner and northern redbelly dace. Monitoring during

the drought of 2002 demonstrated that Rock Creek

flows remain consistent in dry years.

Native fish restoration efforts began in 2002, when

largemouth bass and other non-native fish were

removed from the Lindsay Ponds with rotenone (a

piscicide). In June and August 2003, common shiner

and northern redbelly dace were introduced to the

Rock Creek drainage, with the intention of establishing

a new population of these rare and declining native fish

species (Rosenlund 2003). 

WILDLIFE SPECIES OF SPECIAL CONCERN

In addition to federally listed wildlife species described

below in the Federal Threatened and Endangered

Species section, the Rocky Flats site has been known

to support numerous species with special status

designated by CDOW because of their rare or

imperiled status (Table 9). Western burrowing owl has

been observed in grasslands and the ferruginous hawk

has been observed in riparian woodlands and open

grasslands (PTI 1997; DOE 1997).

WILDLIFE CORRIDORS

While Rocky Flats is surrounded on three sides by

major roads, many wildlife species move between the

site and habitat in surrounding areas. However,

movement corridors between the Refuge and adjacent

lands are not well defined. Movement of most

terrestrial species occurs along broad areas where

disturbance and barriers to movement are minimized

(Howard 2003; Wedermyer 2003).

On the west side of the Refuge, east-west movement

across Highway 93 can be impeded by the South Boulder

Diversion Canal and mining areas on the western edge of

Rocky Flats. Given these barriers, the most likely areas

for wildlife movement are the open lands in the upper

Rock Creek area and the upper Woman Creek area

between the mining areas (on land owned by the State of

Colorado) and the west access road.

Prairie dogs cross Highway 128 in the northwest

corner of the Refuge, to access other colonies on

adjacent open space lands. Otherwise, north-south

prairie dog movement across Highway 128 does not

likely occur at any specific location. The Rock Creek

drainage along the highway is impeded by the highway

embankment and the culverts for the creek are too

small for use by larger species of mammals. Likewise,

the east side of the Refuge is open in most places and

wildlife moves across a broad front, although the

Walnut Creek and Woman Creek drainages provide

natural corridors for east-west movement for small and

mid-size mammals across Indiana Street. The Refuge contains about 2,460 acres of potential

prairie dog habitat.

© USFWS

Preble’s meadow jumping mouse.

© RFETS
Chapter 3: Affected Environment

126 Rocky Flats National Wildlife Refuge 

Most deer on Rocky Flats do not migrate offsite and

elk periodically descend from the foothills and enter

Rocky Flats from the west. In the spring of 2003,

several cow elk used the Rock Creek drainage as a

calving ground (Wedermyer 2003). The behavior of

other species is less known.

POTENTIAL CONTAMINATION ISSUES

Extensive studies have been conducted on the

potential effects of contamination on wildlife and

vegetation at Rocky Flats since the mid 1970s, mostly

by Colorado State University. These studies include

two deer studies as well as studies of small mammals,

arthropods (insects), snakes, and cattle. Samples

were taken of various species for the Draft Ecological

Risk Assessments for Walnut Creek and Woman

Creek Watersheds at Rocky Flats Environmental

Technology Site (September 1995) and included

samples consisting of small mammals, insects, benthic

invertebrates, and fish. Additional studies were done

by CSU on vegetation uptake of plutonium, in both

terrestrial and aquatic species. Studies conducted at

other DOE facilities can be used to compare to Rocky

Flats. See Section 1.8 - Issues Outside the Scope of

This EIS, and Section 3.2 - Geology and Soils for

more information about residual soil contamination at

Rocky Flats.

Tissue samples, including edible tissues of deer

harvested at Rocky Flats in 2002, have been analyzed

for contaminants. The results of these analyses

indicate radionuclide tissue levels of non-detectable

quantities or at method detection limits. In all cases

the edible tissue levels are below the 1x10-6 risk-based

level for consumption of Rocky Flats deer tissue.

3.6. FEDERAL THREATENED AND 

ENDANGERED SPECIES

Rocky Flats supports two wildlife species listed as

threatened or endangered under the Endangered

Species Act (ESA). The Preble’s meadow jumping

mouse and the bald eagle are listed as threatened. 

As discussed in the preceeding Wildlife section, the

black-tailed prairie dog is no longer listed as a

candidate species (Service 2004b). 

PREBLE’S MEADOW JUMPING MOUSE

Preble’s meadow jumping mouse (Preble’s) occurs in

every major drainage on the site. Listed as a

threatened species in 1998, the mouse occurs in habitat

adjacent to streams and waterways along the Front

Range of Colorado and southeastern Wyoming. At

Rocky Flats, Preble’s also has been found in wetlands

and shrubland communities adjacent to the Rock

Creek and Woman Creek drainages. Knowledge of the

natural history and ecology of the Preble’s is limited.

An increase in knowledge about the species may

change our understanding of their habitat needs and

associations. In 2003, the Service designated critical

habitat for the Preble’s. The critical habitat did not

include any of the drainages at Rocky Flats because

the site is to become a Refuge (Service 2003). 

In March 2004, the Service initiated a status review of

the Preble’s based on two petitions to remove the

mouse from federal protection under the Endangered

Species Act. When the status review is finished, the

Service will issue a finding regarding whether the

subspecies should remain listed or should be proposed

for delisting (Service 2004). Until the status review

and finding are finalized, the Service will continue to

manage Preble’s as a threatened species in accordance

with existing laws and policies.

Table 9. Wildlife Species of State Special Concern at Rocky Flats

Common Name

Plains sharp-tailed grouse

Western burrowing owl

Northern leopard frog

American peregrine falcon 

Common garter snake

Ferruginous hawk

Greater sandhill crane

Long-billed curlew

Mountain plover

Scientific Name

Tympanuchus phasianellus jamesii

Athene cunicularia hypugea

Rana pipiens

Falco peregrinus

Thamnophis sirtalis

Buteo regalis

Grus canadensis tibida

Numenius americanus

Charadrius montanus

Status

State endangered

State threatened

State special concern

State special concern

State special concern

State special concern

State special concern

State special concern

State special concern

Occurrence at 

Rocky Flats

Observed infrequently

Known resident or regular visitor

Known resident

Regular visitor

Observed infrequently

Known resident or regular visitor

Observed infrequently

Observed infrequently

Observed infrequently
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 127

BALD EAGLE

The bald eagle occasionally forages at Rocky Flats

although no nests have been identified. An active nest

is located to the east of Rocky Flats near Standley

Lake. Eagles feed primarily on fish and waterbirds but

also on small mammals and mammal carcasses

(DOE/Service 2001). The bald eagle was federally

listed as endangered in 1967 and was downlisted to

threatened in 1994. 

PLANT SPECIES

No federally listed plant species are known to occur at

Rocky Flats. While many of the riparian and wetland

communities support potential habitat for the Ute

ladies’-tresses orchid and Colorado butterfly plant,

these species are not known to occur at the site (ESCO

1994). The mosaic of vegetation communities at Rocky

Flats contains several rare and sensitive plant

communities. These include the xeric tallgrass

grassland, tall upland shrubland, riparian shrubland,

mountain-loving sedge, forktip three-awn,

carrionflower greenbriar, dwarf wild indigo and plains

cottonwood riparian woodland communities. Each of

these communities is described in detail in the

Vegetation Communities section.

3.7. CULTURAL RESOURCES

Cultural resource surveys have identified and recorded

45 cultural sites or artifacts at Rocky Flats (Figure 20).

Most of these sites or artifacts are related to EuroAmerican occupation of the area within the last 120

years. None of the identified cultural resources are

recommended as eligible for listing in the National

Register of Historic Places.

PREHISTORIC RESOURCES

While various Native American groups occupied the

Rocky Flats region prior to 1800, few remains from

this period have been found on the site. Cultural

resource inventories have identified several isolated

finds of prehistoric origin, including stone enclosures

and stone cairns (Dames and Moore 1991).

HISTORIC RESOURCES

Numerous sites and artifacts related to agricultural

and mining activity at Rocky Flats in the early 20th

century have been identified. These include ditches,

stock ponds, rock piles, building remains, fencing

materials and other farming and ranching-related

equipment (Figure 20). Remnants of an apple orchard

are near the site of a former stage coach stop in the

Woman Creek drainage. An abandoned railroad grade,

whose construction began in 1881 and was never

completed, traverses the Refuge.

Many historic sites relate to land uses at Rocky Flats

during the early 20th century. During this time, the

cattle industry along the Front Range boomed and

several families acquired land for pasture in the Rocky

Remnants of an apple orchard are among the cultural resources found in the Woman Creek drainage.

© Shapins Associates
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 129

Flats area. In most cases, the primary ranch sites

were outside of what became the Rocky Flats site,

with the exception of the Lindsay Ranch (Dames and

Moore 1991).

Lindsay Ranch

The area known as the Lindsay Ranch was originally

homesteaded by the Scott family in 1868. The

northern part of this area was given to the railroad

in 1897 as part of the railroad land grants. Other

lands surrounding what became the Lindsay Ranch

were homesteaded by various settlers in the 1880s

and 1890s. Between the late 1880s and 1916, the

Jones family, one of the original homesteaders in the

area, had acquired the area that would become the

Lindsay Ranch. During this time, many of the

original homesteads were being consolidated into

larger parcels to provide pasture for cattle (Dames

and Moore 1991). 

In 1916, almost 700 acres of land in the area was sold

to the Ebertharter family, who controlled 1,280 acres

along the northern portion of the current Rocky Flats

site. In 1941, a 640-acre ranch property was sold to

George and Susan Lindsay. The Lindsays resided in

Denver and raised cattle on the ranch at Rocky Flats.

The Lindsays owned the ranch property at Rocky

Flats and a 320-acre ranch parcel at the west end of

Leyden Gulch, south of Rocky Flats. The barn was

constructed in the mid-1940s, followed by the

construction of the house in 1949. The house was

occupied by a caretaker until the property was

condemned by the U.S. Atomic Energy Commission

for the development of the Rocky Flats plant in 1951.

Maintenance of the ranch structures ceased in 1952.

During the operation of the Rocky Flats plant,

security personnel informally used both the house

and barn for target practice. The Lindsay Ranch

area now consists of a large barn, a collapsed shed,

corral, livestock chute, and a frame house. A blizzard

in March 2003 dumped over 3 feet of snow in the

area, collapsing the east and west wings of the barn.

During the fall of 2003, the Service, in partnership

with DOE stabilized the barn to prevent further

damage to the structure (Norman 2003). The two

wings were essentially rebuilt. Part of the barn roof

was repaired. Portions of the concrete foundations

were replaced. The windows and doors were boarded

to protect the structure from wind and moisture. 

The house is in a dilapidated condition, with holes in the

roof and walls and an unstable floor, and has not been

maintained or stabilized since it was last used in 1951.

Cold War Era

The Rocky Flats site was one of the 13 nuclear

weapons production facilities in the United States

during the Cold War. Weapons production ended in

1989. The DOE completed an inventory of all buildings

on the site and determined 64 facilities within the

Industrial Area are very important to regional, national

and international history for their role during the Cold

War era. The State Historic Preservation Office has

determined that these 64 facilities are eligible for

listing in the National Register of Historic Places as a

historic district (DOE 1997). All of these facilities will

be removed prior to site closure and establishment of

the Refuge.

3.8. INFRASTRUCTURE, EASEMENTS, 

AND UTILITIES

TRANSPORTATION

The Rocky Flats site is surrounded on all sides by state

highways or a major thoroughfare. Colorado Highway

East entrance road to Rocky Flats.

© USFWS

The Lindsay Ranch barn is the most prominent historic

resource at Rocky Flats.

© Shapins Associates
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 131

128 defines most of the site’s northern boundary, while

Highway 93 runs parallel to the western boundary

about 1⁄4 mile to the west. Less than 1 mile to the south,

Highway 72 runs parallel to the site’s southern

boundary. Indiana Street defines the site’s eastern

boundary. Current access to the site is from Highway

93 or Indiana Street. The existing access road leading

into Rocky Flats Environmental Technology Site east

from Highway 93 carries approximately 2,700 vehicles

per day (David Evans 2003). However, traffic on the

existing access road will be greatly reduced following

cleanup and closure of the site by DOE.

Highway 93

Colorado State Highway 93 west of Rocky Flats is

relatively straight and flat with adequate sight distance

in the vicinity of the existing access road. The Rocky

Flats access road intersects Highway 93 at a signalized

intersection about 1.5 miles north of Highway 72. The

section of Highway 93 at the access road has two

through travel lanes with a southbound left turn lane

and northbound right turn lane, as well as northbound

and southbound acceleration lanes at the intersection.

This segment of Highway 93 is categorized as an

Expressway (Category E-X) in the CDOT State

Highway Access Category Assignment Schedule

(CDOT 2001), which defines the requirements for

access locations, operation and design criteria along

roadways on the state highway system. The speed

limit along Highway 93 approaching the signal is 45

mph. Highway 93 carries about 22,100 vehicles per

day (measured north of the west access road) (David

Evans 2003). This volume is projected to increase

during the life of the CCP (Table 10). 

The Highway 93 and Highway 72 intersection

southwest of the site is signalized. The Highway 93

and Highway 128 intersection northwest of the site is

also signalized.

Highway 128

Colorado State Highway 128 north of the site is two

lanes with substantial horizontal and vertical curves

between Highway 93 and McCaslin Boulevard. This

segment of Highway 128 is categorized as a Regional

Highway (Category R-A) in the CDOT State Highway

Access Category Assignment Schedule (CDOT 2001).

City of Boulder and Boulder County Open Space is

adjacent to the roadway on the north side and a

signalized intersection is at McCaslin Boulevard. The

speed limit in this segment is 55 mph. Highway 128

west of McCaslin Boulevard carries about 5,200 vehicles

per day (David Evans 2003). This volume is projected to

increase during the life of the CCP (Table 10).

Indiana Street

Indiana Street east of the site is a straight two-lane

alignment over rolling terrain with little to no

shoulder between Highway 128 and 96th Avenue. The

speed limit in this segment is 50 mph. Indiana Street

east of the project site carries about 5,600 vehicles

daily (David Evans 2003). Traffic volume is projected

to increase during the life of the CCP (Table 10).

Clay mining along the Refuge’s western boundary.

© USFWS

Table 10. Daily and Peak Hour Traffic Volume Summary

Roadway Segment

SH 93 – West of Rocky Flats

SH 128 – East of SH 93

Indiana Street – East of Rocky Flats

2002 AADT†

19,040

4,510

–

2003

Weekday Count

22,110

5,170

5,580

2021

Estimated AADT

28,500

6,700

8,100

† Traffic volumes from CDOT website (CDOT 2003). 

AADT = Annual Average Daily Traffic.

Source: David Evans and Associates, Inc. (2003).
Chapter 3: Affected Environment

132 Rocky Flats National Wildlife Refuge 

This roadway is an arterial maintained by Jefferson

County. The land on the east side of the roadway is

City and County of Broomfield and City of

Westminster Open Space and land owned by the

Woman Creek Reservoir Authority. The Highway 128

and Indiana Street intersection northeast of the site is

signalized. The existing Rocky Flats Environmental

Technology Site has a gated access at a signalized

intersection on Indiana Street about 1.5 miles north of

96th Avenue. The Indiana Street and 96th Avenue

intersection southeast of the site is also signalized.

Internal Roads

The Rocky Flats site currently has many roads, fences

and utilities that serve its pre-closure functions.

Outside of the Industrial Area, which currently

contains a network of paved streets, most of the site is

accessed by a network of graded gravel roads and

minor two-track roads. In addition, existing mineral

rights and water rights on site are owned by outside

entities. Existing infrastructure, utility easements and

mining permits are shown on Figure 21.

UTILITIES

The utility infrastructure currently serving the site,

including electric and sewer lines, will be removed or

remediated in place prior to closure. According to the

Refuge Act (Appendix A), existing, privately owned

utility easements across the site will remain in place

and the owners of those easements will have the right

to continue to access them.

Natural Gas Easements

Two natural gas easements are currently on the site, a

north-south easement and an east-west easement. The

north-south easement runs through the eastern portion

of the site. The east-west easement runs along the

southern edge of the Industrial Area, extending

between the east and west access gates (Figure 21). In

an area east and south of the Industrial Area, the title

to portions of both natural gas easements is unclear

(Schiesswohl 2003). 

Electrical Line Easements

A 230-kV electrical line follows an easement through

the southern and eastern portions of the site. The line

runs in a north-south orientation between the north

boundary and the proximity of South Woman Creek,

where it then runs southwesterly toward the southern

boundary of Rocky Flats. A second electrical line

easement runs from the proximity of the C-2 pond to

the east gate along Indiana Street. 

Two parallel 115-kV electrical lines follow easements

from the northeast corner of Rocky Flats toward the

Industrial Area. These lines were constructed

primarily to serve the Industrial Area and will be

removed and easements abandoned prior to site

closure. Another electrical line easement follows the

west access road from Highway 93 to the Industrial

Area. This electrical line has been removed and the

easement will be abandoned (the title to this easement

is unclear). These easements are shown on Figure 21.

An electrical line with no easement follows the west

side of Indiana Street, within the Rocky Flats

boundary. 

Other Utilities

A fiber optic line with an easement runs from the

NWTC in the northwest corner of the site, across the

Rock Creek drainage, to the Industrial Area. The

future of this line and easement is uncertain. In addition

to the electrical line along the west side of Indiana

Street, a telephone and fiber optic line also follows the

Indiana right of way. These utility lines do not have

easements and may be within the Rocky Flats site

(instead of the Indiana right of way) (Schiesswohl 2003).

MINERAL RIGHTS

A substantial portion of the mineral estate (subsurface

mineral rights) associated with lands at Rocky Flats is

privately owned. The Service believes that the exercise

of these existing privately owned mineral rights,

particularly surface mining of gravel and other

aggregate material, at Rocky Flats will have an

adverse impact on the management of the Refuge. The

Service does not believe it can manage the Refuge for

meeting the purposes of section 3177(e)(2) of the

Refuge Act if certain mineral rights are exercised.

Accordingly, the Service will not accept transfer of

Many internal roads would be revegetated.

© Shapins Associates
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 133

administrative jurisdiction from DOE for lands subject to

the mining of gravel and other aggregate material at

Rocky Flats until the United States owns the mineral

rights of the land to be transferred to the Service, or

until the mined lands have been reclaimed to a mixed

prairie grassland community. 

Three permitted mining areas currently exist on Rocky

Flats (Figure 21):

• Bluestone Sand and Gravel mine and Bluestone

expansion – 425 acres

• Lakewood Brick and Tile – 80 acres

• Church Ranch Rocky Flats Pit – 94 acres

LaFarge, Inc. (formerly Western Aggregates) operates

the Bluestone sand and gravel quarry in the

northwestern corner of the site. While the permit area

includes 425 acres of land, about 300 acres are

designated for habitat preservation, or non-mining

setback, easements and buffer areas (Jefferson County

2002). The Bluestone permit allows expansion of the

mine into the northern portion of the Rock Creek

drainage, near the NWTC (Figure 21). Most of the

Rock Creek drainage is included in a habitat

preservation area. 

Lakewood Brick and Tile operates an 80-acre 

clay mining area immediately north of the west

access road. 

In 2004, Church Ranch received a permit for gravel

extraction from the Rocky Flats Pit, located east of the

Lakewood Brick and Tile operation on the north side

of the west access road. As directed by the Colorado

Division of Minerals and Geology in the mining permit,

the Church Ranch mining plan stipulates that it will

not expose groundwater. Mining activities will stay a

minimum of 2 feet above groundwater (CDMG 2004;

Church Ranch 2004). 

WATER RIGHTS

As discussed in the Water Resources section, the

current water supply to the Rocky Flats site will be

terminated following the cleanup and closure of the

existing facilities. The U.S. Government does not

own water rights on the Rocky Flats site. However,

two outside entities do own water rights. The

Smart Ditch and Irrigation Company owns water

rights through the Smart Ditch from Rocky Flats

Lake (west of the site) to the D-2 Pond in the

southeast corner. The City and County of

Broomfield owns water rights in the Upper Church

Ditch and the McKay Ditch, which convey water

across Rocky Flats to the east and northeast. Other

water rights on the site include the Mower Ditch

and the Kinnear Ditch (Advanced Sciences 1991). A

new water supply to serve the Rocky Flats NWR is

not planned.

3.9. SURROUNDING LAND USE

The Rocky Flats site is at the intersection of Jefferson,

Boulder and Broomfield counties. The site is

surrounded by open space to the north, east and west

and urban development to the northeast and southeast

(Figure 22). Other nearby land uses include mining

operations, wind energy research, and water collection

and storage facilities.

MUNICIPALITIES

Four principal cities and towns, Arvada, Westminster,

Broomfield and Superior, are located within close

proximity of Rocky Flats. The general land uses of

those portions of these municipalities located near the

site are described below.

The City of Arvada is located southeast of Rocky Flats.

While most of Arvada’s residential and commercial

development is over 1 mile from Rocky Flats, the

Downy paintbrush.

© Nelson, RFETS
Chapter 3: Affected Environment

134 Rocky Flats National Wildlife Refuge 

City’s incorporated boundary directly abuts the site. A

large area immediately south of Rocky Flats and east of

Highway 93 has been annexed by the City and is

planned for residential and mixed development (see

Section 2.10 - Reasonably Foreseeable Activities). This

area, known as the Vauxmont property, is currently

vacant and used for livestock grazing.

North of Arvada, the City of Westminster is located

directly east of Rocky Flats. However, most of the

western portions of Westminster’s incorporated area

consist of open space. Residential land uses begin about

1.5 miles east of Rocky Flats.

The City and County of Broomfield is located

immediately east and northeast of Rocky Flats. The

area to the east is dominated by open space associated

with Great Western Reservoir and undeveloped land.

Other portions of this area are planned for development

supporting office complexes. An existing office complex

is located about 1 mile northeast of Rocky Flats on the

north side of Highway 128.

The Town of Superior is north and northeast of Rocky

Flats’ northeastern corner. Existing residential land

uses are about 1⁄4 mile north of Rocky Flats and future

residential developments are proposed for the area.

Superior’s town center is located about 2 miles north of

the Rocky Flats boundary.

WOMAN CREEK RESERVOIR AUTHORITY

The Woman Creek Reservoir Authority is a separate

unit of government composed of the cities of

Westminster, Thornton and Northglenn. The Authority

constructed the Woman Creek Reservoir in 1996 to

prevent the flow of surface water from Rocky Flats into

Standley Lake, a drinking water source for several

communities (CDPHE 2003a). The Woman Creek

Reservoir Authority owns the reservoir and some of the

land surrounding the reservoir.

OPEN SPACE

The Rocky Flats site is surrounded on three sides by

designated open space. These open space lands are

owned and managed by seven different jurisdictions and

are described in detail in Section 3.10.

OTHER NEARBY LAND USES

The Colorado State Land Board manages state land in

Section 16 immediately southwest of Rocky Flats.

Portions of Section 16 have been mined for clay 

and aggregates and most of the land is leased for

grazing livestock. 

The DOE’s National Renewable Energy Laboratory

operates the NWTC immediately northwest of Rocky

Flats. This facility is used for research on powergenerating wind turbines. 

Denver Water owns a large tract of land about 1 mile to

the southwest of Rocky Flats along the west side of

Highway 93 from Highway 72 south to Ralston

Reservoir. While portions of this land are used for

water collection and distribution facilities, most of it is

undeveloped. This property includes a potential

reservoir site in Leyden Gulch (Bassett 2002).

Two companies, TXI and LaFarge, operate gravel

mining and processing facilities on two separate but

contiguous sites in the northwest corner of Rocky

Flats site and on adjacent privately owned land. The

mining facilities consist of surface excavations,

material conveyors, rail lines and processing facilities

(DOE-NREL 2002).

Jefferson County Airport is located about 2 miles east of

Rocky Flats. Airport runways are aligned in a

northeast/southwest configuration. Aircraft takeoff and

landing patterns currently do not pass directly over the

Rocky Flats site (DOE-NREL 2002).

3.10. OPEN SPACE, RECREATION AND TRAILS

Rocky Flats is surrounded on three sides by designated

open space. While some of these open space parcels

restrict public use, others provide a network of

recreational trails that are connected to the surrounding

communities (Figures 22 and 23).

CITY OF BOULDER OPEN SPACE AND MOUNTAIN PARKS

The City of Boulder Open Space and Mountain Parks

(BOSMP) owns and manages several large open space

parcels near the northern and western edges of Rocky

Flats. BOSMP lands along the northern edge of Rocky

Flats extend from near the middle of Rocky Flats to the

west along the Boulder/Jefferson county line for over 4

miles to the top of Eldorado Mountain. These lands are

collectively referred to as South Boulder Open Space.

Within Jefferson County, BOSMP also owns the Jewell

Mountain and Van Fleet properties to the west of Rocky

Flats between Highway 93 and Coal Creek. 

BOSMP lands offer a network of soft-surface trails

available for hiking, mountain biking and equestrian

use. The Flatirons Vista and Greenbelt Plateau

trailheads are located about 1 mile from Rocky Flats to

the northwest near the Highway 93/128 intersection.
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 137

BOSMP is working with several other organizations to

protect and restore the Coal Creek riparian area that

runs through their properties near Rocky Flats.

Restoration activities include fencing to control

livestock, stream channel restoration, wetland

restoration and monitoring. Small mammal trapping

along Coal Creek has revealed several occurrences of

Preble’s meadow jumping mouse (BOSMP 2002).

BOULDER COUNTY OPEN SPACE

Boulder County owns several open space parcels on the

north side of Rocky Flats between the Town of

Superior to the east and BOSMP lands to the west.

These holdings include the Lindsay, Zacharias/Thomas

and Carlson/Lastoka properties. Recreational access to

Boulder County Open Space lands to the north and

northeast of Rocky Flats is from the Coalton Trail,

which begins on Highway 128 north of Rocky Flats.

The Coalton Trail provides recreational access (hiking,

biking and equestrian uses) to the County open space

lands northeast of Rocky Flats. The trail connects to

the Rock Creek Trail in the Town of Superior.

JEFFERSON COUNTY OPEN SPACE

Jefferson County owns and manages several parcels to

the west and southwest of Rocky Flats. The RansonEdwards property immediately west of Rocky Flats

extends from Coal Creek to the west. Coal Creek

Canyon Open Space is located along the south side of

Highway 72 about 2 miles west of Rocky Flats.

Jefferson County also owns several conservation

easements in this area. White Ranch Open Space is

located about 3 miles to the southwest of Rocky Flats. 

The 2,807-acre Coal Creek Canyon Park currently has

no developed trails or facilities. Due to uncertainty

surrounding the future management of surrounding

publicly owned properties, including Rocky Flats and

Denver Water properties, Coal Creek’s Management

Plan recommends postponing trail and facility

development for 5 to 7 years (JCOS 2001).

CITY OF ARVADA OPEN SPACE

The City of Arvada owns several open space parcels

about 2 miles south of Rocky Flats. These parcels are

around Arvada Reservoir, along Leyden Gulch, and in

the area between the two. A network of paved and

unpaved trails runs throughout the City of Arvada,

including the unpaved Leyden Gulch trail located about

1.5 miles south of Rocky Flats.

The City has identified additional trail corridors south

of the Rocky Flats site that would provide potential

linkages between Arvada and the Refuge (City of

Arvada 2001). Proposed trails include the following:

• Leyden Gulch Trail – This extension of an

existing trail will cross Highway 93,

providing access to Jefferson County open

space. It will be open to hiking, biking and

equestrian users.

• Big Dry Creek – The trail will follow the Big

Dry Creek from Standley Lake to Highway

93 and would border the Refuge’s southern

boundary. A proposed trailhead for the Big

Dry Creek trail will be 1

/8mile south of the

Refuge’s boundary. The hiking and biking

trail could also link the Refuge to the

proposed Vauxmont Park. 

• Barbara Gulch Trail – This trail will extend

from the Highway 72/93 intersection to the

City of Arvada. The trailhead at the

intersection would be an important hub in

an alternative transportation route (e.g.,

bike commuters) along Highway 93.

The white-tailed jack rabbit is found on the Refuge.

© USFWS
Chapter 3: Affected Environment

138 Rocky Flats National Wildlife Refuge 

• Jeffco Trail – The City’s master plan also

identifies a proposed Jeffco trail along

Church Ditch which runs north-south

between the Refuge and Standley Lake.

CITY OF WESTMINSTER OPEN SPACE

The City of Westminster has several open space

properties to the east and southeast of Rocky Flats.

These properties include the Colorado Hills Open

Space and Standley Lake Regional Park. Colorado

Hills includes a soft-surface trail between Mower

Reservoir and adjacent residential areas. Standley

Lake is a regional destination for boating,

swimming and picnicking. This park is also a focal

point for Arvada and Westminster’s paved

greenway trail systems. The city’s soft surface

Walnut Creek Trail terminates less than 2 miles

from Rocky Flats’ eastern boundary and is open to

hiking and biking. The trail could provide a

potential link between the Refuge, surrounding

communities and the Westminster trail system.

CITY AND COUNTY OF BROOMFIELD OPEN SPACE

Directly east of Rocky Flats, Broomfield owns the

Great Western Open Space lands surrounding its Great

Western Reservoir. This area consists mainly of former

grazed or cultivated fields. The City and County of

Broomfield considers Great Western Open Space to be

a highly suitable receiving site for prairie dog

relocation (City and County of Broomfield 2001). The

establishment of a large prairie dog town at Great

Western Reservoir Open Space would likely attract a

greater number of raptors and other predators to the

area and may encourage the expansion of prairie dogs

in the eastern portions of the Refuge.

TOWN OF SUPERIOR OPEN SPACE

Superior’s open space is located across Highway 128 at

the northeast corner of Rocky Flats, on the east side of

McCaslin Boulevard. A network of paved trails

throughout Superior’s residential neighborhoods

connects to the Rock Creek Trail, which continues to

the northeast into Broomfield (Superior 2001).

3.11. VISUAL RESOURCES

Visual resources at Rocky Flats can be placed

under three general categories: views of the Rocky

Flats area from surrounding communities, views

from Rocky Flats to surrounding landmarks, and

internal views. Disturbed areas at Rocky Flats are

also a component of its current visual character.

VIEWS FROM SURROUNDING AREAS

Situated on a high, sloping pediment, the Rocky Flats

site lies at the base of the Front Range of the Rocky

Mountains. This area is commonly referred to as the

Front Range mountain backdrop and consists of

various ridges and peaks including South Boulder

Peak, Eldorado Mountain, Crescent Peak and the

Ralston Buttes. Beyond the mountain backdrop are the

Indian Peaks, which are intermittently visible from

Rocky Flats and surrounding communities. 

The Rocky Flats area, including the Refuge and

surrounding open space lands, defines the

northwestern boundary of the Denver metropolitan

area, where urban and suburban development gives

way to open grasslands that slope up into the craggy

forests of the mountain backdrop. Views to Rocky Flats

capture a range of landscape types as the grasslands

give way to the ponderosa draped foothills and on to

the towering Rocky Mountains. This view can be

appreciated from many areas throughout the Denver

metropolitan region. 

VIEWS FROM ROCKY FLATS

Several notable views from the Refuge characterize the

site’s visual quality. These views, both internal and

distant, are enjoyed from some of the high points along

the pediment in the western and central portions of the

Refuge. The view of the Rock Creek drainage and

Lindsay Ranch from the east is one of the most

striking views from the Refuge. 

While Rock Creek offers topographical relief and

vegetative variety, the Lindsay Ranch structures reveal

Larkspur with a Rocky Mountain backdrop.

© Shapins Associates
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 139

the site’s history. Beyond these immediate features, the

high peaks along the Continental Divide are visible

through Eldorado Canyon. From the upper Walnut

Creek area looking east, the mixed grassland prairie

and riparian areas in the eastern portions of the

Refuge are backed by Great Western Reservoir and

the communities and open plains beyond. Several high

points in the southern portion of the Refuge provide

distant views to the southeast of Standley Lake and the

downtown Denver skyline. 

INTERNAL VIEWS

Internal views at Rocky Flats are generally

characterized by the open grassland landscape. While

the majority of the site is composed of large expanses

of uninterrupted grassland, distinct vegetation along

drainages (i.e., cottonwoods and upland shrubs) and

varied topography present additional visual resources.

Numerous drainages and gullies slope steeply to the

east where the flat pediment top gives way to more

rolling grasslands. This terrain provides numerous

opportunities for scenic overlooks with commanding

views as well as secluded pockets with intimate views of

the Refuge landscape.

DISTURBED AREAS

Visual resources at Rocky Flats are affected by

facilities associated with mining and former weapons

production on the site. Currently over 70 miles of

maintenance and access roads occur on the Rocky

Flats site (including Refuge land and area to be

retained by DOE). While these roads are generally not

visible from surrounding areas, they interrupt many of

the internal views at Rocky Flats.

The buildings and facilities within the Industrial Area

are visible throughout the site and are a visual

landmark from surrounding areas. Prior to the

establishment of the Refuge, these facilities will be

removed and much of the current Industrial Area will

consist of restored grasslands. While the industrial

nature of this area will change, it will continue to

compromise internal views and will be a visual

reminder of the former facilities for several years. Over

the long term, as grassland restoration begins to take

form, DOE envisions a visually “seamless” division

between the Refuge and the former industrial site that

will be retained by DOE. 

3.12. NOISE

Existing noise levels vary widely across the Refuge.

Noise levels on the north, west and east perimeter are

affected by traffic on the highways adjacent to these

locations. Because traffic volumes are higher on

Highway 93, noise levels are higher on the western

perimeter than at other locations. Noise levels are

lower on the southern perimeter because Highway 72

is farther from the site boundary. Wind generators at

the NWTC also generate noise. While the site is

undergoing cleanup and building demolition,

construction noise near the Industrial Area is

considerably louder than ambient conditions. Noise

levels vary with the type of cleanup activity. Rocky

Flats is typically a very windy location and wind noise

contributes to the overall ambient noise levels.

Noise levels decrease away from area highways, site

cleanup, and NWTC wind generators. After cleanup,

noise levels in the center of the Refuge will be very low

and the Refuge will provide opportunities for solitude.

3.13. AIR QUALITY

Rocky Flats is located within the boundary of the

Denver Metropolitan Area for air quality planning

purposes. For many years, the Denver metropolitan

area has experienced carbon monoxide, ozone, and

particulate matter air pollution as well as visibility

problems. These conditions have recently improved,

however, and the Denver area is now in attainment of

most of EPA’s health-based standards for air quality

with the exception of ozone (EPA 2002). Ozone levels in

the summer of 2003 violated standards (CDPHE 2003).

Regulatory requirements may control the timing of

certain natural resources management activities, such

as prescribed burning, which requires a permit from

the state.

Air quality is monitored at five air monitoring stations

operated by the CDPHE. Two of these stations are

located just off-site at the northeast and southeast site

boundary along Indiana Street, downwind of Rocky

Flats. All criteria air pollutants are below state

standards. It has not been determined whether the air

monitoring stations will be removed following cleanup

of the site.

3.14. SOCIOECONOMICS

POPULATION AND DEMOGRAPHICS

The population in Jefferson County grew from 438,430

in 1990 to 527,056 in 2000 (U.S. Census Bureau 2002),

an average annual increase of about 1.8%. Jefferson

County population is expected to increase about 0.75%

annually from 2000 to 2015, while the state population

is expected to increase by 1.7% annually (Colorado

Department of Local Affairs 2002). 
Chapter 3: Affected Environment

140 Rocky Flats National Wildlife Refuge 

Rocky Flats is located in Jefferson County’s North

Plains Community Planning Area, which also includes

portions of Westminster, Arvada, Golden and

unincorporated areas. Within this planning area, the

population grew from 8,453 in 1990 to 10,194 in 2000, an

average annual increase of about 2% (Jefferson County

2002). About 95% of the North Plains population

consider themselves to be white (compared to 83%

state wide), while about 5% consider themselves to be

Hispanic or Latino in origin (Jefferson County 2002).

EMPLOYMENT

The average unemployment rate for Jefferson

County in 2001 was 3%, while the state average was

3.72% (Colorado Department of Local Affairs 2002).

In 2000, the services sector employed 79,317

workers while the retail trade sector employed

62,838 and the government sector employed 51,762

(Colorado Department of Local Affairs 2002).

INCOME

In 2000, per capita personal income was $36,442, a

5.6% annual increase since 1990. Total personal

income in Jefferson County was $19.3 billion in

2000, up from about $9.4 billion in 1990, reflecting

an average annual growth rate of about 7.5%

(Bureau of Economic Analysis 2002). The largest

sources of work-related personal earnings by

industry were services (16.1%), government (8.3%),

and manufacturing (7.9%). Retail trade accounted

for about 3% of the total personal income in 2000.

Transfer payments, dividends, interest and rent

accounted for 22% of personal income in 2000

(Bureau of Economic Analysis 2002). 

3.15. REFERENCES

Advanced Sciences, Inc. 1991. Surface-Water

and Ground-Water Rights Study in the

Vicinity of the Rocky Flats Plan. Prepared

for EG&G Rocky Flats, Inc. Lakewood,

Colorado.

Bassett, Marie. 2002. Denver Water

Department. Personal Communication with

Bill Mangle, ERO Resources, September 4,

2002.

Brennan, Mark. 2003. Boulder County Parks

and Open Space Department. Personal

Communication with Ron Beane, ERO

Resources, April 16, 2003.

Bureau of Economic Analysis. 2002. Regional Accounts

Data: Local Area Personal Income.

http://www.bea.doc.gov/regional/reis/action.cfm

Church Ranch. 2004. Technical Revision to Rocky

Flats Pit, Permit number M-1987-113.

City and County of Broomfield. 2001. Final

Draft Policies for Prairie Dog Conservation

and Management.

City of Arvada. 2001. City of Arvada Parks,

Trails and Open Space Plan. Prepared by

EDAW.

City of Boulder Open Space and Mountain Parks

Department. 2002. Rocky Flats EIS

Scoping Response: Sharp-tailed Grouse

Reintroduction.

Clippinger, N.W. 1989. Habitat suitability index

models: black tailed prairie dog. Biological

Report 82 (10.156): 1-21. U.S. Fish and

Wildlife Research and Development.

Washington, D.C.

Colorado Department of Local Affairs. 2002.

Colorado Economic and Demographic

Information System.

http://www.dola.state.co.us/is/cedishom.htm

Colorado Department of Public Health and

Environment. 2003a. Contaminants Released

to Surface Water from Rocky Flats. Technical

Topic Papers: Rocky Flats Historical Public

Exposures Studies.

http://www.cdphe.state.co.us/rf/contamin.htm 

Colorado Department of Public Health and

Environment. 2003b. Colorado Air Quality

Control Commission: Report to the Public,

2002-2003.

Colorado Department of Transportation. 2001.

Colorado Department of Transportation

State Highway Access Category

Assignment Schedule.

Colorado Department of Transportation. 2003.

The Colorado Department of Transportation

Traffic Information Page.

http//www.dot.state.co.us/App_DTD_DataAc

cess/Traffic/.

Colorado Division of Minerals and Geology

(CDMG). 2004. Permit issuance, Rocky

Flats Pit, Permit number M-1987-113, with

rider. January 13, 2004.
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 141

Colorado Division of Wildlife. 1992. Plains

Sharp-tailed Grouse Recovery Plan.

Colorado Division of Wildlife. 2001. Colorado

Vertebrate Ranking System (COVERS)

Database.

ftp://www.NDIS.NREL.colostate.edu/. 

Colorado Division of Wildlife. 2003. Grassland

Species Conservation Plan. Colorado

Division of Wildlife.

Dames and Moore. 1991. Cultural Resources

Class III Survey of the Department of

Energy Rocky Flats Plant, Northern

Jefferson and Boulder Counties, Colorado.

Prepared for EG&G Rocky Flats. 

David Evans and Associates, Inc. 2003. Letter

Report: Rocky Flats National Wildlife

Refuge Comprehensive Conservation Plan –

Traffic Analysis. Prepared by Stacy Tschour,

P.E. August 19, 2003.

ESCO Associates, Inc. 1994. Report of Findings: Ute

Ladies’-Tresses and Colorado Butterfly Weed

Surveys. Rocky Flats Buffer Zone. Jefferson

County, Colorado.

ESCO Associates, Inc. 2002. Draft Report of

Findings: Five-year Study of the Ecology of

Bluestem-dominated Grasslands of the

Rocky Flats Area, 1996-2001. Jefferson and

Boulder Counties, Colorado. 

Essington, K.D., S.M. Kettler, S.E. Simonson,

C.A. Pague, J.S. Sanderson, P.M. Pineda and

A.R. Ellingson. 1996. Natural Heritage

Resources of the Rocky Flats

Environmental Technology Site and their

Conservation. Phase II: The Buffer Zone.

Colorado Natural Heritage Program, Fort

Collins, Colorado.

Gershman, M. 1992. Comment letter from Mark

Gershman, City of Boulder Open Space to

Clait Braun (CDOW) on the Draft Plains

Sharp-tailed Grouse Recovery Plan.

January 1992.

Howard, Tom. 2003. District Wildlife Manager,

Colorado Division of Wildlife. Personal

communication with Ron Beane, ERO

Resources Corporation, July 3, 2003.

Industrial Area Transition Task Force. 1998.

Environmental Conditions, Rocky Flats

Environmental Technology Site, Golden,

Colorado. Prepared by ERO Resources Corp.

Jefferson County Open Space. 2001. Executive

Summary: Coal Creek Canyon Park

Management Plan.

Jefferson County. 2002. The North Plains

Community Demographic Profile.

http://206.247.49.21/ext/dpt/public_works/pla

nning/demographics/community/northplains/north-plains.htm.

Kaiser-Hill Ecology Group. 2002. GIS data

showing the geographical extent of wildfires

between 1993 and 2002. "master fire

file.shp."

Kaiser-Hill, LLC. 1997. Metadata report

accompanying veg96b.shp GIS data showing

land cover data derived from 1995-1996 field

surveys.

Kaiser-Hill, LLC. 2000. 1999 Annual Wildlife

Survey for the Rocky Flats Environmental

Technology Site. Golden, CO.

Kaiser-Hill, LLC. 2001. 2000 Annual Wildlife

Survey for the Rocky Flats Environmental

Technology Site. Golden, CO.

Kaiser-Hill, LLC. 2002a. 2002 Annual Vegetation

Management Plan for the Rocky Flats

Environmental Technology Site. Golden,

CO.

Kaiser-Hill, LLC. 2002b. Site-Wide Water

Balance Model Report for the Rocky Flats

Environmental Technology Site.

Kaiser-Hill, LLC. 2002c. 2001 Annual Vegetation

Report for the Rocky Flats Environmental

Technology Site.

Kettler, S.M., S.E. Simonson, C.A. Pague, A. R.

Ellingson. 1994. Significant Natural

Heritage Resources of the Rocky Flats

Environmental Technology Site and Their

Conservation: Phase I: The Rock Creek

Drainage. Colorado Natural Heritage

Program, Fort Collins, Colorado.
Chapter 3: Affected Environment

142 Rocky Flats National Wildlife Refuge 

Kuford, C.C., 1958. Prairie dogs, Whitefaces and

Blue Grama. Wildlife Monograph 1-78.

Lane, Eric. State Weed Coordinator. Colorado

Department of Agriculture. Information

provided in comments to Draft CCP/EIS,

April 26, 2004.

Nelson, Jody. 2003. Senior Ecologist, Kaiser-Hill

Ecology Group. Rocky Flats Environmental

Technology Site. Personal communication

with Bill Mangle, ERO Resources. January

14, 2003.

Norman, Cathleen. 2003. History of the

Lindsay Ranch Property. 10/27/03.

Power, M.E., D. Tilman, J.A. Estes, B.A. Menge,

W.T. Bond, L.S. Mills, G. Daily, J.C. Castilla,

J. Lutchonco and R.T. Paine. 1996.

Challenges in the Quest for Keystone

Species. BioScience 46:609-620.

PTI Environmental Services. 1997. Ecological

Resource Management Plan for the Rocky

Flats Environmental Technology Site.

Prepared for Kaiser-Hill, LLC.

Rosenlund, Bruce. 2003. Draft paper on native fish

restoration. U.S Fish & Wildlife Service.

Schiesswohl, Steve. U.S. Department of Energy.

Personal communication with Bill Mangle, ERO

Resources, February 1, 2003.

Shroba, Ralph R. and P.E Carrara. 1996.

Surficial Geologic Map of the Rocky Flats

Environmental Technology Site and Vicinity,

Jefferson and Boulder Counties, Colorado.

U.S. Geological Survey. Map number OF-94-

162.

Smith, R.E. 1967. Natural History of the Prairie

Dog in Kansas. University of Kansas

Museum of Natural History Misc.

Publication no. 49.

Stone, Eric. Biologist. U.S Fish & Wildlife

Service. Personal communication with Bill

Mangle, ERO Resources. January 5, 2004.

Superior (Town of). 2001. Town of Superior

Parks, Open Space and Trails Plan.

U.S. Army Corps of Engineers. 1994. Rocky Flats

Plant Wetlands Mapping and Resource Study.

U.S. Census Bureau. 2002. American Factfinder

Census Data. http://factfinder.census.gov.

U.S. Department of Energy Rocky Flats

Environmental Technology Site and the U.S

Fish & Wildlife Service. 2001. Integrated

Natural Resources Management Plan,

Environmental Assessment and Finding of

No Significant Impacts for Rock Creek

Reserve, 2001-Closure. 

U.S. Department of Energy – National Renewable

Energy Laboratory. 2002. Final Site-Wide

Environmental Assessment of National Renewable

Energy Laboratory’s National Wind Technology

Center.

U.S. Department of Energy. 1999. Vegetation

Management Environmental Assessment. Rocky

Flats Field Office.

U.S. Department of Energy. 1997. Rocky Flats

Cumulative Impacts Document. Rocky Flats Field

Office, Rocky Flats Environmental Technology

Site. Golden, Colorado.

U.S. Environmental Protection Agency. 2002.

Region 8 – Air Program.

www.epa.gov/region8/air/. September 6, 2002. 

U.S. Fish & Wildlife Service. 2002. Candidate

Conservation Program.

http://endangered.fws.gov/candidates/index.html

U.S. Fish & Wildlife Service. 2003. Endangered

and Threatened Wildlife and Plants;

Designation of Critical Habitat for the

Preble’s Meadow Jumping Mouse (Zapus

hudsonius preblei); Federal Register, 68:

37276-37332, June 23.

U.S. Fish and Wildlife Service. 2004a.

Endangered and Threatened Wildlife and

Plants; 90-day Finding for a Petition to

Delist the Preble’s Meadow Jumping Mouse

in Colorado and Wyoming and Initiation of a

5-year Review; Federal Register, 69: 16944-

16946, March 31.

U.S. Fish and Wildlife Service. 2004b.

Endangered and Threatened Wildlife and

Plants; Finding for the Resubmitted

Petition to List the Black-Tailed Prairie Dog

as Threatened; Federal Register, 69: 51217-

51226.
Chapter 3: Affected Environment

Final Comprehensive Conservation Plan & EIS 143

Wedermyer, Michael. 2003. District Wildlife

Manager, Colorado Division of Wildlife.

Personal communication with Ron Beane,

ERO Resources Corporation, July 1, 2003.

Whicker, A. D. and J. K. Detling. 1988.

Ecological Consequences of Prairie Dog

Disturbances. BioScience, 38:778- 785.

Witmer, G.W., K.C. VerCauteren, K.M. Manci,

D.M. Dees. 2002. Urban-suburban prairie

dog management opportunities and

challenges. Proceedings of 19th Vertebrate

Pest Conference. 19:439-444.

chapter 4

ENVIRONMENTAL CONSEQUENCES

Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 147

4.1. INTRODUCTION

This chapter provides an analysis of the potential

effects on environmental resources associated with the

implementation of each of the four management

alternatives for the Refuge. Potential impacts were

identified for each alternative based on a review of

relevant scientific literature, previously prepared

environmental documents for Rocky Flats, and the

best professional judgment of Service staff and other

resource specialists.

This chapter is organized by resource, and provides an

analytical comparison of the alternatives. Many of the

potential management actions and resource impacts

are similar between the alternatives, but the

discussion differentiates impacts where applicable.

Resource impacts are discussed according to the

management goals and the appropriate types of actions

or activities associated with those goals. For example,

the discussion of impacts to vegetation associated with

Goal 1 – Wildlife and Habitat Management includes the

potential effects associated with Preble’s Habitat

Management, Xeric Tallgrass Management, Mixed

Grassland Prairie Management, and other

management actions. Not all goals, objectives, and

accompanying management actions are applicable to

each resource; therefore, only those that are relevant

for a particular resource are described.

Discussions are organized consistent with the goals,

objectives, and strategies described in Chapter 2.

General topic areas include:

• Wildlife and Habitat Management (Goal 1)

• Public Use, Education, and Interpretation

(Goal 2)

• Refuge Operations, Safety, and

Partnerships (Goals 3 to 6)

A summary of the impacts discussed is provided at

the end of Chapter 4 in Table 21 - Summary of

Environmental Consequences.

The Refuge Act (Appendix A) directs the Service to

consider “the characteristics and configuration of any

perimeter fencing that may be appropriate or

compatible for cleanup and closure purposes, refuge

purposes, or other purposes.” Fencing options and

their impacts are discussed in Section 4.15 - Fencing

Considerations. An assessment of the potential

effects that nearby transportation improvements could

have on Refuge resources, as well as recommendations

to mitigate those effects, is found in Section 4.16 -

Possible Transportation Improvements Near the

Refuge. An assessment of how the proposed

alternatives conform with the Refuge goals is included

in Section 4.17 - Adherence to Planning Goals.

METHODS

Effects are evaluated at several levels, including

whether the effects are adverse or beneficial, and

whether the effects are direct, indirect, or cumulative

with other independent actions. The duration of effects

also is used in the evaluation of environmental

consequences.

Direct effects are those where the impact on the

resource is immediate and is a direct result of a

specific action or activity. Examples of a direct

effect include the effect of trail construction on

vegetation along the trail or the effect of hunting

on wildlife.

Indirect, or secondary, effects are those that are

induced by implementation actions, but occur later in

time or farther removed from the place of action

through a series of interconnected effects. Examples

of indirect effects include the downstream water

quality effects from an upstream surface disturbance,

Chapter 4. Environmental Consequences

The potential effects of management activities on

wildlife and habitat are analyzed for each alternative.

© Mauro
Chapter 4: Environmental Consequences

148 Rocky Flats National Wildlife Refuge 

or the impact that recreational use along a trail may

have on nearby plant communities (through the

periodic introduction of noxious weeds).

A cumulative effect is defined as “the impact on the

environment which results from the incremental impact

of the action when added to other past, present, and

reasonably foreseeable future actions regardless of

what agency (federal or non-federal) or person

undertakes such other actions” (40 CFR 1508.7).

Reasonably foreseeable future actions independent of

the CCP for the Refuge are described in Section 2.9.

Impacts are often described in terms of their context,

intensity, and duration. Table 20 - Impact Threshold

Definitions, at the end of the chapter, defines the

intensity levels (negligible, minor, moderate, and major)

for each resource. The duration of effects are described

as either short term or long term. Short-term effects

would persist for a period of 3 to 5 years, and would

consist primarily of temporary disturbance due to

habitat restoration or facility construction and

subsequent revegetation efforts. Long-term effects

would last more than 5 years after project initiation,

and may outlast the 15-year life of the CCP. Many longterm effects consist of long-term benefits to wildlife

habitat resulting from habitat management actions.

4.2. GEOLOGY AND SOILS

Previous studies and available information on

geologic and soil resources at Rocky Flats were used

to identify potential effects from alternative actions.

Potential effects were qualitatively and quantitatively

evaluated based on the types and amount of landdisturbing activities for each alternative. Impacts to

geologic resources are not discussed because none of

the alternatives would affect geologic features or

resources. Actions of concern for soils include those

likely to generate erosion and reduce soil

productivity or actions that promote soil stability and

reduce soil loss.

WILDLIFE AND HABITAT MANAGEMENT ACTIONS

Xeric Tallgrass Management

Alternatives A, B, and C would include prescribed

fire as a management tool for maintaining native

prairie habitat and controlling weeds. In addition,

Biological controls would be used as a weed

management tool in all alternatives.

© Mauro

Grazing and prescribed fire would be used in

Alternatives A, B, and C to restore and maintain

xeric tallgrass grasslands.

© USFWS
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 149

Alternative B would allow livestock grazing. When

used as habitat restoration tools, both prescribed

fire and grazing would temporarily reduce

vegetation cover in a treatment area. These

restoration tools usually stimulate new plant growth

and increase the vigor of existing plant communities.

However, the use of these restoration tools has the

potential to result in localized, short-term erosion,

soil loss, and the release of soil particles (dust) into

the air. A potential minor effect on soil erosion from

prescribed fire in Alternative A would be limited to

the Rock Creek Reserve. Alternative D would not

include the use of burning or grazing and would not

have the potential soils impacts resulting from use of

these tools.

Concentrations of all soil contaminants are low

throughout the Refuge, and prescribed fire could be

used safely anywhere on the Refuge (Appendix D).

Although contaminant concentrations are low

throughout the Refuge, they are slightly higher south

of the east entrance road (Figure 4). Prescribed fire

would not be used in this area (Figure 10).

Mixed Prairie Grasslands Management

Restoration of 300 acres of non-native grassland in

Alternatives B and C may result in a short-term

minor disturbance of soil resources during site

preparation and planting. Following establishment

of native grasses, soil protection and productivity

would be maintained long term. There would be

no effect to soil resources if non-native vegetation

is not restored under Alternatives A and D.

Concentrations of all soil contaminants are low

throughout the Refuge, and safety precautions

during habitat restoration activities probably

would not be needed (Appendix D). Final safety

requirements to address any remaining soil

contamination for any surface or subsurface

disturbance on Refuge lands will be identified in

the Corrective Action Decision/Record of Decision

discussed in Chapter 1. It is anticipated that DOE

will retain any lands that have institutional controls

on agricultural practices such as tilling.

Road Restoration and Revegetation

Excluding the area retained by DOE, the Refuge

currently has 56.5 miles of paved, graded, or two-track

roads and numerous road stream crossings. The length

of roads and number of stream crossings that would be

removed and revegetated in each alternative are:

• Alternative A – 11.9 miles; 7 stream crossings

• Alternative B – 26.3 miles; 13 stream crossings

• Alternative C – 25.7 miles; 13 stream crossings

• Alternative D – 24.3 miles; 6 stream crossings

(While Alternative C would have fewer roads and trails

overall, the length of road to be revegetated in

Alternative B is greater than Alternative C because in

Alternative B, a new trail segment would replace the

existing road in the Woman Creek drainage. See

Figures 25 and 26.) 

Road restoration efforts would include ripping,

grading, or other methods to remove the existing

roadbed and prepare the area for planting. Although

restoration would be confined primarily to the

existing disturbed road prism, soils adjacent to the

road may be disturbed resulting in minor, short-term

soil disturbance and erosion. However, successful

revegetation and planned use of erosion control

measures, such as mulching and water bars to control

water flows, would minimize impacts. The greatest

potential for soil erosion from roads would occur in

Alternative A, which limits road restoration to the

Rock Creek portion of the Refuge. Thus, a number

of the existing roads would remain in place but would

not be maintained, resulting in moderate long-term

soil erosion. A long-term moderate benefit to soil

resources would occur for Alternative A in the Rock

Creek Reserve and Alternatives B, C and D Refugewide by stabilizing and revegetating roads that would

no longer be needed.

Prairie Dog Management

Prairie dog communities are dynamic and vegetation

and surface conditions often vary from year to year.

Wildflowers such as blue flax are found in Refuge grasslands.

© RFETS
Chapter 4: Environmental Consequences

150 Rocky Flats National Wildlife Refuge 

Additionally, the enhanced nutrient cycling from prairie

dog activities can stimulate plant growth and can

contribute to soil stability. However, limited soil

surface erosion may occur in each of the alternatives

from the potential expansion of prairie dog

populations. Through grazing, prairie dogs often clip

vegetation to allow better visibility of their

surroundings; therefore, the amount of bare soil is

typically greater than surrounding lands. Exposed

soils are more prone to wind and water erosion. 

Alternative A would have the greatest potential for

direct soil impacts with unlimited expansion of prairie

dog populations, followed by Alternative D with 1,000

acres, Alternative B with 750 acres, and Alternative

C with 500 acres. The loss of soil resources for

Alternatives B, C, and D would be minor and would

not adversely affect soil productivity. Soil loss from

unlimited expansion of prairie dog populations in

Alternative A would range from minor to moderate,

depending on the size and distribution of the colonies. 

Concentrations of all soil contaminants are low

throughout the Refuge (Figure 4), and are not present

in subsurface soils in the areas that will become the

Refuge. Burrowing by prairie dogs on Refuge lands is

not expected to expose contaminated soils.

DOE will be responsible for management of the DOE

retained area, and such management is not discussed

in this CCP. Any requirements to limit burrowing

animals in the DOE retained area will be identified in

the Corrective Action Decision/Record of Decision.

If burrowing animals are required to be prohibited in

the DOE retained area, the Service will cooperate

with DOE to minimize potential for burrowing

animals to invade DOE the retained lands from

adjoining refuge lands.

PUBLIC USE, EDUCATION, AND INTERPRETATION ACTIONS

Public Use Facilities

New Trails. For Alternatives B and D, the

construction of new trails would result in localized

soil disturbance, including erosion and reduced soil

productivity. Alternative B has 4.6 miles of new trail,

while Alternative D has 6.4 miles of new trail.

Reduced soil productivity would be a long-term

minor effect, but erosion would be minimized by

revegetation efforts and the use of appropriate

erosion and drainage control measures. Alternatives

A and C do not include new trails and would have no

effect on soil resources.

Trails Converted from Existing Roads. In

Alternatives B, C, and D, the conversion of existing

roads to trails (11.9 miles in B, 0.6 mile in C, and 14.9

miles in D) would result in minor localized soil

disturbance and erosion during construction.

However, these trails would be constructed within the

existing disturbed roadway and the total amount of

exposed soil would be less than current conditions

following conversion from a roadway to a trail and

revegetation bordering the trail. The short-term

construction-related impacts to soils would be

reduced by implementing trail design features such

as water bars and tread resurfacing, resulting in

negligible long-term effects.

The multi-use switchback trail proposed for the upper

Woman Creek drainage in Alternatives B and D would

replace the existing steep road grade. Construction of

this trail and planned restoration of the existing road

would have a long-term beneficial effect to soil

resources by reducing erosion.

Trail Use. Alternatives B and D would allow hiking, as

well as bicycle and limited equestrian use along multiuse trails. Trail use by hikers, bikers and equestrians

typically have the potential to cause soil compaction

and erosion (Seney 1991; Dehring 1998). Several

studies indicate that while all trail users cause soil

impacts, they can be more pronounced by equestrian

use (Dehring 1998; DeLuca et al. 1998; Cole and

Spildie 1998). Some studies indicate that the erosional

impacts of bicycles can be less than either equestrians

or hikers (Weir 2000; Seney 1991).

Most of the multi-use trails in Alternatives B and D

would be located on flat, dry areas that are less

susceptible to the erosional impacts of public use. In

addition, most of the trails would be located along

existing stabilized roadways. Activities such as trail

use have the potential to release dust into the air.

Concentrations of all soil contaminants in the areas

planned for trail use are low and trail use on Refuge

lands would be safe for all Refuge visitors, regardless

of user type. Informational signs would convey the

history of the site. Final safety requirements to

address any remaining soil contamination for any

visitor use on Refuge lands will be identified in the

Corrective Action Decision/Record of Decision

discussed in Chapter 1. Any safety requirements for

visitor use on Refuge lands required in the Corrective

Action Decision/Record of Decision will be discussed in

the step-down Visitor Use Plan. The Service would not

require visitors to sign an informed consent statement. 
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 151

The DOE does not anticipate transferring any lands

to the Service that would require additional safety

requirements for either the Refuge worker or the

visitor. The risk assessment efforts that resulted in

the cleanup action level were inclusive of Refuge

management activities such as trail and fence

construction and maintenance, visitor use, and

prescribed fire and were designed to be safe for the

Refuge worker, Refuge visitor, and the 

greater community. 

Impacts to soil resources would be negligible to

minor over the long term with planned trail design,

erosion control measures and revegetation of areas

adjacent to trails. Off-trail pedestrian use would be

limited to select locations; the development of social

trails would be managed through signage, fencing

and other visitor management techniques.

No formal trails would be developed in Alternative A

and the impacts to soils from occasional guided tours

would be negligible. Alternative C would likewise

have negligible impacts to soils from a single short

trail along an existing road.

Visitor Use Facilities. In Alternatives B and D, the

construction of a visitor contact station, parking

facilities, and overlooks would require soil excavation,

grading, and other surface disturbances. Temporary

increases in soil erosion would occur in these areas,

resulting in direct, short-term impacts to soils. The

anticipated extent of soil disturbance due to facility

development in Alternatives B and D is:

• Alternative B – 1.1 acres

• Alternative D – 1.4 acres

A long-term loss in soil productivity may occur from

construction of visitor-related structures. The impacts

of these activities on soils for all alternatives would be

negligible considering the small area of the Refuge that

would be affected. Soil disturbance in Alternatives A

and C would be minimal because the only facility would

be a portable restroom.

REFUGE OPERATIONS

Each alternative would include the construction of

maintenance facilities to support Refuge operations.

There would be a long-term negligible loss in soil

productivity for construction of these facilities and

possible short-term erosion during construction. New

surface disturbances would be minimized by locating

these facilities in areas of existing disturbance.

Estimated areas potentially affected by facility

construction for each alternative are:

• Alternative A – 0.13 acre

• Alternative B – 0.24 acre

• Alternative C – 0.17 acre

• Alternative D – 0.25 acre

Fence Construction

Permanent or temporary fencing may be used

throughout the Refuge. Concentrations of all soil

contaminants are low throughout the Refuge, and

safety precautions during fence construction on

Refuge lands probably would not be needed. Final

Before and after photos of road restoration initiated by

DOE in 1999.

© Nelson, RFETS © Nelson, RFETS
Chapter 4: Environmental Consequences

152 Rocky Flats National Wildlife Refuge 

safety requirements to address any remaining soil

contamination for surface or subsurface disturbance

on Refuge lands will be identified in the Corrective

Action Decision/Record of Decision discussed in

Chapter 1. Safety requirements for surface or

subsurface disturbance on Refuge lands required in

the Corrective Action Decision/Record of Decision

will be discussed in the step-down Vegetation and

Wildlife Management Plan.

CUMULATIVE IMPACTS

Mining

Potential future gravel mining along the western edge

of the Refuge may lead to erosion and windblown soil

deposition from the construction and operation of

surface mines and access roads. Impacts to soils

resulting from any of the Refuge management

alternatives would not contribute substantially to the

impacts from mining.

The Service would work with the mining operators

and the appropriate regulatory agencies to minimize

and mitigate the effects of windblown soil deposition

on the Refuge.

4.3. WATER RESOURCES

Effects to water resources were evaluated based on

existing information on the distribution and quality of

water at the Refuge and the potential for Refuge

activities to impact water resources. Water resource

impacts from Refuge activities would be related

primarily to potential impacts to water quality rather

than changes in surface or ground water flow, which are

expected to be minor. As described in the Future

Hydrological Conditions section of Chapter 3, the

cleanup of Rocky Flats by DOE will result in several

changes to existing water resources including the

removal of discharge ponds, subsurface drains, and

eliminating the import of water. Because these changes

would occur prior to Refuge establishment, the analysis

of impact to water resources for each of the alternatives

is based on post-cleanup hydrologic conditions.

WILDLIFE AND HABITAT MANAGEMENT ACTIONS

Preble’s Habitat Management

Planned protection and maintenance of riparian habitat

along Rock Creek, Walnut Creek, Woman Creek, and

the Smart Ditch in all alternatives would provide a

long-term benefit to water resources by keeping intact

the vegetation buffer surrounding principal drainages

on the Refuge.

Road Restoration and Revegetation

Road Removal. In all alternatives, the Service would

remove and revegetate many of the existing roads

and road crossings of streams. The extent and

location of this restoration would be greatest for

Alternatives B, C, and D and would be least for

Alternative A, which limits restoration to the Rock

Creek Reserve. Alternative A would restore seven

stream crossings, Alternative D would restore six

stream crossings, and Alternatives B and C would

restore 13 stream crossings.

Most streams at the Refuge are ephemeral or

intermittent and restoration activities would be

conducted when the streams are dry to minimize the

direct introduction of sediment. Planned revegetation

and stabilization of the stream channels would reduce

the potential for stream sedimentation during

precipitation events. Removal of road stream crossings

would have a long-term beneficial impact on water

quality by removing a source of erosion and sediment

delivery. Benefits would include improved natural

stream flows, restored channel morphology, and

improved continuity of streamside wetland and riparian

habitats that benefit riparian and Preble’s habitat

management goals. Additional benefits from improved

streamside habitat conditions would include bank

stabilization and the retention and removal of

sediments and pollutants from the water. Alternatives

B and C would provide the most benefit because a

greater number of stream crossings would be restored

than in Alternatives A and D.

Road removal and revegetation at locations outside of

the stream corridor may result in minor, short-term

impacts to water resources due to erosion and

sedimentation during and immediately following

restoration. However, these restoration activities

would result in long-term benefits to water resources.

Indirect benefits from road restoration include an

overall improvement in downstream water quality.

In Alternative A, many of the existing roads outside

of the Rock Creek Reserve would not be revegetated

or maintained. Erosion of these roads over time may

contribute sediment to streams at Rocky Flats,

resulting in minor to moderate adverse effects to

water quality.

Lindsay Ponds. In Alternative C, the Lindsay Ponds

would be removed and the stream channel restored to
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 153

pre-settlement conditions. Removal of the Lindsay

Ponds would result in the long-term loss of aquatic

habitat, water storage, and sediment removal

functions currently provided by the ponds. However,

restoration of the native stream conditions would

return the site back to its original condition. The

Lindsay Ponds would continue to function as they

currently do under Alternatives A, B, and D with no

effect on water resources.

PUBLIC USE, EDUCATION AND INTERPRETATION ACTIONS

Public Use Facilities

Trail Use. In all alternatives, most of the trails

would be located away from drainages and water

features and only negligible effects to water quality

are likely. Alternative D would include an east-west

multi-use trail along Walnut Creek. The close

proximity of this trail to the creek may lead to social

trails and localized erosion. Impacts to water

quality from trail use in Walnut Creek is expected to

be negligible.

Off-trail Use. Off-trail use would be permitted in the

southern portion of the Refuge in Alternatives B and

D. While concentrated off-trail use is not expected, the

potential for sedimentation of water bodies from offtrail use is negligible over the long term.

Visitor Use Facilities. Construction activities involved

in developing parking areas, overlooks, viewing blinds,

and other facilities may result in indirect, short-term

impacts to water resources due to erosion and

sedimentation. The extent of facility development and

corresponding impacts would vary among the

alternatives, with Alternative C having the least

potential for impact and Alternative D having the

greatest potential for impact. Considering the

relatively small amount of facility development and

distance from water features, the resulting impacts to

water resources at Refuge would be negligible.

CUMULATIVE IMPACTS

Mining

Future mining along the western edge of the Refuge

has the potential to alter surface and ground water

flows in the upper Rock Creek drainage. These

changes may adversely affect surface runoff in Rock

Creek and ground water discharge along the pediment

slopes, which in turn may affect riparian and Preble’s

habitat, establishment of a native fishery, and the type

and quality of vegetation communities. Proposed

management actions associated with implementation of

the CCP at the Refuge would not contribute

measurably to the cumulative effects on water

resources from mining. 

The permit for the Church Ranch Rocky Flats Pit

includes stipulations that mining will stay a minimum

of 2 feet above groundwater (CDMG 2004; Church

Ranch 2004). However, the permits for the Bluestone

Pit and the Lakewood Brick and Tile operation do not

have stipulations about groundwater. Therefore,

these operations may potentially impact base flows in

the Rock Creek and Walnut Creek drainages, which

are downgradient of these operations. 

DOE Monitoring and Maintenance

As described in Section 1.8, the DOE retained area

would include areas in the eastern portions of Rocky

Flats where residual contamination levels are low

enough to be safe, but still warrant protection of water

quality in Walnut Creek and Woman Creek. These

protection measures would ensure that long-term

monitoring and maintenance activities within the DOE

Overbrowsing by deer or elk may impact riparian and

shrubland vegetation in Alternative A.

© Mauro
Chapter 4: Environmental Consequences

154 Rocky Flats National Wildlife Refuge 

retained area will not adversely affect water quality on

the Refuge.

4.4. VEGETATION COMMUNITIES

Vegetation management would be a key component to

managing wildlife at the Refuge. Wildlife and

vegetation communities are interrelated; the quality of

wildlife habitat is affected by vegetation management,

and the quality of vegetation is affected by wildlife

management. Potential impacts to vegetation were

evaluated based on the management goals for each

alternative and the potential to disturb vegetation,

change species composition, or change the quality of

the vegetation community. For some actions, such as

road restoration, effects to vegetation are quantified

based on the number of acres restored. For other

actions, a qualitative assessment of effects to

vegetation was made.

WILDLIFE AND HABITAT MANAGEMENT ACTIONS

Preble’s Habitat Management

Habitat Protection. Alternative A would protect and

maintain Preble’s habitat throughout the Refuge, while

Alternatives B, C, and D would also seek to improve

Preble’s habitat, by focusing on the preservation of

woody riparian vegetation. These actions would result

in long-term benefits to the composition and integrity of

riparian and wetland habitats on the Refuge and

continued protection of suitable Preble’s habitat. For all

alternatives, the maintenance and protection of Preble’s

mouse habitat would have a beneficial effect on riparian,

wetland, and shrubland vegetation communities. 

Ungulate Exclusion. Riparian and wetland habitat

management in Alternatives B, C, and D would include

the option to use fencing to selectively exclude grazing

and browsing animals from sensitive riparian areas.

Limiting grazing and browsing would be a long-term

benefit to the structure and integrity of the riparian

communities at the Refuge, but would only be

implemented if monitoring indicates resource damage.

In Alternative A, the Service would not implement

these measures, and use by ungulate and other grazing

animals may result in moderate, long-term adverse

impacts to riparian and shrubland vegetation in some

locations.

Monitoring. Vegetation surveys conducted in

Alternative C would provide long-term benefits to

riparian communities through periodic assessments of

riparian habitat condition. Alternatives A, B, and D

only include species composition data with Preble’s

monitoring, which have negligible value in managing

riparian habitat.

Xeric Tallgrass Management

In all alternatives, the Service would complete a

vegetation management plan and participate in

Goldfinch on a chokecherry branch.

© Mauro

Blanket flower.

© Mauro
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 155

regional efforts to implement tallgrass prairie

conservation measures. These actions would provide

indirect, long-term benefits to the xeric tallgrass

community by improving the Service’s understanding

of the community’s species composition, allowing

implementation of successful restoration techniques,

and appropriate responses to management concerns.

Other components of xeric tallgrass management

would focus on weed management and road

revegetation (discussed below under Road Restoration

and Revegetation). Managing weeds and revegetating

abandoned roads also would result in long-term

benefits to the xeric tallgrass community.

All alternatives would use mowing to help maintain

xeric tallgrass habitat, but only Alternatives A, B, and

C would use prescribed fire. The effects of grazing,

prescribed fire, and other restoration tools are

discussed in greater detail below under Weed

Management. Alternatives A and D would exclude

grazing as an ecological restoration tool. The absence

of grazing for Alternatives A and D and the absence of

prescribed fire for Alternative D would make it more

difficult to maintain the species composition and health

of tallgrass prairie and would have a minor to

moderate adverse effect on the xeric tallgrass

community, depending on the effectiveness of other

management tools.

In Alternative A, the Service would focus grassland

management efforts on about 1,000 acres of xeric

tallgrass habitat in the Rock Creek Reserve.

However, management of those portions of the xeric

tallgrass outside of the Rock Creek Reserve (about

950 acres) would be limited to weed containment,

which includes controlling the spread of existing

weeds rather than reducing overall infestations. This

reactive approach to grassland management may

have long-term, moderately adverse effects on the

xeric tallgrass communities outside of the Rock

Creek Reserve.

Mixed Grassland Prairie Management

Management of shortgrass and mixed grasslands

would include weed control efforts, restoration of nonnative hay meadows (Alternatives B and C), prairie

dog management, and species reintroductions. While

other management measures specific to mixed

grassland prairie communities are not anticipated, the

application of these measures would provide for longterm beneficial protection and maintenance of these

native grasslands.

Management actions for weed control and habitat

restoration outside of the Rock Creek Reserve

would be limited in Alternative A, which may result

in minor to moderate adverse impacts to mixed

grassland prairie. This approach may result in longterm habitat degradation to the mixed grassland

prairie communities outside of the Rock Creek

Reserve because of a reduced capacity to manage

these areas and respond to management issues.

All alternatives would use mowing to help maintain

mixed grassland prairie habitat, but only Alternatives

A, B, and C would use prescribed fire. In Alternative

A, prescribed fire would be limited to the Rock Creek

Reserve. Alternatives A and D would exclude grazing

as an ecological restoration tool. The absence of

grazing for Alternatives A and D and the absence of

prescribed fire for Alternative D would make it more

difficult to maintain the species composition and health

of mixed grassland communities and would have a

minor to moderate adverse effect, depending on the

effectiveness of other management tools.

In Alternatives B and C, the Service would restore

the 300-acre hay meadow and other non-native

grasslands to native mixed grass prairie. This would

have a long-term, beneficial effect to the

environmental integrity of the Refuge by restoring a

native grass ecosystem. A short-term increase in

erosion and weed infestation is possible, but

appropriate management actions would be used to

reduce these impacts. The hay meadow would

remain in Alternative A and D and non-native

grasses may expand their distribution and degrade

adjacent native grasslands.

Road Restoration and Revegetation

In all alternatives, road and stream crossing removal

and revegetation would result in long-term benefits

to vegetation communities on the Refuge by restoring

native plant communities, reducing erosion, and

reducing habitat fragmentation (Table 11). The

removal and revegetation of roads and stream

crossings would include diligent weed control and

erosion control measures to restore large, contiguous

patches of grassland habitat and uninterrupted

corridors of riparian and wetland habitat. Large

patch sizes of undisturbed vegetation reduce the

potential for weed introduction and the spread and

propagation of non-native plant communities in

addition to the benefits of wildlife movement and

distribution as described below in Section 4.5 Wildlife

Resources. Alternative C would provide the greatest
Chapter 4: Environmental Consequences

156 Rocky Flats National Wildlife Refuge 

benefit because of the amount of road restoration,

followed by Alternatives B and C. Alternative A

would provide the least benefit.

The removal of roads and stream crossings for all

alternatives would result in a minor, short-term

impacts to vegetation during excavation, grading,

construction, and revegetation activities. In addition,

road restoration may result in minor impacts to

wetlands where road crossings are removed and the

stream channel restored. The result of these actions

are expected to have a long-term beneficial effect on

wetlands by restoring the natural stream channel and

establishing wetlands where hydrologic conditions

are suitable. 

The Service will comply with Section 404 of the Clean

Water Act should impacts to wetlands require

permitting. Wetland impacts would be mitigated as

required by the U.S. Army Corps of Engineers. In

Alternative A, seven road and stream crossings

would be removed in the Rock Creek Reserve.

Alternative D would have the least beneficial effect to

riparian and wetland vegetation by removal of six

road stream crossings.

Weed Management

The Service would prepare an Integrated Pest

Management (IPM) plan in Alternatives B, C, and D.

IPM planning would enable the Service to develop a

targeted weed management strategy that would result

in long-term benefits to vegetation communities by

controlling or reducing weed infestations on the

Refuge. While the Service would implement IPM

techniques in Alternative A, an IPM plan would not be

completed and a moderate long-term adverse effect to

vegetation communities outside of the Rock Creek

Reserve may occur in the absence of a detailed plan. 

The intensity of weed management efforts and the

different tools including chemical control, prescribed

fire, biological control, and mechanical control would

vary between the alternatives. In general, successful

weed management efforts would benefit vegetation and

wildlife habitat at Rocky Flats by increasing the

diversity and vigor of native plant species. The

magnitude of the impacts and benefits of the following

weed management tools would correspond with the

intensity of the efforts. In Alternative A, weed

reduction targets would apply only to the Rock Creek

Reserve, although weed control outside of the Rock

Creek Reserve would occur. The use of weed control

only outside of the Rock Creek Reserve for Alternative

A would likely increase weed density in currently

affected areas and may make it difficult to implement

weed containment actions.

Chemical Control. Using herbicides to control weeds

would provide a long-term benefit to native vegetation

communities by reducing weed competition,

maintaining desired species composition, and

Table 11. Road Restoration and Average Vegetation Patch Size Following Revegetation 

Xeric Tallgrass Grassland

Riparian and Wetland Areas

Other Grasslands

TOTAL

2.5

74

Roads Removed (miles)

Average Patch Size (acres)

Vegetation Type/Action

0.7

7

53

Roads Removed (miles)

Stream Crossings Removed

Average Patch Size (acres)

4.3

73

Roads Removed (miles)

Average Patch Size (acres)

7.5

18.2

58

8.6

114

5.7

13

71

12

127

26.3

47.8

93

9.2

148

5.8

13

63

10.7

111

25.7

46.2

103

8.5

105

4.6

6

77

11.2

104

24.3

44.2

88

Roads Removed (miles)

Area of road restored (acres)

Average Vegetation Patch Size

Refuge-wide (acres)

Alternative

AB CD
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 157

improving production of grasses and sedges for all

alternatives. Herbicide application may result in shortterm, minor impacts on native grasses and sedges from

physiological damage and reduced growth for the first

growing season after application. However, native

vegetation in application areas would be expected to

recover from the effects of herbicides and increase

production of grasses and sedges in subsequent

growing seasons (DOE 1999).

Prescribed Fire. The grassland communities at Rocky

Flats have evolved with fire over millennia. Natural

grassland fires rejuvenate grassland by controlling

exotic weed species, removing plant litter, and

stimulating new plant growth. While fire has generally

been limited from the site over the last 50 to 75 years,

periodic wildfires due to lightning strikes or humancaused ignition have occurred at Rocky Flats. Periodic

wildfires would continue to occur at Rocky Flats over

the long term. In the event of unplanned fires, the

Service will work with local agencies (through mutual

aid agreements) to aggressively suppress the

unplanned fires.

Prescribed fire is a restoration tool that would simulate

the ecological benefits of natural fires and reduce the

magnitude and severity of periodic wildfires.

Prescribed fires would be conducted in accordance

with approved vegetation management and fire

management plans, Service policy, and state air

quality regulations. In Alternatives A, B, and C, the

use of prescribed fire would have a short-term,

beneficial effect on vegetation communities by

improving plant vigor, controlling weeds, and

maintaining desired species composition. The timing of

prescribed fire is critical to promoting desirable plant

species and controlling weed species.

The indirect, long-term benefits of prescribed fire

include the reduction of hazardous fuel loads that can

contribute to uncontrolled wildfires. Prescribed fire

would not be used as a restoration tool in Alternative D

or in Alternative A outside of the Rock Creek Reserve.

The lack of fire as a restoration tool would have a

moderate adverse effect on the ability to maintain

native plant communities, control weeds, and reduce

the potential for wildfires.

Biological Control. The introduction of a non-native

insect predator to control non-native weeds would

beneficially affect native plant communities by

controlling weed distribution for all alternatives. For

example, in all alternatives the Service would distribute

the field bindweed mite, a biological control agent, to

appropriate locations. However, biological control

methods have the potential to adversely affect native,

non-target plant species. The remote potential for

these adverse impacts is offset by the benefits of using

a weed management tool that is self-sustaining and

reduces the need for herbicide application. 

Mechanical Control. The use of mowing and other

Prescribed fire is a restoration tool that would be used in Alternatives A, B, and C to improve plant vigor, control weeds,

and maintain species composition.

© USFWS
Chapter 4: Environmental Consequences

158 Rocky Flats National Wildlife Refuge 

mechanical methods to control weeds as part of an

overall IPM strategy would provide an additional

weed management tool for all alternatives. Although

mechanical control would not introduce chemicals into

the environment, they may result in adverse impacts

to vegetation communities, such as the dispersal of

weed seeds, soil disturbance, and direct impacts to

native plants within treatment areas. However, the

potential adverse effects of mowing are generally

offset by their benefits.

Grazing. Alternatives B and C would include selective

grazing by cattle, goats or other livestock, which would

have a beneficial effect on vegetation communities by

reducing the number and density of weed species and

stimulating native plant growth. A secondary benefit of

selective grazing would be weed control. Grazing may

also result in short-term impacts to wildlife, particularly

elk, due to competition for limited forage. However, the

benefits of managed grazing, such as grassland

enhancement and weed control, are expected to have

long-term beneficial effects on grasslands. Alternatives

A and D would not include grazing and would not

realize the potential benefits of weed control.

Weed Mapping. All alternatives include annual

mapping of weed patches and treatment sites. This

management tool would provide long-term benefits to a

variety of vegetation communities on the Refuge by

allowing Refuge staff to respond to new infestations and

adapt weed control strategies based on past experience.

Interior Fencing. In Alternatives B and C, the Service

would construct interior fencing to control and collect

wind-dispersed tumbleweeds. While this may increase

weed establishment near the fence, it would result in

long-term overall benefits to a variety of vegetation

communities at Rocky Flats. No interior fencing would

be used for Alternatives A or D, and weed dispersal for

species such as diffuse knapweed may be greater.

Deer and Elk Management

In all alternatives, the Service and/or CDOW would

maintain deer and elk populations to meet target

population estimates for the Refuge. This is expected

to reduce the potential for overgrazing or overbrowsing

of vegetation, resulting in long-term benefits to

grassland and shrubland communities on the Refuge.

Alternative A does not specify a timeframe for meeting

target population goals. The potential for minor

adverse effects to vegetation from overgrazing would

be greatest for Alternative A followed by Alternative B

and then Alternatives C and D.

All alternatives call for monitoring of ungulateinduced degradation of vegetation, although the

frequency, methods, and detail of monitoring would

vary among the alternatives. Monitoring would

provide an indirect benefit to grassland and

shrubland communities by enabling the Service to

more readily respond to deer and/or elk overgrazing

or overbrowsing.

Prairie Dog Management

Management of prairie dog populations for

Alternatives B, C, and D would include confining

their range to short and mixed grasslands and nonnative grasslands. In Alternative A, prairie dog

populations would be allowed to expand subject to

natural habitat and predator controls. Under natural

conditions, xeric tallgrass habitat does not provide

suitable prairie dog habitat because of the tall height

of the grass and the stony soils. Riparian

communities are too moist and/or vegetation is too

The Service and CDOW would work together to manage

deer and elk populations.

© Mauro
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 159

tall to favor prairie dog establishment. However,

prairie dogs have been known to colonize these areas

when they have been degraded by drought, weeds, or

accumulated thatch, which can lead to additional

habitat degradation and further colonization

(Hygnstrom et al. 2002).

If necessary, to protect important vegetation

communities from the potential impacts of prairie dog

colonization, all alternatives would trap and relocate

prairie dogs from riparian areas. Prairie dog

exclusion from these habitats would benefit the longterm viability of riparian communities and still allow

development of sustainable prairie dog colonies. In

Alternative A, the capture and relocation of prairie

dogs from riparian areas would occur only in the Rock

Creek Reserve. Alternatives B, C, and D would also

relocate prairie dogs to protect xeric tallgrass habitat.

The expansion of prairie dog populations in Alternative

A may have minor to moderate adverse effects on

native plant communities, depending on the extent of

prairie dog dispersal. A shift in vegetation composition

for portions of the Refuge is possible. In Alternatives

B, C, and D, limits on prairie dog expansion are

expected to have a minor adverse effect on species

composition and distribution.

Species Reintroductions

The planned removal of the Lindsay Ponds in

Alternative C would affect about 1 acre of open water

and adjacent wetland habitat. Restoration of the native

stream channel is expected to replace some of the

affected wetlands, but no open water habitat would be

created. If the removal of the Lindsay Ponds requires

a 404 permit and wetlands are affected, the Service

would mitigate replacement wetlands in accordance

with Service policy and permitting requirements.

None of the other alternatives would affect wetlands or

open water at the Lindsay Ponds.

PUBLIC USE, EDUCATION AND INTERPRETATION ACTIONS

Public Use Facilities

New Trails. Implementation of Alternatives B and D

would result in the direct long-term loss of vegetation

from the construction of new trail segments within the

xeric tallgrass and mixed grassland prairie communities

(Figures 24 and 26). The area of disturbance from

constructing these trails is 3.7 acres for Alternative B

and 6.5 acres for Alternative D (Table 12). The loss of

vegetation for both of these alternatives would be minor

and would not adversely affect the overall quality and

characteristics of vegetation communities. No new

trails are planned for Alternatives A and C; hence,

there would be no disturbance to vegetation

communities (Figures 23 and 25).

In Alternatives B and D, several trails would cross

through riparian and wetland habitat areas sensitive to

disturbance. Alternative B would have 11 such

crossings, while Alternative D would have 18. All trail

crossings would use existing culverts, bridges, or lowflow crossings to minimize effects to vegetation. 

Alternative D includes a new, 0.2-mile hiking trail

connecting the Lindsay Ranch area and the Plum

Branch within the Rock Creek drainage. This short

trail would descend through mixed grassland prairie

along the pediment slopes adjacent to an area

dominated by shrublands including the rare tall upland

shrubland community. Only minor adverse effects to

these shrubland communities are expected with careful

trail design and placement. 

Trail Use. Public trail use on the Refuge in

Alternatives B and D would have the potential to

adversely impact surrounding vegetation

communities by:

• Development of social trails

• Localized trampling and erosion

• Soil compaction

• Introduction and dispersal of noxious weeds

and other introduced species

• Fragmentation of habitat

While there is disagreement in the scientific and

recreation communities about the specific effects of

various trail uses, the Service recognizes that, in

Trails would be designed to minimize impacts to wildlife.

© Mauro
Chapter 4: Environmental Consequences

164 Rocky Flats National Wildlife Refuge 

general, social trails and trampling are typically

associated with hiking and equestrian use, while weed

dispersal can be exacerbated along multi-use trails

where bicycling and equestrian use is permitted

(Weir 2000). Bicycles have the potential to carry and

disperse weed seeds on the bike itself, while horses

may introduce noxious weed seeds from off-site in

their manure, hooves, and coat (Weir 2000;

Benninger-Traux et al. 1992). Soil compaction

associated with public use of social trails, especially in

the case of equestrian use (Swinker et al. 2000), can

hinder the re-establishment of native vegetation

(Dehring 1997).

Public use of Refuge trails in Alternatives B and D

may result in localized, long-term effects to

vegetation communities near trails. However, with

appropriate trail maintenance and visitor use

management, the overall effect of public trail use on

vegetation communities would be minor. The limited

trail use in Alternatives A and C would have a

negligible effect on vegetation.

In Alternatives B and D, the Service would monitor the

impacts of public use on riparian communities.

Monitoring would provide a long-term benefit to

riparian habitat by allowing the Service to effectively

respond to impacts and implement appropriate

management measures.

Off-trail Use. Seasonal off-trail use in Alternatives B

and D may result in localized vegetation trampling, the

development of social trails, and increased weed

dispersal in the southern portion of the Refuge

(Figures 24 and 26). The extent and severity of these

impacts may be increased by consistent off-trail use of

specific areas, or by large groups of visitors. Impacts

would be minimized by restricting off-trail access to the

non-growing season. As a result, only minor, long-term

effects to vegetation are anticipated for off-trail use in

Alternatives B and D.

No off-trail public use would be allowed under

Alternatives A and C, and there would be no effect

to vegetation.

Table 13. Vegetation Impacts from Public Use Facilities

Xeric Tallgrass Grassland

Other Grassland

Riparian and Wetland

TOTAL

Vegetation Type Area of Impact (acres)†

–

–

–

–

0.5

0.6

–

1.1

0.01

–

–

0.01

0.08

1.3

–

1.4

Alt. A Alt. B Alt. C Alt. D

† This does not include impacts from new trail construction shown in Table 12.

– = No impact.

Table 12. Vegetation Disturbance Associated With New Trail Construction

1

2

3

4

5

6

7

Rock Creek Loop

Upper Woman Creek switchbacks

South ridge through trail

Southeast loop connection

South ridge loop

Lindsay Ranch-Plum Branch connection

North boundary connection

TOTAL

New Trail Segment Map ID†

Segment

Length

(ft.)

Xeric Tallgrass Impact

(acres)‡

Mixed Grassland Impact

(acres)‡

4,180

1,487

6,551

1,580

4,909

1,012

2,166

–

–

--

–

–

–

–

–

A

0.9

0.1

0.4

--

–

–

–

1.4

B

–

–

–

–

–

–

–

–

C

0.9

0.1

0.4

–

1.6

–

0.2

3.2

D

–

–

–

–

–

–

–

–

A

0.6

0.4

0.8

0.5

–

–

–

2.3

B

–

–

–

–

–

–

–

–

C

0.6

0.4

0.8

0.5

0.1

0.4

0.5

3.3

D

† Shown in Figure 25 and Figure 27. 

‡ Area calculated assuming a 15-foot impact width during construction (does not include trails converted from existing roads). 

– = No impact.
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 165

Visitor Use Facilities. Construction of public use and

Refuge management facilities in Alternatives B, C,

and D would result in minor impacts to the vegetation

communities at Rocky Flats. New facilities would

include parking areas, trailheads, restrooms,

overlooks, viewing blinds, visitor contact facilities, and

interpretive facilities. Disturbance to vegetation

communities from specific facilities in Alternatives B,

C, and D would be small (Table 13). The central

parking and trailhead area in Alternatives B, C, and

D would be primarily in a previously disturbed area

of xeric tallgrass grassland north of the Upper

Church Ditch. Additional indirect impacts may result

from social trails, trampling, and weed infestations

associated with public use of the parking and

trailhead areas. Construction of most of these

facilities would result in a minor, long-term loss of

vegetation, but effects would be minimized by placing

facilities in previously disturbed areas and directing

visitors to developed facilities.

REFUGE OPERATIONS, SAFETY AND PARTNERSHIPS

Refuge Operations

Maintenance Facilities. In all alternatives, the

Service would construct a maintenance facility within

degraded portions of the xeric tallgrass community

to minimize effects. This would be a stand-alone

facility in Alternative A; in Alternatives B, C, and D,

the maintenance facility would be co-located with

visitor use facilities (described above). The area of

permanent impact for a maintenance facility would

be less than 1 acre for all alternatives.

The construction of maintenance facilities would

result in a minor, long-term loss of vegetation in the

xeric tallgrass community. Additional, indirect

impacts may result from social trails, trampling, and

weed infestations associated with the ongoing use of

the facility.

Partnerships

Regional Coordination. In Alternatives B, C, and D,

the Service would meet annually with nearby open

space managers and landowners to coordinate

resource management strategies. Coordination of

Refuge resources and management issues with

adjacent land managers would likely result in longterm benefits to vegetation communities. The

sharing of knowledge between agencies and other

landowners would result in more effective and

efficient vegetation management, including weed

control, habitat restoration, and fire management.

The coordination of management strategies would

help ensure that resource management strategies

off Refuge do not conflict with or counteract

management actions on the Refuge. Alternative A

would not realize these benefits.

Research. In alternatives B, C, and D, the Service

would identify information needs and consider

proposals for compatible scientific research on the

Refuge by staff or external researchers. The Refuge

presents many opportunities for targeted research on

various resource management issues. This research

would result in indirect benefits to wildlife and habitat

on the Refuge by improving the Service’s base of

knowledge for management and decision-making.

Alternative A would not realize these benefits.

Monitoring Preble’s meadow jumping mouse populations

within the riparian habitat

© Mauro
Chapter 4: Environmental Consequences

166 Rocky Flats National Wildlife Refuge 

CUMULATIVE IMPACTS

Mining

Potential future mining along the western edge of the

Refuge would result in major, long-term impacts to the

vegetation communities in those areas, due to major

habitat disturbance and the encroachment of weed

species. About 264 acres of xeric tallgrass grassland

and 16 acres of riparian habitat may be lost or

disturbed within the permitted mining areas. These

vegetation communities may eventually be reestablished following mining, but reclamation would be

a long-term effort.

The deposition of windblown soil from mining areas has

the potential to adversely impact adjacent vegetation

communities by burying native plants and by providing

a foothold for noxious weed infestations. The Service

would work with the mining operators and the

appropriate regulatory agencies to minimize and

mitigate the effects of windblown soil deposition on the

Refuge. Management actions on the Refuge would not

add to the adverse cumulative impacts from mining.

The permit for the Church Ranch Rocky Flats Pit

includes stipulations that mining will stay a minimum

of 2 feet above groundwater (CDMG 2004; Church

Ranch 2004). However, the permits for the Bluestone

Pit and the Lakewood Brick and Tile operation do not

have stipulations about groundwater. Therefore, these

operations may potentially impact riparian vegetation

communities in the Rock Creek and Walnut Creek

drainages, which are downgradient of these operations.

Urban Development 

Urban development adjacent to the Refuge to the

south and west has the potential to adversely impact

vegetation communities on the Refuge by contributing

to the spread of noxious weeds on the Refuge. The

process of urban development typically creates large

areas of vacant, disturbed land as it is prepared for

future development. These areas are prone to

invasions of noxious weeds and in turn can become the

source of subsequent infestations on the Refuge.

These cumulative effects can be reduced by minimizing

the size and duration of disturbed land during

construction, developing and implementing a weed

management plan, and if possible, incorporating into

development plans a buffer of native vegetation

between the Refuge and development areas.

The Service would work with local jurisdictions during

the the land use and development planning process to

minimize the impact of adjacent urban development on

Refuge resources. 

Invasive weeds such as Dalmatian toadflax can dominate native plant communities.

© Mauro
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 167

DOE Monitoring and Maintenance

The Refuge will surround the DOE retained area on all

sides. Ongoing monitoring and maintenance activities

within the DOE retained area may include ground

disturbing activities that would be prone to noxious

weed infestations. While the Service will provide the

DOE recommendations on revegetation and natural

resource management, the Service does not have

decision-making authority on these matters.

Therefore, the DOE retained area does have the

potential to adversely affect vegetation communities on

the Refuge through the spread of noxious weeds.

4.5. WILDLIFE RESOURCES

Potential effects to wildlife species were evaluated

based on the anticipated types of actions and

disturbances associated with each alternative.

Quantifiable impacts to wildlife are not readily

predicted, but inferences can be made based on the

amount of habitat lost or gained, changes in the

quality of the habitat, and known wildlife response to

human activity and other disturbances. Potential

effects to wildlife were refined further by input from

regional wildlife specialists, the knowledge of Service

and consulting biologists, previous studies at Rocky

Flats, and published information.

WILDLIFE AND HABITAT MANAGEMENT ACTIONS

Preble’s Habitat Management

All alternatives would protect and maintain Preble’s

habitat on Refuge streams, survey habitat to detect

any degradation, and allow natural revegetation of

native species on abandoned roads. Habitat

protection for Preble’s in all alternatives would provide

secondary benefits to riparian wildlife species such as

raptors, numerous songbirds, voles, and other riparian

rodents. This section addresses environmental

consequences of Preble’s habitat management on

general wildlife resources; direct impacts of Preble’s

habitat management on Preble’s and other threatened

and endangered species is discussed in the Threatened

and Endangered Species section.

Alternative A would provide the least benefit for

Preble’s and other wildlife. This alternative would

protect Preble’s habitat, control weeds (with limited

herbicide use), and monitor the presence/absence of

Preble’s, but provides few other benefits to wildlife

in general.

Alternatives B, C, and D would provide additional

moderate benefits to all riparian wildlife species by

protecting riparian vegetation with temporary fencing

as needed and providing better control of ungulate

populations. These measures have the potential to

adversely affect some species by restricting movement

and access to habitat areas. However, fencing to

exclude ungulates from riparian habitat is not expected

to be widely used, if at all, so the expected impacts to

other wildlife species are expected to be minor to

negligible. These three alternatives would protect,

maintain, and improve about 1,000 acres of Preble’s

habitat, providing a moderate benefit to Preble’s

compared to the simple habitat protection in

Alternative A. Alternative D would also establish a

plan to monitor trail use and recreation impacts on

Preble’s. Results from monitoring would indirectly

provide moderate benefits to other riparian wildlife

potentially impacted by recreation and public use in

sensitive habitats.

Maintaining target populations of deer and elk would

ensure healthy populations and limit habitat degradation.

© Mauro

The intensity of weed management efforts

would vary between alternatives.

© Mauro
Chapter 4: Environmental Consequences

168 Rocky Flats National Wildlife Refuge 

In all alternatives, the periodic presence of humans in

riparian habitat during monitoring may disturb or

temporarily displace individual animals. The extent of

the disturbance would depend on the magnitude,

intensity, and duration of monitoring. Alternatives C

and D have the greatest potential to disturb riparian

wildlife as a result of more extensive vegetation

monitoring; however, because of the low magnitude

and short duration of monitoring, short-term impacts

would be negligible in all alternatives. No long-term

adverse effects to wildlife are anticipated with planned

levels of monitoring.

Xeric Tallgrass Management

The maintenance and improvement of xeric tallgrass

would benefit native wildlife species in all alternatives.

Alternative A would manage 1,000 acres of tallgrass

habitat; Alternatives B, C, and D would manage 1,500

acres of tallgrass habitat.

The short-term, minor, adverse impacts of xeric tallgrass

management would be the same for all alternatives,

possibly including direct injury or mortality of wildlife

from weed control management strategies. Native

wildlife, however, evolved with natural ecological

processes such as fire and grazing and have developed

behavioral or physiological adaptations to survive these

events. Other strategies such as mowing are not

anticipated to adversely affect wildlife populations. 

Alternative A would have the fewest short-term adverse

impacts and would provide the fewest long-term benefits

for native wildlife by limiting xeric tallgrass

management efforts to the Rock Creek Reserve.

Prescribed fire would be used only within Rock Creek

Reserve resulting in minor short-term adverse impacts

and, because this tool would not be used Refuge-wide,

long-term benefits also would be minor. Conversely,

Alternatives B and C would have moderate short-term

adverse impacts from restoration tools including

prescribed fire and grazing, but also would result in the

moderate to major long-term benefits for native wildlife

by improving the quality of the habitat. 

Alternative D would manage xeric tallgrass grasslands

Refuge-wide, but the tools available would be limited.

Prescribed fire and large herbivore grazing are part of

the natural functions of the prairie ecosystem and

excluding these processes may indirectly adversely

impact wildlife. Alternative D would have minor

short-term direct impacts on existing wildlife and,

because natural processes would be suppressed, would

result in negligible to minor benefits to the native

prairie wildlife community. Alternatives B and C

would monitor ecological conditions and provide longterm minor indirect benefits to wildlife. Alternatives

A and D would have no monitoring and any short- or

long-term benefits would not be realized.

Mixed Grassland Prairie Management

The only management activity specific to mixed

grassland is related to grassland restoration.

Alternatives B and C would restore 300 acres of

monoculture hayfield and other areas to native

grassland. These efforts would result in minor shortterm impacts on wildlife species that use non-native

grasslands or that would be directly impacted by

grading or removal of existing vegetation (such as

burrowing mammals). However, revegetation efforts

would improve and diversify habitat conditions for a

variety of wildlife species, including grassland birds

and native burrowing mammals. Alternatives B and C

would provide direct long-term benefits to wildlife at

the Refuge. Alternatives A and D would not establish

native vegetation in the existing hay meadow, and

benefits to native wildlife would not be realized.

Road Restoration and Revegetation

In all alternatives, varying lengths of existing roads

and stream crossings on the Refuge would be

removed and revegetated. The short-term impacts of

these restoration efforts on wildlife would be

negligible to minor, primarily affecting species such

as burrowing mammals and nesting birds that may

be directly impacted by construction and grading

activities. Restoration efforts, however, would result

in major long-term benefits to a variety of wildlife

species by reducing habitat fragmentation, increasing

habitat patch size, and improving the overall quality

and amount of wildlife habitat on the Refuge. In

general, larger average patch sizes would have a

positive effect on wildlife and habitat. Alternative C

would have the most beneficial effect on patch size

followed by Alternatives B, D, and A (Table 11). 

Weed Management

Developing and implementing an IPM plan involves

various applications of weed control strategies and

monitoring. Invasive weeds can dominate a native

plant community, alter native habitats, reduce the

suitability of the habitat for native wildlife species,

and attract non-native species. Short-term adverse

impacts of weed management on wildlife populations

could include direct injury or mortality to individuals

from the various IPM strategies (such as mowing,

prescribed fire, and chemical control), depending on
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 169

the intensity, duration and timing of control activities.

Activities conducted during summer breeding or

other active periods for wildlife have the greatest

potential for adverse impacts. Implementation of an

IPM plan would have long-term benefits for native

wildlife species and communities on the Refuge

including enhanced habitat quality and a reduction in

non-native wildlife species.

While the intensity of weed management efforts would

vary between alternatives, the tools would be similar

except neither Alternative A nor Alternative D would

use grazing, and prescribed fire would not be used in

Alternative D. Alternative A would use only limited

prescribed fire in the Rock Creek Reserve. The

difference in impacts between the various tools would

be negligible. 

Large ungulate grazing of short, intense duration is a

natural process in prairie ecosystems. Controlled

grazing would have short-term minor impacts on large

herbivores by reducing available forage, but would

result in long-term moderate benefits to wildlife by

restoring native grassland vegetation and processes.

A compatibility determination would be required for

any grazing program that provides an economic benefit

to a private party. This would not be needed for a

contract to use goats for the purpose of weed control.

Chemical control has the potential for secondary

impacts caused by inadvertent application to nontarget species or secondary poisoning effects. All

chemicals would be applied according to strict state,

Service, and EPA requirements and guidelines to

minimize adverse effects. Prescribed fire may

directly impact wildlife by temporarily displacing

animals or disturbing important breeding or foraging

areas; however, native grassland wildlife evolved with

fire as an important ecosystem process and has

adapted fire survival mechanisms and behavior.

Biological control would be a low impact strategy, but

would have inherent risks such as impacts to nontarget species and introduction of non-native

organisms to the ecosystem.

Implementation of Alternative A would have the fewest

short-term adverse impacts and, conversely, would

provide the fewest long-term benefits for native wildlife

by limiting weed control efforts to the Rock Creek

Reserve plus weed control outside the Reserve.

Alternatives B, C, and D would have the greatest

short-term adverse impacts, but also would result in

the greatest long-term benefits for native wildlife. 

In Alternatives B and C, the establishment of interior

fencing to collect weeds would have minor long-term

impacts by creating barriers for certain species.

Fencing would cause minor long-term impacts by

altering the microhabitat, including altering moisture

regimes, changing plant species composition, and

establishing linear strips, or edges, of a perpetual early

seral stage community. These edge effects would

benefit some species and be detrimental to others.

Weeds built up along fencelines also provide temporary

cover for numerous bird, mammal and reptile species.

Placing fences along existing edges such as trails or

roads would minimize edge effects.

Deer and Elk Management

Population Management. The concept of management

for a target population level would be used for deer and

elk populations on the Refuge. Target population levels

would be established in coordination with CDOW to

maintain an optimum number of animals that can be

supported by their habitat without that habitat being

significantly degraded.

In all alternatives, the development and use of a target

population would result in long-term benefits to deer

and elk populations, other species, and their habitats.

Establishing a target population level would allow the

Service to be proactive in deer and elk management,

maintain herd health in response to environmental

variables including chronic wasting disease, and prevent

or minimize the adverse effects of overgrazing and

overbrowsing on habitat on which other species depend. 

Alternative A would not have a time frame for

establishing and achieving population targets, but

would implement population targets in accordance

with other Refuge management priorities.

The Service would monitor deer and elk populations and

their impacts on sensitive habitat areas.

© NJAG
Chapter 4: Environmental Consequences

170 Rocky Flats National Wildlife Refuge 

Alternatives B, C, and D would establish population

targets within 3 years with the goal to achieve these

targets within 5 years. Several population control

methods would be used to achieve population targets

including culling by Service staff and public hunting.

Alternatives A and C would not include public hunting

as a management tool.

Population targets would be the same in all alternatives

(deer and elk populations would be maintained at target

levels below the maximum supported by the Refuge in

the absence of other refuge goals) and the impacts to

deer and elk herds on the Refuge would be similar in all

alternatives. Maintaining population target levels would

directly impact individual animals that are killed by

culling or public hunting, but would have negligible

impacts on the overall population of the CDOW’s

Boulder Herd Management unit, in which the Refuge is

located. Culling and hunting deer and elk would have

minor, short-term impacts on the remaining herd.

Implementing population management measures would

result in moderate, long-term benefits to the health and

sustainability of deer and elk populations on the

Refuge. Over the course of 15 years, the effects of

culling and/or hunting, combined with the increased

disturbance in Alternatives B and D from public trail

use, may result in increased movement of deer between

the Refuge and adjacent habitat areas. While this

increased movement may benefit the population as a

whole by increasing genetic diversity and reducing

overuse of the habitat, it also may result in a minor

increase in ungulate mortality along the roads and

highways surrounding the Refuge.

The schedule for implementing these management

strategies would vary among alternatives. Alternative

A would have no specified implementation schedule and

would risk populations exceeding targets and degrading

habitat before any control measures would be enacted.

Population control activities under this alternative likely

would be implemented after current herds have

expanded. Thus, Alternative A would require greater

initial population control (culling and hunting).

Alternatives B, C, and D would establish a target

population within 3 years. This schedule would permit

the Service to implement control measures in a timely

manner and minimize impacts to vegetation and

sensitive habitats from overgrazing.

Monitoring. In addition to monitoring deer and elk

impacts on riparian and upland shrub communities in all

alternatives, Alternatives B and C also would include

monitoring of deer and elk populations and indices of

herd health. Monitoring in Alternatives A and D would

identify potential habitat degradation of sensitive shrub

communities associated with an overabundance of deer

and elk, but this may be inadequate to obtain reasonable

population parameters for determining viable target

populations and maintaining herd health. Without

reasonable target population estimates in Alternative A,

the Service may implement inappropriate population

control, resulting in the inadequate or unnecessary

removal of animals.

In Alternative B, riparian and shrub monitoring would

every two years, and annual deer and elk counts would

measure abundance and density. This level of

monitoring would provide an adequate measure of deer

and elk populations. However, monitoring in

Alternative B may not be sufficient to assess seasonal

movement and use patterns on the Refuge and the

extent of emigration and immigration off-Refuge. 

In addition to the monitoring in Alternative B,

Alternative C also would include seasonal surveys of

movement patterns, and annual surveys of population

size, age and sex composition, fawning rates, and fawn

survival. This level of monitoring would provide a

moderate benefit by obtaining adequate information on

population parameters necessary to establish

sustainable target population, and provide managers the

ability to accurately establish population control goals.

Obtaining information on fawning rates and fawn

survival usually involves intensive and invasive

monitoring that requires some form of mark and

recapture or telemetry methods that may result in

occasional direct and indirect injury or death to fawns.

Prairie Dog Management

The biodiversity and productivity of grasslands result

from a mosaic of habitat types; the prairie dog town is

Wavy leaf thistle.

© Nelson, RFETS
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 171

one of those types. Alternatives B, C, and D would

allow intra-Refuge relocation of prairie dogs, while

Alternative D would evaluate the suitability of

relocating prairie dogs onto the Refuge from other

jurisdictions. Prairie dog relocations require careful

and detailed planning, and are very labor intensive.

Despite the best care, regional data collected by City

of Boulder Open Space and Mountain Parks (City of

Boulder 2003) show that only about 40 to 60 percent

of relocated prairie dogs survive the relocation

process. Prairie dog relocations also fail to address

the survival of other animals that depend on their

complex of burrows. When prairie dogs are livetrapped and removed, effects of habitat loss to other

wildlife species that occupy the site are often ignored

(City of Boulder 2003) resulting in minor impacts to

common, widely dispersed species and moderate

adverse impacts to uncommon or narrowly

distributed species, such as the burrowing owl.

The prairie dog management objectives for all

alternatives are similar and would vary primarily in

the acreage allowed to be occupied by prairie dogs.

Prairie dogs are prey for numerous avian and

mammalian predators. In general, the more acreage

occupied by prairie dogs, the more prey is available for

larger predators, such as eagles, coyotes, and badgers.

Alternative A would permit unlimited natural

expansion of prairie dogs throughout the Refuge.

Because natural expansion of prairie dog colonies

would occur gradually, all impacts would be considered

long term. Moderate impacts to wildlife species

assemblages may occur on a local scale, because

changes in vegetation structure would result in local

reductions of species associated with taller grasslands.

On a Refuge-wide or regional scale, an increase in

prairie dog acreage would have only a minor effect on

the relative abundance or distribution of wildlife

species preferring this habitat type, but would not

likely change the overall species composition (gain or

loss of additional species). Prairie dogs would be

excluded from sensitive habitats within the Rock

Creek Reserve and Preble’s habitat, but not

throughout the Refuge, and colonies may expand

unchecked into sensitive xeric tallgrass communities

resulting in moderate impacts to this community. 

Alternatives B, C, and D would restrict prairie dog

expansion. Alternatives B and C would be more

restrictive in the acreage allowed to become occupied

by prairie dogs (750 and 500 acres, respectively). The

expansion of the prairie dog population on the Refuge

would have a beneficial effect on other wildlife species

that typically inhabit prairie dog colonies, although

some displacement of other mixed prairie grassland

species, including bird and small mammal species, is

likely. Overall, a greater diversity of wildlife is

expected with expansion of prairie dog colonies.

Alternatives B, C, and D would exclude prairie dogs

from xeric tallgrass communities and Preble’s habitat,

providing a greater amount of protection and,

consequently, negligible adverse impacts to these

sensitive wildlife habitats. 

Alternative D would allow expansion of prairie dogs up

to 1,000 acres. This amount of habitat conversion

would have moderate beneficial impacts on wildlife

species assemblages by increasing the diversity of

habitats on the Refuge. Alternative D would also

evaluate the suitability of accepting prairie dogs from

off-site locations. This may lead to the introduction of

the plague or a more rapid expansion of prairie dog

populations to the 1,000-acre limit.

Species Reintroductions 

In Alternatives B, C, and D, the Service would work

with the CDOW to evaluate the suitability of

reintroducing extirpated species to the Refuge. In

Alternative A, species reintroduction would be

conducted at the discretion of CDOW. Species

currently under consideration include native fish

species and plains sharp-tailed grouse. The CDOW

would be primarily responsible for the implementation,

management, and control of the consequences of

introductions. While the Service would not play a

leading role in these activities, it would work with

CDOW and other land management agencies in Sharp-tailed grouse would be a priority species for

reintroduction efforts.

© USFWS
Chapter 4: Environmental Consequences

172 Rocky Flats National Wildlife Refuge 

providing habitat for reintroduced species and

cooperating in other measures to improve the

potential for successful reintroductions. The success

of any reintroduction effort would depend on close

cooperation with CDOW and surrounding open space

land management agencies.

Native Fish Species. In all alternatives, the Service

would continue to assist the CDOW with on-going

reintroduction and monitoring of native fish species

such as the common shiner and northern redbelly

dace in Rock Creek and the Lindsay Ponds. The

successful reintroduction and establishment of

native fish species would provide long-term benefits

to the survival of these species by establishing a

population in its native habitat that can be a source

for future reintroductions to other foothills and

plains streams. Increasing the numbers and

survival rates of these species in Colorado also may

reduce the potential for future federal listing.

Reintroduction monitoring data would enable

Service staff to evaluate long-term population and

habitat trends and respond accordingly.

All alternatives would have a monitoring component.

In Alternatives A and D, the Service would only

assist CDOW with monitoring. In Alternatives B and

C, the Service would take a more active role and

oversee annual monitoring. Monitoring common

shiner and redbelly dace populations, which were

introduced in 2003, would help CDOW determine if

additional reintroductions are appropriate or other

management actions are necessary. 

In Alternatives A, B, and D, the Lindsay Ponds would

remain intact, resulting in a long-term benefit for

common shiner and redbelly dace. In Alternative C,

additional native fish reintroductions would not occur

until the Lindsay Ponds are removed and the stream

habitat restored. Removal of the Lindsay Ponds in

Alternative C would result in major short-term and

long-term adverse impacts to common shiner and

redbelly dace populations introduced in 2003. Lindsay

Ponds provide both feeding and spawning habitat for

these two species (Rosenlund 2003) and removing the

ponds would result in a long-term loss of spawning

habitat for both species in the Rock Creek drainage

and eventual loss of population (Aquatics Associates

2003). Even if other suitable habitat is available for

relocation of these native fish species, overall available

habitat on the Refuge would be substantially reduced.

Alternative B would also evaluate reintroduction of

native fish species into Walnut and Woman Creeks.

This would provide additional long-term benefits for

native species by expanding the distribution of the

species and reducing the potential adverse effects of a

single catastrophic event. 

Plains Sharp-tailed Grouse. While the proposed plan to

allow sharp-tailed grouse reintroduction to the Refuge

is the same among all alternatives, the timing and

distribution of reintroduction efforts and the frequency

of monitoring would be different for each alternative

depending on different rates of satisfying pre-release

procedures in the CDOW Plains Sharp-tailed Grouse

Recovery Plan (CDOW 1992). The long-term benefits

of grouse reintroduction efforts would include

expanding the existing range and population stability of

the grouse, increasing wildlife diversity on the Refuge,

and an additional opportunity for wildlife observation

and interpretation.

In Alternative A, the Service would adopt a passive

approach to grouse re-introduction, assisting CDOW,

but not taking the lead in reintroduction activities and

The use of established viewing blinds and overlooks would

help reduce the impacts of public use on wildlife.

© USFWS
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 173

monitoring. The Service would not develop sitespecific management plans for grouse in Alternative A.

The lack of adequate planning would likely result in

poorly defined management objectives, ineffective

monitoring, inadequate success criteria, and conflicting

management priorities on the Refuge that may lead to

the failure of grouse re-introduction. Without proper

management of the habitat, Alternative A may

adversely affect the success of grouse reintroductions.

In Alternatives B, C, and D, the Service would evaluate

the suitability of sharp-tail grouse reintroduction and

complete a sharp-tailed grouse management plan

within the first 2 to 3 years of the Refuge. This plan

would benefit grouse by increasing the prospect for

successful reintroduction. The success of grouse

reintroduction efforts depends on the availability of

suitable habitat. Sharp-tailed grouse reintroduction in

habitat that is not suitable because of weed infestations

or incorrect habitat composition (plant species) may

result in increased sharp-tailed grouse mortality. 

Grouse reintroduction in all alternatives probably would

not impact or displace other ground-nesting birds or

other wildlife species because the grouse would be refilling a niche vacated by their earlier extirpation.

Managing tallgrass and other grassland habitat for

sharp-tailed grouse would conflict with shortgrass

habitat requirements of prairie dogs. 

Other Reintroductions. Alternative B also would

evaluate the suitability for reintroduction of additional

native species. This would provide an overall benefit to

the Refuge by further enhancing the biodiversity of the

Refuge and contributing to the overall functioning of

the ecosystem.

PUBLIC USE, EDUCATION, AND INTERPRETATION ACTIONS

Public Use and Facilities

Visitor Use Facilities. Impacts to wildlife from the

construction of visitor use facilities would primarily

involve disturbance or alteration of vegetation, which is

discussed in Section 4.4, Vegetation Communities.

Hunting. Alternatives B and D call for a limited youth

and/or disabled hunting program focused on mule deer

and elk populations at Rocky Flats. No public hunting

would occur in Alternatives A and C. The short-term

impacts of this program would include direct impacts

on individuals that are taken during the hunts, and the

effect on the Refuge deer population from the

introduction of a new disturbance. These minor shortterm impacts would be offset by the long-term benefits

of improved population dynamics (migration and

dispersal) that may result from hunting.

Unharassed wildlife populations quickly adapt to some

human disturbances such as wildlife observation and

predictable levels of activity. Limited hunting on the

Refuge would reinforce skittish behavior in wildlife and

would result in minor to moderate impacts to wildlife

observation opportunities.

New Trails. Construction of new trails can favor

invasive weed species that may capitalize on the

existence of trail corridors. These effects can include

introducing a new pathway for predators, or the

creation of an unnatural wildlife dispersal corridor for

species such as prairie dogs. No new trails would be

constructed in Alternatives A and C; thus, there would

be no effect to wildlife. New trail segments would be

constructed in Alternatives B and D, resulting in longterm impacts to wildlife, primarily burrowing animals.

The area disturbed by new trail construction in

Alternatives B and D is small (Table 12) and minor

adverse impacts are expected to be offset by the

benefits of restoring and revegetating abandoned roads

and converting some roads to trails.

The conversion of existing roads to trails would

minimize the effects to wildlife habitat for Alternatives

B and D. Trail construction along existing roadways

would result in a narrowing of the tread surface and

active restoration (including weed management) in the

areas adjacent to the trail. Over the long term, these

activities would benefit wildlife and their habitat, and

would help mitigate the impacts of public use along

these trails.

Red-winged blackbird.

© USFWS
Chapter 4: Environmental Consequences

174 Rocky Flats National Wildlife Refuge 

Trail Use. Public use of trails would result in both

short- and long-term adverse effects on wildlife

species due to disturbance. While most trails would

be along existing roads, the frequency and nature of

disturbance would increase relative to present

conditions. Presently, Rocky Flats roads are used

sporadically by individual maintenance and patrol

vehicles, resulting in infrequent disturbance to

wildlife for short durations. Public trail use in

Alternatives B and D would result in more 

continuous disturbance from trail users during peak

public use periods resulting in minor local adverse

impacts to wildlife.

Wildlife responses to recreational use of trails would

vary by species, habitat type, and type of recreational

use. Factors that influence the amount of wildlife

disturbance include:

• Time of year

• Group size

• Number of visitors

• Duration (time spent near habitat)

• Predictability and habituation to trail use

• Noise and detectability

• Natural and created noise/visual barriers

Different uses would result in different types of

impacts. Visitors engaging in wildlife photography

and observation can cause short-term impacts to

wildlife due to the long duration and

unpredictability of their behavior (Knight and Cole

1995; Weir 2000). The use of established blinds and

overlooks, as well as guided interpretive visits,

would help mitigate these impacts. 

Short-term impacts generally would apply to

individuals rather than populations or communities,

and include behavioral changes such as nest

abandonment, changes in food habits, and physiological

changes such as elevated heart rates during flight

(Knight and Cole 1995). Repeated disturbance may

result in long-term changes to the behaviors of both

individuals and populations. These changes would

include abandonment of preferred foraging areas,

alterations in energy budgets due to flight and, in some

cases, abandonment of broad habitat areas (Knight and

Cole 1995).

Trail use disturbance to large, broad ranging species

such as mule deer would result in minor adverse

impacts by causing changes in movement patterns and

abandonment of certain concentration areas. While elk

are occasionally found in portions of Rocky Flats, their

presence is limited and sporadic. Changes in public use

of the Refuge are not anticipated to affect elk or their

periodic use of the Refuge. Trails in the Rock Creek

drainage would be closed seasonally to protect sensitive

breeding areas. Trail use would have a beneficial effect

if elk displacement resulting in a reduction in the

amount of degradation to sensitive riparian habitat

from overbrowsing. For smaller species including birds,

small mammals, reptiles, and insects, the presence and

ongoing use of a trail would be a minor and localized

adverse impact by creating a barrier to movement and

use of nearby habitat for species such as voles (Meaney

et al. 2002; Dickerson 2003; Miller and Knight 2001).

Trails and visitor use of the Refuge would have

negligible to minor impacts on prairie dogs. The

experience from trails located within or near prairie

dog colonies on City of Boulder and Boulder County

open space suggests that prairie dogs adapt to

adjacent trails.

General Trail Density. Depending on the specific trail

configuration, the overall trail density in a given area

can be an indicator of the potential for use of those

trails to adversely affect wildlife and habitat. The

potential for such impacts are often balanced against

the provision of trails for public access and recreation,

as is the case with many open space areas near Rocky

Flats. As shown in Table 14, the trail density in

Alternative D would be comparable to other nearby

open space areas, while Alternative B would have a

lower trail density than many nearby open space areas.

Internal barbed-wire fencing would be removed.

© Mauro
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 175

When compared against nearby open space areas with

a similar grassland character such as the Mesa/South

Boulder Creek area, both Alternatives B and D would

be similar. By these measures, Alternatives B and D

do not appear to have an excessive density of trails for

the land area that is anticipated to become the Refuge. 

Potential Impacts of Specific Trails

Northern East-West Trail. The east-west, multi-use

trail in the northern portion of the Refuge

(Alternatives B and D) may result in habitat

fragmentation by disrupting the movement of mule

deer and other wildlife species between the Rock

Creek drainage and the Walnut Creek drainage. While

several existing roads cross this area, public use along

a single trail may create a barrier of disturbance

during periods of high visitation. Such an impact would

be moderate over the long term. 

Rock Creek Hiking Trail. The hiking-only trail

traversing the upper (western) portions of the Rock

Creek drainage (Alternatives B and D) would have

the potential to affect the movement of wildlife

between Rock Creek and the open lands to the west of

the Refuge, as well as disturbance to wildlife species

in the vicinity of the trail. As a newly constructed

trail, this trail also would have the potential to

increase weed dispersal in the area. Because low

pedestrian traffic and seasonal closures are expected

along this trail, the long-term impacts to wildlife are

anticipated to be minor. 

Plum Branch Trail. In Alternative D, a hiking trail

would traverse the Rock Creek drainage along the

Plum Branch. Similar to the Rock Creek trail, this

trail would have minor impacts on wildlife movement

within the Rock Creek drainage. This trail would

follow an existing road through riparian areas and mule

deer concentration areas. The effects of disturbance

and habitat fragmentation from this trail would be

moderate at certain times of the year. During periods

of heavy public use, the cumulative effect of this and

the three other trails that would traverse the Rock

Creek drainage in Alternative D may result in

moderate to major impacts to some species of wildlife.

These impacts would be partially mitigated by the

enforcement of seasonal trail closures.

South Ridge East-West Through Trail. In Alternatives

B and D, public use along an east-west multi-use trail

may result in some fragmentation and disturbance of

wildlife movement between Antelope Springs and the

Woman Creek drainage, including mule deer

concentration areas. This would constitute a minor

impact to mule deer populations.

Walnut Creek, Smart Ditch, and Woman Creek Trails.

In Alternative D, several trails would follow existing

roads in close proximity to riparian habitat along

Walnut Creek, the Smart Ditch, and South Woman

Creek. Public use along these three trails would

disturb potential raptor nesting habitat. In addition,

public use along the Walnut Creek and Smart Ditch

trails has the potential to fragment or disturb mule

Area Jurisdiction Size (acres) Miles of Trail Acres per

Mile of Trail ‡ 

Alternative B USFWS 5,000 16.4 305 

Alternative D USFWS 5,000 21.1 237 

Boulder

Mountain Park City of Boulder 5,719 40.2 142 

Mesa/South

Boulder Creek † City of Boulder 3,174 19.8 165 

White Ranch Park Jefferson County 4,335 19.6 221 

Walker Ranch 

Open Space 

Boulder County/ 

Co. State Parks 3,507 11.4 308 

Doudy Draw 

Open Space † City of Boulder 1,629 5.0 326 

Source: City of Boulder and Boulder County GIS data; Jefferson County Open Space web page. 

† Generally consists of grassland communities comparable to those at Rocky Flats. 

‡ Areas with higher values have fewer trails per acre. 

Table 14. Comparison of Proposed Trail Density to Other Open Space Areas
Chapter 4: Environmental Consequences

176 Rocky Flats National Wildlife Refuge 

deer concentration areas. Individually, the impacts of

public use would be relatively minor. The combined

impact of all three trails, however, may have a

moderate impact on the availability of suitable

nesting habitat for various raptor species, most

notably, American kestrels, great horned owls, and

red-tailed hawks.

REFUGE OPERATIONS, SAFETY AND PARTNERSHIPS

Cultural Resource Management 

Cultural resource management is not anticipated to

affect overall wildlife habitat, populations or species

composition on the Refuge. Removal of the Lindsay

Ranch structures in Alternative C would eliminate

some barn owl, bat, and invertebrate (honey bee)

habitat. These effects would not occur in

Alternatives A, B, or D.

Refuge Operations

Fencing

The existing barbed wire perimeter fence, which

would remain in all alternatives, and would have

negligible impacts to the movement of wildlife species.

Partnerships

In Alternative A, the Service would maintain

dialogue with adjacent landowners and open space

management agencies, while in Alternatives B, C and

D, the Service would meet annually with adjacent

open space managers. These activities would benefit

wildlife populations on the Refuge by allowing the

Service to learn about other landowners’ and agencies’

wildlife and wildlife habitat management successes and

failures. This regional dialogue also would benefit

wildlife on the Refuge by improving the coordination of

habitat management across jurisdictional boundaries to

improve and expand the range of available habitat for

many species. Coordination with adjacent land

managers also would be useful in protecting wildlife

movement corridors between properties.

Research. All alternatives would allow for compatible

scientific research that focuses on habitat, wildlife, and

public use. All field research would introduce

additional short-term researcher disturbance. This

disturbance would be offset by improved knowledge

that may be directly applied to the management and

conservation of habitat.

CUMULATIVE IMPACTS

Mining

The impact of future aggregate mining on wildlife

corridors along the western edge of the Refuge would

disrupt or alter deer and elk movement between the

Refuge and areas to the west and fragment existing

grassland communities. Noise and human activity, as

well as noxious weed infestations related to mining also

would indirectly reduce habitat for native wildlife using

lands surrounding the Refuge. The cumulative effect

of reduced habitat, movement barriers and fragmented

habitat from mining combined with increased public

use may curtail ungulate movements on and off the

Refuge and would have moderate adverse impacts to

elk and possibly deer use on the Refuge. 

Trail use in Alternative D could impact nesting sites for

raptors.

© USFWS
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 177

Urban Development

The development of private lands along the western

boundary of the Refuge would adversely impact

numerous wildlife species on the Refuge by eliminating

a major east-west movement corridor between the

Refuge and the open space lands and foothills to the

west. Development along the southern boundary of the

Refuge would similarly impact the movement of

wildlife species between the Refuge and the Big Dry

Creek drainage. Urban development along the Refuge

boundaries also has the potential to increase the

occurrence of wildlife conflicts. Such conflicts include,

but are not limited to wildlife seeking domestic food

sources (gardens or trash), wildlife preying upon

domestic pets, and domestic pets preying upon birds

and small mammals, and traffic conflicts. Overall,

these conflicts can be a nuisance and in some cases a

danger to humans. Additionaly, wildlife/human

conflicts can alter the natural foraging and movement

patterns of some wildlife.

DOE Monitoring and Maintenance

The Service has recommended to the RFCA parties

that DOE construct a four-strand barbed-wire stock

fence around the DOE retained area to demarcate the

boundary between the Refuge and DOE retained lands

(Appendix E). The impact of such a fence on wildlife

would be negligible to minor, depending on the species. 

4.6. THREATENED AND ENDANGERED SPECIES

Potential effects to threatened and endangered

species from alternative actions were evaluated

based on potential impacts to Preble’s meadow

jumping mouse, which is found in riparian habitat

on the Refuge, and bald eagles, which occasionally

forage on the site. The determination of effects to

these species was based the likelihood for direct

impacts to individuals or a loss or change in

habitat used by these species. No assessment of

effects on threatened or endangered plant species

was conducted because none are known to exist at

the Refuge.

WILDLIFE AND HABITAT MANAGEMENT ACTIONS

Preble’s Habitat Management

The protection and management of riparian and

adjacent upland grasslands specifically for Preble’s

would provide long-term benefits to the mouse. The

periodic presence of humans in Preble’s habitat for

monitoring may potentially disturb or temporarily

displace individual Preble’s. The extent of the

disturbance would depend on the magnitude, intensity

and duration of monitoring, but is expected to be

negligible for all alternatives. Alternatives C and D

would have the greatest potential to disturb Preble’s as

a result of more extensive vegetation monitoring than

Alternatives A and B. The magnitude and intensity of

the disturbance would be substantially less then

previous population monitoring of Preble’s at Rocky

Flats, which included extensive trapping, marking, and

fitting individuals with radio transmitters or other

marking devices.

Habitat surveys in all alternatives would facilitate more

responsive management to early detection of problems

or positive responses to habitat restoration. These

surveys would detect any habitat degradation and lead

to responsive actions such as deer and elk population

management or weed control.

Road Restoration and Revegetation

Reclamation of roads and stream crossings would

benefit all threatened and endangered species by:

• Improving habitat connectivity

• Reducing habitat fragmentation

• Reducing conduits for invasive weeds 

and predators

Alternative A would provide the least benefit by

restoring 12 miles of unused roads and seven stream

crossings. Alternatives B, C, and D would restore

between 24 and 27 miles of unused roads Refuge-wide

and up to 13 stream crossings. These alternatives

would benefit Preble’s by reducing habitat

fragmentation and restoring connectivity Refuge-wide.

Bald eagles would indirectly benefit from reduced

fragmentation that may increase the distribution,

diversity, and availability of prey populations.

Restoration (road restoration in all alternatives and

hay meadow restoration in Alternatives B and C) and

weed management efforts (all alternatives) may

indirectly improve foraging habitat for the bald eagle

by increasing the abundance and diversity of prey

species in the grasslands at Rocky Flats.

Weed Management

Weed management would benefit threatened and

endangered species by reducing competition or

degradation of habitat from invasive weeds. As

discussed in Section 4.4, all forms of weed management

would carry inherent short-term risk for adverse direct

impacts to threatened and endangered species or their

habitat. Alternative A would have the fewest short-
Chapter 4: Environmental Consequences

178 Rocky Flats National Wildlife Refuge 

term adverse impacts and, conversely, would provide

the fewest long-term benefits for threatened and

endangered species by limiting efforts primarily to the

Rock Creek Reserve. Alternatives B, C, and D would

have the greatest short-term adverse impacts, but also

would result in the greatest long-term benefits for

threatened and endangered species.

Weed management and habitat restoration efforts

would increase populations of some bird and small

mammal species that provide prey for bald eagles,

while populations of other species would decrease,

resulting in overall negligible impacts to eagles.

Deer and Elk Management

Monitoring deer impacts on riparian habitat in

Alternatives B and C would benefit Preble’s by

identifying excessive browsing that would prompt

management activities to prevent excessive damage to

Preble’s habitat. Impacts of deer and elk management

on bald eagles would be negligible in all alternatives. 

Prairie Dog Management

Prairie dog exclusion from riparian, wetland, and xeric

tallgrass habitat areas (Alternatives B, C, and D) would

not reduce substantially the available colonization sites

for prairie dogs, and would maintain the quality of

native habitat for other Refuge resources, including

Preble’s. Intra-Refuge relocation (Alternatives B, C,

and D) may benefit prairie dog populations, but would

result in an accompanying change in the composition of

existing shortgrass and mesic mixed grass habitat.

Accepting prairie dogs from off-site locations

(Alternative D) may benefit prairie dog populations at

the expense of other Refuge resources, but may

possibly introduce plague and other diseases.

A moderate adverse impact would occur in Alternative

A with the potential expansion of prairie dog colonies

into upland foraging habitat and shrub areas that

would reduce habitat suitability for Preble’s.

Alternatives B, C, and D would exclude prairie dog

expansion into Preble’s habitat resulting in

negligible impacts.

Prairie dog expansion in all alternatives would

improve foraging conditions for both nesting and

wintering bald eagles from surrounding areas.

Expanded prairie dog populations may be a

particularly important winter prey resource for

Front Range eagles (U.S. Fish and Wildlife Service

1992; Gillihan 1998). The expansion of prairie dog

habitat also would benefit other species by providing

prey for predators, or habitat for prairie dog

associates, such as burrowing owls and horned larks.

Species Reintroduction

In all alternatives, native fish reintroduction would

have a negligible impact on terrestrial threatened and

endangered species, including Preble’s, and bald eagle.

Creating a sustainable native fishery in Rock Creek

would benefit aquatic predators such as herons and

cormorants, but the native fish are typically too small

to provide prey for bald eagles.

Reintroduction of sharp-tailed grouse in all alternatives

likely would involve habitat restoration and weed

management activities. Alternative A provides for no

specific grouse management activities, while

Alternatives B, C, and D would be implemented after

the development of a management plan. Habitat

restoration would benefit Preble’s by maintaining or

enhancing native grass and shrub communities.

Grouse also may provide an additional prey species for

both nesting and wintering bald eagles. 

PUBLIC USE, EDUCATION AND INTERPRETATION ACTIONS

Public Use

Trail Use. Public use may result in minor indirect

impacts to Preble’s populations, distribution, and

behavior due to trail use in habitat areas. Meaney et

al. (2002) found no strong indication that Preble’s are

adversely impacted by trails, although the study

suggests possible negative trail effects on Preble’s

distribution and abundance.

Alternatives A and C would have the least impact to

Preble’s resulting from the conversion of existing roads

into trails or other public uses. These two alternatives

would have no trails or public use of riparian areas.

Alternative B would have minor impacts to Preble’s

because some existing roads within riparian areas

Alternatives A, B, and D would maintain the scenic, historic,

and interpretive value of the Lindsay Ranch.

© Shapins Associates
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 179

would be converted to pedestrian trails. While the

existing number of roads would be reduced in this

alternative, the use of trails will exceed the current

occasional use of roads. The Ecological Services

branch of the Service has previously concluded that

conversion of a graded or two-track road did not

constitute a change in land use and does not result in

“take” of Preble’s.

Public use of the Refuge may displace or discourage

bald eagle use of potential foraging or perching areas.

Currently, the Refuge is only occasionally visited by

wintering bald eagles or possibly by eagles from

nearby nesting areas. As habitat restoration

progresses and the availability of prey (prairie dogs)

increases under the various alternatives, bald eagle

use of the Refuge would be expected to increase and

potential human/eagle conflicts would also increase.

Alternatives A and C would have the least public use

and a negligible effect on bald eagles. Alternative B

would have more trails and a greater potential impact

on bald eagles; however, trails in Alternative B

generally avoid riparian areas and other suitable eagle

foraging or perching habitat. Alternative D would

likely have the highest visitor use, the most diverse

uses, and the most widely dispersed human use.

Several trails specific to Alternative D would follow

existing roads in close proximity to riparian habitat

along Walnut Creek, the Smart Ditch, and South

Woman Creek, and public use along all three of the

trails may indirectly impact bald eagles by human

activity near potential perch sites. Alternatives B and

D are expected to have a minor effect on bald eagles

because of their limited current use of Refuge habitat.

Trail Construction. In Alternative B, approximately

0.4 mile of existing roads within Preble’s habitat would

be converted to trails and 0.1 mile of new trail

construction would occur in Preble’s habitat. In

Alternative D, 0.6 mile of existing roads would be

converted to trails and 0.1 mile of new trail

construction would occur in Preble’s habitat (Table 15). 

Construction of a new hiking trail in the Rock Creek

area may fragment some habitat as it descends from

the pediment top into the Short Ear Branch of Rock

Creek (Alternative D). To avoid adverse impacts to

Preble’s, construction activities for new trails would

be conducted outside the Preble’s active season (May

through September). Adverse impacts would be

minor if trails are constructed during Preble’s

hibernation. Alternative D would have the most

human disturbance within Preble’s habitat, the most

new trail construction, and the greatest potential for

secondary impacts associated with erosion caused by

equestrian and bicycle use. New trail construction for

Alternatives B and D would have a minor effect on

Preble’s because of the limited extent of construction

in Preble’s habitat.

Because no new trails would be constructed for

Alternatives A and C, there would be no effect on

Preble’s habitat. A beneficial effect would occur for

all alternatives with the conversion of roads to trails

and revegetation of the narrower corridor.

Monitoring for recreation impacts in Alternatives B

and D would benefit Preble’s through adaptive

management prescriptions implemented in response

to recreation impacts. 

Trail construction in Alternatives B and D may directly

impact some prairie dog colonies due to disturbance

and fragmentation in their habitat areas. This activity

also would indirectly impact bald eagles by eliminating

or curtailing use of some potential foraging areas.

Hunting

Limited deer and elk hunting would have no direct

impact on any threatened or endangered species.

Indirect short-term impacts would result from

disturbance caused by the additional human presence

in unpredictable locations and noise from gunshots. 

Visitor Use Facilities

Construction of visitor use facilities such as parking

areas, overlooks, and viewing blinds would be located in

areas of previous disturbance. These facilities for all

alternatives would have a negligible effect on

threatened or endangered species.

REFUGE OPERATIONS, SAFETY AND PARTNERSHIP ACTIONS

Minor to negligible adverse impacts to threatened and

endangered species would occur from most Refuge

operations, including staffing, office and maintenance

facilities, and cultural resources management.

Table 15. Trail Lengths Within Preble’s Habitat

Existing Road

New Trail

TOTAL

Alternatives

0.4 mi.

0.1 mi.

0.5 mi.

0.6 mi.

0.1 mi.

0.7 mi.

B D

Mileage based on riparian and wetland vegetation types that supports

Preble’s habitat. Upland grassland habitat is not included.
Chapter 4: Environmental Consequences

180 Rocky Flats National Wildlife Refuge 

Alternatives C and D would result in the most benefits

from monitoring and adaptive management

prescriptions, due to staff available to implement

monitoring efforts. These benefits would be reduced in

Alternative B. Staffing levels in Alternative A would be

inadequate for effective monitoring and management.

Partnerships

In Alternative A, the Service would maintain a dialogue

with adjacent landowners and open space agencies.

Alternatives B, C, and D would entail annual meetings

with Refuge neighbors. These activities would benefit

threatened or endangered species populations on the

Refuge by allowing the Service to learn about

successes and failures of other landowners and

agencies in matters regarding threatened and

endangered species habitat management. This

regional dialogue also would benefit threatened and

endangered wildlife and sensitive plant species on the

Refuge by improving coordination of habitat

management across jurisdictional boundaries to

improve and expand the range of available habitat for

many species.

Fencing

The existing stock fence that surrounds the Refuge

would be maintained in all alternatives. This would

permit wildlife movement, and maintain habitat

connectivity and the exchange of genetic information

between species, including Preble’s.

CUMULATIVE IMPACTS

Mining

Future aggregate mining may directly or indirectly

affect Preble’s habitat though habitat loss, introduction

of noise and disturbance adjacent to habitat, and by

changes to the hydrology that supports riparian habitat

used by Preble’s. 

The permit for the Church Ranch Rocky Flats Pit

includes stipulations that mining will stay a minimum

of 2 feet above groundwater (CDMG 2004, Church

Ranch 2004). However, the permits for the Bluestone

Pit and the Lakewood Brick and Tile operation do not

have stipulations about groundwater. Therefore, these

operations may potentially impact habitat for the

Preble’s in the Rock Creek and Woman Creek

drainages, which are downgradient of these operations.

Urban Development

Possible residential development along the southern

boundary has the potential to impact Preble’s due to

harassment or predation by domestic cats. While such

cumulative impacts are generally unlikely, they do have

the potential to occur.

4.7. CULTURAL RESOURCES

The analysis of cultural resource effects was based on

known cultural resources present on the site and

anticipated disturbances. Effects were evaluated on a

site’s integrity of location, design, setting, materials,

workmanship, feeling, and association. Site-specific

impacts to cultural resources would be determined

during final design and layout prior to surface

disturbance. As discussed in Chapter 3, no identified

cultural resources are eligible for listing in the

National Register of Historic Places.

WILDLIFE AND HABITAT MANAGEMENT ACTIONS

Some weed management tools, such as burning and

mowing, have the potential to disturb, destroy, or

otherwise impact cultural resource sites throughout the

Refuge. Using these tools may adversely affect the

integrity of some resources.

REFUGE OPERATIONS, SAFETY AND PARTNERSHIPS

Cultural Resources

Lindsay Ranch. In Alternatives A, B and D, the

Service would stabilize the Lindsay Ranch barn and

allow other features, including the ranch house, to

Habitat restoration in the mixed grassland prairie

communities would help enhance internal views on 

the Refuge.

© Shapins Associates
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 181

deteriorate. The barn would be interpreted in

Alternatives B and D. These actions would maintain

the scenic, historical, and interpretive value of the barn.

The integrity of the ranch house and other features

would be lost over time. Alternative C would remove

all Lindsay Ranch structures. This action would affect

the integrity of the site as a historic, scenic, and

interpretive resource.

Other Resources. Construction of new trails or

facilities in all alternatives would not affect any

identified sites. Disturbance and vandalism

associated with improved public access to portions of

the Refuge may indirectly affect some resources. In

all alternatives, the Service would maintain an

inventory of other cultural resources (such as the

apple orchard) on the Refuge. None of the additional

cultural resources would be maintained or restored.

In Alternatives B and D, some of these resources

would be interpreted to the public through signage

and/or programs. Such interpretation would

mitigate the long-term effects of not maintaining

such resources.

CUMULATIVE IMPACTS

Mining

The development of private mineral rights in the

western portion of the Refuge has the potential to

impact several cultural resource sites in those areas.

Those sites, however, are not eligible for listing in the

National Register of Historic Places.

Rocky Flats Cold War Museum

The proposed establishment of the Rocky Flats Cold

War Museum near the Refuge would benefit cultural

resources associated with the site by providing a

venue to present and interpret the history of the site

as former ranchland and a nuclear weapons

production facility.

4.8. TRANSPORTATION

VISITATION/ACCESS

Visitation in Alternatives A and C would be similar to

existing visitation unrelated to site cleanup. Annual

visitation in Alternative A is estimated to be about 300

people per year and 1,000 people per year in

Alternative C, and would be limited to guided tours

(Table 16). Because of the public use component of

Alternatives B and D, visitation in these alternatives

would be considerably higher than in Alternatives A

and C. In Alternative B, annual visitation is estimated

to be 10,000 visitors in the first 3 to 5 years, increasing

to 85,000 visitors after year 5 as more public use

development occurs. Similarly, Alternative D would

have less visitation anticipated in years 1 through 3,

and would increase to 135,000 visitors after year 5. In

all alternatives, weekend visitation is expected to be

twice as much as weekday visitation (Table 16).

Vehicles per day would range from less than 1 in

Alternatives A and C to 325 on a weekend in

Alternative D (Table 16). For analysis purposes, it was

assumed all visitors in all alternatives would access the

site by vehicle. Non-motorized access would not occur

in Alternatives A and C; the proportion of nonmotorized access, such as by foot, bike, or horse, in

Alternatives B and D is not known. Vehicles per day

estimated for Alternatives B and D probably would be

lower than those shown due to non-motorized access.

Alternative B would include three parking areas: a

north trailhead parking lot with access off of Highway

128; and a central parking lot and west parking lot with

a single access off of Highway 93 at the location of the

existing Rocky Flats Environmental Technology Site

gate. Alternative D would include three more parking

areas in addition to the parking proposed with

Alternative B: a northeast trailhead parking lot with

access off of Indiana Street; a southeast trailhead

100

200

100

200

Annual

Visitation

<1

<1

<1

<1

Vehicles/

day

3,300

6,700

28,000

57,000

Annual

Visitation

12

24

102

204

Vehicles/

day

333

667

333

667

Annual

Visitation

<1

<1

<1

<1

Vehicles/

day

8,000

17,000

45,000

90,000

Annual

Visitation

30

60

162

325

Vehicles/

day

Table 16. Estimated Visitation and Associated Vehicles Per Day 

Weekday Years 1-3

Weekend Years 1-3

Weekday Years >5

Weekend Years >5

Period

Alternative A Alternative B Alternative C Alternative D
Chapter 4: Environmental Consequences

182 Rocky Flats National Wildlife Refuge 

parking lot with an access off of Indiana Street; and an

additional west parking area with a visitor center that

would use the Highway 93 access (David Evans 2003).

Effect on Highway 93

The existing access road leading into Rocky Flats

Environmental Technology Site carries about 2,700

vehicles per day. In all alternatives, this volume is

expected to decrease substantially when the site is

converted to a wildlife refuge. Alternative D, which

would place the most traffic onto Highway 93, would

include a visitor center and about 70 parking spaces on

the access road. Alternative D would result in an

estimated 422 vehicles per day using the Highway 93

access on a weekend day after year 5 (Table 17). This is

a decrease of almost 85 percent from the current daily

traffic. The Highway 93 access intersection would not

warrant signalization through 2021 in all alternatives. 

The existing deceleration and acceleration lanes would

be beneficial to the safety of the intersection if the

traffic signal is removed. The sight distance at the

intersection appears adequate for stop control on the

Highway 93 access. Traffic capacity and operations

also would be improved along Highway 93 if CDOT

removes the traffic signal (David Evans 2003).

However, the removal of the existing traffic signal

could make it difficult for visitors to exit the Refuge on

to Highway 93. Truck traffic related to ongoing mining

activities may increase the need for a traffic signal.

Effect on Highway 128

Alternative D would include a roadside overlook at an

existing pull off on the south side of Highway 128

across from an existing unimproved Boulder County

trailhead. The overlook would be improved and paved

to match the grade of Highway 128. Although the sight

distance is good at this location, it would be improved

with grading improvements. The Boulder County

trailhead may provide informal spillover parking for

the overlook. Placing pedestrian crossing warning

signs would improve safety.

Alternatives B and D would include a trailhead with

parking along Highway 128 in the vicinity of Rock

Creek. The location would provide adequate sight

distance from the horizontal curve to the west and good

sight distance to the east.

Alternative B would include a pedestrian crossing of

Highway 128 west of McCaslin Boulevard, contingent

on the establishment of connecting trails. Locating the

crossing at a signalized intersection would protect

pedestrians. Pedestrian signals and push buttons

would help crossing pedestrians (David Evans 2003).

Effect on Indiana Street

The existing access to the Rocky Flats Environmental

Technology Site from Indiana Street is not proposed

for public use in any alternative. Therefore, the

Stream crossings would be restored and many roads

revegetated.

© Shapins Associates

-

-

18

61

97

Daily

Volume

-

-

2

8

13

Peak 

Hour Volume

Table 17. Daily and Peak Hour Traffic Volume for Access and Trailheads Proposed in Alternatives B and D

Alternative B

Years 1 - 5

Years > 5

Alternative D

Years 1 - 3

Years 4 - 5

Years > 5

Scenario

S. Indiana Trailhead

-

-

6

20

32

Daily

Volume

-

-

1

3

4

Peak 

Hour Volume

N. Indiana Trailhead

-

143

18

61

97

Daily

Volume

-

19

2

8

13

Peak 

Hour Volume

SH 128 Trailhead

48

266

78

266

422

48

409

120

409

649

Daily

Volume

Daily

Volume

6

35

10

35

55

Peak 

Hour Volume

Total Site SH 93 Access
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 183

existing signal would not be warranted and would likely

be removed by CDOT. Although sight distance is poor

looking north from the access, it would be adequate for

infrequent use by Service or DOE vehicles. Reducing

the existing wide access road approach to the signal

would discourage public use for parking or turn around

maneuvers. Modifying pavement markings on Indiana

Street would eliminate the existing intersection turn

lanes. Traffic capacity and operations would be

improved along Indiana Street if CDOT removes the

traffic signal.

Alternative B would include a pedestrian crossing on

Indiana Street south of Highway 128, contingent on

the provision of connecting trails by neighboring

entities. This crossing would connect the Refuge

trail system to the future Great Western Trail in the

Broomfield Open Space east of Indiana Street. Due

to the rolling terrain along Indiana Street, the

pedestrian crossing would be located north of

Walnut Creek to maintain good visibility for

approaching vehicles.

Another pedestrian crossing on Indiana Street north of

96th Avenue would be included in Alternative B. This

crossing would connect the Refuge trail system to the

future Westminster trail system in the Westminster

Open Space east of Indiana Street. The proposed

location of the crossing south of Woman Creek in the

area of the monitoring station has good visibility for

approaching vehicles.

Alternative D would include a trailhead with parking

along Indiana Street in the vicinity of Walnut Creek.

Similar to the potential pedestrian crossing, it is

recommended that the trailhead be located north of

Walnut Creek to achieve good sight distance with the

vertical curves on Indiana Street. Alternative D would

include another trailhead with parking along Indiana

Street north of the signal at 96th Avenue. Traffic

expected to use the accesses would not require

acceleration or deceleration lanes for right turning

traffic on Indiana Street. 

The two trailhead access intersections proposed with

Alternative D would need the minimum 40-foot length,

so the total length of left turn lane required would be

540 feet at each access. Due to the limited distance to

the 96th Avenue signal, the left turn lane at the

southern trailhead access would be coordinated with the

existing left turn lane at the 96th Avenue intersection.

If the roadway improvements at the Indiana Street

trailhead accesses require replacement of the drainage

structures located near the trailheads, the Service

would consult with CDOT to determine if an expanded

underpass structure would be needed to accommodate

both drainage and pedestrian/bicyclists. This would

remove crossing pedestrians and bicyclists from the

vehicular travel lanes and lower the possibility of

pedestrian/vehicle conflicts (David Evans 2003).

CUMULATIVE IMPACTS

A discussion about the general effects of any

transportation improvements to the roads and

highways surrounding the Refuge is included in

Section 4.16.

Urban Development

Urban development south and east of the Refuge

would likely increase traffic on the roads and highways

that surround the Refuge. Traffic associated with the

Refuge and urban development would contribute to the

overall traffic.

4.9. OPEN SPACE, RECREATION AND TRAILS

Refuge establishment would make a significant

contribution to a nearly contiguous block of open space

in northern Jefferson County and southern Boulder

County. In all alternatives, the protection of the site

from development would help conserve the

interconnected natural resources of the Rocky Flats

area for the long term. This section provides an

analysis of the regional consequences or benefits of the

proposed alternatives, and how they would affect

resources on the Refuge and on adjacent open space

lands and trails.

WILDLIFE AND HABITAT MANAGEMENT ACTIONS

Preble’s Habitat Management

Successful protection and enhancement of riparian

habitat on the Refuge would benefit wildlife species on

adjacent open space lands. Protection of riparian

habitat also would provide a potential source of

Preble’s for downstream areas on Rock Creek, and

open space to the east (Standley Lake). Recreational

users would benefit from riparian area management by

maintaining vegetation and scenic diversity.

Xeric Tallgrass Management

Several adjacent open space areas support xeric

tallgrass habitat that is similar to the habitat at

Rocky Flats. In all alternatives, the Service would

develop a vegetation management plan and work

with adjacent open space agencies towards regional
Chapter 4: Environmental Consequences

184 Rocky Flats National Wildlife Refuge 

xeric tallgrass conservation. This management

planning and collaboration would benefit both the

Service and nearby open space management

agencies in their management and restoration of the

xeric tallgrass community.

Weed Management

In general, on-going weed management efforts in all

alternatives would benefit adjacent open space lands.

In Alternative A, the Service would focus weed

management and reduction efforts in the Rock Creek

Reserve. Efforts outside of Rock Creek Reserve

would be limited to containing existing weed

infestations. Adjacent open space lands would be

adversely affected if weeds are not adequately

contained in Alternative A. The proposed reduction of

weed infestations in Alternatives B, C, and D would

benefit adjacent open space lands by reducing the

spread of weeds onto adjacent lands and by providing

a source of information for regional weed

management strategies.

Deer and Elk Management

In all alternatives, developing a target population for

the Refuge and managing that population would benefit

adjacent open space areas by reducing the potential

effects of overgrazing or overbrowsing on adjacent open

space areas. Alternatives B, C and D would include

extensive monitoring of deer and elk populations, deer

and elk habitat impacts, and fawning rates and survival

in Alternative C. This monitoring would provide longterm benefits to adjacent open space managers by

providing a growing base of scientific information that

would be used in developing wildlife and habitat

management strategies in other areas.

Prairie Dog Management

The Refuge has the potential to support many more

prairie dog colonies and individuals than currently

occupy the site. A healthy prairie dog population on the

Refuge would provide a genetic base for the region if

populations on nearby open space lands were eliminated

due to plague, predation, or other reasons. In

Alternative D, the Service would consider accepting

unwanted prairie dogs onto the Refuge from off-Refuge

locations. If deemed appropriate, relocations from offsite would benefit nearby open space managers by

providing a non-lethal option for prairie dog removal.

Species Reintroduction

Species reintroduction would benefit wildlife diversity

on open space lands throughout the area. Any

expansion of wildlife populations also would provide a

long-term benefit to adjacent open space, and

recreational opportunity by improving wildlife

viewing opportunities.

PUBLIC USE, EDUCATION AND INTERPRETATION ACTIONS

Public Use

Recreation Opportunities. The wildlife-dependent

public use programs proposed in Alternatives B and D

would enhance the availability and diversity of outdoor

recreation opportunities in the Rocky Flats area.

These programs, including environmental education,

interpretation, wildlife observation, and trail use, would

complement recreational opportunities on nearby open

space lands.

The guided tours and interpretive programs in

Alternative C would also complement other outdoor

recreation and learning opportunities in the Rocky

Flats area. However, these opportunities at the Refuge

would be limited to 1,000 visitors per year. In

Alternative A, visitation would be limited to 300 visitors

per year and recreational opportunities would be

significantly less than in the other three alternatives.

The multi-use trails that are planned for Alternatives B

and D could result in user conflicts between hikers and

bikers in the northern portion of the Refuge, and

hikers, bikers and equestrian users in the southern

portion of the Refuge. Due to the size of the Refuge,

the length of multi-use trails, and the open sight lines

that characterize trails in a predominantly prairie

landscape, user conflicts are anticipated to be rare, and

their effect on the overall trail experience are

anticipated to be minor. Conflicts among trail users

can be reduced and mitigated by education,

appropriate signage, and where necessary, law

enforcement activities.

Equestrian use on the multi-use trails in the southern

portion of the Refuge could potentially impact trail

aesthetics from the accumulation of horse manure on

trails. Concentrations of horse manure on trails could

result in a minor impact on trail use and the

experiences of other trail users. Removal of horse

manure by volunteers, as stipulated in the

Compatibility Determination for Multi-Use Trails

(Appendix B), would mitigate these impacts.

Wildlife Displacement. Increased human presence,

visitor use, and hunting in the Rocky Flats buffer zone

in Alternatives B and D have the potential to displace

some wildlife species, especially mule deer, and could
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 185

cause them to migrate onto adjacent open space lands.

Wildlife displacement onto adjacent lands could

decrease wildlife viewing opportunities on the Refuge,

and could facilitate the spread of CWD to the deer

population on the Refuge. Wildlife displacement,

however, may benefit adjacent open space areas by

increasing their native wildlife diversity and

opportunities for wildlife viewing, depending on visitor

use and habitat conditions on those lands.

Recreation Facilities

Trail Development. Recreational trails exist or are

planned on open space parcels to the south, east, and

north of Rocky Flats. A segment of the regional Front

Range Trail is conceptually planned for the Highway 93

corridor on the west side of the Refuge. In Alternatives

A and C, which would not have publicly accessible trails,

Rocky Flats would continue to be a barrier to regional

open space trail connections. In Alternatives B and D,

the trail system at Rocky Flats would provide regional

connections between Broomfield, Westminster, and

Arvada trails, as well as the proposed Front Range

Trail. These alternatives would not provide a direct

connection to the City of Boulder or Boulder County’s

trails to the northwest, and would not provide

connections for trail users with dogs. Alternative B

would provide less trail connectivity for equestrians

than Alternative D because it would not allow horse use

on the northern multi-use trails that connect to

Broomfield and Superior.

Trailhead Facilities. In addition to trail connections

from adjacent open space areas, access to the trails and

other wildlife observation facilities at the Refuge would

be provided from the main entrance on Highway 93,

and trailhead facilities on the periphery. Alternative B

would provide a single peripheral trailhead along

Highway 128, while Alternative D would provide

additional trailhead facilities along Indiana Street.

These facilities would benefit public access to the

Refuge. However, the proposed parking and trailhead

location along the north edge of the Refuge has the

potential to impact nearby open space resources due to

trespass to the north across Highway 128.

Refuge Operations, Safety, and Partnerships

Partnerships

Regional Coordination. In Alternative A, the Service

would maintain dialogue with adjacent landowners and

open space management agencies, while in Alternatives

B, C and D, the Service would meet annually with

adjacent open space managers. These efforts would

benefit both the Refuge and surrounding open space

by improving collaboration and coordination in

resource and visitor use management plans, strategies

and techniques.

Research. Alternatives B, C and D would support

research related to wildlife, habitat and public use.

Over the long term, this research would benefit

nearby open space managers by providing an

expanded foundation of scientific knowledge on 

which they can base resource and public use

management decisions.

CUMULATIVE IMPACTS

Trails

The cities of Arvada, Westminster, and Broomfield

have future trails planned that can connect to the

Refuge and to each other. The Refuge trail systems

proposed in Alternatives B and D would contribute to

this enhanced network of regional open space trails.

In Alternatives A and C, which would not have

publicly accessible trails, Rocky Flats would remain a

barrier to regional open space trail connections. 

4.10. VISUAL RESOURCES

Visual resources on the Refuge generally comprise

views from surrounding areas, views from Rocky

Flats to surrounding landmarks, and internal views.

This section evaluates the impacts of the CCP

alternatives on these resources. Given the qualitative

nature of visual resources, the descriptions of the

effects in this section attempt to account for

differences in visual preferences.

WILDLIFE AND HABITAT MANAGEMENT ACTIONS

Xeric Tallgrass Management

Habitat Maintenance and Enhancement. In all

alternatives, the Service would focus weed

management and habitat restoration tools to maintain

and enhance the xeric tallgrass communities.

Alternative A would focus these efforts on xeric

tallgrass habitat within the Rock Creek Reserve.

Successful maintenance and restoration of the xeric

tallgrass community would likely result in a taller, more

robust grassland that would benefit the quality and

diversity of views within the Refuge.

Prescribed Fire. Smoke associated with prescribed fire

in all alternatives except D would result in short-term

visual impacts. Such impacts would include impaired

views of the Rocky Flats/mountain backdrop area from
Chapter 4: Environmental Consequences

186 Rocky Flats National Wildlife Refuge 

surrounding communities, and obscured views within

the Refuge during fires. Blackened stubble that

would likely follow fires would be a short-term visual

impact. However, successful ecological restoration in

these areas would benefit the visual quality and

diversity in the long term.

Grazing. From the perspective of Refuge visitors

(internal views), the use of grazing as a grassland

management tool may result in short-term visual

impacts to some areas due to manure, trampling, and

dust. Some may consider the pastoral view of

livestock grazing on Rocky Flats grasslands to be a

benefit to internal visual resources. Livestock

grazing would not be visible from surrounding

communities and would not affect views from off

Refuge.

Mixed Grassland Prairie Management

In Alternatives B and C, the 300-acre hay meadow in

the southeast corner of the Refuge would be restored

to native prairie. During the restoration process, the

removal of non-native grasses and the establishment of

native grasses would result in short-term visual

impacts to the area, which would be bare, patchy, or

weedy for several years. These impacts would affect

internal views and distant views from the Refuge

looking southeast, where the hay meadow provides a

vegetated foreground to panoramic views. However,

successful prairie restoration in this area would benefit

the visual quality and diversity in the long term. 

Road Restoration and Revegetation

In all alternatives, some roads and stream crossings

would be removed and revegetated. Once completed,

the revegetation efforts would benefit views on the

Refuge and views from within the Refuge by 

creating larger patches of undisturbed grasslands 

and shrublands. 

Deer and Elk Management

In all alternatives, the Service would monitor deer and

elk browsing in riparian and upland shrub areas

throughout the Refuge. This monitoring, and

subsequent actions to prevent overbrowsing, may

indirectly benefit internal visual quality in some

riparian areas by facilitating healthy, robust vegetation.

Prairie Dog Management

In all alternatives, prairie dogs would be allowed to

naturally expand within their habitat areas. To some,

prairie dog colonies add to the natural diversity of the

prairie landscape; to others, they are an eyesore.

Depending on their location and arrangement,

expanded prairie dog colonies may impact the visual

quality of Rocky Flats grasslands as they pertain to

internal views and as a foreground for distant views

toward the east. These impacts would be the most

pronounced in Alternatives A (unlimited expansion)

and D (where prairie dogs may expand to 1,000 acres)

and less pronounced in Alternatives B and C (750 and

500 acres, respectively).

PUBLIC USE, EDUCATION AND INTERPRETATION ACTIONS

Public Use Facilities

Public use facilities, such as trails, parking lots,

restrooms, kiosks, viewing blinds and overlooks,

would be constructed in Alternatives B, C, and D.

These facilities would be designed and located to

minimize their visual impact both within the Refuge

and from outside of its boundaries. Most of these

facilities, however, would be visible from surrounding

roads. The extent of the visual impact of these

facilities would be proportional to their quantity,

ranging from negligible in Alternative C to minor in

Alternatives A, B and D.

CUMULATIVE IMPACTS

Urban Development

The planned Vauxmont development, as described in

the Reasonably Foreseeable Activities section in

Chapter 2, will be south of the Refuge boundary. This

development will change the visual character of the

Rocky Flats area, and may result in long-term impacts

to the quality of views of the Refuge and the mountain

backdrop from nearby communities. This

development may also affect views from the Refuge to

Views from Rocky Flats to downtown Denver.

© Mauro
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 187

the south from overlooks and trails. Refuge facilities

and management would not contribute to the visual

impacts of adjacent development. Any development

adjacent to the Refuge could impact visual resources

by increasing the number of lights in the area during

the evening and night.

The development of private lands to the west would

have a similar effect, and would further interrupt

mountain views from the visitor contact station and

other facilities in the western part of the Refuge.

Mining

Existing mined areas on the western edge of the

Refuge have the potential to expand onto the Refuge in

other permitted areas. If the permitted areas were

mined, the visual quality of the western edge of the

Refuge would be affected by aggregate mining

operations. Visual resources on the Refuge would be

affected, including views of the mountain backdrop

from the Refuge, and internal views in the western

portion of the Refuge. While expanded mining

operations may be visible from surrounding

communities, the impact on distant views of the Refuge

would be less substantial than more local views from

the Refuge.

Wind Technology Center

Located adjacent to the Refuge to the northwest, the

National Wind Technology Center operates tall wind

turbines for research on wind power generation. From

many areas on the Refuge, these turbines interrupt the

views of the mountain backdrop and Eldorado Canyon.

To some visitors, however, the turbines may be a visual

attraction in itself that adds to the character of the

Rocky Flats area.

DOE Monitoring and Maintenance

The Service has recommended to the RFCA parties

that DOE construct a four-strand barbed-wire stock

fence around the DOE retained area to demarcate the

boundary between the Refuge and DOE retained lands

(Appendix E). Such a fence would only be visible from

close distances, would be consistent with the character

of the western landscape, and would not detract from

the visual aesthetics of the Refuge.

Future aggregate mining may impact wildlife habitat.

© USFWS
Chapter 4: Environmental Consequences

188 Rocky Flats National Wildlife Refuge 

4.11. NOISE

WILDLIFE AND HABITAT MANAGEMENT ACTIONS

In all alternatives, the Service and/or CDOW may use

culling to manage deer and elk populations. Hunting

rifles may be used for culling, resulting in occasional

gunshots that may be audible on and off Refuge.

Infrequent gunshots during deer and elk culling would

result in a minor increase in noise levels within and

around the Refuge.

Public hunting programs in Alternatives B and D

would allow the use of shotguns. Gunshots associated

with the use of such weapons may be audible from onand off-Refuge, depending on hunter location, wind,

and topography. Public hunting on the Refuge would

result in short-term minor increase in noise levels in

some areas of the Refuge. However, areas in the

Refuge used for hunting would be closed to other

visitors during hunting periods, and it is unlikely that

noise from gunshots would adversely affect

surrounding communities. Noise levels would return

to existing levels after hunting ceases.

The removal and revegetation of roads and stream

crossings in all alternatives would require the use of

heavy equipment to regrade some areas. This

equipment would result in a short-term minor increase

in noise levels in the immediate vicinity of the

restoration activities. Noise levels would return to

existing levels after construction ceases.

PUBLIC USE, EDUCATION AND INTERPRETATION ACTIONS

Recreation Facilities

Construction of trails, overlooks, parking lots and other

visitor use facilities would require the use of heavy

equipment for site excavation and grading. This

equipment would produce higher, short-term noise

levels in the immediate vicinity of the construction

activities. Noise levels would return to existing levels

after construction ceases.

CUMULATIVE IMPACTS

Urban Development

Construction of the proposed Vauxmont development

to the south of Rocky Flats will require the use of

heavy equipment for site excavation and grading. This

equipment will produce higher, short-term noise levels

in the immediate vicinity of the construction activities

and may add to the cumulative noise levels on the

Refuge. Noise levels would be reduced after

construction ceases, but would would not likely return

to existing levels after the development is occupied.

Mining

Ongoing surface mining in the western portions of

the Refuge would adversely impact wildlife and

public use in areas that are in close proximity to 

the mining operations. 

4.12. AIR QUALITY

DUST AND EMISSIONS

Implementation of all alternatives would result in

varying levels of equipment usage. Construction of

public use facilities, habitat restoration activities, and

on-going Refuge management would likely require the

use of motorized equipment, which would result in

localized carbon monoxide and hydrocarbon emissions.

Construction activities also would create fugitive dust.

Impacts of equipment usage on the Refuge would have

a negligible effect on air quality in the Rocky Flats

region, and would be mitigated by best management

practices. Increased emissions and dust would cease

after construction is completed.

Public access to the Refuge would occur in all

alternatives, with Alternative D having the highest Sparrow

© Mauro
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 189

public use and Alternatives A and C having the lowest.

Some visitors would access the Refuge using

automobiles. Auto emissions would be higher in

Alternative D and lower in Alternatives A and C. 

Prescribed Fire

Prescribed fire has been identified as a grassland

management tool in all alternatives except D. This

prescription would apply to lands managed by the

Service and not lands retained by the DOE.

Prescribed fires would be subject to approved plans,

and factors such as weather conditions, fuel conditions,

adequate firebreaks, and the preparedness of fire

management and emergency response crews.

Prescribed fire would be conducted in accordance with

approved vegetation management plans, and an

approved Fire Management Plan. These step-down

plans would be developed with the involvement of the

public and nearby communities. Any prescribed fire

would be conducted in accordance with Service policy,

and would adhere to state air quality regulations.

The periodic use of fire may result in short-term

increases in particulates and decreased visibility in

nearby areas. The amount of smoke and particulates

generated by a prescribed fire would depend on

variables such as wind, soil and vegetation moisture,

and fire intensity.

In response to concerns about residual contamination

outside of the DOE retained area, the EPA and the

CDPHE believe the use of fire is an appropriate

management tool on Refuge lands (Appendix D).

Section 1.8 includes a discussion of issues related to

contamination. In accordance with Service and DOE

policies, any naturally occurring or human-caused

wildfires on the Rocky Flats site, regardless of whether

they are on Refuge lands or DOE-retained areas,

would be aggressively suppressed.

CUMULATIVE IMPACTS

Urban Development

Urban development south or west of the Refuge 

would likely require the use of motorized equipment,

which would result in localized carbon monoxide and

hydrocarbon emissions. Construction activities also

create fugitive dust. Cumulatively, construction

activities on- and off-Refuge are not expected to

adversely affect regional air quality. Increased

emissions and dust will cease after construction 

is completed.

Mining

Continued mining adjacent to the Refuge will likely

increase dust blowing across the Refuge. Rocky Flats

is a very windy location, and best management

practices to reduce the amount of dust generated will

not be able to be totally effective.

The accumulation of windblown sand onto the Refuge

has been a problem in the past, because it facilitates

the establishment of noxious weeds in the native

grassland communities. The Service would work with

mining operators and the appropriate regulatory

agencies to minimize and mitigate the effects of

windblown soil deposition on the Refuge.

4.13. SOCIOECONOMICS

EMPLOYMENT, INCOME, AND HOUSING

Staffing levels at the Refuge would range between two

full-time employees in Alternative A to eight employees

in Alternative D. Annual staffing income is estimated

to range from $77,000 in Alternative A to $468,000 in

Alternative D. Additional temporary employment as

well as indirect employment may be generated during

construction of Refuge facilities. These anticipated

staffing levels would have a negligible effect on local

employment, income, or housing conditions in the

communities surrounding Rocky Flats, or in the

Denver metropolitan region.

Community

Over the long term, the establishment and successful

management of Rocky Flats as a National Wildlife

Refuge may alter the public perception of the site.

While current public perception is dominated by its

history as a former nuclear weapons facility with

contamination issues, future perceptions may associate

the site with wildlife habitat and protected open space.

Such a change would benefit Rocky Flats and the

surrounding communities. Rocky Flats serves as both

a gateway and a backdrop to several surrounding

communities, including Boulder, Arvada, Superior, and

Broomfield. The open, rural visual character of all

alternatives would benefit these communities. 

Environmental Justice

Rocky Flats is not located in an area predominated by

minority and low-income populations. None of the

alternatives would result in disproportionately high and

adverse human health or environmental effects on a

minority population, low-income population, or Native

American tribe.
Chapter 4: Environmental Consequences

190 Rocky Flats National Wildlife Refuge 

CUMULATIVE IMPACTS

Urban Development

Construction of the Vauxmont development south of

the Refuge along with the Refuge development may

benefit economic and employment conditions in Arvada

as well as other nearby communities. While Refuge

establishment may make development of adjacent

lands more attractive, it would not cumulatively affect

any land use, employment or income conditions outside

of the Refuge.

4.14. WILDERNESS REVIEW

A wilderness review is the process used by the Service

to determine whether to recommend lands or waters in

the NWRS to Congress for designation as wilderness.

The Service is required to conduct a wilderness review

for each refuge as part of the CCP process. Land or

waters that meet the minimum criteria for wilderness

are identified in a CCP and further evaluated to

determine whether they merit recommendation for

inclusion in the Wilderness System. According to

Section 13 of the Service’s Director’s Order No. 125

(July 2000), in order for a refuge to be considered for

wilderness designation, all or part of the refuge must:

• Be affected primarily by the forces of nature,

with the human imprint substantially

unnoticeable

• Have outstanding opportunities for solitude or

primitive and unconfined type of recreation

• Have at least 5,000 contiguous acres or be

sufficient in size to make practical its

preservation and use in an unimpaired

condition, or be capable of restoration to

wilderness character through appropriate

management, at the time of review

• Be a roadless island

Rocky Flats NWR does not meet the above criteria

and is not recommended for inclusion in the Wilderness

System. The Refuge has considerable evidence of past

human use, does not have outstanding opportunities for

solitude or unconfined recreation, and is not roadless.

4.15. FENCING CONSIDERATIONS

The Refuge Act (Appendix A) directs the Service to

consider “the characteristics and configuration of any

perimeter fencing that may be appropriate or

compatible for cleanup and closure purposes, refuge

purposes, or other purposes.” Fencing options that

were considered during the planning process include:

• Chain-link security fence

• Barbed-wire stock fence (existing)

After consideration of the two fencing options, the

maintenance of the existing stock fence was retained

for all alternatives, as described in Objective 6.3 -

Fencing. The chain-link security fence was not

recommended because of the cost and ecological

impacts (discussed below) and because it would not be

consistent with the Refuge purpose and goals.

Fencing Costs

The estimated cost of installing a 6-foot chain-link

security fence around the perimeter of the Refuge (a

distance of about 13.5 miles) is about $4 million. A

barbed-wire stock fence, which is currently in place,

would have no installation costs. Costs of materials

needed to maintain a chainlink fence would be

approximately $ 7.50 per linear foot while barbed wire

fencing materials would be only $ 0.17 per linear foot.

Fence maintenance costs would be included in the

Refuge operations budget. 

Fencing Impacts

Wildlife

A chain-link security fence would result in major,

long-term impacts to the movement of wildlife

between the Refuge and surrounding areas. The

fence would directly impact several mammal species

such as deer, elk, fox, and coyote, while it may

indirectly impact many other species due to changes

in predator/prey relationships and habitat conditions.

Such a fence may be an annoyance to prairie dogs, but

would not likely create a barrier to movement for

Preble’s, prairie dogs, or bald eagles. The existing

barbed-wire boundary fence would have negligible

impacts to the movement of wildlife species, and

habitat connectivity. 

Visual Resources

A chain-link boundary fence would be visible from

within the Refuge and from neighboring areas,

changing the character of the Refuge from rural to

semi-industrial. This change in the visual character of

the Refuge and its surroundings would have a longterm major impact on visual resources in the

immediate Rocky Flats area. However, this change

would not be discernable from greater distances and

would have a negligible impact on views of the

mountain backdrop from surrounding communities.
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 191

The existing barbed-wire stock fence would maintain

the rural character of the Refuge, would not be visible

from most areas, and would not impact views of or

from the Refuge.

4.16. POSSIBLE TRANSPORTATION

IMPROVEMENTS NEAR THE REFUGE

The Refuge Act directs the Service to address and

make recommendations on the land to be made

available along Indiana Street for transportation

improvements. This section addresses the Service's

concerns and recommendations related to

transportation improvements to any of the road

corridors adjacent to or near the Refuge: Indiana

Street, State Highway 128, and State Highway 93.

While a definitive analysis of the direct impacts of

potential transportation improvements is outside the

scope of this CCP/EIS, this section includes potential

indirect impacts to the Refuge, as well as

recommendations that could minimize or mitigate the

effects of transportation improvements surrounding

the Refuge. Additional information about the

Northwest Corridor Transportation Study EIS, or

any other plans that address transportation

improvements near Rocky Flats can be obtained from

the Colorado Department of Transportation.

LANDS WITHIN 300 FEET OF INDIANA STREET

The Refuge Act’s §3174 prohibits the construction of a

public road through the Refuge. However, the DOE

can make available land along the eastern boundary of

the Refuge for the sole purpose of transportation

improvements along Indiana Street. Land made

available under §3174 may not extend more than 300

feet from the west edge of the existing Indiana Street

right of way. To be made available, DOE must receive

an application submitted by a county, city, or other

political subdivision of the State of Colorado that

includes documentation demonstrating that the

transportation improvements for which the land is to

be made available:

• Are carried out so as to minimize adverse effects

on the management of the Refuge as a wildlife

refuge

• Are included in the regional transportation plan of

the metropolitan planning organization

designated for the Denver Metropolitan area

The Refuge Act requires that the CCP address and

make recommendations on the land to be made

available. Three possible alternative widths, 50 feet,

125 feet and 300 feet, are analyzed. A range of widths

is analyzed to provide information to the Service and

the DOE regarding lands that could be made

available. The DOE will be responsible for

determining the width of any transferred lands, but it

is likely the width would range between 50 and 300

feet. The transfer of a 50-foot right of way would

make the right of way along Indiana Street 100 feet

wide, wide enough for a four-lane, undivided road.

Similarly, the transfer of a 100-foot right of way would

make the right of way along Indiana Street 200 feet

wide. A 100-foot or 200-foot wide right of way would

not be wide enough for a four-lane, divided highway.

Typical right of way widths for a four-lane, divided

highway are 300 to 400 feet. The transfer of a 300-

foot right of way would make the right of way along

Indiana Street 350 feet wide, wide enough for a fourlane, divided highway. The transfer would be

designed to help meet regional transportation needs.

The amount of land that could be transferred is

directly proportional to the possible width; a 300-foot

width would transfer about 99 acres (Table 18). A 50-

foot width would transfer about 16 acres. The intent

of the analysis in Table 18 is to quantify the amount of

each resource within each right of way width that has

the potential to be impacted by transportation

improvements. Some resources require qualitative

descriptions. The analysis assumes the transfer of a

given width along the entire eastern boundary of the

Refuge. In all cases, the lands that could be

transferred would be primarily mixed grasslands.

Any wetlands directly or indirectly affected by

transportation improvements along Indiana Street

would require mitigation in accordance with CDOT

policy. The Service would review any wetland

mitigation plans. Similarly, the Service would consult

on any improvement that may affect a threatened or

endangered species, such as the Preble’s mouse.

Based on this analysis, and the need for future

coordination and consultation associated with any

transportation improvement along Indiana Street, the

Service finds that transfer of a corridor up to 300 feet

wide would not adversely affect the management of

the Refuge.

POTENTIAL IMPACTS FROM TRANSPORTATION

IMPROVEMENTS

The following discussion briefly describes impacts that

may result from any transportation improvement

adjacent to or near the Refuge boundaries. It also

includes recommended measures that can minimize or

help mitigate the effects of the potential impacts. Such
Chapter 4: Environmental Consequences

192 Rocky Flats National Wildlife Refuge 

mitigation is typically included for any proposed road

improvements along the Front Range. This analysis

was not completed in response to any particular plans

or proposals, but is instead intended to characterize

the types of impacts that could result from

transportation improvements around the Refuge.

As discussed previously, a detailed analysis of any

specific type of transportation improvement along

Indiana Street, such as construction of a four-lane

divided highway, is outside the scope of this CCP/EIS.

The reader is referred to CDOT for more information

about its Northwest Corridor Transportation Study.

Segments of roadway that were considered for

potential impacts include Indiana Street along the

east boundary of the Refuge, State Highway 128

along the north boundary of the Refuge, and State

Highway 93, which runs parallel to the west boundary

of the Refuge, 1⁄4 mile to the west.

Water Quality

Additional runoff from Highway 128 and Highway 93

has the potential to impact water quality on the

Refuge due to increased storm water runoff. These

impacts could be reduced or mitigated through the

use of best management practices to minimize

discharges and erosion, and dissipate storm flows

before they are conveyed to area creeks.

Noxious Weeds

Construction along any of the roadway corridors has

the potential to exacerbate existing problems with

noxious weeds at Rocky Flats, which could further

impact native plant communities and wildlife habitat

throughout the Refuge. This is especially the case

along Highway 93 because it is generally upwind of

the Refuge. Noxious weed impacts could be reduced

by designing construction to minimize ground

Possible Transferred Width Resource 50 feet 125 feet 300 feet 

Area (acres) 16.4 41.0 98.7 

Soils Loss of soil productivity of paved area 

Water Resources 

(length of streams/ditches - feet) 705 2,218 5,133 

Vegetation (acres)

Wetlands 

Mesic mixed grassland 

Reclaimed mixed grassland 

Riparian shrubland/woodland 

Xeric tallgrass grassland 

Xeric needle and thread grassland 

Other 

0.6 

10.6 

2.7 

0.1 

0.6 

1.5 

0.3 

1.5 

25.9 

7.0 

0.3 

1.9 

3.8 

0.6 

3.5 

61.0 

17.5 

0.7 

4.0 

9.2 

2.8 

Wildlife 

No direct impacts to mule deer concentration areas or known raptor nest 

sites. General impacts to overall wildlife habitat, potential raptor nesting 

habitat, and movement corridors would occur. 

Prairie dog suitable habitat (acres)

Prairie dog active colony (acres)

12.7 

< 0.1 

31.9 

0.4 

76.6 

1.9 

Threatened, Endangered, and Candidate Species 

Preble’s habitat (acres) 0.9 2.8 8.5 

Cultural Resources 

(number of sites) 1 1 1 

Public Use/Recreation 

(Alternatives B/D) 

Trails (feet)

Trail connections 

Parking Areas 

Trailhead/Restroom 

1,300/6,000 

2/2 

1/2 

0/1 

1,500/6,200 

2/2 

1/2 

0/1 

2,000/6,600 

2/2 

1/2 

0/1 

Visual Easterly views from portions of the Refuge may be affected, depending 

on road grade and viewer location 

Noise Increased noise levels may affect wildlife use and visitor use in portions 

of the Refuge 

Air Quality May affect air quality in the eastern portion of the Refuge from increased 

concentrations of gaseous pollutants 

Table 18. Potential Resource Impacts Within Various Right-of-Way Widths
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 193

disturbance, developing and implementing a noxious

weed management plan prior to and during

construction, and monitoring and controlling noxious

weeds during and after construction.

Wildlife Corridors

Indiana Street can be a barrier to wildlife movement

between the Refuge and the open space lands to the

east during high traffic periods. A variety of

terrestrial wildlife species, including mule deer,

periodically cross between Rocky Flats and open

space lands to the east. A larger and/or faster

roadway along Indiana Street would increase the

barrier effect for wildlife.

During high traffic periods, Highway 128 is a barrier

to the movement of a variety of wildlife species,

including mule deer, elk, prairie dogs, and other

terrestrial species between the Refuge and open

space lands to the north. The culvert at the Rock

Creek crossing is too small to provide safe passage for

many species. Likewise, Highway 93 to the west of

the Refuge cuts across a broad plain that is a major

movement corridor between the Refuge and the Front

Range foothills and open space lands to the west for a

variety of wildlife species, including mule deer and

elk. A larger and/or faster roadway along Highways

128 or 93 could contribute to wildlife corridor impacts.

In general, impacts to wildlife corridors to and from

the Refuge could be minimized or mitigated with the

following measures:

• Install below-grade wildlife crossings where

necessary to facilitate the movement of

wildlife under the roadway

• Locate crossings at stream corridors and in select

upland locations

• Create designated wildlife corridors;

minimize shared wildlife crossings and trail

crossings

• Construct fencing, as appropriate, to prevent

wildlife from crossing roadways and encourage

the use of constructed crossings

In the case of Indiana Street, the Service does not

want to encourage the movement of deer and elk

between the Refuge and the open space lands to the

east because of the potential for impacts to nearby

subdivisions, and efforts to discourage the

establishment of a resident elk herd in the grasslands

around Rocky Flats. For these reasons, the design of

any transportation improvements along the Indiana

Street corridor could include crossings that facilitate

the movement of smaller species (such as small

mammals and reptiles) while prohibiting the

movement of deer and elk. Crossings should be

located at Woman Creek and Walnut Creek, as well as

select upland locations.

If Highway 128 is widened, the Service recommends

that the small culvert at Rock Creek be removed and

replaced with a roadway design that facilitates the

movement of wildlife (including deer and elk) between

the Refuge and the open space lands to the north. The

Service recommends that roadway designs along

Highway 93 include wildlife crossings at several

locations to facilitate the movement of wildlife between

the Refuge and the open space lands to the west.

Noise and Aesthetics

Increased noise along any of the adjacent corridors

could displace or alter the behavior and productivity

of some wildlife species on the Refuge. Many species

depend on sound to communicate, avoid danger and

locate food. Studies have found that noise can impact

reproduction, productivity, behavior and energy

expenditure in wildlife (Bowles 1995). This is

especially true in the case of Highway 128, which

crosses through the Rock Creek drainage, one of the

most important wildlife habitat areas on the Refuge.

Increased traffic volume and/or speeds may impact

wildlife species sensitive to noise. Lighting equipment

and increased light along the roadway could adversely

affect some wildlife species. Artificial light can

disrupt bird behavior, affect migration, increase bird

collisions with structures, and increase risk of

predation (IDA 2002).

Impacts to the Refuge could be reduced by

incorporating berms, sound walls, vegetation, or other

noise-reducing techniques into the design of

transportation improvements to reduce the impacts of

traffic noise on wildlife and Refuge visitors. Roadway

lighting could be designed to reduce light emission

and be positioned to minimize effects to wildlife and

Refuge aesthetics.

Public Use Facilities

The northern trailhead and overlook proposed in

Alternatives B and D would be located adjacent to

Highway 128. Roadway improvements could affect

the use and safe access to these facilities. The

northern multi-use trail proposed in Alternative B

would parallel the south side of Highway 128 for

about 1.5 miles in the northeastern part of the Refuge.

In addition, a short section of the proposed Rock
Chapter 4: Environmental Consequences

194 Rocky Flats National Wildlife Refuge 

Creek hiking trail would be in close proximity to the

highway. Improvements to the highway could result

in visual and noise impacts to trail users.

Improvements along Indiana could impact parking

areas, trails, and trail connections on the Refuge. A

larger and/or faster roadway along Highway 93 could

hinder the safe access to the Refuge for visitors and

staff.

Impacts to public use facilities can be reduced by

relocating trails, trailheads, and other facilities to

complement both the transportation improvements

and Refuge operations, and by designing the roadway

improvements to provide safe and reasonable access to

the Refuge entrance, trailheads, and trail connections. 

4.17. ADHERENCE TO PLANNING GOALS

Goal 1. Wildlife and Habitat Management

Conserve, restore, and sustain biological diversity of

the native flora and fauna of the mountain/prairie

interface with particular consideration given to

threatened and endangered species.

While basic resource management would occur Refugewide under Alternative A, it would not be sufficient to

satisfy this goal. However, the resource management

activities for the Rock Creek Reserve (as directed by

the 2001 Rock Creek Reserve Integrated Natural

Resources Management Plan) would satisfy Goal 1. 

Alternatives B, C, and D would satisfy Goal 1. The

habitat restoration and resource management

programs in all of these alternative are sufficient,

although they would be the strongest in Alternative C,

followed by B and D.

Goal 2. Public Use, Education, and Interpretation

Provide visitors and students high quality

recreational, educational, and interpretive

opportunities and foster and understanding and

appreciation of the Refuge’s xeric tallgrass prairie,

upland shrub, and wetland habitats; native wildlife;

the history of the site; and the NWRS.

While limited guided tours and interpretation would

occur in Alternatives A and C, these programs would

not be sufficient to satisfy Goal 2. Alternatives B and

D both satisfy this goal, with the programs in D having

the strongest adherence to the goal.

Goal 3. Safety

Conduct operations and manage public access in

accordance with the final Rocky Flats cleanup

decision documents to ensure the safety of the Refuge

visitors, staff, and neighbors.

All alternatives would ensure the safety of visitors,

staff, and neighbors, and would satisfy Goal 3.

Goal 4. Effective and Open Communication

Conduct communication outreach efforts to raise

public awareness about Refuge programs,

management decisions, and the mission of the U.S.

Fish and Wildlife Service and the NWRS among

visitors, students, and nearby residents.

Outreach efforts in Alternative A would be minimal,

and would only partially satisfy Goal 4. Efforts in

Alternatives B and D would be much more extensive

and would satisfy this goal. Outreach efforts in

Alternative C would be similar, but would not reach

many visitors.

GOAL A B C D

1. Wildlife and Habitat Management

2. Public Use, Education and Interpretation

3. Safety

4. Effective and Open Communication

5. Working with Others

6. Refuge Operations

z = The alternative satisfies the goal.

 = The alternative partially satisfies the goal.

 = The alternative does not satisfy the goal.

A L T E R N A T I V E S

z

z

z

z

z

z





z







z



z



z

z

z

z

z

z

z

z

Table 19. Adherence to Planning Goals
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 195

Goal 5. Working with Others

Foster beneficial partnerships with individuals,

government agencies and non-governmental

organizations and others that promote resource

conservation, compatible wildlife-related research,

public use, site history, and infrastructure.

Alternatives B, C, and D would satisfy Goal 4, while the

reduced partnership efforts in Alternative A would

partially satisfy the goal.

Goal 6. Refuge Operations

Based on available funds, provide facilities and staff

to fulfill the Refuge vision and purpose.

While the staffing levels in Alternative A would be

sufficient to manage the proposed activities, the

alternative would not fulfill the Refuge vision and

purpose. Alternatives B, C, and D would all provide

sufficient facilities and staff to satisfy Goal 6.

4.18. RESOURCE COMMITMENTS COMMON TO

ALL ALTERNATIVES

NEPA requires a discussion of any irreversible or

irretrievable commitment of resources that would

result from implementing the alternatives. An

irreversible commitment of resources means

nonrenewable resources are consumed or destroyed.

These resources are permanently lost due to plan

implementation. In contrast to an irreversible

commitment of resources, an irretrievable commitment

of resources is the loss of resources or resource

production, or use of renewable resources during the

15-year life of the plan.

All alternatives would result in an irreversible

commitment of soil resources. Topsoil would be

removed before trail and facility construction for use in

revegetation of disturbed areas, but some irreversible

soil loss due to erosion would occur. The soil

productivity of trails over the long term would be less

than original undisturbed conditions, which would be

an irreversible commitment of resources. Loss of soil

productivity and vegetation, as well as changes to

visual resources due to facility development would be

an irretrievable commitment of resources.

Federal funding for staff and operations would be an

irretrievable commitment of resources. These

resources would not be available for other federal

programs or projects.

Fossil fuels used during construction of facilities would

represent an irreversible commitment of resources

because their use is lost for future generations. 

Rocky Flats lands transferred from the DOE to the

Service would be retained as “public lands” unavailable

for private use or development, with the exception of

the transportation right of way. DOE also may

transfer up to a 300-foot right of way. These transfers

would be an irretrievable commitment of resources.

4.19. SHORT-TERM USES OF THE

ENVIRONMENT AND MAINTENANCE OF LONGTERM PRODUCTIVITY

Historical uses of the Refuge, including early

settlement, the manufacture of nuclear weapons

components, and cleanup of soil and ground water

contamination, have affected the long-term productivity

of the Refuge’s ecological environment. Short-term

uses of the Refuge associated with implementing the

CCP include the construction of facilities and

modifications and enhancement of the natural

environment. The effects of implementing the CCP

would contribute to the maintenance and enhancement

of long-term productivity of the Refuge environment.

4.20. UNAVOIDABLE ADVERSE

ENVIRONMENTAL EFFECTS

Adverse environmental effects associated with

implementation of the CCP would be short term and

minimal. During construction of additional facilities on

the Refuge, wildlife would be disturbed and

temporarily displaced. Facilities construction also

would result in minor, short-term disturbance of soils

and erosion. The long-term effects of implementing

the CCP would be beneficial to the biological

community and the diversity and productivity of the

Refuge ecosystem.

4.21. SUMMARY OF ENVIRONMENTAL

CONSEQUENCES

On the following pages, Table 21 compares the effects

of the alternatives relative to the resources discussed in

Chapter 3. Summary statements in this table are

abbreviated and taken out of context to provide a quick

comparison by resource. The reader is encouraged to

review the supporting analysis in Chapter 4. 
Chapter 4: Environmental Consequences

196 Rocky Flats National Wildlife Refuge 

4.22. REFERENCES

Aquatics Associates, 2003. Personal

communication between R. Beane (ERO

Resources) and T. Schneck (Aquatics

Associates), September 9.

Benniger-Traux, M., J.L. Vankat, and R.L.

Schaefer. 1992. Trail corridors and Habitat

and Conduits for Movement of Plant Species

in Rocky Mountain National Park, CO,

USA. Landscape Ecology. 6(4):269-278.

Bowles, A.E. 1995. Responses of wildlife to

noise. Pp. 109-156. In Wildlife and

recreationists: coexistence through

management and research. R.L. Knight

and K.J. Gutzwiller, editors. Island Press,

Washington D.C.

Caughley, G. 1977. Analysis of vertebrate

populations. John Wiley and Sons, New

York, NY. 234 pp.

Church Ranch. 2004. Technical Revision to Rocky

Flats Pit, Permit number M-1987-113.

City of Boulder. 2003. Managing Prairie Dogs

on Open Space and Mountain Parks:

Relocation is not a panacea.

http://www.ci.boulder.co.us/openspace/nature

/pdogs_management.htm#relocating.

Cole, D.N. and D.R. Spildie. 1998. Hiker, horse

and llama trampling effects on native

vegetation in Montana, USA. Journal of

Environmental Management 53: 61-71.

Colorado Department of Transportation. 2003.

The Colorado Department of Transportation

Traffic Information Page.

http//www.dot.state.co.us/App_DTD_DataAc

cess/Traffic/.

Colorado Division of Minerals and Geology

(CDMG). 2004. Permit issuance, Rocky

Flats Pit, Permit number M-1987-113, with

rider. January 13, 2004.

Colorado Division of Wildlife. 2003.

Conservation Plan for Grassland Species in

Colorado. Colorado Division of Wildlife and

Colorado Grassland Species Working

Group. August 27. 

Colorado Division of Wildlife. 1992. State of

Colorado Department of Natural Resources,

Division of Wildlife Plains Sharp-tailed

Grouse Recovery Plan. May.

David Evans and Associates, Inc. 2003. Letter

Report: Rocky Flats National Wildlife

Refuge Comprehensive Conservation Plan –

Traffic Analysis. August 19.

Dehring, Faith J. and Frank J. Mazzotti. 1997.

Impacts of Equestrian Trails on Natural

Areas. Publication WEC-122. University of

Florida Cooperative Extension Service.

DeLuca, T.H., W.A. Patterson IV, W.A.

Freimund,, and D.N. Cole. 1998. Influence

of llamas, horses, and hikers on soil erosion

from established recreation trails in western

Montana, USA. Environmental

Management 22(2):255-262.

Department of Energy. 1999. The Rocky Flats

Environmental Technology Site Vegetation

Management Environmental Assessment.

Rocky Flats Field Office. Golden, CO.

Gillihan, S. W. 1998. Final report on the

behavioral ecology and habitat use of the

Standley Lake Bald Eagle pair, 2 October

1997 – 18 August 1998. Submitted to

Jefferson County Open Space.

Haysimith, L. and J.D. Hunt. 1995. Nature

Tourism: Impacts and Management. In

Knight, R.L. and K.J. Gutzwiller, editors.

Wildlife and Recreationists Coexistence

through Management and Research. Island

Press, Washington, D.C.

Hygnstrom, S.E., D. Virchow and J. Hobbs.

2002. Prairie dogs and their control.

Nebraska Cooperative Extension G02-1476-

A under Wildlife Management A-4, Wildlife

Damage Control Issued September. 7 pp.

International Dark-Sky Association (IDA) 2002.

Effects of Artificial Light at Night on

Wildlife. Information Sheet #187. IDA,

Inc., Tucson, Arizona.

Knight, R. L. and D.N. Cole. 1995. Wildlife

Responses to Recreationists. In Knight, R.

L. and K.J. Gutzwiller, editors. Wildlife and

Recreationists Coexistence through

Management and Research. Island Press,

Washington, D.C.
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 197

Knight, R.L. and K.J. Gutzwiller, editors.

Wildlife and Recreationists Coexistence

through Management and Research. Island

Press, Washington, D.C.

Kuford, C.C., 1958. Prairie dogs, Whitefaces

and Blue Grama. Wildlife Monograph 1-78.

Meaney, C. A. A. K. Ruggles, N.W. Clippinger,

and B.C. Lubow. 2002. The impact of

recreational trails and grazing on small

mammals in the Colorado Piedmont.

Prairie Naturalist 34:115-136.

Miller, S. G., R. L. Knight, and C. K. Miller.

2001. Wildlife responses to pedestrians and

dogs. Wildlife Society Bulletin 29:124-132.

Power, M.E., D. Tilman, J.A. Estes, B.A. Menge,

W.T. Bond, L.S. Mills, G. Daily, J.C. Castilla,

J. Lutchonco, and R.T. Paine. 1996.

Challenges in the Quest for Keystone

Species. BioScience 46:609-620.

Rosenlund, Bruce. 2003. Draft paper on native

fish reintroduction to Rock Creek. U.S.

Fish and Wildlife Service.

Seney, Joseph. 1991. Erosional impact of

hikers, horses, off-road bicycles, and

motorcycles on mountain trails.

Unpublished thesis, Montana State

University. Bozeman, Montana.

Smith, R.E. 1967. Natural History of the

Prairie Dog in Kansas. University of

Kansas Museum of Natural History Misc.

Publication no. 49.

Strickland, M.D., H.J. Harju, K.R. McCaffery,

H.W. Miller, L.M. Smith and R.J. Stoll.

1994. Harvest management in Research

and Management Techniques for Wildlife

and Habitats. T.A. Bookhout (ed.). The

Wildlife Society, Bethesda, Maryland.

Swinker, A.M, K.N. Forde, J. Hyatt, and J.L.

Traub-Dargatz. 2000. Commercial and

private trail horse recreational use on public

lands in Colorado. Research Report.

Colorado State University Department of

Animal Sciences.

http://ansci.colostate.edu/ran/equine/ams001

.htm.

U.S. Fish and Wildlife Service. 1992. The

potential effects of Rocky Mountain Arsenal

cleanup and Denver Metropolitan

transportation development on bald eagles:

Final study report. July, 148 pp.

Weir, Donald. 2000. A Guide to the Impacts of

Non-Motorized Trail Use. Donald V. Weir &

Associates. Edmonton, Alberta, Canada.

Whicker, A. D., and J. K. Detling. 1988.

Ecological Consequences of Prairie Dog

Disturbances. BioScience, 38:778- 785.

Witmer, G.W., K.C. VerCauteren, K.M. Manci,

D.M. Dees. 2002. Urban-suburban prairie

dog management opportunities and

challenges. Proceedings of 19th Vertebrate

Pest Conference. 19:439-444.
Chapter 4: Environmental Consequences

198 Rocky Flats National Wildlife Refuge 

Impact 

Topics

GEOLOGY AND

SOILS

WATER

RESOURCES

VEGETATION

COMMUNITIES

WILDLIFE AND

AQUATIC

SPECIES

Negligible

Change to the landscape

or geologic formations

would not be noticeable.

Soils would not be

affected or the effect

would be below or at the

lower end of detection.

Any effects to soil

productivity or fertility

would be slight.

Changes in water quality

or quantity would not be

measurable.

Some individual native

plants would be affected,

but there would be no

effect on native species

populations. The effects

would be on a small scale.

Wildlife and aquatic

resources would not be

affected or the changes

would be so slight that

they would not be of any

measurable or

perceptible consequence

to a species' population

on a regional or local

scale.

Minor

The effects to the

landscape, geologic

formations, and soils

would be detectable.

Changes to the landscape

and geologic features

would be small in size or

area. The extent and

magnitude of effects to

soil productivity or

fertility would be small or

short-lived.

Changes in water quality

or quantity would be

measurable, although the

changes would be small

and the effects would be

localized. Water quality

standards would not be

exceeded.

Some individual native

plants would be affected

over a relatively small

area and minor portion of

that species' population.

A minor introduction or

spread of non-native

plant species is possible

over a small area and

eradication or control

would be easily achieved.

Effects to individual

wildlife and aquatic

species are possible,

although the effects

would be localized, small,

and of little consequence

to the species' population

on a regional or local

scale.

Moderate

The effect to the

landscape, geology, and

soils would be readily

apparent. Effects would

result in a change to the

landscape, geology, and

soil character over a

relatively large area or

multiple locations.

Changes in water quality

or quantity would be

measurable, affecting

water resources on Rocky

Flats. Water quality

standards would not be

exceeded.

Some individual native

plants would be affected

over a relatively wide

area or multiple sites and

would be readily

noticeable. There would

be limited impact to the

species population, but

for individual species, a

sizeable segment of the

species' population could

be affected. The

introduction or spread 

of non-native plant

species would occur at

multiple locations and

extensive weed control

measures would need to

be implemented.

Effects to individual

wildlife and aquatic

species are likely and

localized, with

consequences at the

population level. 

Major

The effect on the

landscape, geology, and

soils would be readily

apparent and would

substantially change the

character of these

resources over a large

area.

Changes in water quality

or quantity would be

readily measurable, and

would be noticed off of

Rocky Flats. Water

quality standards would

be exceeded.

Native plant populations

would be affected over a

relatively large area. A

widespread introduction

or spread of non-native

plant species would occur

resulting in the likely

establishment of exotic

species and the need for

aggressive weed control.

Effects to wildlife and

aquatic resources would

have substantial

consequences to species

populations on both a

local and regional scale.

Table 20. Impact Threshold Definitions 
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 199

Negligible

No federally listed species

would be affected, or an

individual of a listed

species or its critical

habitat would be affected,

but the change would be

so small that it would not

be of any measurable or

perceptible consequence

to the protected individual

or its population.

Negligible effect is the

same as a "no effect"

determination in a U.S.

Fish and Wildlife Service

Biological Opinion.

Impact is at the lowest

level of detection, with no 

perceptible consequences,

either adverse or

beneficial, to

archeological or historic

resources. For purposes

of Section 106, the

determination of effect

would be no adverse

effect.

Changes in visitor use or

recreation opportunity

would be below the level

of detection.

Effects would not result

in any perceptible

changes to existing

viewsheds.

New noise sources would

be below existing levels.

Minor

Individuals of a listed

species or its habitat

would be affected, but the

change would be small or

short-lived. Minor affect

is the same as a "may

effect" determination in a

U.S. Fish and Wildlife

Service Biological

Opinion and would be

accompanied by a

statement of "not likely to

adversely affect" the

species.

Disturbance of a site

would be confined to a

small area with little, if

any, loss of important

information potential.

Impact would not affect a

character-defining

feature of a structure or

building listed or eligible

for listing in the National

Register of Historic

Places. For purposes of

Section 106, the

determination of effect

would be no adverse

effect.

Changes in visitor use or

recreation opportunity

would be detectable, but

the changes would be

slight.

Changes to visual

resources would be shortlived or affect a small

portion of the Refuge.

New noise sources would

be above existing levels,

but would be temporary

and not adversely affect

visitors or wildlife.

Moderate

An individual or 

population of a listed

species, or its habitat

would be noticeably

affected. The effect could

have some long-term

consequence to the

individual, population, or

habitat. Moderate effect

is the same as a "may

affect" determination in a

U.S. Fish and Wildlife

Service Biological

Opinion and would be

accompanied by a

statement of "likely to

adversely affect" the

species or a "not likely to

adversely affect with

mitigation and

conservation measures."

Disturbance of a site

would not result in a

substantial loss of

important information.

Impact would alter a

character-defining

feature of the structure

or building, but would not

diminish the integrity of

the resource to the extent

that its National Register 

eligibility is jeopardized.

For purposes of Section

106, the determination of

effect would be either

adverse effect or no

adverse effect.

Changes in visitor use or

recreation opportunity

would be apparent, but

temporary.

Effects would be readily

apparent and would

change the character of

the visual resources in

the area. 

New noise sources would

be substantially above

existing levels and would

adversely affect visitors

and wildlife for short

periods of time.

Major

An individual or

population of a listed

species, or its habitat

would be noticeably

affected with a long-term,

consequence to the

individual, population, or

habitat. Major effect is

the same as a "may

affect" determination in a

U.S. Fish and Wildlife

Service Biological

Opinion and would be

accompanied by a

statement of "likely to

adversely affect" the

species or critical habitat.

Mitigation and

conservation measures

would lessen the effect,

but would not completely

remove the adverse

effect.

Disturbance of a site is 

substantial and results in

the loss of most or all of

the site and its potential

to yield important

information. Impact

would alter a characterdefining

feature of the structure

or building, diminishing

the integrity of the

resource to the extent

that it is no longer

eligible to be listed in the

National Register. For

purposes of Section 106,

the determination of

effect would be an

adverse effect.

Changes in visitor use or

recreation opportunity

would be readily

apparent and longlasting.

Effects would be highly

noticeable and

permanent, affecting

significant views of or

from the Refuge.

New noise sources would

be substantially above

existing levels and would

adversely affect visitors

and wildlife for long 

periods of time. 

Impact 

Topic

THREATENED

AND

ENDANGERED

SPECIES AND

SPECIES OF

CONCERN

CULTURAL

AND HISTORIC

RESOURCES

OPEN SPACE,

RECREATION

AND TRAILS

VISUAL

RESOURCES

NOISE

Table 20. Impact Threshold Definitions (continued)
Chapter 4: Environmental Consequences

200 Rocky Flats National Wildlife Refuge 

Table 20. Impact Threshold Definitions (continued)

Negligible

Changes in traffic at or

around the Refuge would

not be noticeable.

Change in existing air

quality or visibility would

not be measurable or

noticeable.

No effects would occur or

the effects to socioeconomic conditions would

be below or at the level of

detection.

Minor

Traffic at or around the

Refuge would increase

above existing conditions,

but would not be noticeable

to most travelers on

surrounding public roads.

Increased airborne

pollutants would be slight,

but measurable. Changes in

visibility would be

observable at local sites.

Air quality standards would

not be exceeded.

Effects to employment,

income and housing would

be insignificant in relation

to the local economy. Effect

on low income and minority

populations would be

similar to the surrounding

area.

Moderate

Traffic to and from the

Refuge would increase above

existing conditions. The

additional traffic would cause

an unacceptable level of

service at some locations.

Increased airborne

pollutants would be readily

measurable. Impacts to

visibility would be readily

observable and widespread.

Air quality standards would

not be exceeded.

Effects to employment,

income and housing would be

would be measurable,

altering the local economy.

Impacts borne by low

income and minority

populations would be slight,

but larger than average in

the surrounding area.

Major

Traffic to and from the

Refuge would increase

substantially, causing an

unacceptable level of service

at many locations.

Increased airborne

pollutants would be readily

measurable. Visibility at the

Refuge or surrounding areas

would be reduced. Air

quality standards would be

exceeded.

Effects to employment,

income, and housing would

have substantial impacts to

the regional population or

economy. Impacts borne by

low income and minority

populations would be

significantly larger than the

average in the 

surrounding area.

Impact 

Topic

TRANSPORTATION

AIR QUALITY

SOCIOECONOMIC

RESOURCES
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 201

This Page Intentionally Left Blank
Chapter 4: Environmental Consequences

202 Rocky Flats National Wildlife Refuge 

Table 21. Summary of Environmental Consequences

Geology

and Soils

Water 

Resources

ALTERNATIVE A — No Action

• Deer and Elk Management: Population control would

reduce potential for soil erosion due to overgrazing.

• Prairie Dog Expansion: May result in increased soil

erosion. These impacts may be offset by the increased

nutrient cycling and soil stability provided by prairie dog

colonies. Effects could be Refuge-wide.

• Road Restoration and Revegetation: Removal and

revegetation of roads and stream crossings would result

in short-term soil disturbance and erosion. Long-term

benefits of revegetation would offset the short-term

effects.

– 12 miles of road and 7 stream crossings restored

– Rock Creek Reserve only

• Preble’s Habitat Management: Protection and

maintenance of riparian habitat and vegetated buffer

would benefit water resources.

• Road Restoration and Revegetation: Road removal in

Rock Creek Reserve may result in short-term impacts

due to sedimentation, and long-term benefits due to

improved bank vegetation, stream channel, etc. Outside

of Rock Creek Reserve, lack of restoration may result in

long-term sedimentation from existing roads.

ALTERNATIVE B — Wildlife, Habitat, & Public Use

(Preferred Alternative)

• Prairie Dog Expansion: Same effects as A, up to 750

acres.

• Mixed Prairie Grassland Management: Restoration of

hay meadow and other disturbed areas would result in

short-term soil disturbance and long-term benefits.

• Road Restoration and Revegetation: Road removal

would result in short-term soil disturbance and erosion.

Long-term benefits of revegetation would offset the

short-term effects.

– 26 miles of road and 13 stream crossings restored

• Public Use and Maintenance Facilities: New trails and

facilities would result in localized soil disturbance and

erosion during construction, and long-term impacts from

use. 

– Soil loss on 1.1 acres from facilities

– Soil disturbance from 1.7 miles of newly constructed trail

• Weed Management: Localized, short-term

erosion may occur following prescribed fire or grazing.

• Road Restoration and Revegetation: Road removal

Refuge-wide may result in short-term impacts due to

sedimentation, and long-term benefits due to improved

bank vegetation, stream channel, etc. 

• Public Use: Trail use and off-trail use near streams

may result in bank destabilization and erosion. Facility

construction may result in short-term impacts due to

erosion and sedimentation. 
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 203

ALTERNATIVE C — Ecological Restoration ALTERNATIVE D — Public Use

• Prairie Dog Expansion: Same effects as A, up to 500

acres.

• Road Restoration and Revegetation: Same as B, except:

– 26 miles of road and 13 stream crossings restored

• Public Use and Maintenance Facilities: Same as B,

except:

– Soil loss on 0.2 acres from facilities

– No newly constructed trails

• Lindsay Pond: Pond removal would result in a long-term

loss of aquatic habitat, water storage, and sediment

removal.

Prairie dog expansion: Same effects as A, up to 1,000

acres.

• Road Restoration and Revegetation: Same as A, except:

– 24 miles of road and 6 stream crossings restored

• Public Use and Maintenance Facilities: Same as B,

except: 

– Soil loss on 1.7 acres from facilities

– Soil disturbance from 3.3 miles of newly constructed

trail

• No grazing or prescribed fire.

• Public Use: Same effects as B.
Chapter 4: Environmental Consequences

204 Rocky Flats National Wildlife Refuge 

Table 21. Summary of Environmental Consequences (continued)

Vegetation

Communities

ALTERNATIVE A — No Action

• Deer and Elk Management: Population management by

CDOW and vegetation monitoring would benefit vegetation

by reducing impacts of overbrowsing/ overgrazing.

Benefits more uncertain by lack of a timeframe.

• Prairie Dog Management: Exclusion of prairie dogs

from riparian and xeric tallgrass habitat in Rock Creek

Reserve would benefit these communities. Outside of

Rock Creek Reserve, prairie dogs could degrade plant

communities. 

• Preble’s Habitat Management: Maintenance and

protection of riparian and wetland habitat would benefit

these communities.

– Exclusion of ungulates would benefit riparian habitat 

• Xeric Tallgrass Conservation: Management planning

and regional conservation efforts would benefit xeric

tallgrass community. Benefits would be limited to Rock

Creek Reserve.

• Road Restoration and Revegetation: Road removal

would benefit vegetation communities within the Rock

Creek Reserve by reducing fragmentation. Removal of

stream crossings would result in short-term impacts to

wetlands and riparian habitat. Would result in:

– 18 acres of additional habitat 

– Average patch size of 58 acres

• Weed Management: Weed management efforts in Rock

Creek Reserve would benefit vegetation communities.

– Chemical, biological, and mechanical control may

have short-term adverse impacts that would be offset

by long-term benefits. Benefits may be reduced by

lack of grazing as a management tool

– Outside of Rock Creek Reserve, benefits would be

greatly reduced

ALTERNATIVE B — Wildlife, Habitat, & Public Use

(Preferred Alternative)

• Deer and Elk Management: Same benefits as A, except

benefits would be increased by the Service’s larger role

and the 5-year target population timeframe.

• Prairie Dog Management: Prairie dogs may impact some

plant communities. Exclusion of prairie dogs

from riparian and xeric tallgrass habitat Refuge-wide

would benefit these communities.

• Preble’s Habitat Management: Maintenance, protection,

and improvement of riparian and wetland habitat would

benefit those communities.

– Exclusion of ungulates would benefit riparian habitat

– Monitoring recreation impacts only may provide

insufficient information for effective riparian habitat

management

• Xeric Tallgrass Conservation: Same as A, except

benefits would be Refuge-wide.

• Mixed Grassland Prairie Management: Restoration of

hay meadow and other areas would benefit grassland

communities.

• Road Restoration and Revegetation: Road removal

would benefit vegetation communities Refuge-wide by

reducing fragmentation. Removal of stream crossings

may result in short-term impacts to wetlands and riparian

habitat, with long-term benefits. Would result in:

– 48 acres of additional habitat

– Average patch size of 93 acres

• Weed Management: Same as A, except benefits and

impacts would be Refuge-wide.

– Benefits may be increased because of Refuge-wide use

of rescribed fire and grazing

• Public Use Facilities: New trails and facilities would

directly impact vegetation, and indirectly impact adjacent

vegetation. Includes: 

– 4.8 acres of impacts to vegetation

• Off-trail Use: Minor impacts to vegetation due to

trampling, social trails, and weed dispersal.

• Public Use Monitoring: Monitoring impacts of public use

on riparian habitat would provide long-term benefit.

• Regional Coordination: Coordination with adjacent

landowners would benefit vegetation through better

management.

• Research: Habitat-related research would benefit

vegetation and habitat management.
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 205

ALTERNATIVE C — Ecological Restoration ALTERNATIVE D — Public Use

• Preble’s Habitat Management: Same as B, except:

– Vegetation surveys would benefit riparian habitats

• Road Restoration and Revegetation: Same as B, with a

larger reduction in fragmentation. Would result in:

– 46 acres of additional habitat

– Average patch size of 121 acres

• Public Use Facilities: Same as B, except:

– 0.01 acre of impacts to vegetation

• Prairie Dog Relocation: Accepting unwanted prairie

dogs from other jurisdictions may impact grassland

communities.

• Preble’s Habitat Management: Same as B.

• Road Restoration and Revegetation: Same as B, except

no benefits from hay meadow restoration. Would result

in:

– 44 acres of additional habitat

– Average patch size of 90 acres

• Weed Management: Same as A, except benefits and

impacts would be Refuge-wide. Benefits may be reduced

due to a lack of grazing and prescribed fire as

management tools.

• Public Use Facilities: Same as B, except:

– 7.9 acres of impacts to vegetation

• Off-trail Use: Same as B.

• Public Use Monitoring: Same as B.
Chapter 4: Environmental Consequences

206 Rocky Flats National Wildlife Refuge 

Table 21. Summary of Environmental Consequences (continued)

Wildlife

ALTERNATIVE A — No Action

• Native Fish Reintroduction: Would provide long-term

benefits to fish populations and survival rates.

• Sharp-tailed Grouse Reintroduction: Lack of

management plan may result in conflicting management

priorities and adverse impacts on introduced grouse.

• Deer and Elk Management: Passive approach to

population management by CDOW with no set

timeframe; may impact ungulates and other resources.

– Culling would impact individual animals due to

mortality, but would provide long-term population

benefits. 

– Monitoring levels would be inadequate for effective

population management.

• Preble’s Habitat Management: Habitat protection would

benefit other riparian wildlife species.

• Prairie Dog Management: Colony expansion could result

in long-term impacts to vegetation structure and local

extirpation of some species over large areas of the

Refuge. 

• Road Restoration and Revegetation: Road revegetation

would benefit various wildlife species in Rock Creek

Reserve. 

• Vegetation and Wildlife Monitoring: May result in

short-term impacts (disturbance/displacement) to

individual animals.

• Xeric Tallgrass Management: Efforts in Rock Creek

Reserve may have short-term adverse impacts to wildlife

and long-term benefits due to habitat enhancement.

• Weed Management: Various management tools have the

potential to cause direct mortality or injury to individual

animals. Impacts would be offset by long-term benefits

of improved habitat.

• Regional Coordination: Coordination with other land

managers would improve wildlife and habitat

management.

ALTERNATIVE B — Wildlife, Habitat, & Public Use

(Preferred Alternative)

• Sharp-tailed Grouse Reintroduction: Management

planning and weed management efforts would benefit

grouse reintroduction efforts.

• Deer and Elk Management: Population targets would be

realized within 5 years, providing moderate benefits.

– Culling and hunting would impact animals due to

mortality or stress, would provide long-term benefits.

– Monitoring would be minimum necessary for effective

population management.

• Preble’s Habitat Management: Same as A, plus: 

Minor impacts to riparian wildlife species due to greater

Preble’s monitoring.

• Prairie Dog Management: Same as A except reduced

magnitude of change (750 acres).

• Road Restoration and Revegetation: Road revegetation

would benefit various wildlife species Refuge-wide. 

• Xeric Tallgrass Management: Efforts Refuge-wide 

may have greater short-term adverse impacts to wildlife

and long-term benefits due to habitat enhancement.

• Mixed Grassland Prairie Management: Restoration of

disturbed areas may impact some resident wildlife;

would result in long-term habitat benefits to wildlife.

• Public Use: Trail use throughout the Refuge may

adversely affect wildlife in the following ways:

– Creating a new disturbance that may disrupt wildlife

movement and fragment habitat areas.

– New trails may provide a conduit for predators and

weeds.

– Short-term stress and adjustment for mule deer;

followed by long-term benefits of increased deer

movement that may improve genetic diversity and

decrease habitat impacts.

• Regional Coordination: Same as A, except more

pronounced benefits due to better coordination.

• Research: Short-term wildlife disturbance would be

offset by improved knowledge of wildlife management.

• Fence Removal: Removal of unnecessary interior stock

fencing would benefit wildlife species by facilitating open

movement through Refuge.
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 207

ALTERNATIVE C — Ecological Restoration ALTERNATIVE D — Public Use

• Native Fish Reintroduction: Same as A, except:

Removal of the Lindsay Ponds would result in major

adverse impacts to common shiner and redbelly dace

populations on the Refuge.

• Deer and Elk Management: Same as B, except: 

– No hunting.

– Monitoring would provide adequate information for

effective population management.

– Fawn monitoring may result in injury or death of

some fawns.

• Prairie Dog Management: Same as A except reduced

magnitude of change (500 acres).

• Vegetation monitoring: May result in short-term

impacts (disturbance/displacement) to individual animals.

More extensive monitoring may have greater impacts.

• Public Use: Impacts in Alternative C would be

negligible.

• Lindsay Ranch: Removal of structures would eliminate

some habitat for barn owl, bats, and other species.

• Native Fish Reintroduction: Same as A.

• Deer and Elk Management: Same as B, except:

– Monitoring levels would be inadequate for effective

population management.

• Prairie Dog Management: Same as A except moderate

magnitude of change (1,000 acres). 

• Public Use: Same as B, except:

– Additional impacts to raptor nesting habitat.

– General impacts to wildlife more pronounced.
Chapter 4: Environmental Consequences

208 Rocky Flats National Wildlife Refuge 

Table 21. Summary of Environmental Consequences (continued)

Threatened

and

Endangered 

Species 

Cultural and

Historic

Resources

Open Space,

Recreation, 

and Trails

ALTERNATIVE A — No Action

• Grouse Reintroduction: Grouse habitat management

would provide additional eagle prey; may conflict with

prairie dog habitat management.

• Deer and Elk Management: Delayed population

management may impact Preble’s through overbrowsing.

• Prairie Dog Management: Unlimited colony expansion

acres could improve foraging for bald eagles, but could

impact Preble’s habitat. 

• Preble’s Habitat Management: Exclusion of grazing

from habitat may have moderate benefits to Preble’s.

Monitoring could lead to short-term disturbance. Habitat

management may benefit bald eagle foraging perches.

• Road Restoration and Revegetation: Revegetation of

unused roads and stream crossings would benefit all

species.

• Weed Management: Short-term habitat impacts from

management tools followed by long-term habitat

improvements.

• Lindsay Ranch: Stabilization efforts would benefit barn,

but continued degradation of the hours would impair its

interpretive value.

• Wildlife Management: Species reintroductions and deer

and elk population management on the Refuge may result

in long-term benefits to wildlife populations and wildlife

viewing opportunities on adjacent open space lands.

• Preble’s Habitat Management: Refuge could provide a

core reserve for Preble’s and other species that would

benefit populations on adjacent open space lands.

• Vegetation Management: Efforts such as xeric tallgrass

management planning, and regional collaboration could

benefit adjacent open space areas by improving

knowledge and coordination.

• Weed Management: Reduced diligence outside of Rock

Creek Reserve may impact adjacent open space areas by

potentially contributing to spread of weeds.

• Trail Facilities: Rocky Flats would continue to be a

barrier for regional trail connectivity.

ALTERNATIVE B — Wildlife, Habitat, & Public Use

(Preferred Alternative)

• Deer and Elk Management: More aggressive population

management could benefit Preble’s by reducing

overbrowsing.

• Prairie Dog Management: Same benefits and impacts as

A but reduced in magnitude (750 acres).

• Weed Management: Same as A, except impacts and

benefits would be more pronounced.

• Public Use: Trail development and use in riparian areas

may impact Preble’s (mitigated by seasonal closures).

Facility development may impact prairie dogs and

associated foraging habitat for eagles. 

• Wildlife Management: Same as A, but benefits would be

more pronounced.

• Weed Management: Weed reduction efforts on the

Refuge could benefit adjacent open space by reducing

spread of weeds and increasing management knowledge.

• Recreation Opportunities: Recreation programs would

compliment but not duplicate opportunities on nearby

open space lands.

• Trail Facilities: Trails and trailheads would benefit the

regional connectivity of trails, but would lack a direct

connection to Boulder trails. 
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 209

ALTERNATIVE C — Ecological Restoration ALTERNATIVE D — Public Use

• Prairie Dog Management: Same benefits and impacts as

A but reduced in magnitude (500 acres).

• Preble’s Habitat Management: Same as A, except

increased magnitude of disturbance due to monitoring.

• Lindsay Ranch: Removal of all structures would impact

historical and interpretive value of site.

• Wildlife Management: Same as A, but benefits would be

greatest.

• Trail Facilities: Same impact as A.

• Prairie Dog Management: Same benefits, impacts, and

similar magnitude as A (1,000 acres).

• Public Use: Same as B, except:

– More extensive impacts from additional trail use.

– Potential impacts to bald eagle habitat due to trail use

adjacent to riparian areas.

• Lindsay Ranch: Stabilized barn would have greatest

benefits for site; house would be lost.

• Wildlife Management: Same as B.

• Recreation Opportunities: Same as B, except more

pronounced.

• Trail Facilities: Same effects as B, but greater trail

connectivity.
Chapter 4: Environmental Consequences

210 Rocky Flats National Wildlife Refuge 

Table 21. Summary of Environmental Consequences (continued)

Visual 

Resources

Noise

Transportation

Air Quality

Socio -

economics

ALTERNATIVE A — No Action

• Deer and Elk Management: May reduce visual impacts

of overgrazing/overbrowsing.

• Prairie Dog Management: Colonies would be a visual

impact to some, a benefit to others. Greatest effects in

Alternative A (unlimited).

• Prescribed Fire: Short-term visual impacts associated

with smoke and burned areas from prescribed fires.

• Grazing: May result in short-term visual impacts; though

some may consider livestock to be a benefit for landscape

views.

• Road Removal and Revegetation: Revegetation would

benefit visual aesthetics within Rock Creek Reserve.

• Deer and Elk Management: Occasional gunshots

associated with culling may be audible from within

Refuge, but would not impact overall noise levels.

• Excavation and Construction: Heavy equipment for

road restoration and facility development would result in

short-term noise impacts in nearby areas. 

• Highway 93: Contribution of Refuge traffic to Highway

93 would be much less than pre-Refuge conditions.

Would not warrant a traffic signal at access road

intersection.

• Dust and Emissions: Equipment usage would result

in short-term localized emissions and fugitive dust.

• Prescribed Fire: Would result in short-term increases

in particulates and decreased visibility nearby.

• Staffing: Staffing levels would have no impact on

regional employment, income or housing conditions.

• Community: Change from past use to Refuge would

benefit community perceptions of Rocky Flats.

• Environmental Justice: No adverse effects on minority

or low-income populations, or Native Americans.

ALTERNATIVE B — Wildlife, Habitat, & Public Use

(Preferred Alternative)

• Prairie Dog Management: Same effects as A, but less

pronounced (750 acres).

• Road Removal and Revegetation: Revegetation

would benefit visual aesthetics Refuge-wide.

• Mixed Grassland Prairie Management: Revegetation

would likely cause short-term visual impacts followed by

long-term benefits.

• Public Use Facilities: May result in minor visual

impacts.

• Deer and Elk Management: Same as A, except

additional gunshots from public hunting.

• Highway 93: Contribution of Refuge traffic to Highway

93 would be much less than pre-Refuge conditions.

Would not warrant a traffic signal, but existing

acceleration/ deceleration lanes would be beneficial.

• Highway 128: No impacts from trailhead location.

Potential trail crossing at McCaslin would require

pedestrian signals.

• Indiana Street: Potential pedestrian crossings should

include warning signs for safety. Recommended locations

are north of Walnut Creek, and south of Woman Creek. 
Chapter 4: Environmental Consequences

Final Comprehensive Conservation Plan & EIS 211

ALTERNATIVE C — Ecological Restoration ALTERNATIVE D — Public Use

• Prairie Dog Management: Same effects as A, but least

impact (500 acres).

• Public Use Facilities: Negligible visual impact 

from facilities.

• Deer and Elk Management: Same as A.

• All Roads: Same as A.

• Prairie Dog Management: Same effects as A, with

moderate impact (1,000 acres).

• Public Use Facilities: Same as B.

• Deer and Elk Management: Same as B.

• Highway 93: Same as B.

• Highway 128: Same as B.

• Indiana Street: Same effects as B from potential trail

crossings. Trailhead access may require left turn lanes.

PREPARERS

chapter 5

Chapter 5: Preparers

Final Comprehensive Conservation Plan & EIS 215

U.S. FISH AND WILDLIFE SERVICE

Name Responsibilities Education Experience

Dean Rundle Refuge Manager B.S. Fisheries and Wildlife 29 years

M.S. Fisheries and Wildlife

Laurie Shannon Team Leader, RF CCP Plan B.S. Recreation Resources Mgmt. 27 years

Michael Spratt Chief of Refuge Planning B.S. Forestry 23 years

Region 6 M.S. Landscape Architecture

Mark Sattelberg Contaminants Biologist RF B.A. Chemistry and Biology 15 years

M.S. Biology

Andrew Todd Water Quality Specialist B.A. Biology 6 years

M.S. Civil Engineering/Water Res.

Amy Thornburg Refuge Operations Specialist B.S. Wildlife Biology 9 years

Sherry James Supervisory Park Ranger 14 years

Visitor Services, RMA

Bruce Hastings Supervisor, Wildlife/Habitat B.S. Chemistry and Psychology 18 years

RMA M.S. Wildlife Science

Ph.D. Ecology

Lorenz Sollmann Integrated Pest Management B.S. Wildlife Biology 9 years

Fire Management, RMA

Robin Romero Biocontrol of weeds, RF B.S. Animal Science 10 years

Planning Assistance M.S. Biology/Entomology

Beth Dickerson Planning Assistance M.S. Biology 4 years

Preble’s Consultation

SHAPINS ASSOCIATES, INC.

Name Responsibilities Education Experience

Ann Moss Project Manager, CCP B.A. Art and Art History 27 Years

Masters of Landscape Architecture

Mimi Mather Planner, CCP; Public Use B.A. Sociology 4 Years

Masters of Landscape Architecture

Brian Braa Planner, CCP; Public Use B.S. Accounting 4 Years

Masters of Landscape Architecture

Chapter 5. Preparers
Chapter 5: Preparers

216 Rocky Flats National Wildlife Refuge 

RESOLVE

Name Responsibilities Education Experience

Mike Hughes Facilitation B.A. Political Science 20 Years 

Masters of City Planning

Jody Erikson Facilitation B.A. Human Communication 4 Years

ERO RESOURCES CORP.

Name Responsibilities Education Experience

Richard Trenholme Project Manager, EIS B.S. Agronomy 25 years

Bill Mangle Project Planning and B.S. History/Political Science 6 years

Coordination M.S. Natural Resource Policy/Planning

Ron Beane Wildlife B.S. Biology 28 years

M.S. Wildlife Biology

Mark DeHaven Vegetation, Soils, and Geology B.A., Business 24 years

M.S., Natural Resources

Barbara Galloway Water Resources and B.A., Environmental Conservation 20 years

Aquatic Life and Biology

M.S., Water Resources

Michael Simler GIS B.S., Biology 5 years

Martha Clark Technical Editor B.A., English 18 years

ADDITIONAL CONTRIBUTORS

The following individuals also contributed to the development of the CCP/EIS by sharing their knowledge in

planning workshops or at other times during the planning process. 

U.S. FISH AND WILDLIFE SERVICE, REGION 6 REGIONAL OFFICE

Name

Rick Coleman Chief of Refuges 

Ron Cole Former Region 6 Program Supervisor (CO, KS, NE)

Ron Shupe Region 6 Program Supervisor (CO, KS, NE)

Larry Gamble Chief, Environmental Contaminants

Mark Ely Planning, GIS and Mapping Coordinator

Sheri Fetherman Chief, Education and Visitor Services Division

Melvie Uhland Education and Visitor Services, CO/KS/NE

Ken Kerr Zone Fire Management Officer, CO/KS/NE
Chapter 5: Preparers

Final Comprehensive Conservation Plan & EIS 217

Harvey Wittmier Chief, Realty Division

David Redhorse External Affairs

U.S. FISH AND WILDLIFE SERVICE, REGION 6 ECOLOGICAL SERVICES

Name

Lee Carlson Former CO Ecological Services Field Office 

Supervisor

U.S. FISH AND WILDLIFE SERVICE, COLORADO FISH AND WILDLIFE ASSISTANCE OFFICE

Name

Bruce Rosenlund Colorado Management Assistance Office

U.S. FISH AND WILDLIFE SERVICE, PRIVATE LANDS

Name

Bill Noonan Private Lands Coordinator

U.S. FISH AND WILDLIFE SERVICE, WASHINGTON OFFICE

Name

Liz Bellatoni Planning Coordinator 

U.S. FISH AND WILDLIFE SERVICE, ROCKY MOUNTAIN ARSENAL NWR STAFF

Name

Vic Elam Refuge Operations Specialist

Stephen Smith Civil Engineer

Tom Jackson Remedy Coordinator

Mindy Hetrick Wildlife Biologist

Eric Stone Wildlife Biologist

U.S. DEPARTMENT OF ENERGY, ROCKY FLATS FIELD OFFICE

Name

Cliff Franklin Physical Scientist

John Rampe Physical Scientist
Chapter 5: Preparers

218 Rocky Flats National Wildlife Refuge 

KAISER-HILL/LABAT-ANDERSON

Name

Jody Nelson Plant Ecologist

COLORADO DIVISION OF WILDLIFE

Name

Mike Wedermyer District Wildlife Manager

Aaron Lindstrom Wildlife Biologist
CONSULTATION AND COORDINATION

chapter 6

Chapter 6: Consultation and Coordination

Final Comprehensive Conservation Plan & EIS 221

The public involvement process was an important

component of the CCP/EIS project. During the scoping

phase of the project, the Service sought input from the

public and interested organizations and agencies to help

direct the CCP/EIS process. Scoping helped identify

specific opportunities, issues, concerns and ideas related

to the management of the future Refuge.

The Service used various methods to solicit guidance

and feedback from interested citizens, organizations,

and government agencies. These methods included

public scoping meetings, public agency scoping

meetings, briefings and presentations, issue-specific

focus group workshops, as well as letters, email and

telephone calls. 

6.1. PROJECT SCOPING

The scoping process began with informal public

agency consultations in February 2002. On July 23,

2002, Service staff met with the Rocky Flats

Coalition of Local Governments (RFCLOG). The

RFCLOG is a coalition of seven local governments

(Boulder County, Jefferson County, City and

County of Broomfield, and the cities of Arvada,

Boulder, Westminster, and Superior). 

Beginning in early 2002, Service staff met with

representatives from communities, agencies, and

businesses that may have an interest in the Rocky

Flats CCP/EIS process. The Service also met with

state representatives, including the offices of the

Governor, the Attorney General and the CDPHE to

help develop the public process. The purpose of these

meetings was to brief the stakeholders on the planning

process, and solicit their comments and concerns for

the scoping process.

Between February 6 and April 12, 2002, Dean 

Rundle and Laurie Shannon with the U.S. Fish and

Wildlife Service met individually with each member of

the RFCLOG. All the local governments had questions

about developing the Memorandum of Understanding

between DOE and the Service in addition to the

planning process. Copies of the Service’s policy on

Planning and Compatibility were distributed. 

Service staff also met with representatives of the 

cities of Golden, Thornton, Northglenn, Louisville 

and Lafayette.

The formal scoping period for the general public began

on August 23, 2002, with the publication of a Notice of

Intent in the Federal Register. The Notice of Intent

notified the public of the Service’s intent to begin the

CCP/EIS process, set the dates for public scoping

meetings, and solicited public comments. The scoping

period ended on October 31, 2002.

PUBLIC SCOPING MEETINGS

Public scoping meetings were held in September 2002

in Broomfield, Arvada, Westminster, and Boulder.

Several weeks before the public scoping meetings,

Planning Update #1, an announcement of the scoping

meetings, was mailed to 889 individuals, businesses and

organizations. The mailing list consisted of individuals

and organizations that had previously expressed an

interest in Rocky Flats-related issues and were on the

Rocky Flats Citizen Advisory Board (RFCAB), the

DOE, or Kaiser-Hill (DOE contractor) mailing lists. 

Planning Update #1 described the planning process,

the draft vision and goals for the Refuge, and the dates,

times and locations of the public scoping meetings.

Information contained in Planning Update #1 also was

announced at RFCLOG and RFCAB meetings. A

press release soliciting participation in the scoping

process was also sent to 23 local and national media

organizations. The Service placed advertisements in

seven newspapers to publicize the project and invite

the public to the scoping meetings. Flyers announcing

the public scoping meetings were posted in public

buildings in several communities surrounding the

Rocky Flats site.

PROJECT WEBSITE

The Rocky Flats NWR web site (http://rocky

flats.fws.gov/) was published for public access during

the week of July 21, 2002, and contained information

about the public scoping meetings, as well as

downloadable versions of all of the available public

scoping documents. 

PUBLIC AGENCY MEETING

On August 19, 2002, the Service hosted a meeting for

representatives from various state and federal agencies 

Chapter 6. Consultation and Coordination
Chapter 6: Consultation and Coordination

222 Rocky Flats National Wildlife Refuge 

interested in the future management of the Rocky

Flats site. The following agencies were represented:

• Agency for Toxic Substances and Disease

Registry

• City of Westminster

• Colorado Attorney General’s Office

• Colorado Department of Agriculture

• Colorado Department of Public Health and

Environment

• Colorado Department of Transportation

• Colorado Division of Minerals and Geology

• Colorado Division of Wildlife

• Colorado Geological Survey

• Colorado Historical Society

• Colorado State Parks

• Denver Regional Council of Governments 

• Federal Aviation Administration

• Governor Owens’ Office

• Rocky Flats Coalition of Local Governments

• State Land Board

• Senator Allard’s Office

• U.S. Army Corps of Engineers

• U.S. Department of Energy

• U.S. Environmental Protection Agency

• U.S. Fish and Wildlife Service

• Urban Drainage and Flood Control District

• Xcel Energy

FOCUS GROUPS

Six focus group meetings were held on October 28, 29,

and 30, 2002. The purpose of the focus group meetings

was to convene a forum to better explore key issues, as

well as the potential management alternatives and

their potential implications. Participants were invited

because of their knowledge of a particular subject.

Focus groups were convened around the following

topics: Recreation; Environmental Education; Public

Perception/Public Information: Managing a NWR in

the Context of Remediation and Contamination; Trails;

Vegetation Management; and Wildlife Management. 

NATIVE AMERICAN TRIBES

Representatives from the Arapaho Tribe, Cheyenne

and Arapaho Tribes of Oklahoma, Northern Cheyenne

Tribe, the Ute Indian Tribe Business Council, Southern

Ute Tribe, and the Ute Mountain Ute Tribe were

contacted by the Service to solicit their input for the

scoping process. The Service received responses from

the Cheyenne and Arapaho Tribes of Oklahoma and

will continue to work with them during the planning

process. The Service did not receive any scoping

comments from the Tribes.

6.2. RESULTS FROM SCOPING

During the course of the public scoping process, the

planning team received 1,881 comments from the public

or other stakeholders. Every comment was considered

and grouped by topic area (Table 22). The objective of

the scoping process is to gather the full range of

comments, questions and concerns that the public has

about the future Rocky Flats NWR.

Major topics included public use, cultural resources,

real estate, infrastructure, vegetation management,

and wildlife management. Other topics that have

attracted comments include Refuge operations, cleanup

level and remediation issues, and comments on the

planning process. 

Table 22. Percentage of Scoping Comments by Topic

Public Use

Vegetation

Wildlife

Infrastructure

Contamination†

Property‡

Cultural Resources

Refuge Operations

Planning Process

Topic Area

31

13

12

11

10

8

6

6

3

Percentage of 

Comments

† Issues related to contamination and site cleanup are outside the 

scope of this CCP/EIS, as explained in Section 1.8.

‡ Issues related to property include mineral rights, potential land 

acquisitions, and the transportation corridor right of way, all of

which are discussed in Section 2.9. 
Chapter 6: Consultation and Coordination

Final Comprehensive Conservation Plan & EIS 223

Written submissions came in the form of letters, email,

questionnaires, and notes from telephone calls.

Questionnaires were distributed at the public scoping

meetings and could also be downloaded from the

project website. Sixty-two written submissions were

received. All written submissions were carefully read

and evaluated to determine the specific issues or

concerns that were being addressed.

6.3. ALTERNATIVE WORKSHOPS

After the significant issues were identified during the

scoping period, the Service developed alternatives for

the management of the Refuge. In May 2003, the

Service held workshops in Broomfield, Arvada,

Westminster, and Boulder to present four preliminary

management alternatives. The alternatives ranged

from providing little or no public access to extensive

public access and facility development. At each

workshop, the participants were encouraged to provide

comments on the alternatives, and were specifically

asked what they liked or disliked about them.

ISSUES TO RECONSIDER

The public expressed differing opinions on several

issues. The following were the predominant concerns: 

Proposed Action: Re-examine Alternative B and

determine if it should remain as is or be modified in

some specific way.

Equestrian Use: Evaluate whether equestrian use is

consistent with the goals of Alternative B, and if it is

compatible with the Refuge purposes.

Trail Design: Consider modifying trail configurations

in Alternatives B and D to improve connectivity and

enhance visitor experience while minimizing potential

impacts on sensitive natural resources.

Restoration: Consider phasing options that would

accelerate habitat conservation and delay public use

facility and programming development until

restoration efforts are underway.

PUBLIC PREFERENCES

Comments on the alternatives were highly varied as to

people’s desires, with some wanting no public access to

Rocky Flats and some wanting extensive public use.

More people supported Alternative B, either as it is or

with some modifications. A majority of the comments

were related to public use opportunities (42 percent)

and habitat and wildlife management (30 percent).

These percentages reflect what was heard through the

comment period, which ended in June 2003. 

After the workshops were completed, the Service reevaluated all the issues and revised some portions of

the alternatives prior to the development of the

CCP/EIS.

6.4. COMMENTS ON DRAFT EIS

The Draft CCP/EIS was available for public review

from February 19, 2004 to April 25, 2004. In March

2004, the Service held four public hearings on the draft

in Westminster, Boulder, Arvada, and Broomfield. In

addition to the public hearing testimony, comments

were also received in the form of letters, emails, form

letters, and petitions. During the Draft CCP/EIS

comment period, the Service received over 5,000

comments from 251 individuals, 34 agencies/

organizations, and 933 form letters. From those who

specifically stated a preference for a particular

alternative, 21 percent supported Alternative A, 63

percent supported Alternative B, 15 percent for

Alternative C, and 1 percent for Alternative D. 

The most significant issue raised was about public

access and whether there should be any public access

due to past contamination history and the current level

of cleanup on the site and how the DOE retained area

would be demarcated. Other significant issues included

public hunting, prescribed fire and grazing, prairie dog

management, water rights, Lindsay Ranch, cumulative

impacts of adjacent mining, and nearby transportation

improvements. All substantive issues raised in the

comments were addressed in the Final CCP/EIS. 

All of the comments received on the Draft CCP/EIS, as

well as responses to substantive comments, are

included or summarized in Appendix H-Comments

and Responses on the Draft Environmental Impact

Statement (under a separate cover). Public comments

will be available for review at the Front Range

Community College Library, Rocky Flats Reading

Room or at the Rocky Mountain Arsenal National

Wildlife Refuge Visitor Center on weekends.

Responses to comments are included as a companion

document with the Final CCP/EIS.

CHANGES FROM THE DRAFT CCP/EIS

As a result of public comments and concerns about the

Draft CCP/EIS, numerous changes were made to the

Final CCP/EIS. The most significant changes include

the following:

• Trails: New trail configurations for

Alternatives B and D (See Figures 7, 9, 25,

and 27)
Chapter 6: Consultation and Coordination

224 Rocky Flats National Wildlife Refuge 

• Hunting Weaponry: Muzzleloading rifles

were eliminated from the list of weapons to

be allowed for the hunting program.

• Contamination: Expanded discussion of

contamination, cleanup, and the DOE

retained lands (See Sections 1.8, 3.2, and 4.2,

and Appendix E)

• Transportation Improvements: Revised

discussion about the transportation corridor

and nearby transportation improvements

(See Sections 2.10 and 4.16)
Chapter 6: Consultation and Coordination

Final Comprehensive Conservation Plan & EIS 225

6.5. DRAFT CCP/EIS RECIPIENTS

FEDERAL, STATE AND LOCAL AGENCIES

Name

Glen Tucker Agency Toxic Substance and Disease Register 

Scott Fredericksen Federal Aviation Administration

Steve Balzek National Renewable Energy Laboratory

Tim Carey U.S. Army Corps of Engineers

John Rampe U.S. Department of Energy

Frazier Lockart U.S. Department of Energy

Amy Bergstedt U.S. Environmental Protection Agency

Robert Roberts U.S. Environmental Protection Agency

John Brejcha Colorado Board of Land Commissioners

Eric Lane Colorado Department of Agriculture

Ron Cattany Colorado Division of Minerals and Geology

Steve Gunderson Colorado Department of Public Health and Environment

Howard Roitman Colorado Department of Public Health and Environment

Steve Tarlton Colorado Department of Public Health and Environment

Brad Beckham Colorado Department of Transportation

Tim Harris Colorado Department of Transportation

Eric O'Dell Colorado Division of Wildlife

Mike Wedermyer Colorado Division of Wildlife

Scott Hoover Colorado Division of Wildlife

Ken Knox Colorado Division of Water Resources

Charlie Unseld Colorado Department of Local Affairs

Dan Corson Colorado Office of Historic Preservation 

Vicki Cowart Colorado Office of Minerals and Geology

Greg Squire Colorado Office of Minerals and Geology

Bob Finch Colorado State Parks

Roxanne Brickell-Reardon Colorado State Parks

Dan McAuliffe Colorado Water Conservation Board

John Sovell Colorado State University

Dr. George Beck Colorado State University

Len Ackland University of Colorado

Dr. Tim Seastadt University of Colorado 

Bill Broderick Denver Regional Council of Governments

Scott Tucker Urban Drainage and Flood Control District

Honorable Paul Danish Boulder County

Jane Uitti Boulder County 

Rich Koopman Boulder County Parks and Open Space

Scott Robson Boulder County Transportation

Mike Bartleson City and County of Broomfield

Shirley Garcia City and County of Broomfield

Councilor Hank Stoval City and County of Broomfield

Councilor Tom Bruner City and County of Broomfield

Honorable Ken Fellman City of Arvada

Gordon Reusink City of Arvada

Councilor Lorraine Anderson City of Arvada

Clark Johnson City of Arvada

Andrea O'Neill City of Arvada Park Advisory Committee

Shawn McGrath City of Boulder

Mike Weil City of Boulder
Chapter 6: Consultation and Coordination

226 Rocky Flats National Wildlife Refuge 

Jim Crain City of Boulder Open Space

Matt Jones City of Boulder Open Space

Kristin Pritz City of Broomfield Open Space

Councilor Bob Nelson City of Golden

Mike Bestor City of Golden

Gary Klaphake City of Lafayette

Bill Simmons City of Louisville

Philip Nelson City of Northglenn

Jack Ethredge City of Thornton

Ron Hellbusch City of Westminster

Albert Nelson City of Westminster

Lynn Wodell City of Westminster

Councilor Sam Dixon City of Westminster

Honorable Michelle Lawrence Jefferson County

Nannette Neelan Jefferson County

Ken Foelske Jefferson County Open Space

Frank Kunze Jefferson County Open Space

Trustee Karen Imbierowicz Town of Superior

Matt Magley Town of Superior

GOVERNMENT REPRESENTATIVES

Name

Dan Miller Office of Attorney General Ken Salazar

Felicity Hannay Office of Attorney General Ken Salazar

Doug Young Office of Congressman Mark Udall

Terry Van Keuren Office of Congressman Tom Tancredo

John Swartout Office of Governor Bill Owens

Brandy Belta Office of Senator Ben Nighthorse Campbell

Jeanette Alberg Office of Senator Wayne Allard

Kim Cadena Office of Congressman Bob Beauprez

ORGANIZATIONS

Name

Suzanne Webel BATCO - Boulder Area Trails Coalition

Jim McKee Boulder County Nature Assn.; Colorado Wildlife Federation

Jyoti Wind Citizens Concerned About Nuclear Waste Impacts

Steve Davies Cold War Museum

Michael Menefee Colorado Natural Heritage Program

Suzanne O'Neil Colorado Wildlife Federation

David Buckner Esco Associates

Paula Elofson-Gardine Environmental Information Network

David and Doris DePenning Friends of the Foothills

Roman Kohler Homesteaders

Gary Spring International Mountain Biking Association

David Shelton Kaiser-Hill

Bob Meulengracht Mule Deer Foundation

Steve Torbit National Wildlife Federation
Chapter 6: Consultation and Coordination

Final Comprehensive Conservation Plan & EIS 227

Paul Kilburn North Jeffco Area Group

Jim Stone Rocky Flats Cleanup Commission

David Abelson Rocky Flats Coalition of Local Governments

Kimberly Chelboun Rocky Flats Coalition of Local Governments

Tom Gallegos Rocky Flats Citizens Advisory Board

Victor Holm Rocky Flats Citizens Advisory Board

Jerry Henderson Rocky Flats Citizens Advisory Board

William Cossack Rocky Flats Citizens Advisory Board

Ken Korkia Rocky Flats Citizens Advisory Board

Jim Kinsinger Rocky Flats Citizens Advisory Board

Patricia Rice Rocky Flats Citizens Advisory Board

Erin Hamby Rocky Mountain Peace & Justice Center

Tom Marshall Rocky Mountain Peace & Justice Center

LeRoy Moore Rocky Mountain Peace & Justice Center

Hildegard Hix Sierra Club

Joan Seeman Sierra Club

Justin Spring Trust for Public Land

Len Carpenter Wildlife Management Institute

Steve Smith Xcel Energy

NATIVE AMERICAN TRIBES

Name

Anthony Addison, Chairman Arapaho Business Committee

Virgil Franklin, Sr., NAGPRA Contact Cheyenne and Arapaho Tribes of Oklahoma

James Pedro Cheyenne and Arapaho Tribes of Oklahoma

Geri Small, President Northern Cheyenne Tribal Council

Nelson Tallbull Sr., NAGPRA Contact Northern Cheyenne Tribal Council

Leonard Burch, Chairman Southern Ute Tribe

O. Roland McCook Sr., NAGPRA Contact Ute Indian Tribe

Floyd Wopsock, Chairman Ute Indian Tribe Business Committee

Judy Knight-Frank, Chairperson Ute Mountain Ute Tribe

Terry Knight, NAGPRA Ute Mountain Ute Tribe

INDIVIDUALS

Name Name

Bini Abbott Ann Lockhart

Jacques and Carolyn Adam Doug Magee

Donald and Pamela Anderson Julie Maheu

Hildy Armour Brenda Marriott

Amy Bowman Michael Mauro

John Boylan Charlie McKay

Judy Capra Nancy McNally

Judy Childers Caecilia McNeill

Kirk Cunningham Dan and Barb Michaels

Alex Deya-Santiago Chris Morrison

Becky Eades Renee Nelson

Janice Echardt Werner and Nancy Newpert

Judy Enderle Harvey Nichols

Anne Fenerty Shelly Reed
Linda Georges Joel Selbin

John Giezertunner Barbara Taylor

Francesca Giongo Bryan Taylor

Deb Griew Janet Torma

Doug Grinbergs Eric Vogelsberg

Al Gunter Henry Von Struve

Erin Hamby D. Waddington

Jeanniene Haynes Lisa and Rick Woodward

Tom Hoffman Sharon Zuelsdor

Karen Hollweg

Bob Kropfli

PUBLIC LIBRARIES

Name

Arvada Public Library Louisville Public Library

Boulder Public Library Thornton Public Library

Westminster Public Library Mamie Doud Eisenhower Public Library, Broomfield

Golden Public Library Front Range Community College

Daniels Public Library

Chapter 6: Consultation and Coordination

228 Rocky Flats National Wildlife Refuge 
glossary

Glossary

Final Comprehensive Conservation Plan & EIS 231

accessibility: the state or quality of being easily

approached or entered, particularly as it relates to the

Americans With Disabilities Act.

accessible facilities: structures accessible for most

people with disabilities without assistance; ADAaccessible (e.g., parking lots, trails, pathways, ramps).

adaptive management: the rigorous application of

management, research, and monitoring to gain

information and experience necessary to assess and

modify management activities. A process that uses

feedback from refuge research and monitoring and

evaluation of management actions to support or modify

objectives and strategies at all planning levels.

alternative: a reasonable way to fix an identified

problem or satisfy a stated need (40 CFR 1500.2 [cf.

"management alternative"]).

alluvium: soils that have been formed by the

deposition of water borne materials.

appropriate use: a proposed or existing use of a

national wildlife refuge that (1) supports the Refuge

System Mission, the major purposes, goals or

objectives of the refuge; (2) is necessary for the safe

and effective conduct of a priority general public use on

the refuge; (3) is otherwise determined under Service

Manual Chapter 605 FW1 (draft), by the Refuge

Manager and Refuge Supervisor to be appropriate.

aquifer: a formation, group of formations, or part of a

formation that contains sufficient saturated, permeable

material to yield significant quantities of water to wells

and springs.

aquitard: a layer of rock having low permeability that

stores groundwater but delays its flow.

biodiversity: the variety of life in all its forms.

breeding habitat: habitat used by migratory birds or

other animals during the breeding season.

buffer zones: land bordering and protecting critical

habitats; areas created or sustained to lessen the

negative effects of land development on animals, plants,

and their habitats.

candidate species: species for which the Service has

sufficient information on file about their biological

vulnerability and threats to propose their listing under

the Endangered Species Act.

CERCLA: The Comprehensive Environmental

Response, Compensation, and Liability Act (commonly

known as Superfund), which created a tax on the

chemical and petroleum industries to, among other

purposes, establish a trust fund to provide for longterm cleanup of contaminated sites.

Chronic Wasting Disease: a contagious fatal

neurological disease among deer and elk that produces

small lesions in brains of infected animals. It is

characterized by loss of body condition, behavioral

abnormalities and death.

community: the locality in which a group of people

resides and shares the same government.

vegetation community type: a particular assemblage

of plants and animals, named for its dominant

characteristic.

compatible use: “a wildlife-dependent recreational use

or any other use of a refuge that, in the sound

professional judgment of the Director, will not

materially interfere with or detract from the fulfillment

of the mission of the System or the purposes of the

refuge" (National Wildlife Refuge System

Improvement Act of 1997 [Public Law 105-57; 111 Stat.

1253]).

compatibility determination: a required determination

for wildlife-dependent recreational uses or any other

public uses of a refuge before a use is allowed.

Comprehensive Conservation Plan: a document

mandated by the National Wildlife Refuge System

Improvement Act of 1997 that describes desired future

conditions for a refuge unit, and provides long-range

guidance for the unit leader to accomplish the mission

of the System and the purpose(s) of the unit (P.L. 105-

57;FWS Manual 602 FW 1.4).

concern: cf. "issue."

conservation: managing natural resources to prevent

loss or waste (N.b. Management actions may include

preservation, restoration, and enhancement).

conservation agreements: voluntary written

agreements among two or more parties for the purpose

of ensuring the survival and welfare of unlisted species

of fish and wildlife or their habitats or to achieve other

specified conservation goals.

conservation easement: a legal agreement between a

landowner and a land trust (a private, nonprofit

conservation organization) or government agency that

permanently limits uses of a property to protect its

conservation values.

cooperative agreement: the legal instrument used

when the principal purpose of a transaction is the

transfer of money, property, services, or anything of

value to a recipient in order to accomplish a public

purpose authorized by Federal statute, and substantial
Glossary

232 Rocky Flats National Wildlife Refuge 

involvement between the Service and the recipient is

anticipated (cf. "grant agreement").

cultural resource: a general term applied to buildings,

structures, landscape features, places, or other

identifiable artifacts of scientific, aesthetic, educational,

spiritual, archaeological, architectural, or historic

significance. Can also be more narrowly defined to

refer to a prehistoric or historic district, site, building,

structure or object listed in or eligible for listing in the

National Register of Historic Places.

designated wilderness area: an area designated by

Congress as part of the National Wilderness

Preservation System (FWS Manual 610 FW 1.5

[draft]).

disturbed area: an area where natural processes have

been degraded or destroyed due to human impacts

(e.g., mining, cultivation, development).

easement: an agreement by which landowners give up

or sell one of the rights on their property (e.g., ditch

owners may have an easement to maintain the

waterway [cf. "conservation easement"]).

ecosystem: a natural community of organisms

interacting with its physical environment, regarded as

a unit.

endangered species: a Federal- or State-listed

protected species that is in danger of extinction

throughout all or a significant portion of its range.

environmental education: education aimed at

producing a citizenry that is knowledgeable about the

biophysical environment and its associated problems,

aware of how to help solve these problems, and

motivated to work toward their solution" (Stapp et al.

1969).

Environmental Impact Statement: (EIS) a detailed,

written analysis of the environmental impacts of a

proposed action, adverse effects of the project that

cannot be avoided, alternative courses of action, shortterm uses of the environment versus the maintenance

and enhancement of long-term productivity, and any

irreversible and irretrievable commitment of resources

(cf. 40 CFR 1508.11).

erosion: the detachment and movement of soil from the

land by wind, water, or gravity.

extirpated: no longer occurring in a given geographic

area.

Federal land: public land owned by the Federal

Government, including national forests, national parks,

and national wildlife refuges.

Federally listed species: a species listed either as

endangered, threatened, or a species at risk (formerly,

a "candidate species") under the Endangered Species

Act of 1973, as amended.

geographic information system: (GIS) a computerized

system to compile, store, analyze and display

geographically referenced information (e.g., GIS can

overlay multiple sets of information on the distribution

of a variety of biological and physical features).

global positioning system: (GPS) a satellite-based

navigation and positioning system that can be used to

locate and store specific points on the earth. GPS

technology can be used to create accurate maps of

refuge resources or management issues (such as weed

patches) that can be easily loaded onto a GIS for

analysis.

habitat fragmentation: the breaking up of a specific

habitat into smaller, unconnected areas (N.b. A habitat

area that is too small may not provide enough space to

maintain a breeding population of the species in

question).

habitat conservation: protecting an animal or plant

habitat to ensure that the use of that habitat by the

animal or plant is not altered or reduced.

habitat: the place where a particular type of plant or

animal lives.

hay meadow: reference to a 300-acre portion of Rocky

Flats that was once cultivated for agriculture and is

now comprised primarily of non-native smooth brome

and crested wheatgrass. In its current condition, the

hay meadow provides marginal wildlife habitat, though

it does not adversely affect other Refuge resources.

informal monitoring: (see monitoring) the on-going

observation of resource conditions and needs by

Service staff that does not follow a pre-determined

schedule or observation method. 

Integrated Pest Management: (IPM) sustainable

approach to managing pests by combining biological,

cultural, physical, and chemical tools in a way that

minimizes economic, health, and environmental risks.

interpretive facilities: structures that provide

information about an event, place, or thing by a variety

of means, including printed, audiovisual, or multimedia

materials (e.g., kiosks that offer printed materials and

audiovisuals, signs, and trail heads).

forbs: flowering plants (excluding grasses, sedges, and

rushes) that do not have a woody stem and die back to

the ground at the end of the growing season.
Glossary

Final Comprehensive Conservation Plan & EIS 233

interpretive materials: any tool used to provide or

clarify information, explain events or things, or

increase awareness and understanding of the events or

things (e.g., printed materials like brochures, maps or

curriculum materials; audio/visual materials like video

and audio tapes, films, or slides; and, interactive

multimedia materials, CD-ROM or other computer

technology).

issue: any unsettled matter that requires a

management decision (e.g., a Service initiative, an

opportunity, a management problem, a threat to the

resources of the unit, a conflict in uses, a public

concern, or the presence of an undesirable resource

condition).

local agencies: generally, municipal governments,

regional planning commissions, or conservation groups.

long-term protection: mechanisms like fee title

acquisition, conservation easements, or binding

agreements with landowners that ensure land use and

land management practices will remain compatible

with maintaining species populations over the long

term.

managed grazing: the use of livestock such as cattle or

goats for purposes other than livestock production

(including weed management and vegetative

succession). Often requires fencing and moving

animals in an organized fashion to achieve resource

management objectives.

management alternative: a set of objectives and the

strategies needed to accomplish each objective [FWS

Manual 602 FW 1.4].

management concern: cf. "issue"; "migratory nongame

birds of management concern."

management opportunity: cf. "issue."

management plan: a plan that guides future land

management practices on a tract.

management strategy: a general approach to meeting

unit objectives (N.b. A strategy may be broad, or it

may be detailed enough to guide implementation

through specific actions, tasks, and projects [FWS

Manual 602 FW 1.4]).

mission statement: a succinct statement of the purpose

for which the unit was established; its reason for being.

mitigation: actions taken to compensate for the

negative effects of a particular project (e.g., wetland

mitigation usually restores or enhances a previously

damaged wetland or creates a new wetland).

mixed grassland prairie: a combination of several

grassland communities, including mesic mixed

grassland, short grassland, xeric needle and thread

grassland, and reclaimed mixed grassland, that are

composed of similar types of native and non-native

grasses and have common management requirements. 

monitoring: the collection of scientific information to

determine the effects of resource management actions

and to identify changing resource conditions or needs.

multi-use trails: trails designated for a variety of uses

including hiking, biking and, in some cases, equestrian

use.

National Environmental Policy Act of 1969: (NEPA)

requires all Federal agencies to examine the

environmental impacts of their actions, incorporate

environmental information, and use public participation

in planning and implementing environmental actions.

(Federal agencies must integrate NEPA with other

planning requirements, and prepare appropriate

NEPA documents to facilitate better environmental

decision-making [cf. 40 CFR 1500].)

National Register of Historic Places: Authorized

under the National Historic Preservation Act of 1966,

the National Register is the nation's official list of

cultural resources worthy of preservation. National

Register properties are distinguished by having been

documented and evaluated according to uniform

standards. 

National Wildlife Refuge Complex: (Complex) an

internal Service administrative linking of refuge units

closely related by their purposes, goals, ecosystem, or

geopolitical boundaries. In this case, referring to the

Rocky Mountain Arsenal National Wildlife Refuge

(NWR), Two Ponds NWR, and Rocky Flats NWR as a

complex.

National Wildlife Refuge System: (System) all lands

and waters and interests therein administered by the

Service as wildlife refuges, wildlife ranges, wildlife

management areas, waterfowl production areas, and

other areas for the protection and conservation of fish

and wildlife, including those that are threatened with

extinction.

native species: a plant or animal that has grown in the

region since the last glaciation and occurred before

European settlement.

Notice of Intent: (NOI) an announcement published in

the Federal Register that states what the an agency

will prepare and review an environmental impact

statement [40 CFR 1508.22].
Glossary

234 Rocky Flats National Wildlife Refuge 

noxious weeds: non-native species that have been

introduced into an area and, because of their

aggressive growth and lack of natural predators,

displace native species.

objective: a concise statement of what the Service

wants to achieve, how much to achieve, when and

where to achieve it, and who is responsible for the

work. Objectives derive from goals and provide the

basis for determining strategies, monitoring refuge

accomplishments, and evaluating the success of

strategies. Objectives are made to be attainable, timespecific, and measurable.

off-trail use: designated areas where visitors are

permitted to traverse across the landscape and are not

limited to the trail corridors.

outdoor classroom: an environmental education facility

that provides learning space and storage for

educational materials and props in the field.

overlook: A designated viewing area often furnished

with a bench and interpretive signage.

partnership: a contract or agreement among two or

more individuals, groups of individuals, organizations,

or agencies, in which each agrees to famish a part of

the capital or some service in kind (e.g., labor) for a

mutually beneficial enterprise.

patch: a relatively homogenous habitat area that is

not interrupted by disturbance corridors such as

roads, trails, or fences.

permitted mining use: an area in which an outside

party owns the rights to subsurface minerals and a

permit to mine those minerals. Mining could occur on

these areas.

picocurie: A unit of measurement for radioactivity,

equal to one trillionth of a curie (1x10-12). A curie is a

unit of radioactivity, based originally on the

radioactivity of 1 gram of pure radium, equal to 37

billion disintegrations per second.

Planning Updates: newsletters distributed, primarily

through mailing lists, in order to update the

interested public on the status of the CCP project.

pre-settlement condition: a conceptual goal for habitat

restoration based on ecological conditions that existed

prior to ranching and modern use and disturbance of

the site. 

prescribed fire: the application of fire to wildland

fuels, either by natural or intentional ignition, to

achieve identified land use objectives (FWS Manual

621 FW 1.7).

private land: land owned by a private individual or

group or non-government organization.

private landowner: cf. "private land."

private organization: any non-government

organization.

Proposed Action (or alternative): activities for which

an Environmental Impact Statement is being written;

the alternative containing the actions and strategies

recommended by the planning team. The proposed

action is, for all proactive purposes, the draft CCP for

the Refuge. (Referred to as the Preferred Alternative

in the Final CCP/EIS).

pedestrian trails: trails designated for hiking use only

and not opened to other modes of transportation such

as biking or equestrian uses.

protection: mechanisms like fee title acquisition,

conservation easements, or binding agreements with

landowners that ensure land use and land management

practices will remain compatible with maintaining

species populations at a site (cf. “long-term ")

public: individuals, organizations, and non-government

groups; officials of Federal, State, and local

government agencies; Native American tribes, and

foreign nations includes anyone outside the core

planning team, those who may or may not have

indicated an interest in the issues and those who do or

do not realize that our decisions may affect them.

public involvement: offering to interested individuals

and organizations that our actions or policies may

affect an opportunity to become informed; soliciting

their opinion.

public involvement plan: long-term guidance for

involving the public in the comprehensive planning

process.

public land: land owned by the local, State, or Federal

Government.

rare species: species identified for special management

emphasis because of their uncommon occurrence.

rare community types: plant community types

classified as rare by any State program (as used in

CCPs, includes exemplary community types).

recommended wilderness: areas studied and found

suitable for wilderness designation by both the

Director (FWS) and Secretary (DOI), and

recommended by the President to Congress for

inclusion in the National Wilderness System (FWS

Manual 610 FW 1.5 [draft]).
Glossary

Final Comprehensive Conservation Plan & EIS 235

Record of Decision: (ROD) a concise public record of a

decision by a Federal agency pursuant to NEPA. (N.b.

A ROD includes: the decision; all the alternatives

considered; the environmentally preferable alternative;

a summary of monitoring and enforcement, where

applicable, for any mitigation; and, whether all practical

means have been adopted to avoid or minimize

environmental harm from the alternative selected [or if

not, why not].)

refuge goals: ”descriptive, open-ended, and often

broad statements of desired future conditions that

convey a purpose but do not define measurable units"

(Writing Refuge Management Goals and Objectives: A

Handbook).

refuge management economic activity: a management

activity on a national wildlife refuge that results in the

generation of a commodity which is or can be sold as

income or revenue or can be traded for goods and

services. Examples include: farming, grazing, haying,

timber harvesting, and trapping.

Refuge Manager: the official directly in charge of a

national wildlife refuge or a wildlife refuge complex.

refuge purposes: “The purposes specified in or derived

from the law, proclamation, executive order, agreement,

public land order, donation document, or administrative

memorandum establishing, authorizing, or expanding a

refuge, refuge unit, or refuge subunit" (National

Wildlife Refuge System Improvement Act of 1997).

refuge lands: lands in which the Service holds full

interest in fee title or partial interest like an easement.

refuge use: a recreational use (including actions

associated with a recreational use or other general

public use), or refuge management economic activity.

Regional Chief: the official in charge of the National

Wildlife Refuge System within a Region of the U.S.

Fish and Wildlife Service.

relative cover: a measure of abundance for individual

plant species or group of species of interest in a

specified area, relative to the total cover all species.

Can be expressed as a percentage.

restoration: the artificial manipulation of habitat to

restore it to its former condition (e.g., restoration may

involve planting native grasses and forbs, removing

shrubs, prescribed burning, or re-establishing habitat

for native plants and animals on degraded grassland).

restored stream crossing: obstructions such as

culverts, roads and trails are removed or restructured

to allow stream flows to return to a more 

natural condition.

revegetation: the process of establishing a 

native plant community in an area that was formerly

disturbed. May involve removing existing non-native

vegetation, grading, soil preparation, seeding, and

supplemental irrigation.

RFCA Parties: the agencies that are signatories 

to the Rocky Flats Cleanup Agreement: U.S.

Department of Energy, Environmental Protection

Agency, and the Colorado Department of Public Health

and Environment.

riparian area: see riparian habitat.

riparian habitat: habitat along the banks of a stream

or river that is characterized by trees and shrubs 

(such as cottonwood and willow) that grow in 

moist conditions. 

right of way: that land on which a public road may be

built within The Refuge boundary. 

runoff: water from rain, melted snow, or agricultural or

landscape irrigation that flows over a land surface into

a water body (cf. "urban runoff").

scoping: the process used at the beginning of a

planning process to engage the public and other

agencies to determine the scope and significant issues

to be addressed in the plan and analyzed in the EIS.

seasonal closures: areas and/or trails closed for the

protection of wildlife based on their annual life cycles

and habitat needs. Closures are seasonal and are

determined by Refuge staff.

sedimentation: the introduction of eroded soil particles

to a water body which can result in increased turbidity

(cloudiness) and affect aquatic plants and animals. 

Service presence: Service programs and facilities that

it directs or shares with other organizations; public

awareness of the Service as a sole or cooperative

provider of programs and facilities.

site improvement: any activity that changes the

condition of an existing site to better interpret events,

places, or things related to a refuge (e.g., improving

safety and access, replacing non-native with native

plants, refurbishing footbridges and trail ways, and

renovating or expanding exhibits).

Refuge mailing list: A list containing names and

addresses of people with an interest in the Refuge. As

part of the planning process, the list was continually

updated to include conservation agencies, recreation

interests, Congressionals, workbook respondents, open

house/focus group attendees, etc.
Glossary

236 Rocky Flats National Wildlife Refuge 

social trail: unplanned trails that develop informally

through repeated use. Are commonly formed between

planned trails and points of interest.

soil productivity: The overall productive status of a soil

arising from all aspects of its quality, such as its

physical and structural condition as well as its chemical

content.

species of concern: species not federally listed as

threatened or endangered, but about which the Service

or our partners are concerned.

stabilization: reinforcing a building (e.g., Lindsay

Barn) to avoid further deterioration of its 

structural integrity.

State agencies: generally, natural resource agencies of

State governments.

State land: State-owned public land.

State-listed species: cf. Wildlife species that are listed

as threatened or endangered within the State of

Colorado by the Colorado Division of Wildlife.

step-down management plan: a plan for dealing with

specific refuge management subjects, strategies, and

schedules, e.g., hunting, vegetation and fire (FWS

Manual 602 FW 1.4).

target population: the preferred number of animals

(deer or elk) that live on the Refuge, as determined

by Service and CDOW staff based on fluctuating

habitat conditions. 

threatened species: a Federally listed, protected

species that is likely to become an endangered species

in all or a significant portion of its range.

urban runoff: water from rain, melted snow, or

landscape irrigation flowing from city streets and

domestic or commercial properties that may carry

pollutants into a sewer system or water body.

vision statement: a concise statement of what the unit

could achieve in the next 10 to 15 years.

visitor center: a permanently staffed building offering

exhibits and interpretive information to the visiting

public. Some visitor centers are co-located with refuge

offices, others include additional facilities such as

classrooms or wildlife viewing areas.

visitor contact station: compared to a visitor center, a

contact station is a smaller facility that may not be

permanently staffed.

viewing blind: a structure that provides shelter 

and a suitable vantage for wildlife observation 

and photography.

warm-season grass: native prairie grass that grows

the most during summer, when cool-season grasses are

dormant.

trail connections: trailheads along the refuge boundary

that provide a link to outlying trail systems.

watchable wildlife: wildlife that are visible and

enjoyed by Refuge visitors. A watchable wildlife

program is one that helps maintain viable populations

of all native fish and wildlife species by building an

active, well-informed constituency for conservation.

Watchable wildlife programs are tools for meeting

wildlife conservation goals while at the same time

fulfilling public demand for wildlife-dependent

recreational activities (other than sport hunting, sport

fishing, or trapping).

water bar: a constructed trail structure that diverts

water off of the trail surface. May consist of a earthen

berm, rock, wood, or other materials.

watershed: the geographic area within which water

drains into a particular river, stream, or body of water;

land and the body of water into which the land drains.

wetlands: lands transitional between terrestrial and

aquatic systems where the water table is usually at or

near the surface or the land is covered by shallow

water" (Cowardin et al 1979).

wilderness: cf. "designated wilderness."

wildfire: a free-burning fire requiring a suppression

response; all fire other than prescribed fire that occurs

on wildlands (FWS Manual 621 FW 1.7).

wildland fire: every wildland fire is either a wildfire or

a prescribed fire (FWS Manual 621 FW 1.3).

wildlife management: manipulating wildlife

populations, either directly by regulating the numbers,

ages, and sex ratios harvested, or indirectly by

providing favorable habitat conditions and alleviating

limiting factors.

wildlife-dependent recreation: recreational

experiences in which wildlife is the focus. The terms

“wildlife-dependent recreation” and '”wildlifedependent recreational use” mean a use of a refuge

involving hunting, fishing, wildlife observation and

photography, or environmental education and

interpretation (National Wildlife Refuge System

Improvement Act of 1997).
appendices

appendix a

Refuge Legislation

Final Comprehensive Conservation Plan & EIS 241

PUBLIC LAW 107–107—DEC. 28, 2001 115 STAT. 1379

defense plutonium or defense plutonium materials to the Savannah

River Site during the period beginning on February 1, 2002, and

ending on the date on which such plans are submitted to Congress.

(g) RULE OF CONSTRUCTION.—Nothing in this section may be

construed to prohibit or limit the Secretary from shipping defense

plutonium or defense plutonium materials to sites other than the

Savannah River Site during the period referred to in subsection

(f) or any other period.

(h) ANNUAL REPORT ON FUNDING FOR FISSILE MATERIALS DISPOSITION ACTIVITIES.—The Secretary shall include with the budget

justification materials submitted to Congress in support of the

Department of Energy budget for each fiscal year (as submitted

with the budget of the President under section 1105(a) of title

31, United States Code) a report setting forth the extent to which

amounts requested for the Department for such fiscal year for

fissile materials disposition activities will enable the Department

to meet commitments for the disposition of surplus defense plutonium and defense plutonium materials located at the Savannah

River Site, and for any other fissile materials disposition activities,

in such fiscal year.

SEC. 3156. MODIFICATION OF DATE OF REPORT OF PANEL TO ASSESS

THE RELIABILITY, SAFETY, AND SECURITY OF THE

UNITED STATES NUCLEAR STOCKPILE.

Section 3159(d) of the Strom Thurmond National Defense

Authorization Act for Fiscal Year 1999 (Public Law 105–261; 42

U.S.C. 2121 note) is amended by striking ‘‘of each year, beginning

with 1999,’’ and inserting ‘‘of 1999 and 2000, and not later than

February 1, 2002,’’.

Subtitle F—Rocky Flats National Wildlife

Refuge

SEC. 3171. SHORT TITLE.

This subtitle may be cited as the ‘‘Rocky Flats National Wildlife

Refuge Act of 2001’’.

SEC. 3172. FINDINGS AND PURPOSES.

(a) FINDINGS.—Congress finds the following:

(1) The Federal Government, through the Atomic Energy

Commission, acquired the Rocky Flats site in 1951 and began

operations there in 1952. The site remains a Department of

Energy facility. Since 1992, the mission of the Rocky Flats

site has changed from the production of nuclear weapons components to cleanup and closure in a manner that is safe, environmentally and socially responsible, physically secure, and costeffective.

(2) The majority of the Rocky Flats site has generally

remained undisturbed since its acquisition by the Federal

Government.

(3) The State of Colorado is experiencing increasing growth

and development, especially in the metropolitan Denver Front

Range area in the vicinity of the Rocky Flats site. That growth

and development reduces the amount of open space and thereby

diminishes for many metropolitan Denver communities the

vistas of the striking Front Range mountain backdrop.

Rocky Flats

National Wildlife

Refuge Act of

2001.

16 USC 668dd

note.

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242 Rocky Flats National Wildlife Refuge 

115 STAT. 1380 PUBLIC LAW 107–107—DEC. 28, 2001

(4) Some areas of the Rocky Flats site contain contamination and will require further response action. The national

interest requires that the ongoing cleanup and closure of the

entire site be completed safely, effectively, and without unnecessary delay and that the site thereafter be retained by the

United States and managed so as to preserve the value of

the site for open space and wildlife habitat.

(5) The Rocky Flats site provides habitat for many wildlife

species, including a number of threatened and endangered species, and is marked by the presence of rare xeric tallgrass

prairie plant communities. Establishing the site as a unit of

the National Wildlife Refuge System will promote the preservation and enhancement of those resources for present and future

generations.

(b) PURPOSES.—The purposes of this subtitle are—

(1) to provide for the establishment of the Rocky Flats

site as a national wildlife refuge following cleanup and closure

of the site;

(2) to create a process for public input on the management

of the refuge referred to in paragraph (1) before transfer of

administrative jurisdiction to the Secretary of the Interior;

and

(3) to ensure that the Rocky Flats site is thoroughly and

completely cleaned up.

SEC. 3173. DEFINITIONS.

In this subtitle:

(1) CERCLA.—The term ‘‘CERCLA’’ means the Comprehensive Environmental Response, Compensation, and Liability Act

of 1980 (42 U.S.C. 9601 et seq.).

(2) CLEANUP AND CLOSURE.—The term ‘‘cleanup and closure’’ means the response actions for covered substances carried

out at Rocky Flats, as required by any of the following:

(A) The RFCA.

(B) CERCLA.

(C) RCRA.

(D) The Colorado Hazardous Waste Act, 25–15–101

to 25–15–327, Colorado Revised Statutes.

(3) COVERED SUBSTANCE.—The term ‘‘covered substance’’

means any of the following:

(A) Any hazardous substance, as such term is defined

in paragraph (14) of section 101 of CERCLA (42 U.S.C.

9601).

(B) Any pollutant or contaminant, as such term is

defined in paragraph (33) of such section 101.

(C) Any petroleum, including crude oil or any fraction

thereof which is not otherwise specifically listed or designated as a hazardous substance under subparagraphs

(A) through (F) of paragraph (14) of such section 101.

(4) RCRA.—The term ‘‘RCRA’’ means the Solid Waste Disposal Act (42 U.S.C. 6901 et seq.), popularly known as the

Resource Conservation and Recovery Act.

(5) REFUGE.—The term ‘‘refuge’’ means the Rocky Flats

National Wildlife Refuge established under section 3177.

(6) RESPONSE ACTION.—The term ‘‘response action’’ means

any of the following:

Appendix A: Refuge Legislation
Final Comprehensive Conservation Plan & EIS 243

PUBLIC LAW 107–107—DEC. 28, 2001 115 STAT. 1381

(A) A response, as such term is defined in paragraph

(25) of section 101 of CERCLA (42 U.S.C. 9601).

(B) A corrective action under RCRA or under the Colorado Hazardous Waste Act, 25–15–101 to 25–15–327, Colorado Revised Statutes.

(C) Any requirement for institutional controls imposed

by any of the laws referred to in subparagraph (A) or

(B).

(7) RFCA.—The term ‘‘RFCA’’ means the Rocky Flats

Cleanup Agreement, an intergovernmental agreement, dated

July 19, 1996, among—

(A) the Department of Energy;

(B) the Environmental Protection Agency; and

(C) the Department of Public Health and Environment

of the State of Colorado.

(8) ROCKY FLATS.—

(A) IN GENERAL.—Except as provided in subparagraph

(B), the term ‘‘Rocky Flats’’ means the Rocky Flats Environmental Technology Site, Colorado, a defense nuclear

facility, as depicted on the map titled ‘‘Rocky Flats Environmental Technology Site’’, dated October 22, 2001, and available for inspection in the appropriate offices of the United

States Fish and Wildlife Service.

(B) EXCLUSIONS.—The term ‘‘Rocky Flats’’ does not

include—

(i) the land and facilities of the Department of

Energy’s National Renewable Energy Laboratory,

including the acres retained by the Secretary under

section 3174(f); and

(ii) any land and facilities not within the boundaries depicted on the map referred to in subparagraph

(A).

(9) SECRETARY.—The term ‘‘Secretary’’ means the Secretary

of Energy.

SEC. 3174. FUTURE OWNERSHIP AND MANAGEMENT.

(a) FEDERAL OWNERSHIP.—Except as expressly provided in this

subtitle, all right, title, and interest of the United States, held

on or acquired after the date of the enactment of this Act, to

land or interest therein, including minerals, within the boundaries

of Rocky Flats shall be retained by the United States.

(b) LINDSAY RANCH.—The structures that comprise the former

Lindsay Ranch homestead site in the Rock Creek Reserve area

of the buffer zone, as depicted on the map referred to in section

3173(8)(A), shall be permanently preserved and maintained in

accordance with the National Historic Preservation Act (16 U.S.C.

470 et seq.).

(c) PROHIBITION ON ANNEXATION.—Neither the Secretary nor

the Secretary of the Interior shall allow the annexation of land

within the refuge by any unit of local government.

(d) PROHIBITION ON THROUGH ROADS.—Except as provided in

subsection (e), no public road shall be constructed through Rocky

Flats.

(e) TRANSPORTATION RIGHT-OF-WAY.—

(1) IN GENERAL.—

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244 Rocky Flats National Wildlife Refuge 

115 STAT. 1382 PUBLIC LAW 107–107—DEC. 28, 2001

(A) AVAILABILITY OF LAND.—On submission of an

application meeting each of the conditions specified in paragraph (2), the Secretary, in consultation with the Secretary

of the Interior, shall make available land along the eastern

boundary of Rocky Flats for the sole purpose of transportation improvements along Indiana Street.

(B) BOUNDARIES.—Land made available under this

paragraph may not extend more than 300 feet from the

west edge of the Indiana Street right-of-way, as that rightof-way exists as of the date of the enactment of this Act.

(C) EASEMENT OR SALE.—Land may be made available

under this paragraph by easement or sale to one or more

appropriate entities.

(D) COMPLIANCE WITH APPLICABLE LAW.—Any action

under this paragraph shall be taken in compliance with

applicable law.

(2) CONDITIONS.—An application referred to in paragraph

(1) meets the conditions specified in this paragraph if the

application—

(A) is submitted by any county, city, or other political

subdivision of the State of Colorado; and

(B) includes documentation demonstrating that the

transportation improvements for which the land is to be

made available—

(i) are carried out so as to minimize adverse effects

on the management of Rocky Flats as a wildlife refuge;

and

(ii) are included in the regional transportation plan

of the metropolitan planning organization designated

for the Denver metropolitan area under section 5303

of title 49, United States Code.

(f) WIND TECHNOLOGY EXPANSION AREA.—The Secretary shall

retain, for the use of the National Renewable Energy Laboratory,

the approximately 25 acres identified on the map referred to in

section 3173(8)(A) as the ‘‘Wind Technology Expansion Area’’.

SEC. 3175. TRANSFER OF MANAGEMENT RESPONSIBILITIES AND JURISDICTION OVER ROCKY FLATS.

(a) TRANSFER REQUIRED.— (1) IN GENERAL.—Subject to the other provisions of this

section, the Secretary shall transfer administrative jurisdiction

over the property that is to comprise the refuge to the Secretary

of the Interior.

(2) DATE OF TRANSFER.—The transfer shall be carried out

not earlier than the completion certification date, and not later

than 30 business days after that date.

(3) COMPLETION CERTIFICATION DATE.—For purposes of

paragraph (2), the completion certification date is the date

on which the Administrator of the Environmental Protection

Agency certifies to the Secretary and to the Secretary of the

Interior that cleanup and closure at Rocky Flats has been

completed, except for the operation and maintenance associated

with response actions, and that all response actions are operating properly and successfully.

(b) MEMORANDUM OF UNDERSTANDING.— (1) REQUIRED ELEMENTS.—The transfer required by subsection (a) shall be carried out pursuant to a memorandum

Appendix A: Refuge Legislation
Final Comprehensive Conservation Plan & EIS 245

PUBLIC LAW 107–107—DEC. 28, 2001 115 STAT. 1383

of understanding between the Secretary and the Secretary of

the Interior. The memorandum of understanding shall—

(A) provide for the division of responsibilities between

the Secretary and the Secretary of the Interior necessary

to carry out such transfer;

(B) address the impacts that any property rights

referred to in section 3179(a) may have on the management

of the refuge, and provide strategies for resolving or mitigating these impacts;

(C) identify the land the administrative jurisdiction

of which is to be transferred to the Secretary of the Interior;

and

(D) specify the allocation of the Federal costs incurred

at the refuge after the date of such transfer for any site

investigations, response actions, and related activities for

covered substances.

(2) PUBLICATION OF DRAFT.—Not later than one year after

the date of the enactment of this Act, the Secretary and the

Secretary of the Interior shall publish in the Federal Register

a draft of the memorandum of understanding.

(3) FINALIZATION AND IMPLEMENTATION.— (A) Not later than 18 months after the date of the

enactment of this Act, the Secretary and Secretary of the

Interior shall finalize and implement the memorandum

of understanding.

(B) In finalizing the memorandum of understanding,

the Secretary and Secretary of the Interior shall specifically

identify the land the administrative jurisdiction of which

is to be transferred to the Secretary of the Interior and

provide for a determination of the exact acreage and legal

description of such land by a survey mutually satisfactory

to the Secretary and the Secretary of the Interior.

(c) TRANSFER OF IMPROVEMENTS.—The transfer required by

subsection (a) may include such buildings or other improvements

as the Secretary of the Interior has requested in writing for purposes of managing the refuge.

(d) PROPERTY RETAINED FOR RESPONSE ACTIONS.—

(1) IN GENERAL.—The transfer required by subsection (a)

shall not include, and the Secretary shall retain jurisdiction,

authority, and control over, the following real property and

facilities at Rocky Flats:

(A) Any engineered structure, including caps, barrier

walls, and monitoring or treatment wells, to be used in

carrying out a response action for covered substances.

(B) Any real property or facility to be used for any

other purpose relating to a response action or any other

action that is required to be carried out by the Secretary

at Rocky Flats.

(2) CONSULTATION.—The Secretary shall consult with the

Secretary of the Interior, the Administrator of the Environmental Protection Agency, and the Governor of the State of

Colorado on the identification of all real property and facilities

to be retained under this subsection.

(e) COST.—The transfer required by subsection (a) shall be

completed without cost to the Secretary of the Interior.

(f) NO REDUCTION IN FUNDS.—The transfer required by subsection (a), and the memorandum of understanding required by

Appendix A: Refuge Legislation
246 Rocky Flats National Wildlife Refuge 

115 STAT. 1384 PUBLIC LAW 107–107—DEC. 28, 2001

subsection (b), shall not result in any reduction in funds available

to the Secretary for cleanup and closure of Rocky Flats.

SEC. 3176. ADMINISTRATION OF RETAINED PROPERTY; CONTINUATION OF CLEANUP AND CLOSURE.

(a) ADMINISTRATION OF RETAINED PROPERTY.—

(1) IN GENERAL.—In administering the property retained

under section 3175(d), the Secretary shall consult with the

Secretary of the Interior to minimize any conflict between—

(A) the administration by the Secretary of such property for a purpose relating to a response action; and

(B) the administration by the Secretary of the Interior

of land the administrative jurisdiction of which is transferred under section 3175(a).

(2) PRIORITY IN CASE OF CONFLICT.—In the case of any

such conflict, the Secretary and the Secretary of the Interior

shall ensure that the administration for a purpose relating

to a response action, as described in paragraph (1)(A), shall

take priority.

(3) ACCESS.—The Secretary of the Interior shall provide

to the Secretary such access and cooperation with respect to

the refuge as the Secretary requires to carry out operation

and maintenance, future response actions, natural resources

restoration, or any other obligations.

(b) ONGOING CLEANUP AND CLOSURE.—

(1) IN GENERAL.—The Secretary shall carry out to completion cleanup and closure at Rocky Flats.

(2) CLEANUP LEVELS.—The Secretary shall carry out such

cleanup and closure to the levels established for soil, water,

and other media, following a thorough review by the parties

to the RFCA and the public (including the United States Fish

and Wildlife Service and other interested government agencies)

of the appropriateness of the interim levels in the RFCA.

(3) NO RESTRICTION ON USE OF NEW TECHNOLOGIES.—

Nothing in this subtitle, and no action taken under this subtitle,

restricts the Secretary from using at Rocky Flats any new

technology that may become available for remediation of

contamination.

(c) OPPORTUNITY TO COMMENT.—The Secretary of the Interior

shall have the opportunity to comment with respect to any proposed

response action as to the impacts, if any, of such proposed response

action on the refuge.

(d) RULES OF CONSTRUCTION.—

(1) NO RELIEF FROM OBLIGATIONS UNDER OTHER LAW.—

Nothing in this subtitle, and no action taken under this

subtitle—

(A) relieves the Secretary, the Administrator of the

Environmental Protection Agency, the Secretary of the

Interior, or any other person from any obligation or other

liability with respect to Rocky Flats under the RFCA or

any Federal or State law;

(B) impairs or alters any provision of the RFCA; or

(C) alters any authority of the Administrator of the

Environmental Protection Agency under section 120(e) of

CERCLA (42 U.S.C. 9620(e)), or any authority of the State

of Colorado.

Appendix A: Refuge Legislation
Final Comprehensive Conservation Plan & EIS 247

PUBLIC LAW 107–107—DEC. 28, 2001 115 STAT. 1385

(2) CLEANUP LEVELS.—Nothing in this subtitle shall reduce

the level of cleanup and closure at Rocky Flats required under

the RFCA or any Federal or State law.

(3) PAYMENT OF RESPONSE ACTION COSTS.—Nothing in this

subtitle affects the obligation of a Federal department or agency

that had or has operations at Rocky Flats resulting in the

release or threatened release of a covered substance to pay

the costs of response actions carried out to abate the release

of, or clean up, the covered substance.

SEC. 3177. ROCKY FLATS NATIONAL WILDLIFE REFUGE.

(a) IN GENERAL.—On completion of the transfer required by

section 3175(a), and subject to section 3176(a), the Secretary of

the Interior shall commence administration of the real property

comprising the refuge in accordance with this subtitle.

(b) ESTABLISHMENT OF REFUGE.—Not later than 30 days after

the transfer required by section 3175(a), the Secretary of the

Interior shall establish at Rocky Flats a national wildlife refuge

to be known as the Rocky Flats National Wildlife Refuge.

(c) COMPOSITION.—The refuge shall be comprised of the property the administrative jurisdiction of which was transferred as

required by section 3175(a).

(d) NOTICE.—The Secretary of the Interior shall publish in

the Federal Register a notice of the establishment of the refuge.

(e) ADMINISTRATION AND PURPOSES.— (1) IN GENERAL.—The Secretary of the Interior shall manage the refuge in accordance with applicable law, including

this subtitle, the National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd et seq.), and the purposes

specified in that Act.

(2) REFUGE PURPOSES.—The refuge shall be managed for

the purposes of—

(A) restoring and preserving native ecosystems;

(B) providing habitat for, and population management

of, native plants and migratory and resident wildlife;

(C) conserving threatened and endangered species

(including species that are candidates for listing under

the Endangered Species Act of 1973 (16 U.S.C. 1531 et

seq.)); and

(D) providing opportunities for compatible scientific

research.

(3) MANAGEMENT.—In managing the refuge, the Secretary

of the Interior shall—

(A) ensure that wildlife-dependent recreation and

environmental education and interpretation are the priority

public uses of the refuge; and

(B) comply with all response actions.

SEC. 3178. COMPREHENSIVE PLANNING PROCESS.

(a) IN GENERAL.—Not later than 180 days after the date of

the enactment of this Act, in developing a comprehensive conservation plan for the refuge in accordance with section 4(e) of the

National Wildlife Refuge System Administration Act of 1966 (16

U.S.C. 668dd(e)), the Secretary of the Interior shall establish a

comprehensive planning process that involves the public and local

communities. The Secretary of the Interior shall establish such

process in consultation with the Secretary, the members of the

Coalition, the Governor of the State of Colorado, and the Federal

Deadline.

Appendix A: Refuge Legislation
248 Rocky Flats National Wildlife Refuge 

115 STAT. 1386 PUBLIC LAW 107–107—DEC. 28, 2001

and State of Colorado officials who have been designated as trustees

for Rocky Flats under section 107(f)(2) of CERCLA (42 U.S.C.

9607(f)(2)).

(b) OTHER PARTICIPANTS.—In addition to the entities specified

in subsection (a), the comprehensive planning process required by

subsection (a) shall include the opportunity for direct involvement

of entities that are not members of the Coalition as of the date

of the enactment of this Act, including the Rocky Flats Citizens’

Advisory Board and the cities of Thornton, Northglenn, Golden,

Louisville, and Lafayette, Colorado.

(c) DISSOLUTION OF COALITION.—If the Coalition dissolves, or

if any Coalition member elects to leave the Coalition during the

comprehensive planning process required by subsection (a)—

(1) such comprehensive planning process shall continue;

and

(2) an opportunity shall be provided to each entity that

is a member of the Coalition as of September 1, 2000, for

direct involvement in such comprehensive planning process.

(d) CONTENTS.—In addition to the requirements of section 4(e)

of the National Wildlife Refuge System Administration Act of 1966

(16 U.S.C. 668dd(e)), the comprehensive conservation plan referred

to in subsection (a) shall address and make recommendations on

the following:

(1) The identification of any land referred to in subsection

(e) of section 3174 that could be made available under that

subsection.

(2) The characteristics and configuration of any perimeter

fencing that may be appropriate or compatible for cleanup

and closure purposes, refuge purposes, or other purposes.

(3) The feasibility of locating, and the potential location

for, a visitor and education center at the refuge.

(4) Any other issues relating to Rocky Flats.

(e) COALITION DEFINED.—In this section, the term ‘‘Coalition’’

means the Rocky Flats Coalition of Local Governments established

by the Intergovernmental Agreement, dated February 16, 1999,

among—

(1) the city of Arvada, Colorado;

(2) the city of Boulder, Colorado;

(3) the city of Broomfield, Colorado;

(4) the city of Westminster, Colorado;

(5) the town of Superior, Colorado;

(6) Boulder County, Colorado; and

(7) Jefferson County, Colorado.

(f) REPORT.—Not later than three years after the date of the

enactment of this Act, the Secretary of the Interior shall submit

to Congress—

(1) the comprehensive conservation plan referred to in subsection (a); and

(2) a report that contains—

(A) an outline of the involvement of the public and

local communities in the comprehensive planning process,

as required by subsection (a);

(B) to the extent that any input or recommendation

from the comprehensive planning process is not accepted,

a clear statement of the reasons why such input or recommendation is not accepted; and

Deadline.

Appendix A: Refuge Legislation
Final Comprehensive Conservation Plan & EIS 249

PUBLIC LAW 107–107—DEC. 28, 2001 115 STAT. 1387

(C) a discussion of the impacts of any property rights

referred to in section 3179(a) on management of the refuge,

and an identification of strategies for resolving and mitigating these impacts.

SEC. 3179. PROPERTY RIGHTS.

(a) IN GENERAL.—Except as provided in subsections (c) and

(d), nothing in this subtitle limits any valid, existing property

right at Rocky Flats that is owned by any person or entity,

including, but not limited to—

(1) any mineral right;

(2) any water right or related easement; and

(3) any facility or right-of-way for a utility.

(b) ACCESS.—Except as provided in subsection (c), nothing in

this subtitle affects any right of an owner of a property right

referred to in subsection (a) to access the owner’s property.

(c) REASONABLE CONDITIONS.— (1) IN GENERAL.—The Secretary or the Secretary of the

Interior may impose such reasonable conditions on access to

property rights referred to in subsection (a) as are appropriate

for the cleanup and closure of Rocky Flats and for the management of the refuge.

(2) NO EFFECT ON OTHER LAW.—Nothing in this subtitle

affects any Federal, State, or local law (including any regulation) relating to the use, development, and management of

property rights referred to in subsection (a).

(3) NO EFFECT ON ACCESS RIGHTS.—Nothing in this subsection precludes the exercise of any access right, in existence

on the date of the enactment of this Act, that is necessary

to perfect or maintain a water right in existence on that date.

(d) UTILITY EXTENSION.—

(1) IN GENERAL.—The Secretary or the Secretary of the

Interior may allow not more than one extension from an

existing utility right-of-way on Rocky Flats, if necessary.

(2) CONDITIONS.—An extension under paragraph (1) shall

be subject to the conditions specified in subsection (c).

(e) EASEMENT SURVEYS.—Subject to subsection (c), until the

date that is 180 days after the date of the enactment of this

Act, an entity that possesses a decreed water right or prescriptive

easement relating to land at Rocky Flats may carry out such surveys

at Rocky Flats as the entity determines are necessary to perfect

the right or easement.

SEC. 3180. LIABILITIES AND OTHER OBLIGATIONS.

(a) IN GENERAL.—Nothing in this subtitle shall relieve, and

no action may be taken under this subtitle to relieve, the Secretary,

the Secretary of the Interior, or any other person from any liability

or other obligation at Rocky Flats under CERCLA, RCRA, or any

other Federal or State law.

(b) COST RECOVERY, CONTRIBUTION, AND OTHER ACTION.—

Nothing in this subtitle is intended to prevent the United States

from bringing a cost recovery, contribution, or other action that

would otherwise be available under Federal or State law.

SEC. 3181. ROCKY FLATS MUSEUM.

(a) MUSEUM.—To commemorate the contribution that Rocky

Flats and its worker force provided to winning the Cold War and

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250 Rocky Flats National Wildlife Refuge 

115 STAT. 1388 PUBLIC LAW 107–107—DEC. 28, 2001

the impact that such contribution has had on the nearby communities and the State of Colorado, the Secretary may establish a

Rocky Flats Museum.

(b) LOCATION.—The Rocky Flats Museum shall be located in

the city of Arvada, Colorado, unless, after consultation under subsection (c), the Secretary determines otherwise.

(c) CONSULTATION.—The Secretary shall consult with the city

of Arvada, other local communities, and the Colorado State Historical Society on—

(1) the development of the museum;

(2) the siting of the museum; and

(3) any other issues relating to the development and

construction of the museum.

(d) REPORT.—Not later than three years after the date of the

enactment of this Act, the Secretary, in coordination with the city

of Arvada, shall submit to Congress a report on the costs associated

with the construction of the museum and any other issues relating

to the development and construction of the museum.

SEC. 3182. ANNUAL REPORT ON FUNDING.

For each of fiscal years 2003 through 2007, at the time of

submission of the budget of the President under section 1105(a)

of title 31, United States Code, for such fiscal year, the Secretary

and the Secretary of the Interior shall jointly submit to Congress

a report on the costs of implementation of this subtitle. The report

shall include—

(1) the costs incurred by each Secretary in implementing

this subtitle during the preceding fiscal year; and

(2) the funds required by each Secretary to implement

this subtitle during the current and subsequent fiscal years.

TITLE XXXII—DEFENSE NUCLEAR

FACILITIES SAFETY BOARD

Sec. 3201. Authorization.

SEC. 3201. AUTHORIZATION.

There are authorized to be appropriated for fiscal year 2002,

$18,500,000 for the operation of the Defense Nuclear Facilities

Safety Board under chapter 21 of the Atomic Energy Act of 1954

(42 U.S.C. 2286 et seq.).

TITLE XXXIII—NATIONAL DEFENSE

STOCKPILE

Sec. 3301. Definitions.

Sec. 3302. Authorized uses of stockpile funds.

Sec. 3303. Authority to dispose of certain materials in National Defense Stockpile.

Sec. 3304. Revision of limitations on required disposals of certain materials in National Defense Stockpile.

Sec. 3305. Acceleration of required disposal of cobalt in National Defense Stockpile.

Sec. 3306. Restriction on disposal of manganese ferro.

SEC. 3301. DEFINITIONS.

In this title:

50 USC 98d note.

Appendix A: Refuge Legislation
appendix b

Compatability Determinations

Final Comprehensive Conservation Plan & EIS 253

Appendix B: Compatibility Determination

COMPATIBILITY DETERMINATION 

Use: Hunting 

Refuge Name: Rocky Flats National Wildlife Refuge 

 Jefferson and Boulder Counties, Colorado 

Establishing

Authority: Rocky Flats National Wildlife Refuge Act of 2001 (P.L. 107-107) 

Refuge Purposes: 1. Restoring and preserving native ecosystems. 

2. Providing habitat for, and population management of, native plants, and 

migratory and resident wildlife. 

3. Conserving threatened and endangered species (including species that are 

candidates for listing under the Endangered Species Act of 1973 (16 U.S.C. 

1531 et seq.)). 

 4. Providing opportunities for compatible scientific research. 

NWRS Mission: “...to administer a national network of lands and waters for the conservation, 

management, and where appropriate, restoration of the fish, wildlife and plant resources and their habitats, 

of the United States for the benefit of present and future generations of Americans.” (16 U.S.C. 

668dd(a)(2)). 

Description of Use: The Refuge will administer a limited big game (mule deer and elk) hunting program 

for youth and disabled hunters. The program may be expanded after year 2 to include able-bodied hunters, 

if needed to control ungulate populations in order to meet wildlife management goals. 

A maximum of 10 hunter/participants would be allowed per hunt. There will be two hunts per year (one 

for youth and one for disabled hunters). Each hunt will last for 1 weekend, including a Saturday and 

Sunday. Hunts will be scheduled during the period October 15 - January 15 annually. 

Weapons will be limited to: shotguns (20 gauge or larger), firing single projectiles; and archery (bow and 

arrow). No centerfire rifles or muzzleloading rifles will be allowed. Disabled hunters may be authorized to 

use centerfire handguns or cross-bow archery tackle, determined on a case-by-case basis, depending on the 

nature of the hunter’s disability. 

All weapons will meet requirements of the Colorado Division of Wildlife, (CDOW) for the species hunted. 

The Rocky Flats NWR program will be highly managed. Permits/licenses will be issued by drawing 

cooperatively administered by the Refuge and CDOW. All hunters will be required to check-in prior to 

hunting and attend a safety/orientation briefing, and check-out at the end of each hunt day. 

Youth hunters will be required to hunt with a mentor and disabled hunters will be required to have a 

volunteer to assist them. There will be a minimum ratio of 1 Refuge or CDOW staff present on-site for 

every 3 hunter participants. 

Each hunter will be assigned to a unique hunting zone within the Refuge for his/her exclusive use and is 

restricted to hunting in that zone. 
254 Rocky Flats National Wildlife Refuge 

Appendix B: Compatibility Determination

Hunters will be required to present all harvested game for inspection and collection of biological data, 

including sampling for Chronic Wasting Disease. 

Other authorized public uses of the Refuge will be suspended and the Refuge will be closed for any nonhunting public use activities on hunt weekends. 

Hunt dates, bag limits, hunter quotas, and any adjustments to Refuge Hunt Zones will be determined on an 

annual basis, in consultation with CDOW. 

Availability of Resources: It is anticipated that annual planning and execution of the proposed hunting 

program will require approximately 20 staff-days of work, spread among the Refuge Manager, Biological, 

Visitor Services and Law Enforcement staff and cost approximately $5,000 to operate. Refuge O&M 

resources are expected to be augmented by the services and volunteers and partnership with CDOW and 

conservation organizations. 

This is a “pre-acquisition” compatibility determination, prepared to accompany the Comprehensive 

Conservation Plan (CCP) for the future Rocky Flats NWR. No 

facility development will be required to operate the proposed hunting program and funds are anticipated to 

be available for the operation of this program based on the Refuge staffing levels and budget proposed in 

the CCP. 

Anticipated Impacts: This limited big game hunting program is anticipated to have minimal potential 

impacts on Refuge wildlife, but potentially significant beneficial impacts on the unique flora of the Refuge. 

The proposed use is a Wildlife-Dependent Recreational Use and a Priority Public Use of the NWRS. 

The Rocky Flats site has supported a mule deer herd numbering approximately 160 animals (on 6,240 

acres) since at least the late 1990s (Kaiser Hill 2001). Small, but increasing numbers of white-tailed deer 

also occur on the site. Prior to 2002, elk were known to visit Rocky Flats, but were not considered to be a 

resident species by DOE (DOE 1997). During the winter of 2002 - 2003, significant numbers of elk were 

observed regularly on the east side of Highway 93 adjacent to Rocky Flats and at least 9 cow elk are known 

to have calved on the site in the summer of 2003. 

The future Refuge is bordered by public conservation lands to the north and west. Fencing is typical stock 

fencing that does not impede movement of ungulates. Although there is potential for future commercial 

development on the west side of the site, it is anticipated that deer, elk and other large mammals will 

continue to be able to move freely between the Refuge and adjacent public lands, and into the Roosevelt 

National Forest to the west. 

The Refuge is located in CDOW’s Game Management Unit (GMU) No. 38, and adjacent to GMU 29. 

Those two GMUs make up CDOW’s Data Analysis Unit (DAU) D-27 which covers to the Boulder Deer 

Herd. CDOW has published the Boulder Deer Herd Management Plan (CDOW 2002). DAU D-27 lies at 

the edge of the endemic area for Chronic Wasting Disease (CWD) in northeast Colorado. The plan focuses 

on keeping the prevalence of CWD in the Boulder Deer Herd at no more than 1% infection rate and the 

Boulder Deer Herd. 

In December 2002, 26 deer were collected at Rocky Flats, by CDOW as part of the state’s CWD 

surveillance program. All animals harvested were negative for CWD. 

Under the Region 6 CWD Policy, it will be necessary to continue surveillance of the Refuge herds for 

occurrence and prevalence of CWD. Hunter-harvested deer and elk will provide data for this surveillance 

requirement and reduce or eliminate the need for Refuge staff to take deer for CWD surveillance purposes. 

Colorado has the largest elk population of any state or province in North America. The current Colorado 

elk herd is far above CDOW’s objective level, and CDOW has taken aggressive action in recent years to 

reduce the herd through sport hunting. Increasingly, elk are becoming established in suburban and 

agricultural areas along the Front Range. Elk in the cities of Evergreen and Estes Park, and a newly 
Final Comprehensive Conservation Plan & EIS 255

Appendix B: Compatibility Determination

established population near Loveland, Colorado are creating numerous depredation issues. In Rocky 

Mountain National Park, the unhunted elk herd is destroying important riparian habitat. 

It will be important to prevent or control the establishment of a resident elk herd on the Refuge. Yearround grazing and browsing by elk has the potential to significantly degrade rare plant communities and 

destroy or reduce the quality of Preble’s meadow jumping mouse on the Refuge. 

Hunting will have a positive impact on habitats by controlling ungulate grazing and browsing pressure on 

the Refuge. Direct impacts of the hunting program will be insignificant because of the timing (during 

Preble’s meadow jumping mouse hibernation and outside the bird nesting season) and small number of 

participants walking through upland and riparian areas. The program will require no facility development 

or conversion of habitat areas to administrative use. 

Public Review and Comment: This Compatibility Determination was presented for public review and 

comment in conjunction with the public comment period for the Draft CCP/EIS for the future Rocky Flats 

NWR in the first quarter of CY 04. 

At four public hearings, and throughout the comment period for the Draft CCP/EIS for Rocky Flats NWR, 

significant public input was received regarding the provisions in the Proposed Action to provide a hunting 

program at Rocky Flats NWR. None of the comments received were specifically addressed to the Draft 

Compatibility Determination that was published with the Draft CCP/EIS. However, several individuals and 

organizations expressed the opinion that hunting, in general, is not a compatible use of the National 

Wildlife Refuge System. All public testimony presented at the hearings and written comments received 

and responses are reported in Appendix H, Comments and Responses on the Draft Environmental Impact 

Statement (EIS), of the Final EIS for the Rocky Flats NWR Comprehensive Conservation Plan. 

Numerous public comments were received both in favor and in opposition of the proposed hunting 

program. A petition was received with 89 signatures (23 incomplete or illegible) stating “The following 

object to any recreational sport hunting at Rocky Flats National Wildlife Refuge.” The petition did not 

address issues germane to the compatibility determination. 

Letters supporting the hunting proposal were received from: the State of Colorado, Division of Wildlife, 

Colorado Wildlife Federation, National Wildlife Federation and the Wildlife Management Institute and 

other organizations and individuals. Letters opposing hunting were received from the Rocky Mountain 

Peace and Justice Center, Prairie Preservation Alliance and other organizations and individuals. Local 

units of government had mixed responses, with some supporting hunting, and others wanting no public use 

at all. Several local governments expressed concerns about the safety of the hunting proposal, and in 

response to those concerns, the proposal was changed to delete muzzleloading rifles and restrict hunting to 

archery and shotguns/slugs only. See Appendix H, Final CCP/EIS, for full comments and responses. 

At public hearings, concerns were expressed that: the hunting program proposed was excessively 

expensive; the definition of “refuge” was a “place of safety”; ungulate populations should be controlled, if 

necessary, by agency sharpshooters; and that it would be inappropriate to protect animals all year, and then 

shoot at them two weekends per year – implying a “fair-chase” issue. 

In the professional judgment of the undersigned, none of the issues raised at the hearings warrants changing 

the proposal. Hunting is clearly an appropriate use of NWRS – by law. The costs of the program are 

mostly salaries of personnel expended over the course of a fiscal year and are not excessive compared to 

many Refuge programs. Hunting can be an effective tool for ungulate population management that 

provides a wholesome outdoor recreation experience that is absent in culling programs. Many state-wide 

and Refuge deer herds are hunted a few days per year without fair chase concerns. The Rocky Flats herd is 

not fenced, and is currently subject to some hunting pressure on adjacent private, and nearby public lands. 

Compatibility Determination: Using sound professional judgment (603 FW 2.6U and 2.11A), place an 

“X” in appropriate space to indicate whether the use would or would not materially interfere with or detract 

from the NWRS Mission or the Purposes of Rocky Flats NWR. 
256 Rocky Flats National Wildlife Refuge 

Appendix B: Compatibility Determination

 __ Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: The use (hunting) will not begin until a step-down 

hunting plan, ensuring biological integrity, and safety of the program, has been approved under provisions 

of 8RM5, and the Refuge has been formally opened to hunting through publication of a rule in the Federal 

Register and inclusion of Rocky Flats among refuges open to big game hunting in 50 CFR 32.7. 

Justification: Hunting is a form of wildlife-dependent recreation and is a priority use of the NWRS. 

Hunting will help control ungulate populations and distribution on the Refuge, with a net benefit to the 

conservation of rare botanical communities and conservation of habitat for the threatened Preble’s meadow 

jumping mouse. Hunting will provide scientific data for surveillance of Refuge deer and elk populations 

for Chronic Wasting Disease. 

Mandatory Re-evaluation Date: As a priority public use, the Compatibility Determination for this use is 

subject to mandatory re-evaluation in 15 years, on the anniversary of final Compatibility Determination in 

2019.

NEPA Compliance: This use is addressed in an Environmental Impact Statement and Record of Decision. 

Approval/Concurrence: 

Prepared/Approved: 

 Refuge Manager: 

 Signature Date 

 Concurrence: 

 Regional Chief: 

 Signature Date 

References:

Colorado Division of Wildlife. 2002. Boulder Deer Herd Management Plan. Denver, CO. 

Department of Energy. 1997. Rocky Flats Cumulative Impacts Document. Rocky Flats Field Office, 

Rocky Flats Environmental Technology Site. Golden, CO. 
Final Comprehensive Conservation Plan & EIS 257

Appendix B: Compatibility Determination

COMPATIBILITY DETERMINATION 

Use: Interpretation and Environmental Education 

Refuge Name: Rocky Flats National Wildlife Refuge 

 Jefferson and Boulder Counties, Colorado 

Establishing

Authority: Rocky Flats National Wildlife Refuge Act of 2001 (P.L. 107-107) 

Refuge Purposes: 1. Restoring and preserving native ecosystems. 

2. Providing habitat for, and population management of, native plants, and 

migratory and resident wildlife. 

3. Conserving threatened and endangered species (including species that are 

candidates for listing under the Endangered Species Act of 1973 (16 U.S.C. 

1531 et seq.)). 

 4. Providing opportunities for compatible scientific research. 

NWRS Mission: “... to administer a national network of lands and waters for the conservation, 

management, and where appropriate, restoration of the fish, wildlife and plant resources and their habitats, 

of the United States for the benefit of present and future generations of Americans.” (16 U.S.C. 

668dd(a)(2)). 

Description of Use: 

Interpretation: This is a priority public use of the National Wildlife Refuge System per the National 

Wildlife Refuge System Improvement Act of 1997. It is proposed to continue delivery of Interpretation 

programs to accomplish the goals and objectives of the Refuge as established in the CCP. 

Interpretation programs and facilities are proposed along designated trails and at the Visitor Contact Station 

on the west side of the Refuge. Facilities and programs would be mostly passive, consisting of interpretive 

panels on kiosks at trailhead access points and overlooks along trails. Signage would interpret the native 

prairie ecosystem, rare plant communities, wetlands, endangered species, invasive weeds, and the social 

significance and cultural resources of Rocky Flats NWR. 

Guided tours, led by Service personnel or volunteers, provide a similar but more detailed experience than 

the self-guided Refuge visit. Tours and nature programs will be developed for delivery to the public on a 

scheduled basis, and by reservation for groups with special interests and needs. Tours will generally be 

conducted on the established trail system, but when guided by staff, may access all upland portions of the 

Refuge, depending on visitor interests, and the subject matter of the interpretive program. 

A variety of interpretive programs may also be delivered off-site. 

Environmental Education: Environmental education at Rocky Flats NWR will emphasize teacher-led 

programs and be targeted to high school and college level students. No formal outdoor classroom facilities 

are planned, but the Refuge will provide sites for student field trips on an “as-arranged” basis. Temporary 

and impromptu outdoor classrooms will not be established or used in wetland, riparian and other sensitive 

communities during the growing season, and will be scheduled seasonally to avoid impacts to threatened 

and endangered species. Rocky Flats NWR will become a venue for implementation of environmental 

education curricula developed at Rocky Mountain Arsenal NWR 
258 Rocky Flats National Wildlife Refuge 

Appendix B: Compatibility Determination

Availability of Resources: It is anticipated that initial development of interpretive facilities designated in 

the Comprehensive Conservation Plan for Rocky Flats NWR will cost approximately $76,000. It is also 

anticipated that appropriated NWRS Operations and Maintenance funds for development of interpretive 

facilities will be leveraged through partnership arrangements with non-profit organizations and with local 

units of government and state agencies. Once developed, the annual maintenance costs for interpretive 

facilities is anticipated to be approximately $5,000 per year. 

No development of specialized facilities is anticipated to facilitate teacher-led environmental education 

programs at Rocky Flats NWR. It is estimated that development of special curricula and lesson plans for 

Rocky Flats will require approximately 0.5 FTE of labor and $30,000 over the course of the first five years 

following Refuge establishment. The required level of staffing and funding to produce those materials is 

within the current operating budget and staffing pattern of the Rocky Mountain Arsenal NWR Complex. 

This is a “pre-acquisition” compatibility determination, prepared to accompany the Comprehensive 

Conservation Plan (CCP) for the future Rocky Flats NWR. Funds are anticipated to be available for the 

operation of this program based on the Refuge staffing levels and budget proposed in the CCP. 

Anticipated Impacts: Development and implementation of interpretive and education programs at Rocky 

Flats NWR will have minimal and biologically insignificant impacts on Refuge resources. Less than 0.25 

acres of habitat will need to be disturbed or converted for development of all planned interpretive facilities 

(not including parking facilities). 

Human presence and movement on the Refuge for participation in Interpretive and Environmental 

Education programs will result in some wildlife disturbance. The level of disturbance will be minimal and 

will not be additive to disturbances attributed to other public uses such as wildlife observation and trail use. 

Public Review and Comment: This Compatibility Determination was presented for public review and 

comment in conjunction with the public comment period for the Draft CCP/EIS for the future Rocky Flats 

NWR in the first quarter of CY 04. 

Many public comments were received at four public hearings held in March 2004, and throughout the 

public comment period on the Draft CCP/EIS. Comments related to public use were received both from 

those in opposition and in favor of public access for interpretation and environmental education. 

Many people were opposed to any form of public use at Rocky Flats NWR based on their belief that site 

cleanup is inadequate and that public access would result in health and safety risks to visitors. Those 

comments did not address whether wildlife observation and photography were compatible with Refuge 

purposes or the mission of NWRS. 

Comments were received from several organizations, including the Colorado Wildlife Federation that 

supported the proposed action (Alternative B), including interpretation and environmental education. The 

Rocky Flats Citizen’s Advisory Board supported environmental education, but was not in agreement about 

whether those activities should take place on-site. The Rocky Flats Cold War Museum expressed a desire 

to partner with the Service in development of interpretive and education programs. Other groups, including 

the Prairie Preservation Alliance recommended no wildlife-dependent recreation, based on concerns of 

wildlife disturbance, exacerbating invasive weed problems and causing erosion. 

Comments from local units of government also varied, with several cities and counties favoring public 

access for interpretation and environmental education, and others recommending no public use of the 

Refuge. Similarly, written comments received from individuals ran the gamut from advocating more 

extensive public use programs, to the 815 copies of a form letter expressing opposition to any recreational 

access to the Rocky Flats NWR. For the complete record of public comment received on this issue, 

including responses to written comments and testimony received at the public hearings, please see 

Appendix H to the Final Comprehensive Conservation Plan and Environmental Impact Statement for 

Rocky Flats NWR. 
Final Comprehensive Conservation Plan & EIS 259

Appendix B: Compatibility Determination

Several of the comments received were germane to the issue of compatibility. Those comments raised 

concerns mostly related to wildlife disturbance. There were also several general comments opposing public 

use on the basis that a “refuge” should be free of disturbance and a place of inviolate sanctuary for wildlife. 

The undersigned acknowledge that this use is likely to result in some disturbance of wildlife. However, in 

the professional judgment of the undersigned, we do not believe that the level of disturbance that may 

result from this use will materially detract from or prevent the achievement of the Refuge establishment 

purposes or mission of the NWRS. Wildlife interpretation and environmental education are clearly 

appropriate uses of the NWRS, and are among the priority public uses of the Refuge System, as established 

in law. The areas necessary to be disturbed for development of the proposed facilities to support 

interpretation and environmental education are very small. The conversion of those small areas to nonhabitat uses will not materially detract from the ability of the Refuge to achieve its establishment purposes 

or its contribution to accomplishing the NWRS mission. 

Compatibility Determination: Using sound professional judgment (603 FW 2.6U and 2.11A), place an 

“X” in appropriate space to indicate whether the use would or would not materially interfere with or detract 

from the NWRS Mission or the Purposes of Rocky Flats NWR. 

 __ Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility:

1. Development and implementation of Interpretation and Environmental Education programs in the first 

five years following Refuge establishment will be limited to one short trail from the Visitor Contact Station 

on the west side of the Refuge to the Lindsay Ranch site, and one guided interpretive tour per month that 

will follow existing Department of Energy service roads. 

2. A self-study training program will be prepared for use by educators. Teachers will be required to 

participate in that training, or in Service-sponsored teacher workshops prior to leading teacher-lead 

environmental education programs on the Refuge. The training will include information on site history, 

safety, residual contamination, closed areas, endangered species and wetland conservation, and 

preservation of rare habitats. 

Justification: Interpretation and environmental education are forms of wildlife-dependent recreation and 

are priority public uses of the NWRS. Interpretation and Environmental Education will increase public 

awareness and appreciation of the significant wildlife and habitat values of Rocky Flats NWR, and the 

National Wildlife Refuge System. It is anticipated that such appreciation and understanding will foster 

increased public support for the Refuge System and conservation of America’s wildlife resources. 

Mandatory Re-evaluation Date: As a priority public use, the Compatibility Determination for this use is 

subject to mandatory re-evaluation in 15 years, on the anniversary of final Compatibility Determination in 

2019.

NEPA Compliance: This use is addressed in an Environmental Impact Statement and Record of Decision. 

Approval/Concurrence:

 Prepared/Approved: 

 Refuge Manager: 

 Signature Date 

 Concurrence: 

 Regional Chief: 

 Signature Date 
260 Rocky Flats National Wildlife Refuge 

Appendix B: Compatibility Determination

COMPATIBILITY DETERMINATION 

Use: Multi-Use (Equestrian, Bicycle and Foot access) Trails 

Refuge Name: Rocky Flats National Wildlife Refuge 

 Jefferson and Boulder Counties, Colorado 

Establishing

Authority: Rocky Flats National Wildlife Refuge Act of 2001 (P.L. 107-107) 

Refuge Purposes: 1. Restoring and preserving native ecosystems. 

2. Providing habitat for, and population management of, native plants, and 

migratory and resident wildlife. 

3. Conserving threatened and endangered species (including species that are 

candidates for listing under the Endangered Species Act of 1973 (16 U.S.C. 

1531 et seq.)). 

 4. Providing opportunities for compatible scientific research. 

NWRS Mission: “... to administer a national network of lands and waters for the conservation, 

management, and where appropriate, restoration of the fish, wildlife and plant resources and their habitats, 

of the United States for the benefit of present and future generations of Americans.” (16 U.S.C. 

668dd(a)(2)). 

Description of Use: To provide access for compatible wildlife-dependent recreational activities of wildlife 

observation, wildlife photography and interpretation, a 16-mile system of trails will be developed at Rocky 

Flats NWR. 

In order to provide connectivity with regional trail systems and complement public uses of adjacent public 

lands (municipal and county open space), some portions of the Rocky Flats National Wildlife Refuge 

(NWR) trail system will accommodate horseback riding and bicycles as modes of transportation for 

wildlife-dependent recreation. 

Within the total anticipated trail system of 16.5 miles, approximately 3.8 miles of trail will be open to foot 

traffic only, and portions of those foot trails will be closed seasonally to reduce disturbance of 

wetland/riparian habitats during the months of May through September when the threatened Preble’s 

meadow jumping mouse is active above ground. 

In the northern portion of the Refuge, a multi-use trail approximately 4 miles long will follow the top of the 

mesa on the southern boundary of the Rock Creek drainage. This trail will connect a parking lot on State 

Highway 128, with open space parks managed by the City of Boulder, Boulder County, City and County of 

Broomfield, and Town of Superior with the proposed Visitor Contact Station on the west side of the Refuge 

and ultimately with regional trails to be located off-Refuge in the State Highway 93 corridor west of the 

Refuge. This trail will be open for foot and bicycle traffic only. 

In the southern portion of the Refuge, a multi-use trail, approximately 8 miles long will follow portions of 

the Refuge south boundary, and mesa tops south of the main stem of Woman Creek, connecting City of 

Westminster and City of Arvada Open Space with the Visitor Contact Station and eventually with other 

public lands and regional trails west of Rocky Flats. This southern multi-use trail will be open for 

equestrian, bicycle and foot traffic. 
Final Comprehensive Conservation Plan & EIS 261

Appendix B: Compatibility Determination

Availability of Resources: It is anticipated that initial development of interpretive facilities designated in 

the Comprehensive Conservation Plan for Rocky Flats NWR will cost approximately $76,000. It is also 

anticipated that appropriated NWRS Operations and Maintenance funds for development of interpretive 

facilities will be leveraged through partnership arrangements with non-profit organizations and with local 

units of government and state agencies. Once developed, the annual maintenance costs for interpretive 

facilities is anticipated to be approximately $5,000 per year. 

No development of specialized facilities is anticipated to facilitate teacher-led environmental education 

programs at Rocky Flats NWR. It is estimated that development of special curricula and lesson plans for 

Rocky Flats will require approximately 0.5 FTE of labor and $30,000 over the course of the first five years 

following Refuge establishment. The required level of staffing and funding to produce those materials is 

within the current operating budget and staffing pattern of the Rocky Mountain Arsenal NWR Complex. 

This is a “pre-acquisition” compatibility determination, prepared to accompany the Comprehensive 

Conservation Plan (CCP) for the future Rocky Flats NWR. Funds are anticipated to be available for the 

operation of this program based on the Refuge staffing levels and budget proposed in the CCP. 

Anticipated Impacts: Development and implementation of interpretive and education programs at Rocky 

Flats NWR will have minimal and biologically insignificant impacts on Refuge resources. Less than 0.25 

acres of habitat will need to be disturbed or converted for development of all planned interpretive facilities 

(not including parking facilities). 

Human presence and movement on the Refuge for participation in Interpretive and Environmental 

Education programs will result in some wildlife disturbance. The level of disturbance will be minimal and 

will not be additive to disturbances attributed to other public uses such as wildlife observation and trail use. 

Public Review and Comment: This Compatibility Determination was presented for public review and 

comment in conjunction with the public comment period for the Draft CCP/EIS for the future Rocky Flats 

NWR in the first quarter of CY 04. 

Many public comments were received at four public hearings held in March 2004, and throughout the 

public comment period on the Draft CCP/EIS. Comments related to public use were received both from 

those in opposition and in favor of public access for interpretation and environmental education. 

Many people were opposed to any form of public use at Rocky Flats NWR based on their belief that site 

cleanup is inadequate and that public access would result in health and safety risks to visitors. Those 

comments did not address whether wildlife observation and photography were compatible with Refuge 

purposes or the mission of NWRS. 

Comments were received from several organizations, including the Colorado Wildlife Federation that 

supported the proposed action (Alternative B), including interpretation and environmental education. The 

Rocky Flats Citizen’s Advisory Board supported environmental education, but was not in agreement about 

whether those activities should take place on-site. The Rocky Flats Cold War Museum expressed a desire 

to partner with the Service in development of interpretive and education programs. Other groups, including 

the Prairie Preservation Alliance recommended no wildlife-dependent recreation, based on concerns of 

wildlife disturbance, exacerbating invasive weed problems and causing erosion. 

Comments from local units of government also varied, with several cities and counties favoring public 

access for interpretation and environmental education, and others recommending no public use of the 

Refuge. Similarly, written comments received from individuals ran the gamut from advocating more 

extensive public use programs, to the 815 copies of a form letter expressing opposition to any recreational 

access to the Rocky Flats NWR. For the complete record of public comment received on this issue, 

including responses to written comments and testimony received at the public hearings, please see 

Appendix H to the Final Comprehensive Conservation Plan and Environmental Impact Statement for 

Rocky Flats NWR. 
262 Rocky Flats National Wildlife Refuge 

Appendix B: Compatibility Determination

The greatest anticipated impact associated with multi-use trails is the potential for erosion and damage to 

trail surfaces caused by horses and bicycles. Permitting those modes of transportation is likely to increase 

maintenance costs and if not managed, could eventually lead to soil loss and reduced surface water quality. 

It is noted that equestrian use is authorized in most units of the National Wilderness System, and is deemed 

appropriate with preservation of wilderness values, and that bicycle use on trails has proven to be a 

compatible mode of transportation on other urban units of the NWRS, including Minnesota Valley NWR 

and refuges of the San Diego NWR Complex. 

Public Review and Comment: This Compatibility Determination was presented for public review and 

comment in conjunction with the public comment period for the Draft CCP/EIS for the future Rocky Flats 

NWR in the first quarter of CY 04. 

Many public comments were received at four public hearings held in March 2004, and throughout the 

public comment period on the Draft CCP/EIS. Comments related to trails were received both from those in 

opposition and in favor of multi-use trails. 

Many people were opposed to any form of public use at Rocky Flats NWR based on their belief that site 

cleanup is inadequate and that public access would result in health and safety risks to visitors. Those 

comments did not address whether trails were compatible with Refuge purposes or the mission of NWRS. 

Comments were also received from several organizations, including the Boulder Area Trails Coalition and 

Boulder County Horse Association, which supported multi-use trails and other groups, including Plan 

Jeffco and the Prairie Preservation Alliance, which recommended very limited trails or no trails at all due to 

concerns about trail users causing wildlife disturbance, exacerbating invasive weed problems and causing 

erosion. The National Wildlife Federation and others specifically opposed equestrian access based on the 

weed issue. Comments from local units of government also varied, with several cities and counties 

favoring establishment of multi-use trails and others recommending no public use of the Refuge. 

Similarly, written comments received from individuals ran the gamut from advocating more extensive trails 

with greater access for equestrians to 815 copies of a form letter expressing opposition to any recreational 

access to the Rocky Flats NWR. For the complete record of public comment received on this issue, 

including responses to written comments and testimony received at the public hearings, please see 

Appendix H to the Final Comprehensive Conservation Plan and Environmental Impact Statement for 

Rocky Flats NWR. 

Several of the comments received were germane to the issue of compatibility. Those comments raised 

concerns mostly related to wildlife disturbance, habitat fragmentation, weed seed importation and erosion 

that might result from trail use. There were also several general comments opposing public use on the basis 

that a “refuge” should be free of disturbance and a place of inviolate sanctuary for wildlife. 

The undersigned acknowledge that this use is likely to result in some disturbance of wildlife, and that 

active management of this use will be required to mitigate potential for this use to exacerbate weed 

problems and cause erosion. However, in the professional judgment of the undersigned, we do not believe 

that the level of disturbance that may result from this use will materially detract from or prevent the 

achievement of the Refuge establishment purposes or mission of the NWRS. Trails will occupy a very 

small portion of Rocky Flats NWR. Implementation of the Final CCP will result in less habitat 

fragmentation, fewer roads and point sources of soil erosion, and enhanced weed control efforts. If 

implemented with the stipulations listed below, this use will facilitate achievement of Refuge goals for 

wildlife-dependent recreation, and will not significantly interfere with preservation and restoration of native 

habitats, or conservation of native wildlife. 

Compatibility Determination: Using sound professional judgment (603 FW 2.6U and 2.11A), place an 

“X” in appropriate space to indicate whether the use would or would not materially interfere with or detract 

from the NWRS Mission or the Purposes of Rocky Flats NWR. 
Final Comprehensive Conservation Plan & EIS 263

Appendix B: Compatibility Determination

 __ Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility:

1. Multi-use trails with equestrian and bicycle access are limited to those trail segments designated in the 

Comprehensive Conservation Plan for Rocky Flats NWR. Development or opening of additional areas for 

these uses will require additional evaluation under the National Environmental Policy Act, a new 

Compatibility Determination, and a new Intra-Service Section 7 Consultation. 

2. No dogs or other pets will be allowed on any trails or other areas of Rocky Flats NWR. 

3. Equestrian use is contingent on development and implementation of volunteer service agreements with 

equestrian user groups who will agree to pick up and remove horse manure from Refuge trails at least twice 

a month to reduce the potential for horses to become a source of weed seed. 

4. Trails will be posted with “yield” signs indicating that pedestrians must yield to equestrian users and 

bicycles must yield to both equestrians and pedestrians. 

5. Trails open to bicycle use will be located on level ground to the maximum extent possible to discourage 

use by recreational mountain bikers for “thrill riding.” 

Justification: Multi-use trails accommodating equestrian and bicycle use are not a form of wildlife 

dependent recreation. However, they are modes of access and transportation that facilitate public 

participation in wildlife observation, wildlife photography and interpretation. Within the context of an 

urban NWR, surrounded on three sides by public lands administered by local units of government, these 

trails provide needed connectivity among public lands to facilitate the public’s appreciation of open space 

and habitat conservation at the edge of a rapidly urbanizing metropolitan area. 

It is noted that equestrian use is authorized in almost all units of the National Wilderness System, and is 

deemed appropriate with preservation of wilderness values. Bicycle use on trails has proven to be a 

compatible mode of transportation on other urban units of the NWRS, including Minnesota Valley NWR 

and refuges of the San Diego NWR Complex that support far more sensitive habitats and far more 

significant migratory bird and endangered species resources than does Rocky Flats. 

Mandatory Re-evaluation Date: This is not a priority public use. The Compatibility Determination for 

this use is subject to mandatory re-evaluation in 10 years, on the anniversary of final Compatibility 

Determination in 2014. 

NEPA Compliance: This use is addressed in an Environmental Impact Statement and Record of Decision. 

Approval/Concurrence:

 Prepared/Approved: 

 Refuge Manager: 

 Signature Date 

 Concurrence: 

 Regional Chief: 

 Signature Date 
264 Rocky Flats National Wildlife Refuge 

Appendix B: Compatibility Determination

COMPATIBILITY DETERMINATION 

Use: Wildlife Observation and Photography, Including Public Use Facility 

 Development to support those uses. 

Refuge Name: Rocky Flats National Wildlife Refuge 

 Jefferson and Boulder Counties, Colorado 

Establishing

Authority: Rocky Flats National Wildlife Refuge Act of 2001 (P.L. 107-107) 

Refuge Purposes: 1. Restoring and preserving native ecosystems. 

2. Providing habitat for, and population management of, native plants, and 

migratory and resident wildlife. 

3. Conserving threatened and endangered species (including species that are 

candidates for listing under the Endangered Species Act of 1973 (16 U.S.C. 

1531 et seq.)). 

 4. Providing opportunities for compatible scientific research. 

NWRS Mission: “...to administer a national network of lands and waters for the conservation, 

management, and where appropriate, restoration of the fish, wildlife and plant resources and their habitats, 

of the United States for the benefit of present and future generations of Americans.” (16 U.S.C. 

668dd(a)(2)). 

Description of Use: Wildlife Observation and Wildlife Photography programs are provided to the general 

public, during daylight hours, along an established and well delineated system of authorized trails 

designated in the Comprehensive Conservation Plan for Rocky Flats National Wildlife Refuge. A total of 

16.5 miles of trail will be developed and open. Most of the trail system will be open year-round, however 

trails that enter the Rock Creek drainage and cross sensitive habitats of the Preble’s meadow jumping 

mouse will be closed seasonally during May through September. 

Off-trail access for wildlife observation and photography will also be provided seasonally, on the southern 

third of the Refuge, during the Preble’s hibernation season from September through May, outside the birdnesting season. 

Most areas of the Refuge are closed to general public access due to the sensitivity of habitats. Despite 

highly restricted access that prohibits visitor traffic in the Refuge’s sensitive endangered species habitats, 

excellent opportunities are available for observing deer, coyotes, raptors, song birds other species from the 

approved trail system. Opportunities for wildlife observation and photography may also be available in 

conjunction with staff or volunteer-led interpretive tours and programs. 

The CCP calls for access to public use trails for wildlife observation and photography. The CCP also calls 

for enhanced programs including the addition of one wildlife observation and photography blind, and three 

enhanced overlook facilities for observation and photography, a Visitor Contact Station, and trailhead 

parking areas. The Visitor Contact Station would be a small (700 - 1000 square foot) building with 

associated restroom facilities. Parking facilities would include three lots, to accommodate a total of 70 cars 

and 1 bus. Parking lots would be gravel surfaced, and enclosed with post and beam type fencing. Over 

72% of the planned trail system will be located on existing roads. About 2 miles of new foot trail will be 

constructed in the northwest corner of the Refuge. Approximately 0.6 miles of existing roads would have 

to be improved to provide for accessibility for mobility impaired visitors. 
Final Comprehensive Conservation Plan & EIS 265

Appendix B: Compatibility Determination

Availability of Resources: Most of the planned trail system will be located on existing roads, so wildlife 

observation and photography could be initiated without additional facility development, and with minimum 

costs for posting and staffing. 

Construction of two new trail segments (4.6 miles), overlook facilities, viewing/ photography blinds, 

trailhead parking lots and Visitor Contact Station represent one-time construction costs of about $390,000. 

Resources necessary to open and operate wildlife observation and photography programs, using the 

existing trail system are estimated to be 0.5 FTE and $42,000 annually. Those resources are available 

within the existing staffing and budget allocations of the Rocky Mountain Arsenal NWR Complex. They 

will be well within the resources available under the proposed staffing and O&M budget proposed in the 

CCP for Rocky Flats NWR. 

Resources are not currently available for development of new facilities to support the objective level of 

wildlife observation and photography programs for Rocky Flats NWR. Once approved, all facilities called 

for in the CCP will be incorporated in funding packages in the Refuge Operating Needs System (RONS), 

and will be developed as funds become available over the life of the CCP. Development of additional 

facilities are not required to open the Refuge for limited wildlife observation and photography. 

Anticipated Impacts: Continuation of the existing programs for interpretation, wildlife observation and 

wildlife photography will have a negligible impact on habitats. Development of facilities to support these 

uses will result in a loss of 1.9 acres or xeric tallgrass prairie and 2.9 acres of mixed grass prairie, mostly 

for parking lot development. Those acreages represent 0.12% and 0.13% of those habitat types at Rocky 

Flats, respectively. Facility development would result in no loss of upland shrub, riparian, or other wetland 

habitats.

Some wildlife disturbance will result from these programs. Some birds will be flushed from foraging or 

resting habitats by the approach of people on trails. However, the area impacted by these disturbances is 

small compared to the overall habitat area available. Approximately 200 acres of habitat will be within 100 

feet on either side of the proposed trail system. That amounts to 4% of the total acreage at Rocky Flats. It 

is also possible that some particularly sensitive bird species will avoid areas adjacent to trails for nesting 

purposes. However, under the CCP approved trail plan, over 80% of Refuge habitats will be greater than 

100 yards from any trail. 

Off-trail access during the period of October – April in the southern portion of the Refuge is provided to 

give bird watchers and photographers an opportunity for viewing and photographing wildlife that may not 

be available on designated trails. This area avoids occupied Preble’s habitat and the use will occur during 

seasons when there will be no impact to ground-nesting birds. Some trampling of vegetation will occur, 

but most plants will be senescent during those seasons. It is not anticipated that off-trail traffic will be 

intense enough to create social trails or damage habitat. 

Disturbance caused by these uses is not anticipated to cause wildlife to leave or abandon the Refuge, and all 

areas are available to wildlife for undisturbed use during closed hours. Disturbance resulting from wildlife 

observation, and photography programs is deemed to be biologically insignificant. 

Additionally, the CCP calls for continued closure and restoration of many roads and trails that will exist at 

the time of Refuge establishment. Fencing, other barriers, signs and revegetation efforts will restore many 

acres and result in a net habitat gain. All stream crossings will be on existing roads, and no new 

disturbance of riparian habitats will be required for these uses. Numerous existing stream crossings will be 

restored and revegetated. Trails that occur in riparian areas in the Rock Creek drainage will be closed 

seasonally to prevent wildlife observation and photography activities from impacting Preble’s during the 

May through September active period. 

The proposed uses, including development of facilities to support those uses, will foster public appreciation 

and understanding of the prairie ecosystem and the importance of Refuge habitats for wildlife conservation. 
266 Rocky Flats National Wildlife Refuge 

Appendix B: Compatibility Determination

The proposed uses are also priority wildlife-dependent uses of the National Wildlife Refuge System and 

promote fulfillment of the intent of the National Wildlife Refuge System Improvement Act of 1997. 

Public Review and Comment: This Compatibility Determination was presented for public review and 

comment in conjunction with the public comment period for the Draft CCP/EIS for the future Rocky Flats 

NWR in the first quarter of CY 04. 

Many public comments were received at four public hearings held in March 2004, and throughout the 

public comment period on the Draft CCP/EIS. Comments related to public use were received both from 

those in opposition, and in favor of public access for wildlife observation and photography. 

Many people were opposed to any form of public use at Rocky Flats NWR based on their belief that site 

cleanup is inadequate and that public access would result in health and safety risks to visitors. Those 

comments did not address whether wildlife observation and photography were compatible with Refuge 

purposes or the mission of NWRS. 

Comments were received from several organizations that supported the proposed action (Alternative B), 

including wildlife observation and photography. Other groups, including the Prairie Preservation Alliance 

recommended no trails or wildlife-dependent recreation based on concerns of wildlife disturbance, 

exacerbating invasive weed problems and causing erosion. 

Comments from local units of government also varied, with several cities and counties favoring public 

access for wildlife observation and photography, and others recommending no public use of the Refuge. 

Similarly, written comments received from individuals ran the gamut from advocating more extensive 

public use programs, to the 815 copies of a form letter expressing opposition to any recreational access to 

the Rocky Flats NWR. For the complete record of public comment received on this issue, including 

responses to written comments and testimony received at the public hearings, please see Appendix H to the 

Final Comprehensive Conservation Plan and Environmental Impact Statement for Rocky Flats NWR. 

Several of the comments received were germane to the issue of compatibility. Those comments raised 

concerns mostly related to wildlife disturbance. There were also several general comments opposing public 

use on the basis that a “refuge” should be free of disturbance and a place of inviolate sanctuary for wildlife. 

The undersigned acknowledge that this use is likely to result in some disturbance of wildlife. However, in 

the professional judgment of the undersigned, we do not believe that the level of disturbance that may 

result from this use will materially detract from or prevent the achievement of the Refuge establishment 

purposes or mission of the NWRS. Wildlife observation and photography are clearly appropriate uses of 

the NWRS, and are among the priority public uses of the Refuge System, as established in law. The areas 

necessary to be disturbed for development of the proposed facilities to support wildlife observation and 

photography are very small. The conversion of those small areas to non-habitat uses will not materially 

detract from the ability of the Refuge to achieve its establishment purposes or its contribution to 

accomplishing the NWRS mission. 

Compatibility Determination: Using sound professional judgment (603 FW 2.6U., and 2.11A), place an 

"X" in appropriate space to indicate whether the use would or would not materially interfere with or detract 

from the NWRS Mission or the Purposes of Rocky Flats NWR. 

 __ Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility:

1. Wildlife observation and photography programs must be conducted in accordance with the 

Comprehensive Conservation Plan. Any new programs or facilities not prescribed in the CCP must be 

approved through an additional public planning process, in compliance with NEPA, Section 7 of the 

Endangered Species Act, and other environmental compliance requirements, prior to implementation. 
Final Comprehensive Conservation Plan & EIS 267

Appendix B: Compatibility Determination

2. Areas open for off-trail use in the southern third of the Refuge will be closely monitored by Refuge 

staff. If off-trail use exceeds the capacity of the habitat (e.g., to a point where trampling results in loss of 

vegetative cover), the off-trail portion of the program will be curtailed or reduced to preserve habitat 

integrity.

Justification: Wildlife observation, and wildlife photography are priority wildlife-dependent public uses 

of the National Wildlife Refuge System. These uses, including existing and future enhanced programs as 

prescribed in the Comprehensive Conservation Plan for Rocky Flats NWR are compatible with the 

Refuge’s establishment purposes, and with the mission of the National Wildlife Refuge System. These 

uses are not only justified but are encouraged by the National Wildlife Refuge Improvement Act of 1997. 

The Rocky Flats NWR Act of 2001 states that wildlife-dependent recreation is a priority public use of 

Rocky Flats NWR. 

Mandatory Re-evaluation Date: As a priority public use, the Compatibility Determination for this use is 

subject to mandatory re-evaluation in 15 years, on the anniversary of final Compatibility Determination in 

2019.

NEPA Compliance: This use is addressed in an Environmental Impact Statement and Record of Decision. 

Approval/Concurrence:

 Prepared/Approved: 

 Refuge Manager: 

 Signature Date 

 Concurrence: 

 Regional Chief: 

 Signature Date 

appendix c

Laws and Executive Orders

Final Comprehensive Conservation Plan & EIS 271

Appendix C: Laws and Executive Orders 

LAWS AND REGULATIONS AFFECTING 

ROCKY FLATS NWR

Many procedural and substantive requirements of

Federal and applicable State and local laws and

regulations affect Refuge establishment,

management, and development. The following list

identifies the key federal laws and policies that were

considered during the planning process or that could

affect future Refuge management.

AMERICAN INDIAN RELIGIOUS FREEDOM ACT (1978): Directs

agencies to consult with native traditional religious

leaders to determine appropriate policy changes

necessary to protect and preserve Native American

religious cultural rights and practices.

AMERICANS WITH DISABILITIES ACT (1992): Prohibits

discrimination in public accommodations and services.

ANTIQUITIES ACT (1906): Authorizes the scientific

investigation of antiquities on Federal land and

provides penalties for unauthorized removal of objects

taken or collected without a permit.

ARCHAEOLOGICAL AND HISTORIC PRESERVATION ACT (1974):

Directs the preservation of historic and archaeological

data in Federal construction projects.

ARCHAEOLOGICAL RESOURCES PROTECTION ACT (1979) AS AMENDED:

Protects materials of archaeological interest from

unauthorized removal or destruction and requires

Federal managers to develop plans and schedules to

locate archaeological resources.

ARCHITECTURAL BARRIERS ACT (1968): Requires federally

owned, leased, or funded buildings and facilities to be

accessible to persons with disabilities.

BALD AND GOLDEN EAGLE PROTECTION ACT (1940): The Act

prohibits the taking or possession of and commerce in

bald and golden eagles, with limited exceptions. 

CLEAN AIR ACT OF 1977, AS AMENDED: The primary objective

of this Act is to establish Federal standards for various

pollutants from both stationary and mobile sources and 

to provide for the regulation of polluting emissions via

state implementation plants. In addition, and of special

interest for National Wildlife Refuges, some

amendments are designed to prevent significant

deterioration in certain areas where air quality exceeds

national standards, and to provide for improved air

quality in areas which do not meet Federal standards

("non-attainment" areas). Federal facilities are required

to comply with air quality standards to the same extent

as nongovernmental entities (42 U.S.C. 7418).

CLEAN WATER ACT (1977): Requires consultation with the

Corps of Engineers (404 permits) for major wetland

modifications.

EMERGENCY WETLANDS RESOURCES ACT (1986): The purpose of

the Act is "To promote the conservation of migratory

waterfowl and to offset or prevent the serious loss of

wetlands by the acquisition of wetlands and other

essential habitat, and for other purposes."

ENDANGERED SPECIES ACT (1973): Requires all Federal

agencies to carry out programs for the conservation of

endangered and threatened species.

EXECUTIVE ORDER NO. 11593, PROTECTION AND ENHANCEMENT OF

THE CULTURAL ENVIRONMENT (1971): If the Service proposes

any development activities that would affect the

archaeological or historical sites, the Service will

consult with Federal and State Historic Preservation

Officers to comply with Section 106 of the National

Historic Preservation Act of 1966, as amended.

EXECUTIVE ORDER 11987, EXOTIC ORGANISMS (1977): This

Executive Order requires Federal agencies, to the

extent permitted by law, to: restrict the introduction of

exotic species into the natural ecosystems on lands and

waters owned or leased by the United States;

encourage States, local governments, and private

citizens to prevent the introduction of exotic species

into natural ecosystems of the U.S.; restrict the

importation and introduction of exotic species into any

natural U.S. ecosystems as a result of activities they

undertake, fund, or authorize; and restrict the use of

Federal funds, programs, or authorities to export

native species for introduction into ecosystems outside

the U.S. where they do not occur naturally.

EXECUTIVE ORDER 11988, FLOODPLAIN MANAGEMENT (1977):

Each Federal agency shall provide leadership and take

action to reduce the risk of flood loss and minimize the

impact of floods on human safety, and preserve the

natural and beneficial values served by the floodplains.

EXECUTIVE ORDER 11990, PROTECTION OF WETLANDS (1977): This

order directs all Federal agencies to avoid, if possible,

adverse impacts to wetlands and to preserve and

enhance the natural and beneficial values of wetlands.

Each agency shall avoid undertaking or assisting in

wetland construction projects unless the head of the

agency determines that there is no practicable
272 Rocky Flats National Wildlife Refuge 

Appendix C: Laws and Executive Orders

alternative to such construction and that the proposed

action includes measures to minimize harm. Also,

agencies shall provide opportunity for early public

review of proposals for construction in wetlands,

including those projects not requiring an EIS.

EXECUTIVE ORDER 12898, ENVIRONMENTAL JUSTICE (1994): This

order provides minority and low-income populations

an opportunity to comment on the development and

design of Reclamation activities. Federal agencies shall

make achieving environmental justice part of their

missions by identifying and addressing, as

appropriate, disproportionately high and adverse

human health or environmental effects of its

programs, policies, and activities on minority

populations and low-income populations.

EXECUTIVE ORDER 12996 MANAGEMENT AND GENERAL PUBLIC USE

OF THE NATIONAL WILDLIFE REFUGE SYSTEM (1996): Defines the

mission, purpose, and priority public uses of the

National Wildlife Refuge System. It also presents four

principles to guide management of the System.

EXECUTIVE ORDER 13007 INDIAN SACRED SITES (1996): Directs

Federal land management agencies to accommodate

access to and ceremonial use of Indian sacred sites by

Indian religious practitioners, avoid adversely affecting

the physical integrity of such sacred sites, and where

appropriate, maintain the confidentiality of sacred sites.

EXECUTIVE ORDER 13084, CONSULTATION AND COORDINATION WITH

INDIAN TRIBAL GOVERNMENTS (1998): The United States has

a unique legal relationship with Indian tribal

governments as set forth in the Constitution of the

United States, treaties, statutes, Executive orders, and

court decisions. Since the formation of the Union, the

United States has recognized Indian tribes as domestic

dependent nations under its protection. In treaties, our

Nation has guaranteed the right of Indian tribes to

self-government. As domestic dependent nations,

Indian tribes exercise inherent sovereign powers over

their members and territory. The United States

continues to work with Indian tribes on a governmentto-government basis to address issues concerning

Indian tribal self-government, trust resources, and

Indian tribal treaty and other rights.

EXECUTIVE ORDER 13112, INVASIVE SPECIES(1999): Directs federal

agencies to prevent the introduction of invasive species,

control and monitor invasive species, and restore native

species and habitats that have been invaded.

FEDERAL AID IN WILDLIFE RESTORATION ACT OF SEPTEMBER 2, 1937

16 U.S.C.669-669I), AS AMENDED: This Act, commonly

referred to as the "Pittman-Robertson Act", provides

to States for game and non-game wildlife restoration

work. Funds from an excise tax on sporting arms and

ammunition are appropriated to the Secretary of the

Interior annually and apportioned to States on a

formula basis for approved land acquisition, research,

development and management projects and hunter

safety programs.

FEDERAL NOXIOUS WEED ACT (1990): Requires the use of

integrated management systems to control or contain

undesirable plant species; and an interdisciplinary

approach with the cooperation of other Federal and

State agencies.

FISH AND WILDLIFE COORDINATION ACT OF MARCH 10, 1934 (16

U.S.C. 661-66C), AS AMENDED: This Act authorizes the

Secretary of the Interior to assist Federal, State and

other agencies in development, protection, rearing and

stocking fish and wildlife on Federal lands, and to study

effects of pollution on fish and wildlife. The Act also

requires consultation with the Fish and Wildlife

Service and the wildlife agency of any State wherein

the waters of any stream or other water body are

proposed to be impounded, diverted, channelized or

otherwise controlled or modified by any Federal

agency, or any private agency under Federal permit or

license, with a view to preventing loss of, or damage to,

wildlife resources in connection with such water

resource projects. The Act further authorizes Federal

water resource agencies to acquire lands or interests in

connection with water use projects specifically for

mitigation and enhancement of fish and wildlife.

FISH AND WILDLIFE ACT (1956): Established a

comprehensive national fish and wildlife policy and

broadened the authority for acquisition and

development of refuges.

FISH AND WILDLIFE COORDINATION ACT (1958): Allows the Fish

and Wildlife Service to enter into agreements with

private landowners for wildlife management purposes.

FOOD SECURITY ACT OF 1985 (TITLE XII, PUBLIC LAW 99-198, 99

STAT. 1354; DECEMBER 23, 1985), AS AMENDED: Authorizes

acquisition of easements in real property for a term of

not less than 50 years for conservation, recreation, and

wildlife purposes.

LAND AND WATER CONSERVATION FUND ACT (1965): Uses the

receipts from the sale of surplus Federal land, outer

continental shelf oil and gas sales, and other sources

for land acquisition under several authorities.
Final Comprehensive Conservation Plan & EIS 273

Appendix C: Laws and Executive Orders 

MIGRATORY BIRD CONSERVATION ACT (1929): Establishes

procedures for acquisition by purchase, rental, or gift 

of areas approved by the Migratory Bird

Conservation Commission.

MIGRATORY BIRD TREATY ACT (1918): Designates the

protection of migratory birds as a Federal responsibility.

This Act enables the setting of seasons, and other

regulations including the closing of areas, Federal or

nonfederal, to the hunting of migratory birds.

NATIONAL ENVIRONMENTAL POLICY ACT (1969): Requires all

Federal agencies to examine the impacts upon the

environment that their actions might have, to incorporate

the best available environmental information, and the use

of public participation in the planning and

implementation of all actions. All Federal agencies must

integrate NEPA with other planning requirements, and

prepare appropriate NEPA documentation to facilitate

sound environmental decision making. NEPA requires

the disclosure of the environmental impacts of any major

Federal action that affects in a significant way the quality

of the human environment. 

NATIONAL HISTORIC PRESERVATION ACT (1966) AS AMENDED:

Establishes as policy that the Federal Government is to

provide leadership in the preservation of the nation's

prehistoric and historic resources.

NATIONAL WILDLIFE REFUGE SYSTEM ADMINISTRATION ACT OF 1966

AS AMENDED BY THE NATIONAL WILDLIFE REFUGE SYSTEM

IMPROVEMENT ACT OF 1997, 16 U.S.C. 668DD-668EE. (REFUGE

ADMINISTRATION ACT): Defines the National Wildlife

Refuge System and authorizes the Secretary to permit

any use of a refuge provided such use is compatible

with the major purposes for which the refuge was

established. The Refuge Improvement Act clearly

defines a unifying mission for the Refuge System;

establishes the legitimacy and appropriateness of the

six priority public uses (hunting, fishing, wildlife

observation and photography, or environmental

education and interpretation); establishes a formal

process for determining compatibility; established the

responsibilities of the Secretary of Interior for

managing and protecting the System; and requires a

Comprehensive Conservation Plan for each refuge by

the year 2012. This Act amended portions of the

Refuge Recreation Act and National Wildlife Refuge

System Administration Act of 1966.

NATIONAL WILDLIFE REFUGE SYSTEM IMPROVEMENT ACT OF 1997:

Sets the mission and administrative policy for all

refuges in the National Wildlife Refuge System.

Clearly defines a unifying mission for the Refuge

System; establishes the legitimacy and appropriateness

of the six priority public uses (hunting, fishing, wildlife

observation and photography, or environmental

education and interpretation); establishes a formal

process for determining compatibility; establishes the

responsibilities of the Secretary of the Interior for

managing and protecting the System; and requires a

Comprehensive Conservation Plan for each refuge by

the year 2012. This Act amended portions of the

Refuge Recreation Act and National Wildlife Refuge

System Administration Act of 1966.

NATIVE AMERICAN GRAVES PROTECTION AND REPATRIATION ACT

(1990): Requires Federal agencies and museums to

inventory, determine ownership of, and repatriate

cultural items under their control or possession.

REFUGE RECREATION ACT (1962): Allows the use of refuges

for recreation when such uses are compatible with the

refuge's primary purposes and when sufficient funds

are available to manage the uses.

REHABILITATION ACT (1973): Requires programmatic

accessibility in addition to physical accessibility for all

facilities and programs funded by the Federal

government to ensure that anybody can participate in

any program.

REFUGE REVENUE SHARING ACT OF 1935, AS AMENDED: Provides

for payments to counties in lieu of taxes, using

revenues derived from the sale of products from

refuges. Public Law 88-523 (1964) revised this Act and

required that all revenues received from refuge

products, such as animals, timber and minerals, or

from leases or other privileges, be deposited in a

special Treasury account and net receipts distributed to

counties for public schools and roads. Payments to

counties were established as: 1) on acquired land, the

greatest amount calculated on the basis of 75 cents per

acre, three-fourths of one percent of the appraised

value, or 25 percent of the net receipts produced from

the land; and 2) on land withdrawn from the public

domain, 25 percent of net receipts and basic payments

under Public Law 94-565 (31 U.S.C. 1601- 1607, 90 Stat.

2662), payment in lieu of taxes on public lands. 

ROCKY FLATS NATIONAL WILDLIFE REFUGE ACT OF 2001:

Establishes Rocky Flats National Wildlife Refuge

following cleanup and closure of the site, directs the

development of a Comprehensive Conservation Plan

for the Refuge, and other details.

appendix d

Regulatory Letters about Future

Refuge Management

Final Comprehensive Conservation Plan & EIS 277

Appendix D: Regulatory Letters about Future Refuge Management

Printed on Recycled Paper

Ref: 8EPR-F 

Mr. Mark Sattelberg 

Senior Contaminant Biologist 

US Fish and Wildlife Service 

Rocky Mountain Arsenal National Wildlife Refuge 

Building 111 

Commerce City, CO 80222-1748 

 Re: USFWS Future Activities at Rocky Flats 

Dear Mr. Sattelberg: 

 This is in response to your letter dated August 20, 2003, in which you asked whether 

EPA anticipated placing restrictions on activities the US Fish and Wildlife Service (Service) may 

wish to conduct at the future Rocky Flats National Wildlife Refuge. Specifically the Service 

asked about the following activities: prescribed fire, grazing, plowing, and ripping up old roads. 

 Once EPA certifies the remedy to be complete and jurisdiction of property has been 

transferred to the Service, does EPA foresee any restrictions on the use of prescribed fire? 

Similarly, does the EPA envision restrictions on ripping up roads? 

 As you are aware, the widespread contaminants of most concern at Rocky Flats are 

plutonium and americium. Consequently, areas at the site where these contaminants remain at 

closure would have the most use restrictions. In June 2003, CDPHE and EPA approved 

modifications to the Rocky Flats Cleanup Agreement, including revised contaminant soil action 

levels. EPA expects that at the completion of the remedy no significant contamination will be 

left in the surface soils at concentrations greater than outlined in the Attachment 5 of the 

modified agreement. For plutonium, the expectation is that surface soils contaminated at 

concentrations greater than 50 picocuries/gram (pCi/g) will have been removed. Surface soils 

are defined as those less than three feet in depth. EPA anticipates there will be restrictions on 

areas of the Site with residual contamination less than 50 pCi/g but greater than 9 pCi/g – a 

concentration representing lifetime excess cancer risk of one in 1,000,000 to a wildlife refuge 

worker. This is not to say that prescribed fire or ripping up roads would be precluded in areas 

with residual contamination in the 9-50 pCi/g range. Rather, the Service would need to take 

extra precautions in those areas to minimize soil disturbances. The primary concern being that 

major soil disturbances could result in elevated levels of contaminants to migrate to surface 

water. 

UNITED STATES ENVIRONMENTAL PROTECTION 

AGENCY 

REGION 8 

999 18TH STREET - SUITE 300 

DENVER, CO 80202-2466
278 Rocky Flats National Wildlife Refuge 

 The use of prescribed fire at Rocky Flats is of special interest to citizens and public 

officials in the surrounding communities. EPA believes that the use of prescribed fire at the site 

will not pose significant risk to firefighters, Service personnel or the general public. This belief 

is based upon data gathered during and after the 2000 test burn and for accidental burns at the 

site, as well as risk assessment work documented in the Task 3 Report (title/date) on the effects 

of prescribed fire at Rocky Flats. However, relatively large areas of Rocky Flats have not been 

characterized to date. These areas are often referred to as “white spaces.” EPA does not believe 

there is great potential to find contamination in these areas because they are removed from areas 

of known contamination and are not associated with past practices at the site that resulted in 

releases of contamination. Nevertheless, unexpected discoveries have occurred at Rocky Flats 

(e.g., the incinerator near the ash pits), and EPA believes that samples should be collected from 

white spaces before closure and analyzed prior to the application of prescribed fire in those areas. 

 Does EPA foresee any restrictions on the consumption of edible tissues from the grazing 

animals used for weed control at Rocky Flats? 

 Animal studies to date, and studies conducted by the actinide migration panel, indicate 

that there is no significant uptake of contaminants by grazing animals at Rocky Flats. Therefore, 

EPA does not anticipate restrictions on consumption of animals that graze at Rocky Flats. 

However, overgrazing in the areas in the 9 to 50 pCi/g range could result in water quality issues 

as discussed above. Therefore, EPA would expect to see measures put in place that would 

prevent overgrazing. 

 Do you foresee any restrictions on the plowing of areas in the southeast portion of the 

site for the purpose of reestablishing native vegetation? 

 Plowing will in all likelihood be prohibited in any areas of the site where contamination 

concentrations are greater than 9 pCi/g plutonium. 

 EPA looks forward to working with the Service in identifying and implementing the 

necessary restrictions for assuring that residual contamination at the future Rocky Flats National 

Wildlife Refuge poses a negligible risk to workers and members of the public. Please contact me 

at (303) 312-6246. 

Sincerely, 

 

 Gary Kleeman 

 Acting Rocky Flats Team Leader 

cc: Dean Rundle, FWS 

 Steve Gunderson, CDPHE 

 Joe Legare, DOE 

 Dave Shelton, KH 

 Administrative Records, T130G 

Appendix D: Regulatory Letters about Future Refuge Management
Final Comprehensive Conservation Plan & EIS 279

Appendix D: Regulatory Letters about Future Refuge Management
280 Rocky Flats National Wildlife Refuge 

Appendix D: Regulatory Letters about Future Refuge Management
appendix e

Letter to RFCA Parties

Final Comprehensive Conservation Plan & EIS 283

Appendix E: Letter to RFCA Parties
284 Rocky Flats National Wildlife Refuge 

Appendix E: Letter to RFCA Parties
appendix f

Cost Details

Final Comprehensive Conservation Plan & EIS 287

Cost Request Details

Rocky Flats National Wildlife Refuge

Refuge Operations Needs System (RONS) A B C D

Staff* 121,384 $ 431,265 $ 499,448 $ 702,711 $ 

Facility Lease* 210,000

Maintenance (Weed Management)* 25,000 50,000 75,000 50,000 

Utilities* 6,160 20,020 12,520 68,000 

Restoration 16,859 93,736 113,534 53,792 

Trails 41,501 140,395 216,850 

Visitor Facilities 249,269 30,563 457,228 

Interpretation 7,000 81,000 149,000 

Storage/Maintenance Building 15,000 225,000 225,000 350,000 

Cistern 8,000 8,000 18,000 

Septic System 12,000 12,000 25,000 

Burglar Alarm 2,000 2,000 3,000 

Fencing 38,063 46,613 66,720 

Signs 4,905 7,405 7,405 9,405 

Utility Line Installation 15,000 15,000 25,000 

Computers/Fax/Office Equipment 4,400 8,800 11,000 17,600 

Mountain Bike (for Patrol) 1,600 800 1,600 

All Terrain Vehicle (ATV) 13,000 13,000 13,000 13,000 

Spray-Rig for ATV 3,000 3,000 3,000 3,000 

Maintenance Truck 35,000 35,000 35,000 35,000 

Pickup Truck 44,000 44,000 44,000 

Slip-On Spray-Rig for Truck 12,000 12,000 12,000 12,000 

Mower 9,500 9,500 9,500 9,500 

Maintenance Tools 10,000 10,000 10,000 10,000 

Generator 5,000 

Biological Monitoring/Restoration Tools 15,000 15,000 15,000 

Water Storage - 50K Gallon Bladder 15,000 15,000 15,000 15,000 

Water Storage - Pumpkin 7,000 7,000 7,000 7,000 

500 Gallon Fuel Tank/Pump 20,000 20,000 20,000 20,000 

Shared Equipment Budget 100,000 100,000 150,000 100,000 

Planning and Design 78,169 38,504 431,221 

 Sub-Total - RONS $ 1,753,772 423,208 $ 1,680,838 $ 2,928,627 $ 

Maintenance Management System (MMS)

Renovate 1/2 Shed for Office 15,000 $ 

Both RONS and MMS

Visitor Center $ 3,000,000

Maintenance Funds (Annual)

Facility/Equipment Maintenance 21,283 $ 55,779 $ 36,517 $ 232,745 $ 

Fire Funding:

Fire Cache (One-Time) 50,000 $ 50,000 $ 50,000 $ 50,000 $ 

Fire Engine (One-Time) 75,000 75,000 75,000 75,000 

Staff (Ongoing) 133,007 133,007 133,007 83,724 

 Sub-Total - Fire Funding $ 258,007 258,007 $ 258,007 $ 208,724 $ 

 Total Cost Requests $ 2,067,558 717,498 $ 1,975,362 $ 6,370,096 $ 

* Classified as RONS for the first year of Refuge operations, then as annual operating funds.

Alternative

Appendix F: Cost Details
288 Rocky Flats National Wildlife Refuge 

Appendix F: Cost Details

Alternative A Estimated Costs

Rocky Flats National Wildlife Refuge

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

New Funding: $ 168,827 

Staff Cost reflects cost/ $ 121,384

Refuge Operations Specialist (GS-9) unit increased by 45% FTE 48,230 1.0 $ 69,934 $ 

Seasonal Range Technician (GS-6) to reflect training, FTE 35,483 1.0 $ 51,450 $ 

supplies and benefits.

Maintenance $ 41,283

Weed Management Staff Est. of Supplies 25,000 $ 

Lindsay Barn Staff Estimate 2,000 $ 

Facility/Equipment Maintenance 5% of Equip. + .005% 14,283 $ 

of Fence

Utilities $ 6,160

Electricity $ -

Gas $ -

Phone Over 12 months 2 lines 50 $ 1,200 $ 

Cleaning/Trash Pickup Clean 1x/week 4,960 $ 

Existing Base Funding: $ 5,000

Maintenance $ 5,000

Shared Equipment Maintenance 5% of Shared Equip. 5,000 $ 

Total: Operations $ 173,827

Net Present Value of Operations over 15 Year Period $ 1,932,677

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

New Funding: $ 185,664 

Restoration $ 16,859

Seed for Eliminating Roads 11.88 miles @ 20 feet 28.8 ac. 134 $ 3,859 $ 

Stream Crossing Restoration 13 ea. 1,000 $ 13,000 $ 

Facilities $ 34,905

Administrative

Renovate 1/2 Shed for Office 1 lump 15,000 $ 15,000 $ 

Storage/Maintenance Building Pull Shed for Tractor 1 lump 15,000 $ 15,000 $ 

Signs

Roadside 6 ea. 650 $ 3,900 $ 

Boundary Every 1,000 Feet 67 ea. 15 $ 1,005 $ 

Equipment $ 133,900

Computers/Fax/Office Equipment 2 emp. 2,200 $ 4,400 $ 

All Terrain Vehicle (ATV) 2 ea. 6,500 $ 13,000 $ 

Spray-Rig for ATV 2 ea. 1,500 $ 3,000 $ 

Maintenance Truck 1 ea. 35,000 $ 35,000 $ 

Slip-On Spray-Rig for Truck 1 ea. 12,000 $ 12,000 $ 

Mower ea. 9,500 1 $ 9,500 $ 

Maintenance Tools 1 lump 10,000 $ 10,000 $ 

Generator 1 ea. 5,000 $ 5,000 $ 

Water Storage - 50K Gallon Bladder 1 ea. 15,000 $ 15,000 $ 

Water Storage - Pumpkin 2 ea. 3,500 $ 7,000 $ 

500 Gallon Fuel Tank/Pump 2 ea. 10,000 $ 20,000 $ 

Existing Base Funding: $ 100,000

Shared Equipment Budget 1 lump 100,000 $ 100,000 $ 100,000 $ 

Total: Restoration and Implementation $ 285,664

Net Present Value of Restoration and Implementation over 15 Year Period $ 274,677

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

New Funding: $ 258,007

Equipment $ 125,000

Fire Cache (One-Time) Staff Est. of Supplies 50,000 $ 

Fire Engine (One Time) $ 75,000

Staff (Ongoing) Cost reflects cost/ $ 133,007

Fire Program Technician (GS-6/9) unit increased by 45% FTE 49,283 1 $ 49,283 $ 

Fire Engine Foreman (GS-5/6) to reflect training, FTE 44,211 1 $ 44,211 $ 

Fire Fighters (Seasonal) (GS-4/5) supplies and benefits. FTE 39,514 1 $ 39,514 $ 

Total: Fire Management $ 258,007

Net Present Value of Fire Managment over 15 Year Period $ 1,599,016

Restoration and Implementation (One-Time)

Operations (Ongoing)

Fire Management
Final Comprehensive Conservation Plan & EIS 289

Appendix F: Cost Details

Alternative B Estimated Costs

Rocky Flats National Wildlife Refuge

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

New Funding: (see notes) $ 427,914

Staff $ 302,115

Refuge Manager (GS-12) Cost reflects cost/ FTE 69,939 1.0 $ 101,412 $ 

Biologist (GS-11) unit increased by 45% FTE 58,353 1.0 $ 84,612 $ 

Public Use (GS-9) to reflect training, FTE 48,230 1.0 $ 69,934 $ 

Range Biotech (GS-5) supplies and benefits. FTE 31,833 1.0 $ 46,158 $ 

Maintenance $ 100,779

Weed Management Staff Est. of Supplies 50,000 $ 

Lindsay Barn Staff Estimate 2,000 $ 

Facility/Equipment Maintenance 5% of Facilities/Equip. 48,779 $ 

Utilities $ 20,020

Electricity months 250 12 $ 3,000 $ 

Gas months 250 12 $ 3,000 $ 

Phone Over 12 months 5 lines 50 $ 3,000 $ 

Burglar Alarm 12 months 100 $ 1,200 $ 

Cleaning/Trash Pickup Clean 2x/week 9,820 $ 

Interpretive Materials lump 5,000 1 $ 5,000 $ 5,000 $ 

Existing Base Funding: $ 134,150

Staff $ 129,150

Public Use Assistance (GS-11) Cost reflects cost/ FTE 58,353 0.25 $ 21,153 $ 

Public Use Assistance (GS-5) unit increased by 45% FTE 31,833 0.50 $ 23,079 $ 

Administrative Assistance (GS-9) to reflect training, FTE 48,230 0.15 $ 10,490 $ 

Maintenance (WG-7) supplies and benefits. FTE 43,666 0.25 $ 15,829 $ 

Law Enforcement (GS-9) 0.50 FTE 48,230 $ 58,599 $ 

Maintenance $ 5,000

Shared Equipment Maintenance 5% of Shared Equip. 5,000 $ 

Total: Operations $ 562,064

Net Present Value of Operations over 15 Year Period $ 6,249,247

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

New Funding: $ 1,537,151 

Restoration $ 93,736

Seeding

Restoration Seeding Disturbed/Non-Native 417 ac. 134 $ 55,878 $ 

Seed for Eliminating Roads 27.8 miles @ 20 feet 67 ac. 134 $ 9,031 $ 

Seed for Road Narrowing 21 ac. 134 $ 2,827 $ 

Stream Crossing Restoration 26 ea. 1,000 $ 26,000 $ 

Facilities

Public Use $ 465,664

Trails

New Trails - Natural Surface 3.7 Miles 19,536 l.f. 4 $ 78,144 $ 389,664 $ 

ADA Accessible (Reused Ro .9 Miles

Prep 23,760 s.f. 0.12 $ 2,851 $ 

Surfacing 23,760 s.f. 2.50 $ 59,400 $ 

Visitor Facilities

Restroom 1 ea. 26,000 $ 26,000 $ 

Viewing Blind 1 ea. 15,000 $ 15,000 $ 

Seasonal Contact Station 1,200 s.f. 150 $ 180,000 $ 

Benches 4 ea. 1,500 $ 6,000 $ 

Parking Lots 3 Lots/70 Cars/1 Bus

Site Preparation 26,830 s.f. 0.38 $ 10,195 $ 

Surfacing 26,830 s.f. 0.45 $ 12,074 $ 

Interpretation

Interpretive Sign Panels (Porcelain) 4 ea. 5,500 $ 22,000 $ 

Interpretive Signs (Porcelain Trails, Sm. Entrances 6 ea 4,000 $ 24,000 $ 

Kiosk 1 ea. 10,000 $ 10,000 $ 

Interior Display 1 lump 20,000 $ 20,000 $ 

Restoration and Implementation (One-Time)

Operations (Ongoing)
290 Rocky Flats National Wildlife Refuge 

Appendix F: Cost Details

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

Administrative $ 316,018

Administrative Offices Incl. in Contact Sta. - $ 

Storage/Maintenance Building 30'x75' 1 lump 225,000 $ 225,000 $ 

Cistern ea. 8,000 1 $ 8,000 $ 

Septic System 1 lump 12,000 $ 12,000 $ 

Burglar Alarm 1 lump 2,000 $ 2,000 $ 

Fencing

Remove Interior Stock Fence Approx. 8 Miles 42,240 l.f. 0.50 $ 21,120 $ 

Weed Control Fencing Approx. 3 Miles 15,840 l.f. 0.17 $ 2,693 $ 

Security Fencing around Facilities 400 l.f. 57 $ 22,800 $ 

Signs

Roadside 6 ea. 650 $ 3,900 $ 

Boundary Every 1,000 Feet 67 ea. 15 $ 1,005 $ 

Trail Directional 5 ea. 500 $ 2,500 $ 

Utilities

Power 1 lump 15,000 $ 15,000 $ 

Equipment $ 193,900

Computers/Fax/Office Equipment 4 emp. 2,200 $ 8,800 $ 

Mountain Bike (for Patrol) 2 ea. 800 $ 1,600 $ 

All Terrain Vehicle (ATV) 2 ea. 6,500 $ 13,000 $ 

Spray-Rig for ATV 2 ea. 1,500 $ 3,000 $ 

Maintenance Truck 1 ea. 35,000 $ 35,000 $ 

Pickup Truck ea. 22,000 2 $ 44,000 $ 

Slip-On Spray-Rig for Truck 1 ea. 12,000 $ 12,000 $ 

Mower ea. 9,500 1 $ 9,500 $ 

Maintenance Tools 1 lump 10,000 $ 10,000 $ 

Biological Monitoring/Restoration Tools 1 lump 15,000 $ 15,000 $ 

Water Storage - 50K Gallon Bladder 1 ea. 15,000 $ 15,000 $ 

Water Storage - Pumpkin 2 ea. 3,500 $ 7,000 $ 

500 Gallon Fuel Tank/Pump 2 ea. 10,000 $ 20,000 $ 

Planning and Design $ 78,169

Site Layout and Design 10% of Construction 1 lump 78,169 $ 78,169 $ 

Existing Base Funding: $ 100,000

Shared Equipment Budget 1 lump 100,000 $ 100,000 $ 100,000 $ 

Total: Restoration and Implementation $ 1,637,151

Net Present Value of Restoration and Implementation over 15 Year Period $ 1,159,182

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

New Funding: $ 258,007

Equipment $ 125,000

Fire Cache (One-Time) Staff Est. of Supplies 50,000 $ 

Fire Engine (One Time) $ 75,000

Staff (Ongoing) Cost reflects cost/ $ 133,007

Fire Program Technician (GS-6/9) unit increased by 45% FTE 49,283 1 $ 49,283 $ 

Fire Engine Foreman (GS-5/6) to reflect training, FTE 44,211 1 $ 44,211 $ 

Fire Fighters (Seasonal) (GS-4/5) supplies and benefits. FTE 39,514 1 $ 39,514 $ 

Total: Fire Management $ 258,007

Net Present Value of Fire Managment over 15 Year Period $ 1,599,016

Fire Management
Final Comprehensive Conservation Plan & EIS 291

Appendix F: Cost Details

Alternative C Estimated Costs

Rocky Flats National Wildlife Refuge

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

New Funding: (see notes) $ 698,335

Staff $ 370,298

Refuge Manager (GS-12) Cost reflects cost/ FTE 69,939 1.0 $ 101,412 $ 

Biologist (GS-11) unit increased by 45% FTE 58,353 1.0 $ 84,612 $ 

Biologist (GS-9) to reflect training, FTE 48,230 1.0 $ 69,934 $ 

Range Biotech (GS-7) (2) supplies and benefits. FTE 39,428 2.0 $ 114,341 $ 

Maintenance

Weed Management Staff Est. of Supplies 75,000 $ 104,017 $ 

Facility/Equipment Maintenance 5% of Facilities/Equip. 29,017 $ 

Facilities $ 210,000

Office Lease Over 12 months 1,000 s.f. 17.50 $ 210,000 $ 

*Based on Average May, 2003 Office Lease Rate for Westminster

Utilities $ 12,520

Phone Over 12 months 5 lines 50 $ 3,000 $ 

Burglar Alarm (Maintenance Building) 12 months 100 $ 1,200 $ 

Cleaning Clean 2x/week 8,320 $ 

Interpretive Materials lump 1,500 1 $ 1,500 $ 1,500 $ 

Existing Base Funding: $ 136,650

Staff $ 129,150

Public Use Assistance (GS-11) Cost reflects cost/ FTE 58,353 0.25 $ 21,153 $ 

Public Use Assistance (GS-5) unit increased by 45% FTE 31,833 0.50 $ 23,079 $ 

Administrative Assistance (GS-9) to reflect training, FTE 48,230 0.15 $ 10,490 $ 

Maintenance (WG-7) supplies and benefits. FTE 43,666 0.25 $ 15,829 $ 

Law Enforcement (GS-9) 0.50 FTE 48,230 $ 58,599 $ 

Maintenance $ 7,500

Shared Equipment Maintenance 5% of Shared Equip. 7,500 $ 

Total: Operations $ 834,985

Net Present Value of Operations over 15 Year Period $ 9,283,686

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

New Funding:

Restoration $ 732,369

Seeding $ 113,534

Restoration Seeding Disturbed/Non-Native 419 ac. 134 $ 56,146 $ 

Seed for Eliminating Roads 28.9 miles @ 20 feet 70 ac. 134 $ 9,388 $ 

Remove Lindsay Ranch Buildings 1 lump 30,000 $ 30,000 $ 

Stream Crossing Restoration 18 ea. 1,000 $ 18,000 $ 

Facilities

Public Use $ 77,564

Trails

ADA Accessible (Reused Road) .6 Miles

Prep 15,840 s.f. 0.12 $ 1,901 $ 

Surfacing 15,840 s.f. 2.50 $ 39,600 $ 

Visitor Facilities

Restroom 1 ea. 26,000 $ 26,000 $ 

Benches Overlook 1 ea. 1,500 $ 1,500 $ 

Parking Lots 1 Lot/10 Cars

Site Preparation 3,690 s.f. 0.38 $ 1,402 $ 

Surfacing 3,690 s.f. 0.45 $ 1,661 $ 

Interpretation

Interpretive Sign Panels (Porcelain) Overlook 1 ea. 5,500 $ 5,500 $ 

Administrative $ 307,468

Storage/Maintenance Building 30'x75' 1 lump 225,000 $ 225,000 $ 

Cistern ea. 8,000 1 $ 8,000 $ 

Septic System 1 lump 12,000 $ 12,000 $ 

Burglar Alarm 1 lump 2,000 $ 2,000 $ 

Fencing

Remove Interior Stock Fence Approx. 8 Miles 42,240 l.f. 0.50 $ 21,120 $ 

Weed Control Fencing Approx. 3 Miles 15,840 l.f. 0.17 $ 2,693 $ 

Security Fencing around Facilities 250 l.f. 57 $ 14,250 $ 

Restoration and Implementation (One-Time)

Operations (Ongoing)
292 Rocky Flats National Wildlife Refuge 

Appendix F: Cost Details

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

Signs

Roadside 6 ea. 650 $ 3,900 $ 

Boundary Every 1,000 Feet 67 ea. 15 $ 1,005 $ 

Trail Directional 5 ea. 500 $ 2,500 $ 

Utilities

Power lump 15,000 1 $ 15,000 $ 

Equipment $ 195,300

Computers/Fax/Office Equipment 5 emp. 2,200 $ 11,000 $ 

Mountain Bike (for Patrol) 1 ea. 800 $ 800 $ 

All Terrain Vehicle (ATV) 2 ea. 6,500 $ 13,000 $ 

Spray-Rig for ATV 2 ea. 1,500 $ 3,000 $ 

Maintenance Truck 1 ea. 35,000 $ 35,000 $ 

Pickup Truck 2 ea. 22,000 $ 44,000 $ 

Slip-On Spray-Rig for Truck 1 ea. 12,000 $ 12,000 $ 

Mower ea. 9,500 1 $ 9,500 $ 

Maintenance Tools 1 lump 10,000 $ 10,000 $ 

Biological Monitoring/Restoration Tools 1 lump 15,000 $ 15,000 $ 

Water Storage - 50K Gallon Bladder 1 ea. 15,000 $ 15,000 $ 

Water Storage - Pumpkin 2 ea. 3,500 $ 7,000 $ 

500 Gallon Fuel Tank/Pump 2 ea. 10,000 $ 20,000 $ 

Planning and Design

Site Layout and Design 10% of Construction 1 lump 38,504 $ 38,504 $ 38,504 $ 

Existing Base Funding: $ 150,000

Shared Equipment Budget 1 lump 150,000 $ 150,000 $ 150,000 $ 

Total: Restoration and Implementation $ 882,369

Net Present Value of Restoration and Implementation over 15 Year Period $ 834,657

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

New Funding: $ 258,007

Equipment $ 125,000

Fire Cache (One-Time) Staff Est. of Supplies 50,000 $ 

Fire Engine (One Time) $ 75,000

Staff (Ongoing) Cost reflects cost/ $ 133,007

Fire Program Technician (GS-6/9) unit increased by 45% FTE 49,283 1 $ 49,283 $ 

Fire Engine Foreman (GS-5/6) to reflect training, FTE 44,211 1 $ 44,211 $ 

Fire Fighters (Seasonal) (GS-4/5) supplies and benefits. FTE 39,514 1 $ 39,514 $ 

Total: Fire Management $ 258,007

Net Present Value of Fire Managment over 15 Year Period $ 1,599,016

Fire Management
Final Comprehensive Conservation Plan & EIS 293

Appendix F: Cost Details

Alternative D Estimated Costs

Rocky Flats National Wildlife Refuge

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

New Funding: (see notes) $ 1,001,734

Staff $ 647,989

Refuge Manager (GS-12) Cost reflects cost/ FTE 69,939 1.0 $ 101,412 $ 

Biologist (GS-11) unit increased by 45% FTE 58,353 1.0 $ 84,612 $ 

Refuge Operations Specialist (GS-9) to reflect training, FTE 48,230 1.0 $ 69,934 $ 

Public Use (GS-11) supplies and benefits. FTE 58,353 1.0 $ 84,612 $ 

Public Use (GS-9) FTE 48,230 1.0 $ 69,934 $ 

Public Use (GS-7) FTE 39,428 1.0 $ 57,171 $ 

Maintenance/Biotech (WG-7) 1.0 FTE 43,666 $ 63,316 $ 

Law Enforcement (GS-9) Cost reflects law enforcement FTE 48,230 1.0 $ 117,000 $ 

training, supplies and benefits

Maintenance $ 277,745

Weed Management Staff Est. of Supplies 50,000 $ 

Lindsay Barn Staff Estimate 2,000 $ 

Facility/Equipment Maintenance 5% of Facilities/Equip. 225,745 $ 

Utilities $ 68,000

Electricity months 1,200 12 $ 14,400 $ 

Gas months 1,000 12 $ 12,000 $ 

Phone Over 12 months 10 lines 50 $ 6,000 $ 

Burglar Alarm months 200 12 $ 2,400 $ 

Cleaning/Trash Pickup Clean 3x/week 33,200 $ 

Interpretive Materials lump 8,000 1 $ 8,000 $ 8,000 $ 

Existing Base Funding: $ 59,722

Staff $ 54,722

Public Use Assistance (GS-11) Cost reflects cost/ FTE 58,353 0.25 $ 21,153 $ 

Public Use Assistance (GS-5) unit increased by 45% FTE 31,833 0.50 $ 23,079 $ 

Administrative Assistance (GS-9) to reflect training, FTE 48,230 0.15 $ 10,490 $ 

supplies and benefits.

Maintenance $ 5,000

Shared Equipment Maintenance 5% of Shared Equip. 5,000 $ 

Total: Operations $ 1,061,456

Net Present Value of Operations over 15 Year Period $ 11,801,675

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

New Funding: $ 4,999,915 

Restoration $ 53,792

Seeding

Restoration Seeding Disturbed/Non-Native 119 ac. 134 $ 15,946 $ 

Seed for Eliminating Roads 26.4 miles @ 20 feet 64 ac. 134 $ 8,576 $ 

Seed for Road Narrowing 24 ac. 134 $ 3,270 $ 

Stream Crossing Restoration 26 ea. 1,000 $ 26,000 $ 

Facilities

Public Use $ 3,815,078

Trails

New Trails - Natural Surface 4.7 Miles 24,816 l.f. 4 $ 99,264 $ 

ADA Accessible (Reused Road) 1.7 Miles

Prep s.f. 0.12 44,880 $ 5,386 $ 

Surfacing 44,880 s.f. 2.50 $ 112,200 $ 

Visitor Facilities

Restroom ea. 26,000 2 $ 52,000 $ 

Viewing Blind ea. 15,000 2 $ 30,000 $ 

Visitor Center Staff Estimate 1 lump 3,000,000 $ 3,000,000 $ 

Outdoor Education Center Arsenal Estimate 1 ea. 321,753 $ 321,753 $ 

Benches ea. 1,500 8 $ 12,000 $ 

Parking Lots 6 Lots/140 Cars/2 Bus

Site Preparation 49,970 s.f. 0.38 $ 18,989 $ 

Surfacing 49,970 s.f. 0.45 $ 22,487 $ 

Interpretation

Interpretive Sign Panels (Porcelain) 6 ea. 5,500 $ 33,000 $ 

Interpretive Signs (Porcelain) Trails, Sm. Entrances 12 ea 4,000 $ 48,000 $ 

Kiosk ea. 10,000 1 $ 10,000 $ 

Interior Display 1 lump 50,000 $ 50,000 $ 

Restoration and Implementation (One-Time)

Operations (Ongoing)
294 Rocky Flats National Wildlife Refuge 

Appendix F: Cost Details

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

Administrative $ 497,125

Administrative Offices Incl. In Visitor Ctr.

Storage/Maintenance Building 30'x100' 1 lump 350,000 $ 350,000 $ 

Cistern ea. 18,000 1 $ 18,000 $ 

Septic System lump 25,000 1 $ 25,000 $ 

Burglar Alarm lump 3,000 1 $ 3,000 $ 

Fencing

Remove Interior Stock Fence Approx. 8 Miles 42,240 l.f. 0.50 $ 21,120 $ 

Security Fencing around Facilities 800 l.f. 57 $ 45,600 $ 

Signs

Roadside ea. 650 6 $ 3,900 $ 

Boundary Every 1,000 Feet 67 ea. 15 $ 1,005 $ 

Trail Directional 9 ea. 500 $ 4,500 $ 

Utilities

Power lump 25,000 1 $ 25,000 $ 

Equipment $ 202,700

Computers/Fax/Office Equipment 8 emp. 2,200 $ 17,600 $ 

Mountain Bike (for Patrol) 2 ea. 800 $ 1,600 $ 

All Terrain Vehicle (ATV) 2 ea. 6,500 $ 13,000 $ 

Spray-Rig for ATV ea. 1,500 2 $ 3,000 $ 

Maintenance Truck ea. 35,000 1 $ 35,000 $ 

Pickup Truck ea. 22,000 2 $ 44,000 $ 

Slip-On Spray-Rig for Truck 1 ea. 12,000 $ 12,000 $ 

Mower ea. 9,500 1 $ 9,500 $ 

Maintenance Tools lump 10,000 1 $ 10,000 $ 

Biological Monitoring/Restoration Tools 1 lump 15,000 $ 15,000 $ 

Water Storage - 50K Gallon Bladder 1 ea. 15,000 $ 15,000 $ 

Water Storage - Pumpkin 2 ea. 3,500 $ 7,000 $ 

500 Gallon Fuel Tank/Pump 2 ea. 10,000 $ 20,000 $ 

Planning and Design $ 431,221

Site Layout and Design 10% of Construction 431,221 $ 431,221 $ 

Existing Base Funding: $ 100,000

Shared Equipment Budget 1 lump 100,000 $ 100,000 $ 100,000 $ 

Total: Restoration and Implementation $ 5,099,915

Net Present Value of Restoration and Implementation over 15 Year Period $ 4,624,873

Notes Quantity Units Cost/Unit Cost Subtotal Area Subtotal 

New Funding: $ 208,724

Equipment $ 125,000

Fire Cache (One-Time) Staff Est. of Supplies 50,000 $ 

Fire Engine (One Time) $ 75,000

Staff (Ongoing) Cost reflects cost/ $ 83,724

Fire Engine Foreman (GS-5/6) to reflect training, FTE 44,211 1 $ 44,211 $ 

Fire Fighters (Seasonal) (GS-4/5) supplies and benefits. FTE 39,514 1 $ 39,514 $ 

Total: Fire Management $ 208,724

Net Present Value of Fire Managment over 15 Year Period $ 1,051,073

Fire Management
appendix g

Species Lists

Final Comprehensive Conservation Plan & EIS 297

Appendix G: Species Lists

ROCKY FLATS NWR WILDLIFE SPECIES LIST 

BIRDS

Raptors 

American kestrel Falco sparverius

Bald eagle Haliaeetus leucocephalus

Barn owl Tyto alba

Black vulture Coragyps atratus

Broad-winged hawk Buteo platypterus

Burrowing owl Athene cunicularia

Cooper’s hawk Accipiter cooperii

Ferruginous hawk Buteo regalis

Golden eagle Aquila chrysaetos

Great horned owl Bubo virginianus

Long-eared owl Asio otus

Merlin Falco columbarius

Northern goshawk Accipiter gentilis

Northern harrier Circus cyaneus

Osprey Pandion haliaetus

Peregrine falcon Falco peregrinus

Prairie falcon Falco mexicanus

Red-tailed hawk Buteo jamaicensis

Rough-legged hawk Buteo lagopus

Sharp-shinned hawk Accipiter striatus

Short-eared owl Asio flammeus

Swainson’s hawk Buteo swainsoni

Turkey vulture Cathartes aura

Songbirds 

American crow Corvus brachyrhynchos

American goldfinch Carduelis tristis

American pipit Anthus rubescens

American redstart Setophaga ruticilla

American robin Turdus migratorius

American tree sparrow Spizella arborea

Ash-throated flycatcher Myiarchus cinerascens

Barn swallow Hirundo rustica

Belted kingfisher Ceryle alcyon

Black swift Cypseloides niger

Black-billed cuckoo Coccyzus erythropthalmus

Black-billed magpie Pica hudsonia

Black-capped chickadee Poecile atricapilla

Black-headed grosbeak Pheucticus elanocephalus

Black-throated 

gray warbler Dendroica nigrescens

Blue grosbeak Guiraca caerulea

Blue jay Cyanocitta cristata

Blue-gray gnatcatcher Polioptila caerulea

Blue-headed vireo Vireo solitarius

Bohemian waxwing Bombycilla garrulus 

Brewer’s blackbird Euphagus cyanocephalus

Brewer’s sparrow Spizella breweri

Broad-tailed hummingbird Selasphorus platycercus

Brown thrasher Toxostoma rufum

Brown-headed cowbird Molothrus ater

Bullock’s oriole Icterus bullockii

Cassin’s finch Carpodacus cassinii

Cassin’s sparrow Aimophila cassinii

Chestnut-collaredlongspur Calcarius ornatus

Chestnut-sided warbler Dendroica pensylvanica

Chipping sparrow Spizella passerina

Clay-colored sparrow Spizella pallida

Cliff swallow Petrochelidon pyrrhonota

Common grackle Quiscalus quiscula

Common nighthawk Chordeiles minor

Common poorwill Phalaenoptilus nuttallii

Common raven Corvus corax

Common yellowthroat Geothlypis trichas

Cordilleran flycatcher Empidonax occidentalis

Dark-eyed junco Junco hyemalis canice

Downy woodpecker Picoides pubescens

Eastern kingbird Tyrannus tyrannus

Eastern phoebe Sayornis phoebe

European starling Sturnus vulgaris

Field sparrow Spizella pusilla

Fox sparrow Passerella illiaca

Golden-crowned kinglet Regulus satrapa

Grasshopper sparrow Ammodramus savannarum

Gray catbird Dumetella carolinensis

Green-tailed towhee Pipilo chlorurus

Hairy woodpecker Picoides villosus

Hermit thrush Catharus guttatus

Horned lark Eremophila alpestris

House finch Carpodacus mexicanus

House sparrow Passer domesticus

House wren Troglodytes aedon

Lapland longspur Calcarius lapponicus

Lark bunting Calamospiza melanocorys 

Lark sparrow Chondestes grammacus

Lazuli bunting Passerina amoena

Lesser goldfinch Carduelis psaltria

Lincoln’s sparrow Melospiza lincolnii

Loggerhead shrike Lanius ludovicianus

MacGillivray’s warbler Opornis tolmiei

Marsh wren Cistothorus palustris

Mountain bluebird Sialia currucoides

Mountain chickadee Parus gambeii

Mourning dove Zenaida macroura

Northern flicker Colaptes auratus

Northern mockingbird Mimus polyglottus

Northern shrike Lanius excubitor

Orange-crowned warbler Vermivora celata

Ovenbird Seiurus aurocapillus

Palm warbler Dendroica palmarum

Pine siskin Carduelis pinus

Red-breasted nuthatch Sitta canadensis

Red-naped sapsucker Sphyrapicus nuchalis

Red-winged blackbird Agelaius phoeniceus

Rock sove Columba livia

Rock wren Salpinctes obsoletus

Ruby-crowned kinglet Regulus calendula
298 Rocky Flats National Wildlife Refuge 

Appendix G: Species Lists 

Rufous hummingbird Selasphorus rufus

Sage thrasher Oreoscoptes montanus 

Savannah sparrow Passerculus sandwichensis

Say’s phoebe Sayornis saya

Snow bunting Plectrophenax nivalis

Song sparrow Melospiza melodia

Spotted towhee Pipilo maculatus

Swainson’s thrush Catharus ustulatus

Townsend’s solitaire Myadestes townsendi

Tree swallow Tachycineta bicolor

Vesper sparrow Pooecetes gramineus

Violet-green swallow Tachycineta thalassina

Virginia’s warbler Vermivora virginiae

Warbling vireo Vireo gilvus

Western bluebird Sialia mexicana

Western kingbird Tyrannus verticalis

Western meadowlark Sturnella neglecta

Western tanager Piranga ludoviciana

Western wood-pewee Contopus sordidulus

White-breasted nuthatch Sitta carolinensis

White-crowned sparrow Zonotrichia leucophrys

Willow flycatcher Empidonax trailii

Wilson’s warbler Wilsonia pusilla

Yellow warbler Dendroica petechia

Yellow-breasted chat Icteria virens

Yellow-headed blackbird Xanthocephalus xanthocephalus

Yellow-rumped warbler Dendroica coronata 

Upland Game 

Ring-necked pheasant Phasianus colchicus

Sharp-tailed grouse Tympanuchus phasianellus 

Waterfowl and Shorebirds 

American bittern Botaurus lentiginosus

American coot Fulica americana

American white pelican Pelecanus erythrorhynchos

American wigeon Anas americana

Black-crowned nightheron Nycticorax nycticorax

Blue-winged teal Anas discors

Bufflehead Bucephala albeola

Canada goose Branta canadensis

Canvasback Aythya valisineria

Cinnamon teal Anas cyanoptera

Common goldeneye Bucephala clangula

Common merganser Mergus merganser

Common snipe Gallinago gallinago

Double-crested cormorant Phalacrocorax auritus

Eared grebe Podiceps nigricollis

Franklin’s gull Larus pipixcan

Gadwall Anas strepera

Great blue heron Ardea herodias

Great egret Ardea alba

Greater scaup Aythya marila

Greater yellowlegs Tringa melanoleuca

Green-winged teal Anas crecca

Hooded merganser Lophodytes cucullatus

Killdeer Charadrius vociferus

Lesser scaup Aythya affinis

Lesser yellowlegs Tringa flavipes

Long-billed curlew Numenius americanus

Mallard Anas platyrhynchos

Northern pintail Anas acuta

Northern shoveler Anas clypeata

Pectoral sandpiper Calidris melanotos

Pied-billed grebe Podilymbus podiceps

Redhead Aythya americana

Ring-billed gull Larus delawarensis

Ring-necked duck Aythya collaris

Ruddy duck Oxyura jamaicensis

Semipalmated plover Charadrius semipalmatus

Semipalmated sandpiper Calidris pusilla

Snow goose Chen caerulescens

Snowy egret Egretta thula

Solitary sandpiper Tringa solitaria

Sora Porzana carolina

Spotted sandpiper Actitis macularia

Virginia rail Rallus limicola

Western grebe Aechmophorus occidentalis

White-faced Ibis Plegadis chihi

Willet Catoptrophorus semipalmatus

Wilson’s phalarope Phalaropus tricolor

Wood duck Aix sponsa 

MAMMALS

American black bear Ursus americanus

Big brown bat Eptesicus fuscus

Black-tailed prairie dog Cynomys ludovicianus

Bobcat Lynx rufus

Common gray fox Urocyon cinereoargenteus

Common porcupine Erethizon dorsatum

Coyote Canis latrans

Deer mouse Peromyscus maniculatus

Desert cottontail Sylvilagus audubonii

Eastern fox squirrel Sciurus niger

Elk (Wapiti) Cervus elaphus

Hispid pocket mouse Chaetodipus hispidus

House mouse Mus musculus

Long-tailed vole Microtus longicaudus

Masked shrew Sorex cinereus

Meadow vole Microtus pennsylvanicus

Merriam’s shrew Sorex merriami

Mexican woodrat Neotoma mexicana

Mountain lion Felis concolor

Mule deer Odocoileus hemionus

Mule x White-tailed deer Odocoileus hemionus x 

 virginianus

Muskrat Ondatra zibethicus

Northern pocket gopher Thomomys talpoides

Olive-backed pocket mouse Perognathus fasciatus

Plains harvest mouse Reithrodontomys montanus

Plains pocket mouse Perognathus flavescens

Prairie vole Microtus ochrogaster 
Final Comprehensive Conservation Plan & EIS 299

Preble’s meadow 

jumping mouse Zapus hudsonius preblei

Raccoon Procyon lotor

Silky pocket mouse Perognathus flavus

Striped skunk Mephitis mephitis

Thirteen-lined 

ground squirrel Spermophilus tridecemlineatus

Chipmunk Eutamias spp. 

Western harvest mouse Reithrodontomys megalotis

Western jumping mouse Zapus princeps

White-tailed deer Odocoileus virginianus

White-tailed jackrabbit Lepus townsendii

REPTILES AND AMPHIBIANS

Boreal chorus frog Pseudacris triseriatus maculata

Bullfrog Rana catesbeiana

Bullsnake Pituophis melanoleucus

Eastern yellowbelly racer Coluber constrictor

Great Plains toad Bufo cognatus

Northern leopard frog Rana pipiens

Prairie rattlesnake Crotalus viridis

Red-sided garter snake Thamnophis sirtalis 

Short-horned lizard Phynosoma douglassi

Snapping turtle Chelydra serpentian

Tiger salamander Ambystoma tigrinum

Unidentified lizard 

Western painted turtle Chrysemys picta

Western plains garter 

snake Thamnophis radix

FISH

Bluegill Lepomis macrochirus

Creek chub Semotilus atromaculatus

Common shiner Luxilus cornutus

Fathead minnow Pimephales promelas

Green sunfish Lepomis cyanellus

Northern redbelly dace Phoxinus eos

Largemouth bass Micropterus salmoides

Longnose dace Rhinichthys cataractae

Smallmouth bass Micropterus dolomieui

Stoneroller Campostoma anomalum

White sucker Catostomus commersoni

OTHERS

The following types invertebrate species have also been identified at Rocky Flats: 

x 63 species of phytoplankton 

x 63 species of zooplankton 

x 197 macrobiotic invertebrates 

x 72 emergent insects 

x 688 terrestrial invertebrates

Appendix G: Species Lists
300 Rocky Flats National Wildlife Refuge 

ROCKY FLATS NWR PLANT SPECIES LIST 

Listed in alphabetical order by scientific name. 

State listed noxious weeds are marked with an *. 

GRASSES

Jointed Goatgrass* Aegilops cylindrica 

X Agrohordeum macounii 

Slender Wheatgrass Agropyron caninum 

Crested Wheatgrass Agropyron cristatum 

Thickspike Wheatgrass Agropyron dasystachyum 

Crested Wheatgrass Agropyron desertorum

Tall Wheatgrass Agropyron elongatum 

Griffin’s Wheatgrass Agropyron griffithsii 

Intermediate 

Wheatgrass Agropyron intermedium 

Quackgrass * Agropyron repens 

Western Wheatgrass Agropyron smithii

Bluebunch Wheatgrass Agropyron spicatum 

Ticklegrass Agrostis scabra

Redtop Agrostis stolonifera

Marsh Foxtail Alopecurus geniculatus 

Big Bluestem Andropogon gerardii 

Silver Bluestem Andropogon saccharoides

Little Bluestem Andropogon scoparius.

Italian Windgrass Apera interrupta 

Forktip Threeawn Aristida basiramea 

Fendler Threeawn Aristida purpurea 

Red Threeawn Aristida purpurea

Cultivated Oats Avena fatua var. sativa 

Side-oats Grama Bouteloua curtipendula 

Blue Grama Bouteloua gracilis 

Hairy Grama Bouteloua hirsuta 

Rattlesnake Grass Bromus briziformis 

Smooth Brome Bromus inermis 

Japanese Brome Bromus japonicus

Downy Brome * Bromus tectorum

Buffalo-grass Buchloe dactyloides 

Northern Reedgrass Calamagrostis stricta 

Field Sandbur Cenchrus longispinus 

Rescuegrass Ceratochloa marginata 

Bermuda Grass Cynodon dactylon 

Orchardgrass Dactylis glomerata

Poverty Oatgrass Danthonia spicata 

Slimleaf Dichanthelium Dichanthelium linearifolium 

Scribner Dichanthelium Dichanthelium oligosanthes 

Hairy Crabgrass Digitaria sanguinalis 

Inland Salt Grass Distichlis spicata

Barnyard Grass Echinochloa crusgallii.

Canada Wild Rye Elymus canadensis

Russian Wild Rye Elymus juncea

Stinkgrass Eragrostis cilianensis 

Weeping Lovegrass Eragrostis curvula 

Little Lovegrass Eragrostis minor 

India Lovegrass Eragrostis pilosa

Sand Lovegrass Eragrostis trichodes 

Six-weeks Fescue Festuca octoflora

Sheep’s Fescue Festuca ovina 

Meadow Fescue Festuca pratensis

Tall Mannagrass Glyceria grandis 

Fowl Mannagrass Glyceria striata 

Meadow Barley Hordeum brachyantherum 

Foxtail Barley Hordeum jubatum

Little Barley Hordeum pusillum

Junegrass Koeleria pyramidata 

Rice Cutgrass Leersia oryzoides 

Italian Ryegrass Lolium perenne 

Perennial Ryegrass Lolium perenne

Wolftail Lycurus phleoides 

Scratchgrass Muhlenbergia asperifolia 

Muhly Muhlenbergia filiformis 

Mountain Muhly Muhlenbergia montana 

Marsh Muhly Muhlenbergia racemosa

Spike Muhly Muhlenbergia wrightii 

Indian Ricegrass Oryzopsis hymenoides 

Witchgrass Panicum capillare 

Fall Panicum Panicum dichotomiflorum

Switchgrass Panicum virgatum 

Reed Canarygrass Phalaris arundinacea 

Timothy Phleum pratense

Common Reed Phragmites australis 

Bulbous Bluegrass Poa bulbosa 

Canby’s Bluegrass Poa canbyi 

Canada Bluegrass Poa compress

Muttongrass Poa fendleriana 

Alkali Bluegrass Poa juncifolia

Fowl Bluegrass Poa palustris

Kentucky Bluegrass Poa pratensis

Rabbitfoot Grass Polypogon monspeliensis 

Tumblegrass Schedonnardus paniculatus.

Rye Secale cereale 

Green Foxtail Setaria viridis 

Squirreltail Sitanion hystrix 

Indian-grass Sorghastrum nutans 

Prairie Cordgrass Spartina pectinata 

Prairie Wedgegrass Sphenopholis obtusata.

Rough Dropseed Sporobolus asper 

Sand Dropseed Sporobolus cryptandrus 

Prairie Dropseed Sporobolus heterolepis 

Poverty Grass Sporobolus neglectus 

Needle-and-thread Stipa comata 

New Mexico Feather 

Grass Stipa neomexicana 

Sleepy Grass Stipa robusta 

Porcupine-grass Stipa spartea 

Green Needlegrass Stipa viridula 

Wheat Triticum aestivum 

Narrow-leaved Cattail Typha angustifolia 

Common Cattail Typha latifolia 

Blue-eyed Grass Sisyrinchium montanum 

Articulate Rush Juncus articulatus 

Baltic Rush Juncus balticus 

Appendix G: Species Lists 
Final Comprehensive Conservation Plan & EIS 301

Toad Rush Juncus bufonius 

Dudley Rush Juncus dudleyi 

Swordleaf rush Juncus ensifolius 

Inland Rush Juncus interior

Longstyle rush Juncus longistylis

Knotted Rush Juncus nodosus 

Torrey’s Rush Juncus torreyi 

Tracy Rush Juncus tracyi

Spikerush Eleocharis acicularis 

Spikerush Eleocharis compressa 

Spikerush Eleocharis macrostachya 

Blunt Spikerush Eleocharis obtusa

Spikerush Eleocharis parvula 

Bulrush Scirpus acutus 

Bulrush Scirpus pallidus 

Pungent Bulrush Scirpus pungens 

Bulrush Scirpus validus 

Slenderbeak sedge Carex athrostachya 

Golden sedge Carex aurea 

Bebs sedge Carex bebbii 

Short-beaked sedge Carex brevior

Douglas sedge Carex douglasii

Narrowleaf sedge Carex eleocharis 

Emory’s sedge Carex emoryi

Threadleaf sedge Carex filifolia

Bottlebrush sedge Carex hystericina

Inland sedge Carex interior 

Sun sedge Carex inops ssp. heliophila

Woolly sedge Carex lanuginosa

Nebraska sedge Carex nebrascensis

Grassyslope sedge Carex oreocharis

Clustered field sedge Carex praegracilis 

Beaked sedge Carex rostrata 

Broom sedge Carex scoparia 

Analogue sedge Carex simulata 

Prickly sedge Carex stipata 

Fox Sedge Carex vulpinoidea 

Field Horsetail Equisetum arvense 

Smooth Horsetail Equisetum laevigatum 

Variegated Scouring 

Rush Equisetum variegatum 

FORBS

Yarrow Achillea millefolium 

False Dandelion Agoseris glauca 

Striate Agrimony Agrimonia striata 

American Water 

Plantain Alisma trivale 

Wild Onion Allium cernuum 

Geyer’s Onion Allium geyeri 

Wild White Onion Allium textile 

Alder Alnus incana 

Pale Alyssum Alyssum alyssoides 

Alyssum Alyssum minus 

Tumbleweed Amaranthus albus 

Prostrate Pigweed Amaranthus graecizans 

Rough Pigweed Amaranthus retroflexus 

Common Ragweed Ambrosia artemisiifolia 

Western Ragweed Ambrosiapsilostachya 

Giant Ragweed Ambrosia trifida 

Robust Toothcup Ammania robusta 

False Indigo Amorpha fruticosa 

Western Rock Jasmine Androsace occidentalis 

Candle Anemone Anemone cylindrica 

Pasque-flower Anemone patens 

Pink Pussytoes Antennaria microphylla 

Pussytoes Antennaria parvifolia 

Dog Fennel Anthemis cotula 

Spreading Dogbane Apocynum androsaemifolium 

Hemp Dogbane Apocynum cannabinum 

Rock Cress Arabis fendleri 

Tower Mustard Arabis glabra 

Rock Cress Arabis hirsuta 

Burdock * Arctium minus 

Fendler’s Sandwort Arenaria fendleri 

Prickly Poppy Argemone polyanthemos 

Arnica Arnica fulgens 

Swamp Milkweed Asclepias incarnata 

Plains Milkweed Asclepias pumila 

Showy Milkweed Asclepias speciosa 

Narrow-leaved Milkweed Asclepias stenophylla 

Green Milkweed Asclepias viridiflora 

Asparagus Asparagus officinalis 

Madwort Asperugo procumbens 

Meadow Aster Aster campestris 

Aster Aster falcatus 

Fendler’s Aster Aster fendleri 

Panicled Aster Aster hesperius 

Smooth Blue Aster Aster laevis 

Aster Aster porteri 

Standing Milkvetch Astragalus adsurgens 

Field Milkvetch Astragalus agrestis 

Two-grooved Vetch Astragalus bisulcatus 

Canada Milk-vetch Astragalus canadensis 

Ground-plum Astragalus crassicarpus 

Drummond Milkvetch Astragalus drummondii 

Pliant Milkvetch Astragalus flexuosus 

Lotus Milk-Vetch Astragalus lotiflorus 

Parry’s Milkvetch Astragalus parryi 

Short’s Milkvetch Astragalus shortianus 

Draba Milk-Vetch Astragalus spathulatus 

Foothill Milkvetch Astragalus tridactylicus 

Yellowrocket 

Wintercress Barbarea vulgaris 

Water Parsnip Berula erecta 

Nodding Beggarticks Bidens cernua 

Beggar-ticks Bidens frondosa 

Water Starwort Callitriche verna 

Sego Lily Calochortus gunnisonii 

Plains Yellow Primrose Calylophus serrulatus 

Small-seeded False Flax Camelina microcarpa 

Harebell Campanularotundifolia 

Shepherd’s Purse Capsella bursa-pastoris 

Lens-padded Hoary 

Cress Cardaria chalepensis 

Hoary Cress * Cardaria draba 

Musk Thistle * Carduus nutans 

Appendix G: Species Lists
302 Rocky Flats National Wildlife Refuge 

Orange Paintbrush Castilleja integra 

Downy Paintbrush Castilleja sessiliflora. 

Diffuse Knapweed * Centaurea diffusa 

Russian Knapweed * Centaurea repens 

Yellow Star Thistle Centaurea solstitialis 

Prairie Chickweed Cerastium arvense 

Short-stalked 

Chickweed Cerastiumbrachypodum 

Common Mouse-Ear Cerastium vulgatum 

Coontail Ceratophyllum demersum 

Lamb’s Quarters Chenopodium album 

Dark Goosefoot Chenopodium atrovirens 

Pitseed Goosefoot Chenopodium berlandieri 

Jerusalem Oak Chenopodium botrys 

Desert goosefoot Chenopodium dessicatum 

Fremont Goosefoot Chenopodium fremontii 

Goosefoot Chenopodium leptophyllum 

Overi’s Goosefoot Chenopodium overi 

Blue Mustard Chorispora tenella 

Ox-eye Daisy Chrysanthemum leucanthemum 

Golden Aster Chrysopsis fulcrata 

Golden Aster Chrysopsis villosa 

Common Chicory * Cichorium intybus 

Water Hemlock Cicuta maculata 

Canada Thistle * Cirsium arvense 

Flodman’s Thistle Cirsium flodmanni 

Yellow Spine Thistle Cirsium ochrocentrum 

Wavyleaf Thistle Cirsium undulatum 

Bull Thistle * Cirsium vulgare 

Spring Beauty Claytonia rosea 

Rocky Mountain 

Beeplant Cleome serrulata 

Blue Lips Collinsia parviflora 

Collomia Collomia linearis 

Bastard Toadflax Comandra umbellata 

Poison Hemlock * Conium maculatum 

Community Campion Conosilene conica 

Hare’s-ear Mustard Conringia orientalis 

Horseweed Conyza canadensis 

Crown Vetch Coronilla varia 

Nipple Cactus Coryphantha missouriensis 

Hawksbeard Crepis occidentalis 

Hawksbeard Crepis runcinata 

Miners Candle Cryptantha virgata 

Dodder Cuscuta approximata 

Hound’s Tongue Cynoglossum officinale 

Taperleaf Flatsedge Cyperus acuminatus 

Fragile Fern Cystopteris fragilis 

White Prairie Clover Dalea candida 

Purple Prairie Clover Dalea purpurea 

Wild Carrot Daucus carota 

Blue Larkspur Delphinium nuttalianum 

Prairie Larkspur Delphinium virescens 

Tansy Mustard Descurainia pinnata 

Tansy Mustard Descurainia richardsonii 

Flixweed Descurainia sophia 

Shooting Star Dodecatheon pulchellum 

Yellow Whitlowort Draba nemorosa 

White Whitlowort Draba reptans 

Dragonhead Dracocephalum parviflorum 

Fetid Marigold Dyssodia papposa 

Hedgehog Cactus Echinocereus viridiflorus 

Willow Herb Epilobium ciliatum 

Willow Herb Epilobium paniculatum 

Fleabane Erigeron canus 

Fleabane Erigeron compositus 

Fleabane Erigeron divergens 

Fleabane Erigeron flagellaris 

Fleabane Erigeron pumilus 

Oregon Fleabane Erigeron speciosa 

Daisy Fleabane Erigeron strigosus 

LaVeta Fleabane Erigeron vetensis 

Winged Eriogonum Eriogonum alatum 

Spreading Wild 

Buckwheat Eriogonum effusum 

James’ Wild 

Buckwheat Eriogonum jamesii 

Sulphur Flower Eriogonum umbellatum 

Filaria Erodium cicutarium 

Western Wallflower Erysimum capitatum 

Bushy Wallflower Erysimum repandum 

Toothed Spurge Euphorbia dentata 

Fendler’s Euphorbia Euphorbia fendleri 

Snow-on-the-Mountain Euphorbia marginata 

Spurge Euphorbia robusta 

Thyme-leaved Spurge Euphorbia serpyllifolia 

Spurge Euphorbia spathulata 

Fumitory Fumaria vaillentii 

Blanket Flower Gaillardia aristata 

Catchweed Bedstraw Galium aparine 

Northern Bedstraw Galium septentrionale

Scarlet Gaura Gaura coccinea 

Velvety Gaura Gaura parviflora 

Yellow Avens Geum aleppicum 

Large-leaved Avens Geum macrophyllum

Northern Gentian Gentiana affinis 

Common Wild 

Geranium Geranium caespitosum 

Gilia Gilia opthalmoides 

Wild Licorice Glycyrrhiza lepidota 

Cotton-batting Gnapthalium chilense 

Hedge Hyssop Gratiola neglecta 

Curly-top Gumweed Grindelia squarrosa 

Northern Green Orchid Habenaria hyperborea 

Large-flowered 

Stickseed Hackelia floribunda 

Cutleaf Ironplant Happlopappus spinulosus 

Whiskbroom Parsley Harbouria trachypleura 

Rough False 

Pennyroyal Hedeoma hispidum 

Common Sunflower Helianthus annuus 

Texas Blue Weed Helianthus ciliaris 

Maximilian Sunflower Helianthus maximilianii 

Nuttall’s Sunflower Helianthus nuttallii 

Plains Sunflower Helianthus petiolaris 

Sunflower Helianthus pumilus 

Stiff Sunflower Helianthus rigidus 

Showy Goldeneye Heliomeris multiflora 

Appendix G: Species Lists 
Final Comprehensive Conservation Plan & EIS 303

Cow Parsnip Heracleum sphondylium 

Dame’s Rocket * Hesperis matronalis 

Alumroot Heuchera parvifolia 

Nodding Green Violet Hybanthus verticillatus 

Waterleaf Hydrophyllum fendleri 

Hymenopappus Hymenopappus filifolius 

Greater St. John’s-wort Hypericum majus 

Common St. John’swort * Hypericum perforatum 

Spike Gilia Ipomopsis spicata 

Western Blue Flag Iris missouriensis 

Poverty Weed Iva axillaris 

Marsh Elder Iva xanthifolia 

Kochia Kochia scoparia 

False Boneset Kuhnia chlorolepis 

False Boneset Kuhnia eupatorioides 

Blue Lettuce Lactuca oblongifolia. 

Prickly Lettuce Lactuca serriola 

Stickseed Lappula redowskii 

Purple Peavine Lathyrus eucosmus 

Duckweed Lemna minor 

Field Peppergrass Lepidium campestre 

Peppergrass Lepidium densiflorum 

Bladderpod Lesquerella montana 

White Aster Leucelene ericoides 

Mountain Lily Leucocrinum montanum 

Blazing Star Liatris punctata 

Porter’s Lovage Ligusticum porteri 

Mudwort Limosella aquatica 

Texas Toadflax Linaria canadensis. 

Dalmatian Toadflax * Linaria dalmatica 

Butter-and-eggs* Linaria vulgaris 

Blue Flax Linum perenne 

Norton’s Flax Linum pratense 

Plains Flax Linum puberulum 

Fog-fruit Lippia cuneifolia 

Puccoon Lithospermum incisum 

Puccoon Lithospermum multiflorum

Great Lobelia Lobelia siphilitica 

Wild Parsley Lomatium orientale 

Birdfoot Trefoil Lotus corniculatus 

Silvery Lupine Lupinus argenteus 

American Bugleweed Lycopus americanus 

Rough Bugleweed Lycopus asper 

Skeleton-weed Lygodesmia juncea 

Fringed Loostrife Lysimachia ciliata 

Winged Loosestrife Lythrum alatum 

Bigelovi’s Tansy Aster Machaeranthera bigelovii 

Hoary Aster Machaeranthera canescens 

Tarweed Madia glomerata 

Common Mallow Malva neglecta 

Common Horehound Marrubium vulgare 

Black Medick Medicago lupulina 

Alfalfa Medicago sativa 

White Sweetclover Melilotus alba 

Yellow Sweetclover Melilotus officinalis 

Field Mint Mentha arvensis 

Bluebells Mertensia lanceolata 

False Dandelion Microseris cuspidata 

Monkey Flower Mimulus floribundus 

Roundleaf Monkeyflower Mimulus glabratus 

Hairy Four-O’Clock Mirabilis hirsuta 

Narrowleaf Four 

O’Clock Mirabilis linearis 

Wild Four-O’Clock Mirabilis nyctaginea 

Wild Bergamot Monarda fistulosa 

Spotted Bee-Balm Monarda pectinata 

Musineon Musineon divaricatum 

Mousetail Myosurus minimus 

American Milfoil Myriophyllum exalbescens. 

Watercress Nasturtium officinale 

Navarretia Navarretia minima 

Catnip Nepeta cataria 

Evening Primrose Oenothera flava 

Yellow Stemless 

Evening Primrose Oenothera howardii 

Common Evening 

Primrose Oenothera villosa 

Scotch Thistle * Onopordum acanthium 

False Gromwell Onosmodium molle 

Pale Evening Primrose Onothera albicaulis 

Little Prickly Pear Opuntia fragilis 

Twistspine Prickly Pear Opuntia macrorhiza 

Plains Prickly Pear Opuntia polyacantha 

Broomrape Orobanche fasciculata 

Sweet Cicely Osmorhiza chiliensis 

Anise Root Osmorhiza longistylis 

Gray-Green Wood 

Sorrel Oxalis dillenii. 

Purple Locoweed Oxytropis lambertii 

Pennsylvania Pellitory Parietaria pensylvanica 

James’ Nailwort Paronychia jamesii 

Nipple Cactus Pediocactus simpsonii 

White Beardtongue Penstemon albidus 

Penstemon Penstemon secundiflorus 

Rocky Mountain 

Penstemon Penstemon strictus 

Slender Penstemon Penstemon virens 

Penstemon Penstemon virgatus 

Scorpionweed Phacelia heterophylla 

Clammy Ground cherry Physalis heterophylla 

Prairie Ground Cherry Physalis pumila 

Virginia Ground Cherry Physalis virginiana 

Double Bladder-pod Physaria vitulifera 

Picradeniopsis Picradeniopsis oppositifolia 

Popcorn Flower Plagiobothrys scouleri 

English Plantain Plantago lanceolata 

Common Plantain Plantago major 

Patagonian Plantain Plantago patagonica. 

Clammy-weed Polansia dodecandra 

Knotweed Polygonum arenastrum. 

Wild Buckwheat Polygonum convolvulus. 

Knotweed Polygonum douglasii 

Water Pepper Polygonum hydropiper 

Pale Smartweed Polygonum lapathifolium 

Pennsylvania Smartweed Polygonum pensylvanicum 

Lady’s Thumb Polygonum persicaria 

Appendix G: Species Lists
304 Rocky Flats National Wildlife Refuge 

Knotweed Polygonum ramosissimum 

Knotweed Polygonum sawatchense 

Common Purslane Portulaca oleracea 

Leafy Pondweed Potamogeton foliosus 

Floatingleaf Pondweed Potamogeton natans 

Tall Cinquefoil Potentilla arguta 

Cinquefoil Potentilla fissa 

Cinquefoil Potentilla gracilis 

Wooly Cinquefoil Potentilla hippiana 

Norwegian Cinquefoil Potentilla norvegica 

Bushy Cinquefoil Potentilla paradoxa 

Cinquefoil Potentilla pensylvanica 

Hybrid Cinquefoil Potentilla pulcherrima x 

 hippiana 

Cinquefoil Potentilla rivalis 

Selfheal Prunella vulgaris 

Wild Alfala Psoralea tenuiflora 

Purple Ground Cherry Quincula lobata 

Macoun’s Buttercup Ranunculus macounii 

Cursed Crowfoot Ranunculus scleratus 

Hairy Leaf Buttercup Ranunculus trichophyllus 

Prairie Coneflower Ratibida columnifera 

Bog Yellow Cress Rorippa palustris 

Goldenglow Rudbeckia ampla 

Sheep Sorrel Rumex acetosella 

Curly Dock Rumex crispus 

Golden Dock Rumex maritimus 

Bitter Dock Rumex obtusifolius 

Willow Dock Rumex salicifolius. 

Common Arrowhead Sagittaria latifolia 

Russian-Thistle Salsola iberica 

Lance-leaved Sage Salvia reflexa 

Bouncing Bet Saponaria officinalis 

Diamondleaf Saxifrage Saxifraga rhomoidea 

False Salsify Scorzonera laciniata 

Figwort Scrophularia lanceolata 

Britton’s Skullcap Scutellaria brittonii 

Stonecrop Sedum lanceolatum 

Spikemoss Selaginella densa 

Groundsel Senecio fendleri 

Groundsel Senecio integerrimus 

Prairie Ragwort Senecio plattensis 

Groundsel Senecio spartioides 

Groundsel Senecio tridenticulatus 

White Checkermallow Sidalcea candida 

New Mexico 

Checkmallow Sidalcea neomexicana 

Sleepy Catchfly Silene antirrhina 

Campion Silene drummondii 

White Campion Silene pratensis 

Tumbling Mustard Sisymbrium altissimum 

Spikenard Smilacina stellata (L.) 

Carrion Flower Smilax herbacea 

Buffalo Bur Solanum rostratum 

Cut-leaved Nightshade Solanum triflorum 

Canada Goldenrod Solidago canadensis 

Late Goldenrod Solidago gigantea 

Prairie Goldenrod Solidago missouriensis 

Soft Goldenrod Solidago mollis 

Low Goldenrod Solidago nana 

Rigid Goldenrod Solidago rigida 

Field Sow Thistle Sonchus arvensis 

Prickly Sow Thistle Sonchus asper 

Sand Spurry Spergularia rubra 

Red False Mallow Sphaeralcea coccinea 

Hedge Nettle Stachys palustris 

Long-leaved Stitchwort Stellaria longifolia 

Wire Lettuce Stephanomeria pauciflora 

Green Gentian Swertia radiata 

Prairie Fameflower Talinum parviflorum 

Red Seeded Dandelion Taraxacum laevigatum 

Dandelion Taraxacum officinale 

Purple Meadow Rue Thalictrum dasycarpum 

Greenthread Thelesperma megapotanicum 

Golden Banner Thermopsis rhombifolia var. 

 divaricarpa 

Field Penny Cress Thlaspi arvense 

Easter Daisy Townsendia grandiflora 

Easter Daisy Townsendia hookeri 

Spiderwort Tradescantia occidentalis 

Noseburn Tragia ramosa 

Goat’s Beard Tragopogon dubius 

Salsify Tragopogon porrifolius 

Alsike Clover Trifolium hybridum 

Red Clover Trifolium pratense 

White Clover Trifolium repens 

Venus’ Looking Glass Triodanis leptocarpa 

Venus Looking Glass Triodanis perfoliata 

Stinging Nettle Urtica dioica 

Cow Cockle Vaccaria pyramidata 

Moth Mullein * Verbascum blattaria 

Common Mullein * Verbascum thapsus 

Prostrate Vervain Verbena bracteata 

Blue Vervain Verbena hastata 

Golden Crownbeard Verbesina encelioides 

Brooklime Speedwell Veronica americana 

Water Speedwell Veronica anagallis-aquatica 

Catenate Ironweed Veronica catentata 

Purslane Speedwell Veronica peregrina 

American Vetch Vicia americana 

Yellow Prairie Violet Viola nuttallii 

Rydberg’s Violet Viola rydbergii 

Colorado Violet Viola scopulorum 

Northern Bog Violet Viola sororia 

Cocklebur Xanthium strumarium 

Death Camass Zigadenus venenosus 

SHRUBS

Saskatoon Service-berry Amelanchier alnifolia 

Dwarf Wild Indigo Amorpha nana

Western Sagewort Artemisia campestris 

Silky Wormwood Artemisia dracunculus 

Silver Sage Artemisia frigida 

White Sage Artemisia ludoviciana 

Four-winged Saltbush Atriplex canescens 

Oregon Grape Berberis repens 

Buckbrush Ceanothus fendleri 

Appendix G: Species Lists 
Final Comprehensive Conservation Plan & EIS 305

New Jersey Tea Ceanothus herbaceus 

Greenplume 

Rabbitbrush Chrysothamnus nauseosus 

Rubber Rabbitbrush Chrysothamnus nauseosus 

Hawthorne Crataegus erythropoda 

Hawthorn Crataegus succulenta 

Snakeweed Gutierrezia sarothrae

Common Juniper Juniperus communis 

Mountain Ninebark Physocarpus monogynus 

Ninebark Physocarpus opulifolius 

Wild Plum Prunus americana 

Sand Cherry Prunus pumila 

Chokecherry Prunus virginiana 

Apple Pyrus malus 

Fragrant Sumac Rhus aromatica

Golden Currant Ribes aureum 

Western Red Currant Ribes cereum 

Common Gooseberry Ribes inerme 

Prickly Wild Rose Rosa acicularis 

Prairie Wild Rose Rosa arkansana 

Western Wild Rose Rosa woodsii 

Boulder Raspberry Rubus deliciosus 

Raspberry Rubus idaeus 

Coyote Willow Salix exigua 

Sandbar Willow Salix exigua 

Bluestem willow Salix irrorata 

Yellow Willow Salix lutea 

Burnet Sanguisorba minor 

Mountain Ash Sorbus scopulina 

Western Snowberry Symphoricarpos occidentalis 

Snowberry Symphoricarpos oreophilus

Salt Cedar * Tamarix ramosissima

Highbush Cranberry Viburnum opulus 

Yucca Yucca glauca 

TREES

Mountain Maple Acer glabrum 

Box-elder Acer negundo 

Norway Maple Acer platanoides 

Water Birch Betula occidentalis 

Russian Olive * Elaeagnus angustifolia 

Green Ash Fraxinus pennsylvania 

Rocky Mountain 

Juniper Juniperus scopulorum 

Blue Spruce Picea pungens 

Ponderosa Pine Pinus ponderosa 

Silver Poplar Populus alba 

Narrow-leaved 

Cottonwood Populus angustifolia 

Plains Cottonwood Populus deltoides 

Lanceleaf Cottonwood Populus x acuminata 

Douglas-Fir Pseudotsuga menziesii 

Black Locust Robinia pseudo-acacia

Peach-leaf Willow Salix amygdaloides 

Crack Willow Salix fragilis 

Siberian Elm Ulmus pumila 

VINES

Hedge Bindweed Calystegia macouni 

Hedge Bindweed Calystegia sepium 

Hairy Clematis Clematis hirsutissima 

Western Clematis Clematis ligusticifolia 

Field Bindweed * Convolvulus arvensis 

Evolvulus Evolvulus nuttallianus 

Common Hops Humulus lupulus 

Poison Ivy Toxicodendron rydbergii 

Puncture Vine Tribulus terrestris 

River-bank Grape Vitis riparia 

OTHERS

The following types plants have also been identified at Rocky Flats: 

x 15 mosses 

x 24 lichens

Appendix G: Species Lists

Index

Final Comprehensive Conservation Plan & EIS 309

Index

A

Access: S4, S5, S7, S8, S9, 7, 10, 18, 19, 20, 21,

26, 28, 30, 31, 32, 33, 34, 35, 36, 38, 45, 46, 51,

52, 53, 54, 56, 60, 61, 62, 63, 64, 65, 70, 79, 80,

115, 117, 125, 131, 132, 133, 137, 139, 140, 152,

164, 167, 174, 181, 182, 183, 185, 188, 189, 193,

194, 221, 223, 235, 272

Accessible facilities: 231

Adaptive management: 75, 179-180, 231

Air quality: 41-42, 47, 139-140, 157, 188-189,

200, 271

Aquatic species: 124, 126, 198

B

Bald eagle: 4, 126-127, 177-179, 196

Biking: 13, 20-21, 34, 134, 137-138, 226, 233-

234

Biological control: 40, 46, 156-157, 169

Birds: 5, 39, 53, 115, 123, 168, 173-174, 177,

231, 233, 273

Buffer Zone: 3, 141, 184

C

Candidate species: 48, 119, 125-126, 167, 177-

180, 231-232

Chronic Wasting Disease: 47, 169, 231

Cleanup: xiii, S3, S5, S6, 3, 4, 7, 11, 12, 13, 26,

29, 31, 51, 63, 80, 103, 105, 110, 133, 139, 147,

151, 152, 181, 190, 194, 195, 197, 222, 223, 224,

227, 231, 235, 273

Colorado Division of Wildlife: xiii, S7, 18, 141,

143, 196, 218, 222, 225, 236

Colorado Natural Heritage Program: xiii, 39,

111, 141, 226

Communication: S5S9, 7, 8, 20, 28, 38, 65, 140,

141, 142, 143, 194, 196, 216

Compatibility: 4-6, 67, 169, 184, 221, 231, 253-

267, 273

Conservation easement: 231-232

Contamination: 3, 13, 28, 105, 126, 149-150,

152-153, 189, 195, 222-224

Culling: 27, 37, 47-48, 170, 188

Cultural resources: S3, S6, 4, 9, 10, 17, 20, 28,

29, 30, 33, 54, 56, 57, 60, 72, 73, 127, 128, 141,

179, 180, 181, 222, 233

Cumulative impacts: 76, 80, 142, 152-153, 166,

176, 180-181, 183, 185-186, 188-190, 223

D

Deer: S6, S7, S8, S9, S10, 6, 18, 27, 32, 37, 39,

40, 47, 48, 53, 58, 59, 115, 119, 126, 153, 158,

167, 169, 170, 173, 174, 175, 176, 177, 178, 179,

184, 186, 188, 190, 193, 226, 231, 236

Department of Energy: xiii, S3, S6, 3, 80, 141,

142, 196, 217, 222, 225, 235

Ditches: 53, 79, 107, 114, 124, 127

DOE retained lands: 10, 49, 177, 187, 224

E

Easement: 132, 231-232, 235

Elk: S3, S6, S7, S9, S10, 18, 27, 32, 37, 39, 47,

48, 58, 117, 119, 126, 153, 158, 167, 169, 170,

173, 174, 176, 177, 178, 179, 184, 186, 188, 190,

193, 231, 236

Endangered Species Act: xiii, 7, 26, 126, 231-

232, 271

Environmental education: S4, S7, S8, S9, 5, 7,

14, 18, 19, 20, 21, 30, 31, 32, 33, 34, 38, 54, 55,

56, 57, 58, 75, 184, 222, 232, 234, 236, 273

Environmental Justice: 189, 272

Environmental Protection Agency: xiii, S3, 3,

80, 142, 222, 225, 235

Equestrian: S8, 19-21, 34-36, 52, 61-62, 68, 71,

134, 137, 150, 164, 179, 184, 196, 223, 233-234

Erosion: 105, 148-153, 155, 159, 179, 192, 195-

196, 232

F

Fencing: S4, 37, 40, 42, 44, 47-48, 64, 71, 76,

127, 137, 147, 151, 154, 158, 167, 169, 174, 176,

180, 190, 193, 233

Fire: S10, 6, 9, 13-14, 18-19, 26-27, 37-38, 40-

47, 61, 65-66, 68-70, 73-75, 105, 117-118, 123,

141, 148-149, 151, 155-157, 165, 168-169, 185,

189, 215-216, 223, 234, 236

G

Geology: 80, 103-104, 126, 133, 140, 148, 196,

198, 216, 222, 225
310 Rocky Flats National Wildlife Refuge 

Index

Global Positioning System: xiii, 46, 232

Goals: S5, S7, S8, 4, 5, 6, 7, 8, 9, 11, 18, 19, 20,

27, 38, 39, 52, 55, 56, 65, 67, 71, 73, 75, 76, 147,

152, 154, 158, 170, 190, 194, 221, 223, 231, 233,

234, 235, 236

Grazing: S10, 18-19, 21, 26-27, 37, 39-44, 46-

48, 75, 123, 134, 148-150, 154-155, 158, 168-

169, 186, 197, 223, 233, 235

Ground water: 107-108, 110, 114, 152-153, 195

H

Hay meadow: S10, 37, 44, 155, 168, 177, 186,

232

Herbicide: 26, 45, 47, 157, 167

Highway 128: 30, 35-36, 76-77, 79-80, 117, 125,

129, 131-132, 134, 137-138, 181-183, 185, 191-

193

Highway 72: 79-80, 131, 134, 137, 139

Highway 93: 10, 30-31, 76-77, 79, 125, 131-132,

134, 137, 139, 181-182, 185, 191-194

Hiking: S8, 13, 19-21, 31, 38, 60, 134, 137-138,

150, 159, 164, 175, 179, 194, 233-234

Hunting: S7, S8, S9, 5, 14, 18, 19, 20, 27, 29,

32, 33, 37, 38, 48, 52, 58, 59, 75, 147, 170, 173,

179, 184, 188, 223, 236, 273

I

Indiana Street: 61, 77, 79, 107-108, 119, 125,

131-132, 139, 181-183, 185, 191-193

Industrial Area: S3, S6, 3, 11, 80, 103, 107,

110, 117, 119, 124, 129, 132, 139, 141

Integrated Pest Management: xiii, S10, 14,

18, 37, 156, 215, 232

Interpretation: S4S5S8S9, 5, 7, 14, 19, 20, 21,

28, 29, 30, 31, 32, 33, 34, 38, 51, 52, 53, 55, 56,

57, 62, 70, 73, 75, 147, 150, 153, 159, 172, 173,

178, 181, 184, 186, 188, 194, 236, 273

L

Lindsay Ponds: S10, 28, 107, 125, 152-153,

159, 172

Lindsay Ranch: S6, S7, 10, 20, 29, 30, 33, 34,

35, 38, 50, 55, 60, 64, 72, 74, 129, 138, 142, 159,

164, 176, 178, 180, 181, 223

M

Mammals: 5, 39, 115, 119, 125-127, 168, 174,

177, 193, 197

Management zones: 17, 110

Mineral rights: 10, 53, 79, 132-133, 181, 222

Mining: S6, 77, 79, 105, 125, 127, 131-134, 139,

152-153, 166, 176, 180-182, 187-189, 223, 232,

234

Mountain backdrop: S4, 6, 19, 26, 52, 138,

185-187, 190

Mountain plover: 126

Mowing: 26, 41-42, 44, 46, 155, 157-158, 168,

180

N

National Environmental Policy Act: xiii, 7,

233, 273

National Wildlife Refuge System

Improvement Act: 4-5, 14, 231, 235-236, 273

National Wind Technology Center: xiii, 79-80,

142, 187

Native American tribes: 222, 227, 234

Noise: 139, 174, 176, 179-180, 188, 193-194,

196, 199

Noxious weeds: 27, 39-41, 45-47, 112, 115-117,

148, 159, 166-167, 189, 192-193, 234

O

Office space: 19-21, 36, 38, 63, 70, 74

Off-trail use: 34, 53, 153, 164, 234

Open space: xiii, S4, S6, 6, 20, 27, 29, 31, 50,

61, 66, 75, 76, 79, 81, 119, 123, 125, 131, 132,

133, 134, 135, 137, 138, 140, 141, 142, 165, 171,

172, 174, 175, 176, 177, 180, 183, 184, 185, 189,

193, 196, 199, 225, 226

Overbrowsing: S10, 27, 153, 158, 169, 174,

184, 186

Overlook: 21, 29, 33-36, 57, 61-62, 182, 193,

234

P

Parking: S7, 18, 31, 35-36, 53, 60-62, 71, 151,

153, 165, 179, 181-183, 185-186, 188, 231

Partnerships: S5, S7, S8, S9, 7, 10, 18, 19, 20,
Final Comprehensive Conservation Plan & EIS 311

Index

21, 26, 38, 40, 66, 67, 70, 72, 75, 147, 165, 176,

180, 185, 195

Photography: S8, 5, 19, 32-33, 36, 52-53, 60,

62, 174, 236, 273

Planning update: 221

Population targets: S10, 48, 169-170

Preble's meadow jumping mouse: S6, S7, 4,

18, 26, 29, 39, 53, 119, 125, 126, 137, 142, 165,

177

Preferred Alternative: S7, 6-8, 17-18, 20, 234

Public involvement: S5, 8-9, 14, 17, 59, 221,

234

Public outreach: 28, 55, 70-71

Public use facilities: S7, S8, 13, 18, 19, 31, 35,

53, 55, 63, 70, 150, 153, 159, 164, 186, 188, 193,

194

R

Record of Decision: xiii, S3, 4, 149, 150, 152,

235

Refuge Act: S3S4, 4, 6, 7, 8, 63, 77, 79, 132,

147, 190, 191, 273

Refuge operations: xiii, S3, S5, S9, 4, 7, 9, 10,

17, 20, 30, 38, 64, 68, 70, 75, 147, 151, 165, 176,

179, 180, 185, 190, 194, 195, 215, 217, 222

Refuge Recreation Act: 4, 273

Refuge System Administration Act: 4, 14, 273

Reintroduction: S9, 10, 26-28, 37, 39, 44, 50-

51, 123, 140, 171-173, 178, 184, 197

Reptiles and amphibians: 123

Research: S4, S5, S6, S7, S8, S9, 7, 14, 18, 19,

20, 21, 33, 38, 52, 56, 57, 58, 66, 67, 68, 75, 79,

133, 134, 140, 165, 176, 185, 187, 195, 196, 197,

231, 272

Response actions: S6, 4, 7, 11

Riparian: S6, S10, 17, 26, 27, 29, 33, 35, 39, 40,

42, 44, 45, 46, 47, 48, 49, 53, 75, 110, 111, 112,

114, 119, 123, 125, 127, 137, 139, 152, 153, 154,

155, 156, 158, 159, 164, 165, 166, 167, 168, 170,

174, 175, 177, 178, 179, 180, 183, 186, 235

Road revegetation: 155

Rock Creek: S6, S7, S8, S10, 18, 19, 20, 26,

27, 28, 29, 30, 33, 34, 35, 36, 41, 44, 45, 46, 49,

50, 53, 61, 62, 68, 70, 72, 74, 76, 80, 103, 105,

107, 108, 110, 112, 114, 115, 117, 119, 124, 125,

126, 132, 133, 137, 138, 141, 142, 149, 152, 153, 

155, 156, 157, 159, 164, 166, 168, 169, 171, 172,

174, 175, 178, 179, 180, 182, 183, 184, 185, 193,

194, 197

Rocky Flats Cleanup Agreement: xiii, S3, 3,

235

S

Safety: S4, S5, S7, S9, 7, 10, 13, 14, 20, 28, 38,

42, 44, 51, 52, 57, 58, 59, 63, 64, 65, 66, 71, 72,

76, 105, 147, 149, 150, 151, 152, 165, 176, 179,

180, 182, 185, 194, 235, 271, 272

Scoping: S7, 7-10, 14, 17-18, 28, 81, 140, 221-

223, 235

Seasonal closures: 35, 175, 235

Sharp-tailed grouse: S9, 27-28, 37, 44, 50-51,

123, 126, 140-141, 171-173, 178, 196

Signage: S4, 20-21, 29-31, 33, 35, 52, 54, 57-58,

60-62, 64-65, 70-72, 151, 181, 184, 234

Significant issues: 8-9, 17-18, 223, 235

Social trail: 236

Soils: 11-12, 17, 48, 103, 105-106, 111, 115,

123, 126, 148-152, 158, 195, 198, 216, 231

Step-down management plan: 6, 14, 236

Stream crossing: 33, 155, 235

T

Tall upland shrubland: S6, 39, 103, 110-111,

114, 117, 123, 127, 159

Threatened species: S6, 29, 39, 48, 119, 126,

236, 271

Traffic: 131, 139-141, 175, 177, 182-183, 193,

196, 200

Trail impacts: S10

Trailheads: S4, S7, 18, 30, 31, 33, 35, 36, 61,

64, 134, 165, 182, 183, 194, 236

Trails: S7, S8, S10, 18, 19, 20, 21, 26, 27, 30,

31, 33, 34, 35, 36, 38, 40, 45, 47, 52, 53, 55, 60,

61, 62, 68, 70, 71, 76, 79, 80, 134, 136, 137, 138,

140, 142, 150, 151, 153, 159, 160, 161, 162, 163,

164, 165, 169, 173, 174, 175, 176, 178, 179, 181,

182, 183, 184, 185, 186, 187, 188, 194, 195, 196,

197, 199, 222, 223, 226, 231, 233, 234, 235, 236
312 Rocky Flats National Wildlife Refuge 

Index

U

Utilities: 73, 76, 79, 105, 110, 129-130, 132

V

Vauxmont: 76, 79-80, 134, 137, 186, 188, 190

Vegetation communities: S6, S10, 17, 103, 110,

111, 127, 153, 154, 155, 156, 157, 158, 159, 164,

165, 166, 167, 173

Visitor center: S8, 19, 21, 30-31, 34, 36, 38, 53,

57, 62-63, 70-71, 74, 182, 223, 236

Visitor contact station: S7, 18, 20, 33, 36, 38,

53, 61, 70, 151, 187, 236

Visitor use: S3, S7, S9, 4, 13, 18, 31, 51, 52, 54,

55, 56, 62, 68, 70, 71, 75, 105, 150, 151, 153,

164, 165, 173, 174, 179, 184, 185, 188, 199

Visual resources: 138-139, 185-187, 190, 195,

199

Volunteers: 20-21, 30-31, 33-34, 38, 55, 63, 67-

68, 70, 184

W

Walnut Creek: 50, 79, 105, 107, 110, 119, 124-

126, 138-139, 152-153, 175, 179, 183, 193

Water rights: 79, 132-133, 140, 223

Weed management: S9, S10, 26, 27, 37, 39, 40,

41, 42, 44, 46, 49, 60, 75, 112, 148, 155, 156,

157, 158, 166, 167, 168, 169, 173, 177, 178, 180,

184, 185, 193, 233

Wetland: S5, S10, 7, 26, 33, 40, 50, 51, 52, 111,

112, 114, 123, 127, 137, 152, 154, 155, 156, 159,

164, 178, 179, 191, 194, 233, 271

Wildlife and Habitat Management: S5S8S9,

7, 19, 26, 37, 39, 42, 147, 148, 152, 154, 167,

177, 180, 184, 185, 188, 194

Wildlife corridor: 193

Wildlife-dependent public use: S7, 5, 18, 20,

31, 184

Woman Creek: S6, 33, 35, 50, 53, 72, 105, 107-

108, 110, 114-115, 119, 124-127, 132, 134, 150,

152-153, 164, 166, 175, 179-180, 183, 193

X

Xeric tallgrass: S3, S4, S5, S6, S9, 6, 7, 17, 26,

29, 33, 37, 41, 42, 45, 46, 49, 51, 52, 75, 110,

111, 112, 115, 117, 127, 147, 148, 154, 155, 156,

158, 159, 164, 165, 166, 168, 171, 178, 183, 184,

185, 194
Rocky Flats 

National Wildlife Refuge 

 

 

Comments and Responses on the 

Draft Environmental Impact Statement 

 

Appendix H 

to the 

Final Comprehensive Conservation Plan and 

Environmental Impact Statement 

 

September 2004 

 

 

 

 

 

Prepared for: 

U.S. Fish and Wildlife Service 

Rocky Flats National Wildlife Refuge 

Rocky Mountain Arsenal – Building 121 

Commerce City, CO 80022 

Prepared by: 

ERO Resources Corp. 

1842 Clarkson Street 

Denver, CO 80218 

and 

Shapins Associates 

1738 Pearl Street, Ste. 220 

Boulder, CO 80302 

Comments and Responses on the Draft Environmental Impact Statement i

CONTENTS 

 

1. Introduction .................................................................................................................................1

2. Agency, Business, and Organization Comments...................................................................2

3. Responses to Individual Comments ....................................................................................135

How To Find Responses to Individual Comments.............................................................135

Public Comments By Issue.....................................................................................................135

1000 – Purpose and Need........................................................................................................140

2000 – Alternatives...................................................................................................................140

2150 – Public Use Objectives..................................................................................................140

2200 – Education and Interpretation Objectives................................................................146

2210 – Habitat Management Objectives...............................................................................146

2230 – Wildlife/Threatened and Endangered Species Objectives...................................148

2250 - Safety Objectives ..........................................................................................................149

2260 – Communication, Partnerships, and Research Objectives.....................................149

2280 – Cultural Resource Objectives ....................................................................................149

2290 – Fencing ..........................................................................................................................150

2400 – Reasonably Foreseeable Activities...........................................................................151

3000 – Affected Environment and Environmental Consequences ..................................152

3050 – Soils.................................................................................................................................152

3100 – Water Resources ..........................................................................................................153

3200 – Vegetation Communities.............................................................................................154

3300 – Wildlife...........................................................................................................................155

3600 – Recreation and Trails ..................................................................................................156

4000 – Draft Compatibility Determinations ........................................................................156

5000 – Issues Outside of Scope of EIS..................................................................................156

6000 – Comments about CCP/EIS Process.........................................................................157

6300 – Draft CCP/EIS.............................................................................................................157

4. Petitions and Form Letters ..................................................................................................159

Form Letter 1: No Public Use ...............................................................................................159

Form Letter 2: Object to Hunting.........................................................................................160

Form Letter 3: Support Alternative B.................................................................................160

Form Letter 4: Keep Rocky Flats Closed ...........................................................................160

5. Public Hearing Testimony.....................................................................................................161

1. Introduction 

This document is Appendix H to the Final Rocky Flats National Wildlife Refuge Comprehensive

Conservation Plan and Environmental Impact Statement (CCP/EIS). This document includes the 

following components: 

• Copies of written comments from agencies, businesses, and organizations, with responses 

to those comments 

• A summary of comments from individuals, and responses to individual comments 

• A summary of petitions and form letters received

• Transcripts of the public hearing testimony 

The Draft Rocky Flats National Wildlife Refuge CCP/EIS was released to the public for a 45-day

comment period on February 19, 2004. In addition, the U.S. Fish and Wildlife Service (Service)

held a series of four public hearings in Westminster, Boulder, Arvada, and Broomfield to allow

public input on the proposed rehabilitation plan and alternatives. The Service received over 5,000 

comments through public hearing testimony, letters, emails. Comments came from 251 individuals 

and 34 agencies or organizations. The Service also heard from 933 people through form letters and

petitions. This Appendix addresses the substantive comments. Comments, as defined by NEPA

compliance guidelines, are considered substantive if they: 

• Question, with reasonable basis, the accuracy of the information in the document 

• Question, with reasonable basis, the adequacy of the environmental analysis 

• Present reasonable alternatives other than those presented in the environmental impact

statement

• Cause changes or revisions in the proposal

Comments and responses are divided into two sections. The first section includes copies of the 

substantive comments made by government agencies, organizations, and businesses. Beside each

reproduced letter is the numbered response of the U.S. Fish and Wildlife Service (Service)

corresponding to each specific comment. 

The second part of the response to comments includes a summary of the comments made by the 

general public or other entities. Many of the comments made by the public were similar to the 

range of issues and concerns that are addressed in the first section. Rather than print every letter

from individuals, the Service has summarized the main topics of the comments received and has 

responded to the comment topics that are substantive. All public comments and hearing testimony 

will be available for review at the Front Range Community College Library, Rocky Flats Reading

Room or at the Rocky Mountain Arsenal National Wildlife Refuge Visitor Center on weekends. 

Where appropriate, the text of the Final CCP/EIS has been revised to address comments. 

Comments and Responses on the Draft Environmental Impact Statement 1
2. Agency, Business, and Organization 

Comments 

1. U.S. Department of Energy

2. U.S. Environmental Protection Agency

3. Colorado Department of Public Health and Environment

4. Colorado Division of Wildlife

5. Colorado Department of Transportation

6. Colorado Department of Agriculture - State Weed Program

7. Rocky Flats Coalition of Local Governments

8. City of Arvada

9. City of Boulder – City Council

10. City of Boulder – Open Space and Mountain Parks 

11. City and County of Broomfield

12. City of Westminster 

13. Town of Superior

14. Boulder County Commissioners

15. Boulder County Parks and Open Space

16. Jefferson County

17. City of Golden – Mayor’s office 

18. City of Golden – City Manager 

19. Woman Creek Reservoir Authority

20. Alliance for Nuclear Accountability

21. Boulder Area Trails Coalition

22. Boulder County Horse Association 

23. Church Ranch 

24. Colorado Wildlife Federation

25. League of Women Voters – Jefferson County

26. National Wildlife Federation

27. Plan Jeffco 

28. Prairie Preservation Alliance 

29. Rocky Flats Citizen Advisory Board

30. Rocky Flats Cold War Museum

31. Rocky Mountain Peace and Justice Center

32. Sierra Club

33. Wheelin’ Sportsmen

34. Wildlife Management Institute 

2 Rocky Flats National Wildlife Refuge 
Comment

# Letter #1 Respon

1-1 1-2 

1-1. Thank you for your comments.1-2. Under the Refuge Act, no portioRefuge until the EPA certifies that Dclosure.

Rocky Flats National Wildlife Refuge 3 Comments and Responses on the Draft Enviro
Comment

# Letter #2 Respon

2-1 2-2 

2-1. Thank you for your comments.2-2. Thank you for your comments.

Rocky Flats National Wildlife Refuge 4 Comments and Responses on the Draft Enviro
Comment

# Letter #2 continued Respon

2-3 2-4 

5 

2-3. Thank you for your comments.2-4. The appropriate sections have bdescribe the DOE retained area, issuetransportation corridor, regional popumining. Responses to comments 2-7 issues in greater detail.2-5. See response to comment 2-4.

Rocky Flats National Wildlife Refuge 5 Comments and Responses on the Draft Enviro
Comment

# Letter #2 continued Respon

2-6 

2-6. The FEIS discloses the cumulatforeseeable activities on the Refuge. 

Rocky Flats National Wildlife Refuge 6 Comments and Responses on the Draft Enviro
Comment

# Letter #2 continued Respon

2-7 2-8 2-9 

2-10 

2-7. Specific responses to these concto comments 2-8 through 2-15.2-8. Adjacent properties are subject tThe Service will continue to work wilocal governments to minimize the esnoxious weeds.2-9. DOE has had an on-going weed noxious weeds. Weed management iaddressed in the final cleanup plans. work with the DOE, EPA and CDPHcleanup revegetation plans will minimspread of noxious weeds. The potentfrom DOE retained land on the RefugCumulative Impacts section of Chapt2-10. The FEIS was revised to includrelated to residual contamination and 1.8). In the DEIS, the Service and Dthe demarcation between the Refuge “seamless” with few obvious visual dFEIS was revised to indicate that the wire agricultural fence and/or permansignage would best demarcate the DOlivestock out of the DOE retained arewould be closed to public access. Suaffect the movement of wildlife acrosvisually obtrusive. The Service has pto the RFCA parties. With regard to management recommendations, see r

Rocky Flats National Wildlife Refuge 7 Comments and Responses on the Draft Enviro
Comment

# Letter #2 continued Respon

2-11 2-12 2-13 

2-11. The Service believes under NEof reasonably foreseeable activities wproposed action must be disclosed. Ttransportation improvements in the arreasonably foreseeable activity, but thtransportation improvement, such as Refuge, is speculative and not reasonThe Refuge Act directs the Service to dations for the identification of any laavailable for transportation improveminclude a new Section 4.16 that discuwithin a corridor immediately west owide. The new section also describes measures that would minimize adverto any transportation improvements a128, and Highway 93.2-12. The effects of existing adjacensurrounding Rocky Flats are discloseenvironment. 2-13. Urban growth and developmenFEIS as a reasonably foreseeable actisurrounding the Refuge is open space growth and development (see Figure include additional projections of regiRefuge, based on DRCOG projectionpotential impacts of regional urban grcumulative impact sections of Chapte

Rocky Flats National Wildlife Refuge 8 Comments and Responses on the Draft Enviro
Comment

# Letter #4 Respon

2-14 2-15 

2-14. Section 2.10 – Reasonably For

revised to include a discussion of minbased on information in the existing meffects discussions in Chapter 4 for wcommunities, wildlife, and threatened also been revised to include an additiimpacts of gravel mining on these res2-15. See response to comment 2-10

Rocky Flats National Wildlife Refuge 9 Comments and Responses on the Draft Enviro
Comment

# Letter #3 Respon

3-1 3-2 

3-1. Thank you for your participation 3-2. The Service acknowledges that yet been determined, and that prior to remaining contaminant concentrationvisitors, workers, the general public, 

Rocky Flats National Wildlife Refuge 10 Comments and Responses on the Draft Enviro
Comment

# Letter #3 continued Respon

Rocky Flats National Wildlife Refuge 11 Comments and Responses on the Draft Enviro
Comment

# Letter #4 Respon

4-1 4-2 4-3 

4-1. Thank you for your comment.4-2. The Service acknowledges the fby allowing the expansion of the pubwarranted by future resource conditioadded language to Objectives 1.6 (De2.10 (Hunting Program) to better rela

programs to future evaluations of targconditions. 4-3. Thank you for your comment. Tcontinued interest and involvement oWildlife in the CCP/EIS process lookrelationship during the future manage

Rocky Flats National Wildlife Refuge 12 Comments and Responses on the Draft Enviro
Comment

# Letter #5 Respon

5-1 5-2 5-3 5-4 

5-1. Thank you for your comments.5-2. The Service believes some transarea surrounding Rocky Flats is a reathe location of any particular transporalong the east edge of the Refuge, is foreseeable. In the FEIS, Figure 9 wany particular alignment.The Refuge Act directs the Service to recommendations for the identificatiomake available for transportation imprevised to include a new Section 4.16 lands within a corridor immediately wfeet wide. The new section also descmeasures that would minimize adverto any transportation improvements a128, and Highway 93.5-3. Under the Refuge Act, no portioRefuge until the EPA certifies that Dclosure. The FEIS was revised to proabout the steps to becoming a refuge, concentrations, and projected plutoni5-4. Descriptions of impact thresholdand major) are used throughout Chapmagnitude of anticipated impacts.

Rocky Flats National Wildlife Refuge 13 Comments and Responses on the Draft Enviro
Comment

# Letter #6 Respon

6-1 6-2 6-3 

6-1. Thank you for your comment.6-2. The Service’s Proposed Action integrated pest management as the beestablishment and spread of noxious 6-3. Objective 1.5 – Weed Managem

specifically identify weed managemeconsistency with recent changes to thWeed management would be addressdown Integrated Pest Management Plthe Department of Agriculture for rev

Rocky Flats National Wildlife Refuge 14 Comments and Responses on the Draft Enviro
Comment

# Letter #6 continued Respon

6-4 6-5 6-6 6-7 6-8 

6-4. The Service believes that the prto comply with weed laws and implemthe Rocky Mountain Arsenal NWR cmanagement and restoration efforts amanagement staffing at Rocky Flats aRefuge management.6-5. The Service welcomes opportunand other universities regarding reseatopics. Such partnerships are envisioAction’s “working with others” objec6-6. The weed management objectivthere is adequate flexibility in applyinspecific conditions. 6-7. The Service believes that the spxeric tallgrass community are appropupon existing studies of that commun6-8. The background for Objective 1noxious weeds are nonnative plant sp

Rocky Flats National Wildlife Refuge 15 Comments and Responses on the Draft Enviro
Comment

# Letter #6 continued Respon

6-9 

6-10 6-11 6-12 6-13 6-14 6-15 6-16 6-17 

6-9. The Service has found that field disturbed areas throughout Rocky Flaproblem.6-10. While the Service agrees with preventing any new weed infestationmore achievable, which is one of the objectives. 6-11. The cost figures for Restoratioinclude staff labor, which reduces the Staffing costs are included in Annual 6-12. The FEIS was revised to reflec6-13. The FEIS was revised to reflec6-14. Executive Order 13112, Invasilist of relevant laws and executive ord6-15. The FEIS was revised to reflec6-16. The Service is aware that the cshows Dalmatian toadflax, which is fcover of the Final CCP/EIS has been document.6-17. Thank you for you comments.

Rocky Flats National Wildlife Refuge 16 Comments and Responses on the Draft Enviro
Comment

# Letter #7 Respon

7-1 7-2 7-3 

7-1. Thank you for your comments.7-2. The Service appreciates the RFCprocess.7-3. Thank you for your comments.

Rocky Flats National Wildlife Refuge 17 Comments and Responses on the Draft Enviro
Comment

# Letter #7 continued Respon

7-4 7-5 7-6 

7-4. The final configuration of the Dnature of any fencing or structures dethe Refuge, will be decided by the RFcontinue to provide input to the RFCA FEIS was revised to indicate that the wire agricultural fence and/or permansignage would best demarcate the DOlivestock out of the DOE retained arewould be closed to public access. Threcommendations to the RFCA partie7-5. The Service will continue to proregarding cleanup issues, and suppormonitoring of the buffer zone by the of the cleanup and the safety of Refugsampling of the buffer zone is complprovide additional information about existing plutonium concentrations, anconcentrations after cleanup. 7-6. The Service is assured the EPA cleanup that is protective of a Refuge certifying the site in accordance with 

Rocky Flats National Wildlife Refuge 18 Comments and Responses on the Draft Enviro
Comment

# Letter #7 continued Respon

7-7 

7-7. Thank you for your comments.

Rocky Flats National Wildlife Refuge 19 Comments and Responses on the Draft Enviro
Comment

# Letter #8 Respon

8-1 

8-1. Thank you for your comments. Proposed Action would best balance management with public use in accorNational Wildlife Refuge System Imppolicies.

Rocky Flats National Wildlife Refuge 20 Comments and Responses on the Draft Enviro
Comment

# Letter #8 continued Respon

8-2 8-3 8-4 8-5 8-6 

8-2. Alternative B, the Service’s Profull range of weed management tools Management approach. The Service aggressive weed management is needmanagement in Alternative B would constraints and other priorities.8-3. The Service acknowledges that of prairie dog colonies would be an in(10 acres) of existing populations. Prspecies, and the Service has an obligathe Refuge. The Service believes thaacres of prairie dog colonies is still wService could effectively manage and 8-4. Future hydrologic conditions arFEIS under section 3.3, Water Resouinformal consultation with the ServicPreble’s from hydrologic changes of protects existing property rights on thand ditches. The Service does not plareas, but will instead focus on protec8-5. The Service believes the Proposhabitat restoration and wildlife manafuture funding.8-6. The Service believes that the levAlternative B would be appropriate fRefuge. In response to these and othbeen revised to include another off-sisouthwest that will enable the City of along Big Dry Creek south of the Refof the southern multi-use trail has beeimprove the trail experience for visitoconnections to other jurisdictions. Thsignificant additions beyond those justrike an appropriate balance between management, and would increase trai

Rocky Flats National Wildlife Refuge 21 Comments and Responses on the Draft Enviro
Comment

# Letter #8 continued Respon

8-7 8-8 

8-7. Equestrian access was not widelcomments, and raises issues about pothese reasons, the Service’s limitation Alternative B is intended to provide a conservative with regard to ecologica8-8. Due to the level of disturbance tRefuge management, and public concthe public use implementation plan oBy focusing staffing and budgetary rethe first 5 years, the Service would be noxious weed infestations, and initiattrail use would begin.

Rocky Flats National Wildlife Refuge 22 Comments and Responses on the Draft Enviro
Comment

# Letter #8 continued Respon

8-9 

8-10 8-11 

8-9. Thank you for your comment. Nof cleanup related issues is included i8-10. In the DEIS, the Service recomthe DOE retained area be “seamless” differences between the Refuge and t1.8 of the FEIS was revised to indicabarbed-wire agricultural fence and/or demarcate the interior property boundthe DOE lands, and clarify that the Dpublic access. Such a fence would noof wildlife across the site, and would Service has provided these recommen8-11. The Refuge Act directed that thtransportation improvements should nfrom the Indiana Street right-of-way. resources that fall within a distance oThe three different widths (50, 125, aprovide a range of widths and amounwithin each width, up to 300 feet. Thintended to imply a preference for antransferred, or any implication that onwould be available.The Service acknowledges that the trtransportation improvements is the reRefuge Act directs the Service to addfor the identification of any land that transportation improvements. The FESection 4.16 that discusses potential Rimmediately west of Indiana Street usection also describes recommended minimize adverse impacts to the Refuimprovements along Indiana Street, H

Rocky Flats National Wildlife Refuge 23 Comments and Responses on the Draft Enviro
Comment

# Letter #8 continued Respon

8-12 8-13 8-14 

8-12. The FEIS was revised based on 8-13. The Service acknowledges thavisual impacts of future transportatioroadway is designed. However, the RService to make recommendations on available for transportation improvemhas been removed from the FEIS, an potential effects of any transportation been added as Section 4.16, and does potential visual impacts, recognizing improvements do not currently exist. 8-14. The existing barbed-wire fence Service’s proposed action.

Rocky Flats National Wildlife Refuge 24 Comments and Responses on the Draft Enviro
Comment

# Letter #8 continued Respon

8-15 8-16 8-17 8-18 

8-15. Since the public meetings, the include specific signage. However, tcontamination issues in Section 1.8 einclude information on residual contaissues.8-16. The Refuge Act provides for thof the Lindsay Ranch structures in acHistoric Preservation Act. After evalstructures, the Service has concluded beyond repair, and that appropriate redetract Refuge resources away from othese reasons, the Service proposes to only.As stated in the rationale for AlternatObjective 6.4, the Service would be wconsider stabilizing the house if resoupartnerships or grants to undertake sudoes not remain, the Service agrees ththrough a variety of media such as inbeen revised to reflect this. The Servbecoming an attractive nuisance if it security fencing that would be requirdetract from the visual qualities of th8-17. While the depiction of the DOE be visually obtrusive, it is intended to is not responsible for resource managThe maps have been revised to make The Service, however, will provide reregarding resource management issue8-18. Thank you for your comment. the six planning goals of the Refuge.

Rocky Flats National Wildlife Refuge 25 Comments and Responses on the Draft Enviro
Comment

# Letter #8 continued Respon

8-19 

8-19. Thank you for your comments

Rocky Flats National Wildlife Refuge 26 Comments and Responses on the Draft Enviro
Comment

# Letter #9 Respon

9-1 9-2 9-3 9-4 9-5 

9-1. Thank you for your comments.9-2. Although the Refuge will not be completed, and the EPA and CDPHE refuge activities would be safe for the Service believes that the proposed acpublic access (Alternative B) would bmanagement, and public access. UndRefuge would be restricted to public allow time for restoration efforts to bbelieve that the proposed action imprRocky Flats will not be the first refugnuclear facility. Saddle Mountain NWWashington in 1971, with over 30,00DOE’s Hanford Site. Saddle MountaReach National Monument, created a2000. Over 50,000 acres of the Hanfis currently open to public use. Unfosystem there are dozens of sites that hcontaminant issues related to former 9-3. The Service acknowledges that ecological restoration would be majothis reason the Service has elected to management on these issues. After 5 the amount of public use proposed in compatible with on-going restoration The Service believes that wildlife-depinterpretation and environmental eduwith opportunities to observe how the restoration and other management ob9-4. Under the Refuge Act, no portioRefuge until the EPA certifies that Dclosure.9-5. Thank you for your comment.

Rocky Flats National Wildlife Refuge 27 Comments and Responses on the Draft Enviro
Comment

# Letter #9 continued Respon

9-6 9-7 9-8 9-9 

9-6. Under the Refuge Act, the DOE future cleanup-related response actionCCP/EIS includes additional discussiresponsibilities in Chapter 1 – Purpo9-7. See response to comment 9-2. Tarea to become the Refuge are currenany response actions. All of the prevsites that have been discovered at Rothe area to be retained by DOE. Idensites is purpose of the current cleanup 9-8. It is the intent of the Service not administrative jurisdiction for any lanMemorandum of Understanding betwthe Refuge Act, is finalized. The Sertransfer. While the MOU has not yet and DOE have continued to work cootransition issues.9-9. The CCP/EIS does not address pmonitoring on refuge lands because nis currently unaware of any remedy-rrequired on the lands currently identiWildlife Refuge System. DOE is resmonitoring of the remedy, and is requjurisdiction of any lands that require Service does not believe that the RFClong-term monitoring of Buffer Zone Service. The City should address thiand identify the “post-closure monitoCity believes is “critical.”

Rocky Flats National Wildlife Refuge 28 Comments and Responses on the Draft Enviro
Comment

# Letter #9 continued Respon

9-10 9-11 9-12 9-13 9-14 

9-10. The Refuge Act requires that thresponsibility over all engineering strinstitutional controls related to cleanuthe DOE retained area. In the DEIS, the demarcation of the DOE retained obvious visual differences between tharea. The FEIS was revised to elabora barbed-wire agricultural fence and/demarcate the interior property boundthe DOE lands, and clarify that the Daccess. Such a fence would not advewildlife across the site, and would noService has provided these recommenThe Service has also recommended to retained lands be posted with signs thService is not opposed to more robusmonitoring sites and facilities that maRFCA Parties.Regarding prairie dogs, the EPA and subsurface contamination is not an isthe Refuge. The Service agrees with term monitoring and management of quickly detect any pioneering of praircontaminants are left in the subsurfacbe addressed in DOE’s long-term stecan disperse from a natal colony for dsingle movement and, therefore, coulfrom off-site as easily as from within forward to working with adjacent lanthe long-term management of prairie 9-11. See response to comment 9-109-12. See response to comment 9-10the CCP/EIS recommends ongoing mbarbed-wire boundary fence, with apidentifying the Refuge boundary.9-13. Thank you for your comment.

Rocky Flats National Wildlife Refuge 29 Comments and Responses on the Draft Enviro
Comment

# Letter #9 continued Respon

9-15 9-16 9-17 9-18 9-19 

9-14. The Service acknowledges thaprotection, and regional conservation of and benefits from the establishmenRefuge. The Service believes that thB, would best achieve these goals.9-15. Thank you for your comment. the six planning goals of the Refuge.9-16. See response to comments 9-2 9-17. See responses to comments 9-8 9-18. Thank you for your comment.9-19. The Service acknowledges thaconstruction of any roads through the proposal to bisect the Refuge with a r

Rocky Flats National Wildlife Refuge 30 Comments and Responses on the Draft Enviro
Comment

# Letter #9 continued Respon

9-20 

9-20. Thank you for your comment.

Rocky Flats National Wildlife Refuge 31 Comments and Responses on the Draft Enviro
Co

m

m

ent

# Letter #10 

Respon

10-1 10-2 10-3 

10-1.

T

hank you for your com

ments

10-2.

T

hank you for your com

ment. 

the six planni

ng goals of the Refuge.

10-3.

T

hank you for your com

ment. 

partnerships with

neigh

boring jurisdi

component of Refuge ma

nageme

nt. 

10-4. The Service ack

nowledges t

he 

co

ntext of t

he Refuge.

10-5.

T

he Service ac

k

nowle

dges tha

settleme

nt con

ditio

ns is probably not 

acceptable (e.g., natural wildfires, griin this area would be to restore, to the an

d ecological processes that e

xiste

d 

remove as man

y of t

he c

hanges i

ntrod

possible. I

n the pre-settlement era, it 

pop

ulations on this site fluctuate

d o

v

that those pop

ulations will contin

ue t

Service believes its goals for prairie dsocially acceptable, an

d with the rang

occurred i

n the pre-settlement era – w

the i

ntegrity of the D

O

E reme

d

y. 

10-6.

T

hank you for your com

ment. 

the six plan

ning goals of the Refuge, 

research is a refuge purpose.10-7. The Service agrees that the use overgrazing by

wild ungulates i

n Pre

a feasible or reasonable practice. T

he 

reflect that. The Service antici

pates t

through 

h

unting, c

ulling, or hazing w

degradation of riparian ha

bitats by wi

fencing may be used to control mo

ve

grazing prescriptions an

d the Service 

fencing to e

xclu

de wild

u

ngulates fro

u

niq

ue plant commu

nities, s

uch as th

commu

nity. 

Rocky Flats National Wildlife Refuge 32 Com

ments and Responses on the Draft Enviro
Comment

# Letter #10 continued Respon

10-4 10-5 10-6 10-7 10-8 10-9 

10-10 

10-8. The discussion about the effectbe a general description of the types oto occur on the Refuge. The Service document the specific effects of habiresources at Rocky Flats. No such stthe CCP/EIS development and analys10-9. As suggested by the comment, undisturbed” is intended to imply thahuman activity, and has not been totasuppression of natural grassland fires intervention has altered the ecologica10-10. The FEIS was revised as to nother jurisdictions. 10-11. The Service’s goal in any cattattempt to emulate the pre-settlement intensive short-term rotation – flash gacknowledges that there will be costs to implement such a grazing programin finding cooperative ranchers to parthat case, it may be necessary to use ofire or mowing) to restore a more natService does not believe that longer, produce the desired ecological benefiHowever, the Service looks forward tadjacent land managers to see if othesuitable for refuge application.10-12. Depending on how it is applieweed management tool, an ecologicaService anticipates that grazing prescthe ecological integrity of habitats wiemulate bison grazing, and that most would involve other livestock species mentioned under several different objManagement, 1.3 – Mixed Grassland 

Weed Management) as a tool that woobjective. In the DEIS, Table 4 incorand grazing as a management tool unManagement. The FEIS has been rev

Rocky Flats National Wildlife Refuge 33 Comments and Responses on the Draft Enviro
Comment

# Letter #10 continued Respon

10-11 10-12 10-13 10-14 10-15 10-16 10-17 10-18 

10-13. The Service agrees that some of grazing techniques would provide guidance. Such experimentation wouVegetation Management Plan.10-14. The FEIS was revised to inco10-15. The Service anticipates that thinfestations and the reduction of thosmeasured by their areal extent, and thinfestations. The objective text was rinformation. Specific measures woulIntegrated Pest Management Plan.10-16. The Service agrees with your prairie dog as a “keystone species” is while their contribution to grassland The text of Objective 1.7 was revised 10-17. The FEIS has been revised to prairie dog colonies and noxious wee10-18. The Service agrees that it can control prairie dogs, and that existing effective. However, the Service does easier to manage 750 acres of colonieprojected future funding constraints. expansion in Alternatives B and C arthat would allow sustainable populatia threshold at which the Service woupopulations. A secondary purpose of is to ensure that they would not colonriparian habitat, or xeric tallgrass habWith regard to plague control, the Sehuman plague transmission is very rabelieve that plague control is a prudeThe Service currently controls for plaArsenal NWR in areas where visitors 

Rocky Flats National Wildlife Refuge 34 Comments and Responses on the Draft Enviro
Comment

# Letter #10 continued Respon

10-19 10-20 10-21 10-22 10-23 10-24 10-25 10-26 10-27 

10-19. As described in Objective 5.2 

will work with local governments to issues. This would include issues rel10-20. The 1989 Habitat Suitability Iestimate the location and extent of poRefuge, as shown in Figure 17. The dogs often colonize areas that are outIndeed, there is historical documentacolonies within the xeric tallgrass comand the vegetation structure do not famodel. However, the Service believehistorical prairie dog colonization of related to market-driven grazing practhese reasons, the HIS model was useprairie dog management objectives wintervention to prevent the colonizatithe xeric tallgrass prairie.10-21. The Service agrees that potento site closure and permitted mining mRefuge resources. From a NEPA stanoccur before the CCP/EIS takes effec“baseline” conditions. These changeBaseline Conditions in Section 3.3, Wconsulting with the Service to minimthese hydrologic changes.It is noteworthy that the best Preble’s to be in the Rock Creek drainage wheThe hydrologic changes will surely imresources at the site. Unfortunately, tRefuge Act to complete the CCP befofinal plans for re-configuring the sitenot possible to determine what resourby those hydrologic changes.10-22. The FEIS has been revised to work with the mining operators and ato minimize and mitigate the effects othe Refuge.

Rocky Flats National Wildlife Refuge 35 Comments and Responses on the Draft Enviro
Comment

# Letter #10 continued Respon

10-28 10-29 10-30 10-31 10-32 

10-23. The presentation of “average general indicator of habitat fragmentaFor the purposes of the patch size anatheir size, were considered equally. Acomplex indicators are possible, they analysis process.10-24. Objective 1.5 – Weed Manag

elaborate that the use of biological coplanned to reduce potential impacts o10-25. The Service appreciates regiothe ecological function of the Refuge neighboring open space areas. Workplanning goals of the Refuge.10-26. The Service looks forward to City of Boulder and other jurisdictionconservation of tallgrass prairie.10-27. Thank you for the offer of the with others is one of the six planning 10-28. Section 3.5 of the FEIS was r10-29. The Service is dedicated to wcoordinate management and emergenforward to working with the City.10-30. The Service would support th“roundtable” meetings to better coordmanagement efforts.10-31. The Service acknowledges thGoal 5 – Working With Others are quHowever, the objectives illustrate the the City and other entities on regiona10-32. Thank you for your comment

Rocky Flats National Wildlife Refuge 36 Comments and Responses on the Draft Enviro
Comment

# Letter #11 Respon

11-1 

11-1. Thank you for your comments11-2. The MOU between the Service to Refuge establishment. The physicretained by DOE will be demarcated parties and will not be identified in th11-3. See response to comment 11-211-4. See response to comment 11-211-5. See response to comment 11-211-6. Current Preble’s populations at 

documented by the DOE and aMeadow Jumping Mouse Prote– Wildlife Resources. Riparian shown in Figure 13 – Vegetatio

Rocky Flats National Wildlife Refuge 37 Comments and Responses on the Draft Enviro
Comment

# Letter #11 continued Respon

11-2 11-3 11-4 11-5 11-6 11-7 11-8 11-9 

11-10 

11-7. It is the intention of the Servicwithin the constraints that will exist aReduced surface water flow is anticipconstraints. The Refuge Act specificproperty rights on the Refuge, includeasements. However, the Service wilacquisition of water rights on a willin11-8. Due to the level of disturbance Refuge management, and public concthe Service has elected to maintain thplan that was proposed in the DEIS. to address ecological concerns related revegetation of unused roads on the Rbudgetary resources on habitat restorService would be able to reduce the sinfestations, and initiate road restoratintroduce a new disturbance onto the considered expanding the amount of years, and has revised Objective 2.13 

greater flexibility to open additional trestoration objectives are met and thetrails. The Service will not open trail space lands until those regional conn11-9. See response to comment 11-7roads were designed to provide reasoDitch, the Upper Church Ditch, and oRocky Flats. The Service will work Broomfield to ensure reasonable acceeasements.11-10. The Service would solicit the City and County of Broomfield, othethe public during the development of Plan.

Rocky Flats National Wildlife Refuge 38 Comments and Responses on the Draft Enviro
Comment

# Letter #11 continued Respon

11-11 11-12 11-13 11-14 11-15 11-16 11-17 11-18 11-19 

11-11. See response to comment 11-working with the City and County of jurisdictions in addressing your concethe Refuge. A step-down Integrated incorporate those concerns, as well athat are employed by DOE.11-12. The Service would solicit the City and County of Broomfield, othethe public during the development of Management Plan and a specific Fire Service does not have management juretained by DOE, it is our understandconcerns, prescribed fire would not bIn addition, the Service does not propeastern portion of the Refuge between Woman Creek to the south (Figure 1011-13. Biological control measures wavoid adverse effects to native specieinclude this language.11-14. Grazing programs would be hinclude adequate fencing to keep livearea or other non-target areas.11-15. While the specific protocols fsharing are not addressed in the CCPshare the annual weed mapping data public.11-16. The Service looks forward to County of Broomfield, as well as othof Refuge management.11-17. Target populations would be population conditions and would be bjudgment of Service and CDOW staf11-18. If target populations were to balternative, they would likely vary deuse in the alternatives, as well as the vary between alternatives. 

Rocky Flats National Wildlife Refuge 39 Comments and Responses on the Draft Enviro
Comment

# Letter #11 continued Respon

11-20 11-21 11-22 11-23 11-24 11-25 11-26 

11-19. Tissue samples, including ediharvested at Rocky Flats in 2002 havcontaminants. The results of the analsignificant uptake of contaminants by Rocky Flats.11-20. The EPA and CDPHE have vcontamination does not exist in the arThe DOE will be responsible for the facilities within the portions of the Dsubsurface contamination will remainprairie dogs or other burrowing animcontamination. While the Service is within the DOE retained area, and whshould not be an issue on the Refuge, the DOE it is prudent for the Service dog population and to keep those poparea.11-21. Alternative D would allow foother jurisdictions. Alternative B, the 11-22. The prairie dog is an integral ecosystem. While there is about 2,40habitat, there are currently about 10 aRocky Flats. The Service believes thsome prairie dog expansion, and that threshold for prairie dog expansion won sustainable prairie dog expansion. permitted to colonize riparian or wetlhabitat, or the DOE retained area.11-23. The Service believes that the be adequate to manage prairie dogs a11-24. Plague control methods inclucontrol fleas that spread plague. The Prairie Dog Management has been recontrol methods will be used to protewell as Refuge visitors. 11-25. The Service will provide this County of Broomfield. 

Rocky Flats National Wildlife Refuge 40 Comments and Responses on the Draft Enviro
Comment

# Letter #11 continued Respon

11-27 11-28 11-29 11-30 11-31 11-32 11-33 

11-26. The Service would work with Broomfield, as well as other neighboplans for any species reintroductions 11-27. The Service would like to claacres of xeric tallgrass prairie would alignments (including those revised fproposed in Alternative B. With regaresponse to comment 11- 8.11-28. The basis for evaluating the imRefuge activities (Table 10) were detbasis, considering the nature of that rrange of possible effects to that resou11-29. Air quality impact thresholds 11-30. The proposed trail configuratsouthern portion of the Refuge was reand provide a higher quality and morWhile trail revisions slightly extend tAlternative B, they are still within a rService’s goals for Alternative B. Ththe benefits of significant trail additioconstruction and maintenance expens11-31. Trail design, signage, educatibe used to promote a positive trail ex11-32. Thank you for your comment11-33. The Service recognizes the implanning, and is encouraged by the efjurisdictions to develop trail connectitrails, including a north-south connecStreet. As described in strategy 2.13include a trail underpass at Indiana S

Rocky Flats National Wildlife Refuge 41 Comments and Responses on the Draft Enviro
Comment

# Letter #11 continued Respon

11-34 11-35 11-36 11-37 11-38 11-39 11-40 11-41 11-42 11-43 

11-34. Thank you for your comment 11-35. Portable restrooms will be avstation and main trailhead, but not at 11-36. The proposed trailhead along existing access and an existing disturviews from the pediment top overlooand easy and low impact access to inthat is closer to the grade of the existiconsidered in the design process.11-37. Objective 2.2 – Public Access 

that the access hours will be from daw11-38. Objective 2.13 – Recreation F

elaborate on the nature of interpretive entrances.11-39. Thank you for your comment11-40. Thank you for your comment11-41. Thank you for your comment 11-42. The Service believes that a limprogram would be a safe and positive recreation on the Refuge, and would managing ungulate populations. NotElk Management, and Objective 2.10 revised to better correlate the establispopulation size and public hunting pr11-43. Thank you for your comment 

Rocky Flats National Wildlife Refuge 42 Comments and Responses on the Draft Enviro
Comment

# Letter #11 continued Respon

11-44 11-45 11-46 11-47 11-48 11-49 11-50 

11-44. The Service welcomes Broomprograms, as well as independent res11-45. The CCP/EIS is written under be sufficiently remediated and certifithe Refuge. The Service is not a decicleanup, but the EPA and CDPHE haproposed in the CCP would be safe. However, the Service also acknowledmembers of the public regarding the contamination on lands that will becowe have added an additional discussiSection 1.8. The Service welcomes Boutreach and interpretation efforts.11-46. The Service welcome’s Broomduring the development of a step-dowas throughout the Refuge managemen11-47. See response to comment 11-11-48. The Refuge would include sighistory of the site, the location and naand relative risks associated with the developed in a step-down Visitor Ser11-49. All step-down plans, includinbe completed after the MOU is compin place. No step-down plans will be becomes a refuge. 11-50. See response to comment 11-

Rocky Flats National Wildlife Refuge 43 Comments and Responses on the Draft Enviro
Comment

# Letter #11 continued Respon

11-51 11-52 11-53 11-54 11-55 11-56 11-57 

11-51. See response to comments 1111-52. Thank you for your comment 11-53. In the DEIS, the Service recobetween the Refuge and the DOE retfew obvious visual differences. Sectithat the Service believes that a four-sfence and/or permanent obelisks wouproperty boundary, keep any livestocclarify that the DOE lands are closed would not adversely affect the movemand would not be visually obtrusive. recommendations to the RFCA partie11-54. The Service looks forward to other adjacent jurisdictions to coordinmanagement of wildlife and their hab11-55. See response to comment 11-11-56. The Service plans on installinsystem to provide water to the visitor maintenance facilities.11-57. Regular routine maintenance restrooms, would occur independent station is staffed.

Rocky Flats National Wildlife Refuge 44 Comments and Responses on the Draft Enviro
Comment

# Letter #11 continued Respon

11-58 11-59 11-60 11-61 11-62 11-63 11-64 11-65 11-66 

11-58. The transfer of existing structfacility will likely occur prior to Refu11-59. The additional discussion of c1.8 emphasizes that the EPA and CDbecome the Refuge will be safe for anmanagement activities.11-60. The Service does not anticipapresence on the Refuge. However, thproposed levels of staffing are sufficimanagement objectives that are prop11-61. See response to comment 11-11-62. The Service agrees that surfacimpact on the management of the Refwould not be compatible with the purNWRS. The Service has expressed ttransfer of administrative jurisdiction the United States owns the associated lands have been reclaimed to native g11-63. Chapter 4 has been revised to the potential cumulative effects of mi11-64. See response to comment 11-land from DOE to DOI prior to closu11-65. The CCP/EIS is written under be sufficiently remediated and certifithe Refuge. The Service is not a decicleanup, but the EPA and CDPHE haproposed in the CCP will be safe. Thcertification, as well as issues related portions thereof from CERCLA, are mother RFCA parties. The RFCA partService on the certification standards11-66. See response to comment 11-

Rocky Flats National Wildlife Refuge 45 Comments and Responses on the Draft Enviro
Comment

# Letter #11 continued Respon

11-67 11-68 

11-67. The Refuge Act directed that transportation improvements should nfrom the Indiana Street right-of-way. the transfer of land for the purposes othe responsibility of the DOE and woestablishment of the Refuge. HowevService to make recommendations on available for transportation improvemincludes a new Section 4.16, which dthe Service would have related to any along Indiana Street, Highway 128, a11-68. Thank you for your comment

Rocky Flats National Wildlife Refuge 46 Comments and Responses on the Draft Enviro
Comment

# Letter #11 continued Respon

Rocky Flats National Wildlife Refuge 47 Comments and Responses on the Draft Enviro
Comment

# Letter #12 Respon

12-1 12-2 12-3 

12-1. Thank you for your comments12-2. DOE has been working with thon the Preble’s from hydrologic chanintention of the Service to manage Prresources that will exist when the Refsurface water flow is anticipated to bThe Refuge Act specifically protects Refuge, including water rights and reService would consider future volunton a willing-seller basis.12-3. See response to comment 12-2Any residual contamination in the bucontamination that is well below cleaprotect public safety. All areas with contamination will be within the landwill be remediated. For that reason, tverified that Refuge operations, incluwould not expose additional contamipublic.

Rocky Flats National Wildlife Refuge 48 Comments and Responses on the Draft Enviro
Comment

# Letter #12 continued Respon

12-4 12-5 12-6 12-7 12-8 

12-4. The budget for Refuge managehabitat restoration and revegetation wthrough Department of the Interior apstewardship of the DOE retained area appropriations. Xeric tallgrass manawould not affect budgets for DOE lonMaintenance of the xeric tallgrass praCongress authorized the Refuge. The xeric tallgrass are described in ObjecManagement. It is the Service’s beliecommunity has persisted for a very lovegetative community on the portionService believes there is insufficient allow the xeric tallgrass community tshrubland. If that were the case, a shwould have replaced the tallgrass praacquired most of the land in 1951.The Service does not plan to employ Technician to monitor habitat restoraEPA have verified that such activities refuge lands without threatening humissues about residual contamination, 3, as well as the expanded discussion 12-5. See response to comment 12-3discussion in Section 1.8 of the FEIS12-6. The Refuge access roads were access to the DOE retained area, all mother private property rights at Rocky responsibility for all of the lands and cleanup and remedy facilities.12-7. The Service would solicit the iCity of Westminster, other jurisdictioduring the development of an Integra

Rocky Flats National Wildlife Refuge 49 Comments and Responses on the Draft Enviro
Comment

# Letter #12 continued Respon

12-9 

12-10 12-11 12-12 12-13 12-14 

12-8. Depending on how it is appliedcattle can serve as a weed managemetool, both, or neither. Grazing is menobjectives (1.2 – Xeric Tallgrass Man

Grassland Prairie Management, and 

tool that is available to achieve that oWeed Coordinator in comment 6-6, iflexibility in applying managed graziThe Service does not have managemeretained lands, including most of the not recommended any grazing activitand is not aware of any proposal by tlands for any reason.12-9. The Service would solicit the iCity of Westminster, other jurisdictioduring the development of a step-dowEPA and CDPHE have verified that amanagement activities, including preHowever, in response to concerns aboassociated with the 903 pad, the Servapproach and does not propose using portion of the Refuge between WalnuCreek to the south (Figure 8). The Serecommendations and requirements rany application of prescribed fire.12-10. See response to comment 12-working with the City of Westminsteaddressing concerns about weed mandown Integrated Pest Management Plconcerns, as well as many of the currcomplies with EPA-approved labels. applications on the Refuge would go Proposal review process in accordancon the Refuge.

Rocky Flats National Wildlife Refuge 50 Comments and Responses on the Draft Enviro
Comment

# Letter #12 continued Respon

12-15 12-16 12-17 12-18 12-19 

12-11. Tissue samples, including ediharvested at Rocky Flats in 2002 havcontaminants. The results of the analsignificant uptake of contaminants by Rocky Flats.12-12. The exact structure and locatiprograms would be documented in a Service would solicit the input and paWestminster, other jurisdictions, stakthe development of this plan. The Fipropose only archery and shotguns foproposal to allow use of muzzle-loadconsideration of safety comments recthe Draft CCP/EIS.12-13. The EPA and CDPHE have vcontamination does not exist in the arThe DOE will be responsible for the facilities within the portions of the Dsubsurface contamination will remainprairie dogs or other burrowing animcontamination. While the Service is within the DOE retained area, and whshould not be an issue on the Refuge, the DOE it is prudent for the Service dog population and to keep those poparea.During their annual dispersal from namove as far as 10 miles or more, pionis as likely that prairie dogs could invareas outside Rocky Flats as they couThere is no biologically sound, or praestablish any specific distances to keeretained lands. Other issues such as vbarriers are more important than distaneed to develop a robust stand of vegand maintain long-term monitoring to from compromising the remedy. 

Rocky Flats National Wildlife Refuge 51 Comments and Responses on the Draft Enviro
Comment

# Letter #12 continued Respon

12-20 12-21 12-22 12-23 12-24 12-25 12-26 

12-14. The Service would work with well as other neighboring jurisdictionspecies reintroductions to the Refugeto Objective 1.8 – Species Reintroduc

12-15. The Service considered additiincluding those requested by the City jurisdictions, and organizations. The Alternative B in the southern portion improve connectivity and provide a hvisitor experience. The overall length increased only slightly, so it would nof maintaining Refuge trails. As descManagement, trails would be informainfestations and other ecological issueducation, and law enforcement woultrail experience for all users.12-16. All public uses, including equmanaged though a combination of sigenforcement. These methods have prRefuges and in many open space areaThe Service believes that these same keeping the public out of the DOE reresponse to concerns about access to Service has recommended to the RFCagricultural fence and/or permanent oproperty boundary could be used to dwithout adversely affecting the movethe Refuge. 12-17. See response to comment 12-12-18. Off-trail use would be allowepedestrian access only, in the areas sotrail in the southern part of the Refugrestrictions would be managed througenforcement. In regard to specific cocontamination, the EPA and CDPHE public uses, including off-trail use, wproposed off-trail use areas are outsidother areas of residual soil contamina

Rocky Flats National Wildlife Refuge 52 Comments and Responses on the Draft Enviro
Comment

# Letter #12 continued Respon

12-27 12-28 12-29 12-30 12-31 12-32 

12-19. Thank you for your comment12-20. Objective 2.2 – Public Access 

that public access would be limited to – Recreation Facilities has been revissuggestion about the Refuge and its dspace areas.12-21. It is the Service’s intent not to administrative jurisdiction of any lanbetween DOE and DOI, as required bIt will be up to the RFCA parties to dactions are protected, while the EPA certified. As outlined in the Refuge Amaintaining response actions will takmanagement activities.12-22. As the City is aware, the RFCare not responsible for cleanup relate12-23. Thank you for your comment12-24. The establishment of the Cold jurisdiction of the Service and the scothe Service has expressed that it wouRefuge interpretation facilities center such a museum is established and it iRefuge entrance.12-25. See response to comment 12-12-26. Objective 2.13 – Recreation F

specify the recommended location of 12-27. Safety requirements are addreSafety. 12-28. See response to comment 12-12-29. Thank you for your comment12-30. As described in Section 3.8 oexpressed to DOE that it will not accjurisdiction of lands subject to mining the associated mineral rights, or until reclaimed to native grasslands. 

Rocky Flats National Wildlife Refuge 53 Comments and Responses on the Draft Enviro
Comment

# Letter #12 continued Respon

12-33 12-34 12-35 12-36 12-37 

12-31. See response to comment 12-12-32. Thank you for your comment with others is one of the six planning 12-33. The Service is encouraged by neighboring jurisdictions to develop tcomplement Refuge trails. 12-34. While the Service will seek to jurisdictions as early as possible, it wformal arrangements until adequate bestablished.12-35. The Refuge Act specifically pon the Refuge, including water rights addition, see response to comment 12responsible for the maintenance and protection facilities. However, the Seand other stakeholders to ensure that the effectiveness of the remedy.12-36. See response to comment 12-12-37. The Service would solicit the City of Westminster, other jurisdictioduring the development of the step-d

Rocky Flats National Wildlife Refuge 54 Comments and Responses on the Draft Enviro
Comment

# Letter #12 continued Respon

12-38 

12-38. Thank you for your comment

Rocky Flats National Wildlife Refuge 55 Comments and Responses on the Draft Enviro
Comment

# Letter #13 Respon

13-1 13-2 13-3 13-4 13-5 13-6 

13-1. Thank you for your comments13-2. Thank you for your comments13-3. Thank you for your comment.13-4. Thank you for your comment.13-5. In the DEIS, the Service recom“seamless” with few obvious visual dand the DOE retained area. Section 1indicate that the Service believes that and/or permanent obelisks with approdemarcate the DOE retained area, keeretained area, and indicate the DOE laccess. The Service has provided theRFCA parties.13-6. The Service believes that a lim

program would be a safe and positive recreation on the Refuge, and would managing ungulate populations, if neand Elk Management, and Objective 

revised in the FEIS to better correlate of target population size and public h

Rocky Flats National Wildlife Refuge 56 Comments and Responses on the Draft Enviro
Comment

# Letter #13 continued Respon

13-7 13-8 13-9 

13-10 13-11 13-12 

13-7. The Service believes that the pobjectives would take a proactive appinfestations over the life of the CCP.13-8. Prescribed fire would be one cvegetation management strategy that other techniques, to restore native graunplanned wildfire, and where approThe Service does not intend to use prretained lands and is not aware of any prescribed fire.Both the EPA and CDPHE have indifire outside of the DOE retained area to firefighters, Service personnel, or tHowever, in the interest of caution anpublic, the Service does not propose ueastern portion of the Refuge between Woman Creek to the south (Figure 1013-9. In Alternative B and D, the Serbicycle access as modes of transportato priority public uses of the Refuge. the ability to complement and improvThe size of the Refuge also would wabesides hiking. For example, in Altebetween the proposed trail connection the visitor contact station would be 3too far round-trip for some Refuge viAs noted in the Compatibility Determtrails would be constructed using exiconverted to trails. Such access woulhabitat impacts. While weed dispersdisturbance and other impacts to natuconcern, the Service does not believe substantially reduced by excluding biRefuge.

Comment

# Letter #13 continued Respon

Rocky Flats National Wildlife Refuge 57 Comments and Responses on the Draft Enviro
Rocky Flats National Wildlife Refuge 58 Comments and Responses on the Draft Enviro

13-10. Seasonal off-trail hiking accesouthern portion of the Refuge in Altof allowing amateur naturalists, wildlbetter access to their subjects. It is anarea would be limited in numbers and adversely affect vegetation communisafety concerns, the Service believes participate in off-trail access on the Rtheir own physical safety, as would bopen to the public. In regard to specicontamination, the EPA and CDPHE public uses, including off-trail use, wproposed off-trail use areas (Figure 2retained area and other areas of residu4). 13-11. The Refuge will not be establthe land has been cleaned up to be saOnce the Refuge is established, the Son habitat restoration in the first 5 yeopportunities. The 5-year target date contingent on successful habitat restoconstruct and manage visitor use facithe Refuge condition evolves, the Serthose changes. 13-12. Thank you for your comment
Comment

# Letter #14 Respon

14-1 14-2 14-3 

14-1. Thank you for your comments14-2. Thank you for your comment.Although the Refuge will not be estabcompleted, and the EPA and CDPHE activities would be safe for the refuge believes that the proposed plan for Reaccess is appropriately conservative aMost of the refuge would be restricteyears to allow time for restoration eff14-3. Thank you for your comment.

Rocky Flats National Wildlife Refuge 59 Comments and Responses on the Draft Enviro
Comment

# Letter #14 continued Respon

14-4 14-5 

14-4. Section 1.8 of the FEIS was rebelieves that a four-strand barbed-wirpermanent obelisks with appropriate the DOE retained area, keep any livearea, and indicate the DOE lands wouSuch a fence would not adversely affacross the site, and would not be visuprovided these recommendations to tbe responsible for the management anfacilities.The CCP/EIS does specifically definwhere public uses would be authorizespecifically designating “off-limits” aNational Wildlife Refuge is allowed uauthorized. Access to DOE lands is cCCP/EIS. However, the Service has parties that the DOE retained lands bpublic entry.14-5. See response to comment 14-4

Rocky Flats National Wildlife Refuge 60 Comments and Responses on the Draft Enviro
Comment

# Letter #14 continued Respon

14-6 14-7 

14-6. A Refuge Comprehensive Conthat describes the desired future condprovides long-range guidance and mathe purposes of the Refuge. The RefuService to develop a CCP by Decembthe RFCA parties, the RFCLOG, and requires the Service to address and mnumber of issues including the feasibcenter.The CCP will not be implemented uncertified by the EPA and transferred tbeen in continued contact with the Dprocess and has been apprised of the lands that will be retained. Obviousltransfer of lands that DOE is not requtransfer. The Refuge Act requires DOto ensure the long-term protectiveneswill not ask DOE for any lands that thtransfer. While the exact boundaries are likely establishment, the Service is confidenlands and resources that would be incchange. For these reasons, the Servicreasonable and effective to complete See response to comment 14-4 regardretained area.14-7. As stated in responses to commaccess would not occur prior to certifthe Service.

Rocky Flats National Wildlife Refuge 61 Comments and Responses on the Draft Enviro
Comment

# Letter #14 continued Respon

14-8 14-9 

14-8. Thank you for your comment.14-9. Thank you for your comment.

Rocky Flats National Wildlife Refuge 62 Comments and Responses on the Draft Enviro
Comment

# Letter #14 continued Respon

14-10 

14-10. The Refuge will not be establcleanup is complete, and that all of thRefuge would be safe for all of the practivities, including public use. The characterization of the land that will bThe Service believes that it is very uncontamination will be discovered on Refuge, but acknowledges that the direleases is possible. The Service doetransfer of administrative jurisdiction until the Memorandum of Understandrequired by the Refuge Act, is finalizensure that the final MOU will contairesponses to discovery of previously The FEIS was revised to include addirelated issues in Section 1.8.

Rocky Flats National Wildlife Refuge 63 Comments and Responses on the Draft Enviro
Comment

# Letter #14 continued Respon

14-11 14-12 14-13 

14-11. As noted in detail in response County Parks and Open Space (letter the assertion that the proposed trail alriparian habitat.” During the planninspecial care to plan trail configurationminimize impacts to riparian habitat. are planned for Alternative B, 0.4 miwithin riparian habitat areas. The 0.4 riparian habitat areas are trail crossinroads. Adequate bridging and habitaminimize trail impacts at these crossi14-12. The Service acknowledges thecological restoration would be a majthis reason the Service has elected to management on habitat restoration. Abelieves that the modest amount of puB would be compatible with on-going be protective of wildlife habitat needestablished until the EPA has certifieanalysis of the site is sufficient, and thave been completed.14-13. As discussed in response to cpublic use facilities in Alternative B wsensitive areas to the greatest extent pclose proximity to sensitive areas sucwould be managed to minimize potenspecies.

Rocky Flats National Wildlife Refuge 64 Comments and Responses on the Draft Enviro
Comment

# Letter #14 continued Respon

14-14 

14-14. Thank you for your comment

Rocky Flats National Wildlife Refuge 65 Comments and Responses on the Draft Enviro
Comment

# Letter #15 Respon

15-1 15-2 15-3 15-4 15-5 

15-1. Thank you for your comments15-2. The Service agrees that Alternprovide insufficient habitat managemdegradation of wildlife habitat due to noxious weeds. With regard to ongoRefuge would not be established unticharacterization and analysis of the ssubsequent cleanup activities have be15-3. Alternative B does not allocate restoration and conservation efforts. throughout the life o f the plan, just aB simply provides the first 5 years to and conservation efforts before the mimplemented.The Service disagrees with the assertalignments in Alternative B “are all iRock Creek and Woman Creek.” In miles, or 9% of the proposed 3.4 mileriparian areas. All of the trails that wwould be on existing roads, and woulsensitive wildlife species. The east-wCreek drainage would be on the pedimabove the drainage, and would be genslope wetlands and between 300 and In the Woman Creek drainage, 0.1 mmiles of trail would be within riparian multi-use trail would be on an existinabout 150 feet from riparian habitat, small stream crossings that would use 

Rocky Flats National Wildlife Refuge 66 Comments and Responses on the Draft Enviro
Comment

# Letter #15 continued Respon

15-6 15-7 15-8 15-9 

15-10 15-11

During the planning process, the Servtrail configurations that would avoid riparian habitat. Overall, of the 16.5 for Alternative B, 0.4 miles, or 2% of habitat areas. The 0.4 miles of trail thareas are trail crossings, most of whicAdequate bridging and habitat restoratrail impacts at these crossings.15-4. Alternative C would not includthat the Refuge would be closed to alexception of guided tours. There woucontrol wild ungulates, if necessary, t15-5. While Alternative D would havhabitat than Alternative B, the Servicbe compatible with the habitat managAdditional analysis (Table 14) has shacre in Alternative D would be lower facilities.15-6. Section 3.6 of the DEIS and thincludes an analysis of potential prairThis analysis was based on a habitat 15-7. The Service acknowledges thamanagement needs to be balanced agconcerns. Currently, there are 10 acrRocky Flats, most of which are adjacCounty open space lands. The Servicavailable habitat and historical prairie believes that the suggested limits for appropriate guidelines to allow for suOne of the purposes of these guidelinexpansion into xeric tallgrass commu

Rocky Flats National Wildlife Refuge 67 Comments and Responses on the Draft Enviro
Comment

# Letter #15 continued Respon

15-12 15-13 15-14 

The Service appreciates the County’s control issues, and has revised ObjectManagement to better correlate prairimanagement efforts. Objective 5.2 – Service will work with adjacent jurisboundary resource management issuebe arranged in the future on an as-nee15-8. Objective 5.2 – Conservation, 

work with adjacent jurisdictions to admanagement issues. As most of the pappear to be associated with populatiCounty open space lands, this is a gothe Service to work with the County Specific agreements would be arrangbasis.15-9. The Service agrees that unmanAlternative A has the potential to advresources, including sharp-tailed grousituation reflects realities of the “no a15-10. Dr. Meaney’s article was conpotential trail impacts to Preble’s thaaddition, see response to comment 15planned in Preble’s habitat would be that most of these areas would be sub15-11. Thank you for your commentfencing around the DOE retained areRFCA parties, the Service has recomwire fence and/or obelisks that allow across the site.15-12. Managed grazing would be pAs any grazing regime would be highmonitor its results and any adverse efregimes management and monitoring down Vegetation and Wildlife Manag

Rocky Flats National Wildlife Refuge 68 Comments and Responses on the Draft Enviro
Rocky Flats National Wildlife Refuge 69 Comments and Responses on the Draft Enviro

Comment 

# Letter #15 continued Respon

15-13. While the Service agrees that change the nature and frequency of hthese changes are not anticipated to aany alternative. The Service believes plan would allow for wildlife and Rehuman uses on the Refuge. Objectiv

encourage scientific research related wildlife populations. However, the Snecessary to suspend public use until 

15-14. Thank you for your comment
Comment

# Letter #16 Respon

16-1 

16-1. Thank you for your commentsretained area will be decided by the R

Rocky Flats National Wildlife Refuge 70 Comments and Responses on the Draft Enviro
Comment

# Letter #16 continued Respon

16-2 16-3 

16-2. The Service agrees that if weed successful, a broad range of managemThe Service would work with Jeffersjurisdictions in the development of stincluding an Integrated Pest Managem16-3. During the winter of 2003/2004with DOE, the Cold War Museum, anHistorical Society, stabilized the Linddamaged during the March 2003 blizwere essentially rebuilt. After evaluaService has concluded that it is in a dweathered beyond repair. The Servicdemolishing the farmhouse if it poses Refuge visitors. Chapter 3 of the Fininformation on the history and presenRanch.As stated in the rationale for AlternatObjective 6.4, the Service would be wconsider stabilizing the house if resoupartnerships or grants to undertake suthat the house can be interpreted whethrough a variety of media such as inbeen revised to reflect this. The Servbecoming an attractive nuisance if it security fencing that would be requirdetract from the visual qualities of th

Rocky Flats National Wildlife Refuge 71 Comments and Responses on the Draft Enviro
Comment

# Letter #16 continued Respon

16-4 16-5 16-6 

16-4. Several jurisdictions have suggthe southern part of the Refuge. Reviinclude a trail connection to the southto the east, and a new southern east-wa more diverse and higher quality trairevisions do not significantly change Alternative B. The Service believes tthe trail system would no longer strikuse and habitat management that Altewould add to the overall trail length wquality of the experience, and would maintenance.16-5. Due to the level of disturbance Refuge management, and public concthe Service has elected to maintain thplan that was proposed in the Draft Cand budgetary resources on habitat reService would be able to reduce the sinfestations, and initiate road restoratintroduce a new disturbance onto the 2.13 – Recreation Facilities has been flexibility in opening additional trails conditions and funding allow.16-6. In the DEIS and FEIS, the Fronbe a Reasonably Foreseeable Activity outside of the Refuge. None of the aincorporating the Front Range Trail oeffects were not analyzed.In developing the alternatives, the SeRange Trail could be accommodated found that there are currently no reasthe trail on the Refuge. The Service planning the Front Range Trail, but wlocal government proponents if any fdeveloped that include the Refuge.

Rocky Flats National Wildlife Refuge 72 Comments and Responses on the Draft Enviro
Comment

# Letter #16 continued Respon

16-7 16-8 16-9 

16-10 16-11 16-12 

16-7. Alternative B includes equestrisouthern part of the Refuge, under thin the Compatibility Determination in 16-8. The Service is looking forward the County and other nearby jurisdictone of the six planning goals of the R16-9. The Service would consider ththe management of the Refuge.16-10. The Service would work with appropriate emergency response prot16-11. The FEIS was revised accord16-12. The Service does not anticipapresence on the Refuge. However, thproposed levels of staffing are sufficimanagement objectives that are propwould be shared across the refuge comMountain Arsenal NWR and Two Po

Rocky Flats National Wildlife Refuge 73 Comments and Responses on the Draft Enviro
Comment

# Letter #16 continued Respon

16-13 16-14 

16-13. As required by the Refuge Acfencing options in Section 4.15 – Fen

wire boundary fence was recommend1.8 of the FEIS was revised to indicabarbed-wire agricultural fence and/or appropriate signage would best demakeep any livestock out of the DOE reDOE lands would be closed to public adversely affect the movement of wilnot be visually obtrusive. The Servicrecommendations to the RFCA partie16-14. The DEIS and FEIS identify tdistance of 50, 125, 300 feet from Indledges that the transfer of land for the improvements is DOE’s responsibilitestablishment of the Refuge. The Readdress and make recommendations that DOE could make available for trFEIS was revised to include a new Setial Refuge lands within a corridor imup to 300 feet wide. The new section mitigation measures that would minimRefuge related to any transportation iStreet, Highway 128, and Highway 9

Rocky Flats National Wildlife Refuge 74 Comments and Responses on the Draft Enviro
Comment

# Letter #16 continued Respon

16-15 16-16 16-17 16-18 

16-15. Thank you for your comment16-16. See response to comment 16-16-17. The FEIS was revised to clarisettlement” conditions to be a concepbased on ecological conditions that emodern use and disturbance of the sitadded to the glossary.16-18. Thank you for your comment

Rocky Flats National Wildlife Refuge 75 Comments and Responses on the Draft Enviro
Comment

# Letter #16 continued Respon

Rocky Flats National Wildlife Refuge 76 Comments and Responses on the Draft Enviro
Comment

# Letter #17 Respon

17-1 17-2 

17-1. Thank you for your comments17-2. Alternative B includes the stabthe Lindsay Ranch barn.

Rocky Flats National Wildlife Refuge 77 Comments and Responses on the Draft Enviro
Comment

# Letter #18 Respon

18-1 18-2 

18-1. Thank you for your comments18-2. The Service does not have the (up to 300 feet) of a transportation coavailable. The transfer of land for thimprovements is DOE’s responsibilitRefuge establishment.The DEIS identifies those resources t125, and 300 feet from Indiana. The to address and make recommendationland that DOE could make available The FEIS was revised to include a nepotential Refuge lands within a corridStreet up to 300 feet wide. The new recommended mitigation measures thimpacts to the Refuge related to any talong Indiana Street, Highway 128, a

Rocky Flats National Wildlife Refuge 78 Comments and Responses on the Draft Enviro
Comment

# Letter #18 continued Respon

18-3 18-4 

18-3. The Service disagrees with the Refuge Act requires “objective criterfor a corridor. If an application is subthe Service would work with the applthe impacts of transportation improveresponse to comment 18-4 for additio18-4. The Refuge Act directs the Seron land that could be made available improvements. To that end, the FEIwhich discusses potential concerns threlated to any transportation improveHighway 128, and Highway 93.

Rocky Flats National Wildlife Refuge 79 Comments and Responses on the Draft Enviro
Comment

# Letter #18 continued Respon

18-5 18-6 18-7 18-8 

18-5. See response to comment 18-418-6. See response to comment 18-418-7. The FEIS was revised to descrimpacts that adjacent urban developm18-8. Rocky Flats was not included abecause it was designated to become the mouse would be protected as a rethe Refuge was not included in the crPreble’s, the Service disagrees with tof fact implies that “its habitat may bpurposes.” During the critical habitaService directed that areas outside of will continue to be subject to conservprotections (69 Fed. Reg. 37295).The Final CCP/EIS identifies up to 8habitat that would be included in a 30way. While the revised discussion in concerns related to habitat impacts reis not the Service’s responsibility to aimpacts of yet unknown transportatio

Rocky Flats National Wildlife Refuge 80 Comments and Responses on the Draft Enviro
Comment

# Letter #18 continued Respon

Rocky Flats National Wildlife Refuge 81 Comments and Responses on the Draft Enviro
Comment

# Letter #19 Respon

19-1 

19-1. Thank you for your commentsWestminster’s comments (letter #12)

Rocky Flats National Wildlife Refuge 82 Comments and Responses on the Draft Enviro
Comment

# Letter #20 Respon

20-1 20-2 20-3 

20-1. Thank you for your comments20-2. There is no scientific evidence of plutonium or other contaminants s6,500 acre site.” Under the Refuge Abecome a Refuge until the EPA certifcleanup and closure. The EPA and Crecreational activities that may be allRSALS of cleanup were determined. maker in matters regarding cleanup, baccepted that all activities proposed iHowever, in response to public interediscussion of issues related to site cle20-3. See response to comment 20-2

Rocky Flats National Wildlife Refuge 83 Comments and Responses on the Draft Enviro
Comment

# Letter #20 continued Respon

20-4 20-5 20-6 20-7 20-8 20-9 

20-10 

20-4. See response to comment 20-220-5. The final configuration of the Dnature of any fencing or structures dethe Refuge will be decided by DOE aService is not the final decision-makeService will continue to provide inpuIn the DEIS, the Service recommend“seamless” with few obvious visual dand the DOE retained area. Section 1indicate that the Service believes that and/or permanent obelisks with approdemarcate the DOE retained area, keeretained area, and indicate the DOE laccess. Such a fence would not advewildlife across the site, and would noService has provided these recommen20-6. The Refuge was established by Flats National Wildlife Refuge Act othe first refuge established on a formMountain NWR was established in W30,000 acres in the buffer zone of the Mountain was included in the Hanforcreated as part of the Refuge System the Hanford Reach National Monumeuse. Unfortunately, with the Refuge that have to deal with a variety of conformer and/or adjacent land uses.20-7. See response to comment 20-220-8. Tissue samples, including edibharvested at Rocky Flats in 2002 havcontaminants. The results of the analsignificant uptake of contaminants by Rocky Flats.

Rocky Flats National Wildlife Refuge 84 Comments and Responses on the Draft Enviro
Comment

# Letter #20 continued Respon

20-11 

Extensive studies have been conducteRocky Flats since the mid 1970s, moUniversity. These studies include twof small mammals, arthropods (insecwere taken of various species for the Assessments for Walnut Creek and WRocky Flats Environmental Technoloincluded samples from small mammaand fish. Additional studies were donof Pu, in both terrestrial and aquatic sdone at other DOE facilities that can Flats.One of the purposes that the Refuge wresearch. Once the Service takes primwill review proposals for research on establishes that the research will be oadvancement of the Refuge, the invesproceed with the research.20-9. Working with others is one of Refuge.20-10. The Service would involve thdecisions in a variety of forums. Firsmanagement actions would be determmanagement plans, such as a Fire MaPest Management Plan. Step-down minclude a public participation processbe involved in Refuge management i“Friends” group for the Refuge (Objewould implement a volunteer program public to actively engage in Refuge mforums for citizen involvement in mainclude the Rocky Flats Citizen AdviRocky Flats Coalition of Local Gove20-11. Thank you for your comment

Rocky Flats National Wildlife Refuge 85 Comments and Responses on the Draft Enviro
Comment 

# 

L

etter #21 Resp

on

21-1 21-2 21-3 21-4 21-5 21-6 21-7 

21-1. Thank you for your comments21-2. Thank you for your comments21-3. Based on the interest of the Cothe public, the Service considered expopportu

nities on the Refuge. Due to 

limited b

u

dget for Refuge manageme

access to the Refuge, the Service 

mai

implementatio

n

plan for all alternativ

budgetary resources on

habitat restor

Ser

vice would be able to reduce t

he s

infestations, and initiate road restoratintrod

uce a new disturbance onto the 

21-4. A parallel trail along t

he north

incorporated i

nto Alternatives B and 

21-5. The Draft CCP/EIS acknowled

propose

d connection bet

wee

n trails i

n 

Refuge, and the existing and 

propose

Refuge along Highway 128. Based othe City of Boulder, and several citizthis decision, b

ut did not i

ncl

u

de s

uch 

Action. A connection would not be p

drai

nage is the most ecologically sen

therefore would o

nly sup

port seasona

use through trail in this area would hamanage access and seasonal closuresto t

he north would nee

d to ascend ste

and would compromise the Service’s and use in the sensitive Rock Creek d21-6. Throughout the planni

ng proce

interest in a trail alo

ng the east side o

reaso

ns, t

he propose

d action does not 

reasons include uncertainties surrou

n

land along Indiana Street for regional the desired level of trail facilities that Ser

vice’s goal of balanci

ng 

habitat pr

p

u

blic concerns about contaminatio

n 

not hesitate to accept cleanup decisiosafet

y of Refuge visitors and workers

Rocky Flats National Wildlife Refuge 86 Com

ments and Responses on the Draft Enviro
Comment 

# Letter #21 continued Respon

21-8 21-9 

21-10

sensitive to public perceptions and cocontamination on the eastern edge of not propose a north-south trail along Street corridor. However, the Servicdiscussion of preliminary recommendimprovements along the Refuge bounsouth trail connection along the Indiathose recommendations. 21-7. See response to comment 21-5 to the north. In regard to north-south anticipates that the Front Range Trailalong the Highway 93 corridor, woulequestrian access. As noted in responService recommends that a north-souany major transportation improvemen21-8. Issues related to ongoing cleanscope of the CCP/EIS and outside of authority. Due to the high level of puexpanded discussion of issues related Section 1.8. 21-9. The Service recognizes that the to the Refuge is a sensitive political iand CDPHE’s position that once the would be safe for all Refuge activitie21-10. Thank you for your comment

Rocky Flats National Wildlife Refuge 87 Comments and Responses on the Draft Enviro
Comment 

# Letter #22 Respon

22-1 22-2 22-3 22-4 22-5 

22-1. Thank you for your comments22-2. Thank you for your commentsdesigned to provide minimize impactmeaningful visual or physical access provide interesting experience for tra22-3. Thank you for your comment.22-4. Thank you for your comment.22-5. Early in the planning process, Highway 128, adjacent to the Rock Croad from Boulder County’s Coalton potential trailhead location. This traiin any of the alternatives for several rsensitive natural resources in the Rocaforementioned location is bounded tService believes are too steep for an econnection. Second, due to the resouall trails in that area would be hiking trailhead or multi-use trail connection location, the Service does not believe effectively enforce the seasonal and mbe necessary to protect natural resourtrailhead location is not intended to bInstead, it is envisioned to be a startin

Refuge trails and views for the commFlats. The Service understands the desire of connection to the Refuge, but in balathe area, the proximity of the Wind Tpotential mining of most of the westeService was not able to identify a comBoulder’s open space lands. The Seroptions that exist adjacent to the Refugroups to explore other options. 

Rocky Flats National Wildlife Refuge 88 Comments and Responses on the Draft Enviro
Comment 

# Letter #22 continued Respon

22-6 22-7 22-8 22-9 

22-1022-11

In regard to the potential Cold War M128, that location, referenced in SectiForeseeable Activities, was recomme2003 Museum Feasibility Study. The entrance to the National Wind Technmile west of the aforementioned Coa22-6. The proposed trails shown in Fbased on existing plans and documenadjacent jurisdictions. While some hjurisdictions in anticipation of Refuge planned and documented prior to the this reason, the Service sought to estaplanned trails where practicable. It is connections to the Refuge (such as Cwould need to be established in the futhe current plans for those areas. It is work with nearby jurisdictions to esta22-7. The Service acknowledges tha

a direct, north-south trail connection of the Refuge. Based on the concernothers, the planning team reconsidereAlternative B and added a north-soutroad, as well as a trail connection to tAs specified in the Refuge Act, an armay be used for highway improvemeaddition, it is not known at this time wfor the eastern edge of the DOE retainRefuge boundary between the two. Fa trail along the eastern edge of the siany roadway widening project. 22-8. Prior to full implementation of Refuge, the Service will be obligated related to noxious weeds and revegetRefuge. By focusing staffing and burestoration in the first 5 years, the Serseverity of noxious weed infestationsbefore public trail use would introduclandscape. Objective 2.13 – Recreatiallow for more flexibility in opening 

Rocky Flats National Wildlife Refuge 89 Comments and Responses on the Draft Enviro
Comment 

# Letter #22 continued Respon

22-1222-1322-14

22-9. Thank you for your comment.22-10. The Service has received mixand has concerns about the potential additional weed sources, increased trFor these reasons, the Service’s limitAlternative B is intended to provide a conservative with regard to ecologica22-11. The Service is aware that therand conflicting studies regarding the uses on the environment. As noted, tdata about the effects of recreation traIn preparing the DEIS, the Service wthe context and conditions of specific the Rocky Flats environment. Howevthat are possible as a result of various Section 4.4, appear to be a reasonable effects that may occur, the EIS concluwould result in “localized, long term by appropriate trail maintenance and discussion has been revised to better types of potential effects, and the speresult from the alternatives. 22-12. While there is disagreement icommunity about the extent that recrequestrians in particular contribute to along trails, the Service believes that stated in the EIS, that bicycles and hoand disperse weed seeds. The Bennindescribes observations that noxious walong trails. Other studies have confiService does not find reason to validaarticles that equestrians or any other pless responsible for weed dispersal. Tobservations from the articles cited athe policy intentions or the adequacy other studies.22-13. Mr. Lane has been actively inhas provided useful comments to the 

Rocky Flats National Wildlife Refuge 90 Comments and Responses on the Draft Enviro
Comment 

# Letter #22 continued Respon

22-1522-1622-1722-1822-1922-20

22-14. The use of weed-free hay on through education and outreach. The limited resources and the proximity ohorse users, it would be difficult to enTherefore, the Service believes that emore effective.22-15. The Service acknowledges thecological issue at Rocky Flats in the public use. While natural resource prmanagement, equestrian or bicycle acof the Refuge. The inclusion of equewould be permitted with the stipulatiremove horse manure on a volunteer in the interest of protecting native habdispersal. While the Service recognizhorse manure is indeed a vector for wprotection is a higher priority than eqhas elected to take a conservative appAnother concern about equestrian acchorse manure on trails. Extensive amincrease user conflicts and complaintThis is another reason why equestrian the stipulation that equestrian groups a volunteer basis. 22-16. Weed management would be Refuge management scenario. The Sweed management budget in Alternatachieve the weed reduction targets de22-17. Thank you for your participat22-18. Thank you for your comment22-19. The attached map was reviewconsideration is addressed in the respand 22-7. 22-20. Thank you for your input. 

Rocky Flats National Wildlife Refuge 91 Comments and Responses on the Draft Enviro
Comment 

# Letter #22 continued Respon

Rocky Flats National Wildlife Refuge 92 Comments and Responses on the Draft Enviro
Comment 

# Letter #23 Respon

23-1 23-2 

23-1. Figure 19 and the discussion in been revised to reflect the approval opermit. 23-2. Thank you for your comment.

Rocky Flats National Wildlife Refuge 93 Comments and Responses on the Draft Enviro
Comment 

# Letter #23 continued Respon

23-3 

23-3. Thank you for your comment.

Rocky Flats National Wildlife Refuge 94 Comments and Responses on the Draft Enviro
Comment 

# Letter #23 continued Respon

23-4 23-5 

23-4. Thank you for your comments23-5. The proposed access roads havreasonable access to ditches, utility eproperty rights on the Refuge. The SRanch to ensure reasonable access to 

Rocky Flats National Wildlife Refuge 95 Comments and Responses on the Draft Enviro
Comment 

# Letter #24 Respon

24-1 24-2 24-3 24-4 

24-1. Thank you for your comments24-2. Thank you for your comments24-3. Thank you for your comments24-4. The Service agrees that public positive form of wildlife dependent rwould complement other tools for maObjective 1.6 – Deer and Elk Manag

Hunting Program, have been revised establishment and analysis of target phunting programs, and to clarify that population management tool and a forecreation. The Final CCP/EIS has barchery and shotguns for deer/elk hunuse of muzzle-loading rifles has been safety comments received during the CCP/EIS. 

Rocky Flats National Wildlife Refuge 96 Comments and Responses on the Draft Enviro
Comment 

# Letter #24 continued Respon

24-5 24-6 24-7 24-8 24-9 

24-10

24-5. Noxious weed infestations at Rgreatest natural resource concerns on that philosophical goal of eliminating the 15-year life of the CCP. Howevefor writing management objectives is achievable. To that end, the Service approach to weed reduction resulting 15 years would be achievable, and wbenefits. 24-6. The Service agrees that potentiRefuge land in the headwaters of the adverse impact on the management oand would not be compatible with the NWRS. As the DEIS and FEIS discuSection 3.8, the Service will not accejurisdiction of lands subject to mining the associated mineral rights, or until reclaimed to native grasslands. 24-7. If funding becomes available, tpursuing research and monitoring relchanges related to ongoing mining ac24-8. As part of the DOE’s long-term all monitoring equipment, including gwill remain in place. This applies to will become the Refuge, in addition t24-9. Under the Refuge Act, no portRefuge until the EPA certifies DOE hclosure. The Service is not a decisioncleanup. 24-10. Thank you for your comment

Rocky Flats National Wildlife Refuge 97 Comments and Responses on the Draft Enviro
Comment 

# Letter #25 Respon

25-1 25-2 25-3 25-4 

25-1. Thank you for your comments25-2. Under the Refuge Act, no portRefuge until the EPA certifies DOE hclosure. The FEIS includes additionaissues in Section 1.8. 25-3. All public use would be managsignage, education, and law enforcemproven to be effective at other RefugeIn the DEIS, the Service recommendeDOE retained area be “seamless” witbetween the Refuge and the DOE retaFEIS was revised to indicate that the strand barbed-wire agricultural fence would demarcate the interior property out of the DOE lands, and clarify thato public access. Such a fence would movement of wildlife across the site, obtrusive. The Service has provided RFCA parties. 25-4. The Service believes that surfa

have an adverse impact on the managresources, and would not be compatibRefuge or the NWRS. As the DEIS aMineral Rights of Section 3.8, the Seof administrative jurisdiction of lands United States owns the associated mihave been reclaimed to native grassla

Rocky Flats National Wildlife Refuge 98 Comments and Responses on the Draft Enviro
Comment 

# Letter #26 Respon

26-1 26-2 26-3 

26-1. Thank you for your comments26-2. The proposed trails were carefuPreble’s habitat. To that end, all of thPreble’s habitat would use existing romost would be subject to seasonal cloService believes that these measures, restoration, would not adversely affec26-3. The Service supports the philo100 percent native species compositiocommunities during the 15-year life oService’s guidelines for writing manaobjectives are achievable. To that enincremental approach to weed reductmanagement resulting in a 80 percen15 years would be achievable, and wbenefits. 

Rocky Flats National Wildlife Refuge 99 Comments and Responses on the Draft Enviro
Comment 

# Letter #26 continued Respon

26-4 26-5 26-6 26-7 26-8 26-9 

26-1

0

26-11

26-4. The area identified as “disturbebe restored to mixed grassland prairiebeen revised. 26-5. 

With the exception of the main 

would be accessible to the public for existing roads 

would be converted fo

or non-motorized m

ulti-use trails. Ob

been revised to clarify this point. Othwoul

d be close

d as soon as possible, 

immediately following Refuge establconstraints.26-6. Besides grazing prescri

ptions a

Management (IPM) 

program, intense

may be prescri

bed to restore natural e

instance, cattle wo

uld

be used to em

u

the natural disturbance regi

me requir

Service anticipates that grazing progrtemporary electric fences to manage cattle fro

m Preble’s 

habitat, ri

parian a

habitats such as tall u

pland shrubland 

programs will be designed and managof additional

weeds to t

he Refuge. S

outlined in a step-do

w

n IPM 

plan. 

26-7. The primary purpose of plague for the protection of hu

man safety an

language of O

bjective 1.7 – Prairie D

revised to clarify those priorities. Thco

ntrol prairie dogs to facilitate recre

manage prairie dogs to facilitate resothe protectiveness of clean

u

p facilitie

is a short-grass prairie s

pecies. It wo

to native ecosyste

ms to encourage or 

of sensitive plant comm

u

nities such a

or riparian areas. Although the Servimanagement of DOE retained lan

ds, 

to reduce the potential for prairie dogto i

nvade an

d compromise t

he remed

residual subsurface contamination. 26-8. The Service consulted with C

D

CCP/EIS and discussed the issue of pti

me, CDOW is not in favor of 

pro

ng

Rocky Flats National Wildlife Refuge 100 Com

ments and Responses on the Draft Enviro
Rocky Flats National Wildlife Refuge 101 Comments and Responses on the Draft Enviro

Flats due to a lack of sufficient unfrato highways and urbanized areas. Ththis matter and will not consider proncooperation of CDOW.
Comment 

# Letter #26 continued Respon

26-1226-1326-1426-15

26-9. The Service believes that the efence, which is proposed for all alternto the movement of wildlife. With reimprovements, Section 4.16 includes outlines the Service’s potential concerelated to any transportation improveHighway 128, and Highway 93, and rpotential impacts. 26-10. Thank you for your comment26-11. The CCP/EIS is written under be remediated and certified prior to thThe Service is not a decision-maker ithe EPA and CDPHE have indicated CCP would be safe (Appendix D). Hacknowledges the concerns of many the location and level of residual conbecome the Refuge. For this reason, contamination issues has been added 26-12. While there is common specusignificantly to the spread of weeds, tthere is disagreement within the scienon that point. Recognizing this uncerallow limited equestrian access under Compatibility Determination (Appen26-13. The Service would support opother jurisdictions in matters regardinissues.26-14. The Service is looking forwarfrom a variety of organizations to advresources. 26-15. Thank you for your comment

Rocky Flats National Wildlife Refuge 102 Comments and Responses on the Draft Enviro
Comment 

# 

L

etter #27 Resp

on

27-1 27-2 27-3 27-4 27-5 

27-1. Thank you for your comments27-2. The Service agrees 

with your a

27-3. The purposes of the Refuge ansho

uld be managed are established i

n 

Wildlife Refuge Act of 2001 (AppenRefuge Improvement Act of 1997. Tin section 1.1. The Service desig

ned 

Alternative D, to fulfill the letter and Service disagrees with the assessmeneither “intensi

ve or uncontrolled” rec

of recreatio

nal use would be greater i

co

mpatible with the Refuge purposes 

(Table 14) has shown that the length would be lower than other nearb

y ope

27-4. The EPA and CDPHE have indwill beco

me the Refuge wo

uld

be saf

management activities, including

p

u

b

impacts of 

p

u

blic use on native grass

sensitive natural resources, most of thfrom existing roads. With regard to the delineation of the recommended in the DEIS that the defew o

b

vious visual differences bet

we

retained area. Section 1.8 of the FEIbelieves that a barbed-wire agriculturobelisks woul

d demarcate t

he interior 

livestock out of the DOE lan

ds, and c

closed to public access. Such a fence movement of wildlife across the site, obtrusive. T

he Ser

vice has provided 

RFCA parties. 27-5. The Service agrees that the re-

provide an opportu

nity to avoid addit

that end, 72 % of the proposed trails existing roads. The Service believes and density of Alternative B woul

d b

and p

u

blic use, and does not agree t

h

Rocky Flats National Wildlife Refuge 103 Com

ments and Responses on the Draft Enviro
Rocky Flats National Wildlife Refuge 104 Comments and Responses on the Draft Enviro

Comment 

# Letter #27 continued Respon

27-6 27-7 27-8 27-9 

27-1027-1127-12

“excessive.” As shown in Table 14, would be similar to, or less than otheincluding Jefferson County’s White RBoulder’s Mesa/South Boulder Creek With regard to seasonal off-trail use, potential localized impacts of off-trainot adversely affect vegetation commspecific concerns about residual conthave indicated that any proposed pubwould be safe (Appendix D). In addiareas (Figure 23) are outside of the Dof residual soil contamination (Figure 27-6. With the exception of Service 

purposes, motorized vehicles would ntrails in any alternative. Objective 2.revised to clarify that point. Off-trail pedestrian access only, on a seasonal ground-nesting birds and other wildlirestrictions, the Service does not agrewould be a “sacrifice area,” but ratheopportunity for amateur naturalists, wothers to access their subjects and wopurposes of the Refuge and the NWRThe Service agrees that insects, reptiloften underrepresented in managemethese and other species, the Service hconservation and restoration of native Refuge would benefit the native specincluding microfauna. While such spimpacts analysis, the text relating to “has been revised to be inclusive of al27-7. As explained in response to cowould be open for pedestrian use onlthere are about 55 miles of roads in thRefuge. In Alternative B, about 25 mrevegetated, while another 15 miles oreduced in width to trails. The length would be about 1.5 miles. While the 
Comment 

# Letter #27 continued Respon

27-13

fragment habitats, the extent of propowould be compatible with Refuge goof existing roads would have a net beIn regard to noxious weed impacts, thuse can increase the spread of weed sis common speculation that horses caspread of weeds, the Service also recdisagreement within the scientific and point. Recognizing this uncertainty, equestrian access under the conditionDetermination (Appendix B).27-8. As established in the National Improvement Act of 1997, one of the provide the public with compatible, wWhen it is deemed compatible, this pmembers of the public, not just organbelieves that the level of access presecompatible with the habitat protection best balance resource conservation andependent recreation. 27-9. With the exception of the Lind

historical resources would be remove

There are no structures remaining assnear Woman Creek – in Alternative C to die off over time. 27-10. The Service believes that the not have any significant impacts on nSee responses to comments 27-5, -6, 27-11. The Service agrees with your management and prescribed fire, and 27-12. The Service agrees with your management and the utility of managcomment.27-13. Thank you for your comment

Rocky Flats National Wildlife Refuge 105 Comments and Responses on the Draft Enviro
Comment 

# Letter #28 Respon

28-1 28-2 

28-1. Thank you for your comments28-2. See responses to the specific coRefuge Act, no portions of the site caEPA certifies DOE has completed the Service is required by the Refuge AcDecember 31, 2004. 

Rocky Flats National Wildlife Refuge 106 Comments and Responses on the Draft Enviro
Comment 

# Letter #28 continued Respon

28-3 28-4 28-5 28-6 

28-3. While many of the cleanup decfinalized, the Service has worked clodevelop a plan that is consistent with The CCP/EIS is written under the preremediated and certified prior to the eShould the assumptions regarding the safety of the Refuge land prove incorcleanup documents, the Service woul28-4. See response to comment 28-3maker in matters regarding cleanup, bindicated that all activities proposed iHowever, the Service also acknowledlocation and level of residual contambecome the Refuge. For this reason, discussion of contamination issues in 28-5. In their 2003 letters that are incand CDPHE advise the Service to miwith between 7 and 50 picocuries/grashown in Figure 4, these areas are almthe DOE retained area, and do not cofor public use, scientific research, or activities. Section 3.2 – Geology and discussion of residual soil contamina28-6. The Service believes that both 

Refuge without compromising one andeveloped considering the input and pService biologists, planning team meWildlife, and representatives from lo

Rocky Flats National Wildlife Refuge 107 Comments and Responses on the Draft Enviro
Comment 

# Letter #28 continued Respon

28-7 28-8 28-9 

28-10

28-7. A National Wildlife Refuge is a dictionary definition of a “refuge.” Wildlife Refuge System Improvemenof the NWRS is to provide the public dependent public use. Congress has be provided for if they are compatiblelevel of access presented in Alternatithe habitat protection goals of the Reresource conservation and the provisirecreation. 28-8. The Service disagrees with the 

trails and use of prescribed fire would the threats to species extinction. The use existing roads to the greatest extemost sensitive habitat areas would be addition to using existing roads, most includes reducing the width of the roa(about 8 feet), and restoring the adjoiwidely recognized as an important towould be used to improve the overall communities at Rocky Flats. 28-9. See responses to comments 28Service believes that the limited huntand D are unlikely to affect wildlife v28-10. See response to comments 28

Rocky Flats National Wildlife Refuge 108 Comments and Responses on the Draft Enviro
Comment 

# Letter #28 continued Respon

28-1128-1228-13

28-11. Thank you for your comment28-12. While most of the Refuge arehuman activity in the last 30 to 50 yeconstruction, site management, adjachistorical grazing have left its grasslaare increasingly vulnerable to noxiougrazing, mowing, and prescribed fire grassland restoration tools that, if carnoxious weeds and stimulate native pwould be suppressed, since the use of environment like Rocky Flats would safety than prescribed fire would be. a critical component of any grassland that any management tools would no28-13. See response to comment 28-grazing at Rocky Flats would be hightime, to emulate the effects of grazing native grasslands evolved. This type in the types of ecological damage tha

Rocky Flats National Wildlife Refuge 109 Comments and Responses on the Draft Enviro
Comment 

# Letter #28 continued Respon

28-1428-1528-1628-17

28-14. See response to comment 28-28-15. Thank you for your comment28-16. Due to the extent of noxious w

and the effect that weeds have on natbelieves it would be important to retamanagement tools, including chemicaprescribed fire, biological controls, teand handpulling. Each of these tools reduce noxious weed infestations whenvironmental effects. Often a combweed control. 28-17. The Service is confident in thalong with the Colorado Division of Wpopulations that would be appropriate 

Rocky Flats National Wildlife Refuge 110 Comments and Responses on the Draft Enviro
Comment 

# Letter #28 continued Respon

28-1828-1928-2028-2128-22

28-18. The Service believes that limcompatible with Refuge purposes and provide an additional management to28-19. In Alternative B, the Service expansion to a threshold of 750 acrescolonies currently exist at Rocky Flat

the important role that prairie dogs plis also important to manage prairie doother wildlife species and vegetation expansion of prairie dog colonies wodiversity of grasslands, but an overpothe entire Refuge would threaten the as well as the rare xeric tallgrass comof the Refuge. Alternative B would athe current population size, which the sufficient for a sustainable and dynamAnother reason that the Service intenexpansion of prairie dog colonies is dresidual, subsurface contamination wThe EPA and CDPHE have indicated does not exist in the area that will becDOE will be responsible for the protewithin the portions of the DOE retaincontamination will remain, which incother burrowing animals from accessWhile the Service would not be respomanagement within the DOE retained contamination should not be an issue partner with the DOE it is prudent for sustainable prairie dog population anaway from the retained area. 28-20. Prairie dog populations would barriers, on-site relocation, and other 28-21. In Alternative D, the Service accepting unwanted prairie dogs from alternatives, including the Proposed Aaccept prairie dogs from off site. As 

Rocky Flats National Wildlife Refuge 111 Comments and Responses on the Draft Enviro
Comment 

# Letter #28 continued Respon

28-2328-24

comment 28-19, the Service proposes existing and adjacent prairie dog popecologically sustainable. 28-22. Any outbreaks of plague in prmonitored through the observation of monitoring is relatively simple, as oucolonies are readily and quickly appa28-23. Tissue samples, including ediharvested at Rocky Flats in 2002 havcontaminants. The results of the analsignificant uptake of contaminants by 

Rocky Flats. The EPA and CDPHE hproposed Refuge management objectbe safe for the public. 28-24. Thank you for your comment

Rocky Flats National Wildlife Refuge 112 Comments and Responses on the Draft Enviro
Comment 

# Letter #29 Respon

29-1 29-2 29-3 29-4 29-5 29-6 

29-1. Thank you for your comments29-2. Thank you for your comments29-3. Dogs would not be permitted o29-4. Motorized vehicles would not except for designated parking/access fire access, and access to utility easemmineral rights. Objective 2.2 – Publispecify that motorized vehicles would trails and roads except for the above u29-5. The Service agrees that ecologprotection of the xeric tallgrass ecosyof any Refuge management plan. 29-6. The final configuration of the D

nature of any fencing or structures deRefuge will be decided by DOE and Service is not the final decision-makeService will continue to provide inpuIn the DEIS, the Service recommende“seamless” with few obvious visual dand the DOE retained area. Section 1the Service believes that a four-strand and/or permanent obelisks would demboundary, keep any livestock out of tthe DOE lands are closed to public acadversely affect the movement of wilnot be visually obtrusive. The Servicrecommendations to the RFCA partie

Rocky Flats National Wildlife Refuge 113 Comments and Responses on the Draft Enviro
Comment 

# Letter #29 continued Respon

29-7 29-8 29-9 

29-1029-11

29-7. The Service agrees that the preRanch structures is not necessary to pof the site, or to meet the requiremenend, Alternative C calls for the removinterpretation of the history of the siteacknowledges that there is public intestructures, as well as the visual charaFor that reason, the Service recommeinterpretation of the Lindsay Ranch b29-8. The Service agrees that surface have an adverse impact on the managresources, and would not be compatibRefuge or the NWRS. The Service hnot accept the transfer of administratito mining until the United States ownor until mined lands have been reclai29-9. The Service has expressed that Refuge offices and/or visitor facilitiesuch a museum is established and it iRefuge entrance.29-10. In the Service’s preferred alte

environmental education would be tacollege age students. On-site educatiimplemented after 5 years of Refuge of the Refuge and any ensuing public certification by the EPA that the cleauses would be safe for the public. Clmade by the Service and are outside tdue to public interest and concern, an related issues is included in Section 129-11. Thank you for your comment

Rocky Flats National Wildlife Refuge 114 Comments and Responses on the Draft Enviro
Comment 

# Letter #30 Respon

30-1 30-2 30-3 

30-1. Thank you for your comments 30-2. The Service looks forward to othe Museum, as expressed by Objecti30-3. The establishment of the Cold jurisdiction of the Service and the scothe Service has expressed that it wouoffices and/or visitor facilities with thmuseum is established and it is within entrance. 

Rocky Flats National Wildlife Refuge 115 Comments and Responses on the Draft Enviro
Comment 

# Letter #30 continued Respon

30-4 30-5 30-6 

30-4. See response to comment 30-230-5. The Service appreciates your ethe Lindsay Ranch. As outlined in OResources – Site History, the Service partnership opportunities. 30-6. Thank you for your comments

Rocky Flats National Wildlife Refuge 116 Comments and Responses on the Draft Enviro
Comment 

# Letter #31 Respon

31-1 

31-1. Thank you for your commentsthe letter are part of the administrativ

Rocky Flats National Wildlife Refuge 117 Comments and Responses on the Draft Enviro
Comment 

# Letter #31 continued Respon

31-2 31-3 

31-2. The Service agrees that excerp

National Wildlife Refuge System and National Wildlife Refuge are correctlthe language of the National Wildlife Act of 1997, and the legislative historof the Interior is required to provide tdependent recreation that are the prioSystem, whenever those uses are founpurposes of the refuge and the missioconsistent with public safety. The Seuses proposed in the CCP meet the coand are, hence, required by the NWR31-3. In addition to the response to cnot be established until it is certified proposed activities. 

Rocky Flats National Wildlife Refuge 118 Comments and Responses on the Draft Enviro
Comment 

# Letter #31 continued Respon

31-4 31-5 

31-4. As described in Objective 5.3 – would allow for some level of compaRefuge. Currently, the Service anticiconduct research that has direct implirelated to wildlife, habitat, and public to conduct research on efficient remeof plutonium-contaminated sites. Thsince none of the lands coming to the cleanup. 31-5. The Service is not a decision-mcleanup, and the CCP/EIS is not a cleCDPHE have indicated that all activialternatives would be safe for both RRefuge will not be established until thFor these reasons, issues related to clthe scope of this EIS. However, in reconcern, an expanded discussion of iresidual contamination levels is inclu

Rocky Flats National Wildlife Refuge 119 Comments and Responses on the Draft Enviro
Comment 

# Letter #31 continued Respon

31-6 31-7 31-8 

31-6. The Refuge was established by Flats National Wildlife Refuge Act oService to manage those lands not retcertifies the cleanup is complete. Thwritten in accordance with existing S31-7. The Service is not qualified, mestablish or challenge cleanup standakind. These are the responsibilities owhich have authority over the standarIf the standards change, the five-year require DOE, EPA, and CDPHE to redetermine if additional work needs to liability for any residual contaminatio31-8. See response to comment 31-7sometimes higher than standards for that most of the buffer zone and the aRefuge is below the CDPHE standard range for soil is between 0.04 and 0.0value of 0.066 pCi/g for the backgrouto construct a residential building for sampling would be needed and the reapproval before such a building is coalternatives in the CCP include reside

Rocky Flats National Wildlife Refuge 120 Comments and Responses on the Draft Enviro
Comment 

# Letter #31 continued Respon

31-9 

31-10

31-9. Site characterization is the respoversight by the EPA and CDPHE.31-10. See response to comment 31-would be voluntary.

Rocky Flats National Wildlife Refuge 121 Comments and Responses on the Draft Enviro
Comment 

# Letter #31 continued Respon

31-1131-1231-1331-1431-1531-1631-17

31-11. Thank you for your comment31-12. Public use would be minimiz31-13. The EPA and CDPHE have inRefuge activities, in all of the proposboth Refuge workers and the general 31-14. The EPA and CDPHE have inRefuge management activities, includsafe. However, in response to concerthe Service does not propose using prportion of the Refuge between WalnuCreek to the south (Figure 8).31-15. The Service believes limited compatible with the purposes and mabe a compatible form of wildlife depeRefuge, and would provide an additioand elk populations. The safety of pawould be a primary consideration in tthe proposed hunting program.31-16. Off-trail, pedestrian use woulon Figure 23. These areas would be area, and would not contain any instisite cleanup.31-17. In the DEIS, the Service recobe “seamless” with few obvious visuRefuge and the DOE retained area. TService believes that a four-strand baand/or permanent obelisks would demboundary, keep any livestock out of tthe DOE lands are closed to public acadversely affect the movement of wilnot be visually obtrusive. The Servicrecommendations to the RFCA partie

Rocky Flats National Wildlife Refuge 122 Comments and Responses on the Draft Enviro
Comment 

# Letter #31 continued Respon

31-1831-1931-20

31-18. The Refuge would include sighistory of the site, the location and naand relative risks associated with the 31-19. The EPA and CDPHE have inbecome the Refuge will be safe for alincluding scientific research. The cobecome the Refuge are currently safe require any response actions. For thewould not be required in the areas tha31-20. The proposed action, Alternastation rather than a full visitor’s centService has expressed that it would pand/or office facilities with the Cold is established and it is within close pr

Rocky Flats National Wildlife Refuge 123 Comments and Responses on the Draft Enviro
Comment 

# Letter #32 Respon

32-1 32-2 

32-1. Thank you for your comments32-2. Under the Refuge Act, no portRefuge until the EPA certifies DOE hclosure. The CCP/EIS is written under the preremediated and certified prior to the ethe establishment of the Refuge will nthe human environment. If post-cleaassumption, the cleanup will not be cbe established.In response to public interest and conthe FEIS includes an expanded discuof residual soil contamination levels effects of Refuge activities on those sadditional information demonstrates including the health of Refuge workepublic, have been considered throughBased on the cleanup assumptions thestablishment, as well as the levels of lands that will become the Refuge, thand CDPHE that the proposed Refugsignificant effect on the quality of the 

Rocky Flats National Wildlife Refuge 124 Comments and Responses on the Draft Enviro
Comment 

# Letter #32 continued Respon

32-3 

32-3. An expanded discussion of conlevels is included in Section 1.8. The standards is inclusive of all persons, iinfirm. The erosion or dispersion of soil by wconcern in the areas that will become contamination levels in most of those extremely low (below 1 pCi/g) (none lands to become the Refuge would be standard at Rocky Flats is 50 pCi/g). area to become the Refuge are currencleanup) to not require any response any areas where residual contaminaticoncern due to erosion.

Rocky Flats National Wildlife Refuge 125 Comments and Responses on the Draft Enviro
Comment 

# Letter #32 continued Respon

32-4 32-5 

32-4. The timing of the Comprehensprocess was directed by Congress in been in continued contact with the Dprocess and has been apprised of the lands that will be retained by DOE fostewardship. While the exact boundaRefuge establishment, the Service is of the lands and resources that will be change. For these reasons, the Servicreasonable and effective to complete post-cleanup conditions change the Swill be revised accordingly. 32-5. See response to comment 32-2

Rocky Flats National Wildlife Refuge 126 Comments and Responses on the Draft Enviro
Comment 

# Letter #32 continued Respon

32-6 32-7 32-8 32-9 

32-1032-1132-1232-1332-1432-1532-1632-1732-1832-19

32-6. See response to comment 32-232-7. As indicated in response to comdispersion will not be a concern in thRefuge. 32-8. In the DEIS, the Service recombetween the Refuge and the DOE retfew obvious visual differences. Sectithat the Service believes that a four-sfence and/or permanent obelisks wouproperty boundary, keep any livestocclarify that the DOE lands are closed would not adversely affect the movemand would not be visually obtrusive. recommendations to the RFCA partieThe Service will provide signs and dithe site, the location and nature of resrelative risks associated with the Refu32-9. The EPA and CDPHE have indcontamination does not exist in the arThe DOE will be responsible for the facilities within the portions of the Dsubsurface contamination will remainprairie dogs or other burrowing animcontamination. While the Service widogs within the DOE retained area, acontamination should not be an issue partner with the DOE it would be prua sustainable prairie dog population aaway from the DOE retained area. 32-10. As directed by the Refuge Acjurisdiction over any response actionlong-term monitoring that is required addressed in response to comments 3become the Refuge is currently clean response actions and will include onlof human health on the Refuge. 

Rocky Flats National Wildlife Refuge 127 Comments and Responses on the Draft Enviro
Comment 

# Letter #32 continued Respon

32-2032-2132-22

32-11. The proximity to a Superfund area will not appreciably affect the mService will continue to work with thmonitoring, and coordinate habitat memergency response. 32-12. See response to comment 32-32-13. See responses to comments 332-14. The lands that will become th

cleanup, because contamination levelretain all of the areas that will be actisubject to long-term monitoring. 32-15. See responses to comments 332-16. See response to comment 32-32-17. See responses to comments 332-18. See response to comment 32-32-19. The Service does not believe population size at which the deer popWhile the Service considers the deer they are part of a larger management based on habitat conditions and other Service proposes to establish a target guide wildlife and habitat managemewould be used as a management tool populations. Hunting also would be be compatible with the purposes and Objective 1.6 – Deer and Elk Manag

Hunting Program, have been revised establishment and analysis of target phunting programs, and to clarify that population management tool and a forecreation. With regard to the consumption of deincluding edible meat tissues, of deer 2002 have been analyzed for contamianalysis indicate that there is no signiby deer or other wildlife species at R

Rocky Flats National Wildlife Refuge 128 Comments and Responses on the Draft Enviro
Rocky Flats National Wildlife Refuge 129 Comments and Responses on the Draft Enviro

Comment 

# Letter #32 continued Respon

32-20. See response to comment 32-32-21. See response to comment 32-indicated that all of the proposed Refincluding prescribed fire, would be saresponse to concerns about residual cnot propose using prescribed fire on tbetween Walnut Creek to the north an(Figure 10). 32-22. See response to comment 32-
Comment 

# Letter #33 Respon

33-1 

33-1. Thank you for your comments

Rocky Flats National Wildlife Refuge 130 Comments and Responses on the Draft Enviro
Comment 

# Letter #33 continued Respon

33-2 33-3 

33-2. Thank you for your comments33-3. Thank you for your comments

Rocky Flats National Wildlife Refuge 131 Comments and Responses on the Draft Enviro
Comment 

# Letter #34 Respon

34-1 34-2 34-3 34-4 

34-1. Thank you for your comments34-2. The Service has recommended version of Alternative B. 34-3. The Service believes that limitcompatible with the purposes and mathat it would provide an additional mpopulations. Objective 1.6 – Deer an

Objective 2.10 – Hunting Program, h

correlate the establishment and analypublic hunting programs, and to clariboth a population management tool apublic recreation. 34-4. As described in Section 1.9 FuHunting Plan would be a component Colorado Division of Wildlife would development of a Hunting Managemeimplementation of the hunting progra

Rocky Flats National Wildlife Refuge 132 Comments and Responses on the Draft Enviro
Comment 

# Letter #34 continued Respon

34-5 34-6 34-7 34-8 34-9 

34-1034-11

34-5. The Service agrees that aggresincluding the development and impleManagement Plan, should be an impoAlternative B includes the Services mmanagement objectives and strategie34-6. The Service acknowledges tha

component of the prairie ecosystem bcommunity structure and ecosystem falso agrees with the Wildlife Manageunsustainable growth of prairie dog cmanaged to prevent adverse impacts for restoration of degraded habitats, odogs into the DOE retained area. 34-7. Anticipated funding levels do nand the highest levels of habitat restoHowever, the Service believes that thAlternative B will be sufficient to prowildlife habitat on the Refuge. 34-8. The Service acknowledges the research opportunities on the Refugeopportunities. 34-9. As described in Section 4.4 of facilities, including public use and meffect 1.1 acres of the Refuge. The Sof a management presence on-site ounecessary facilities would have on ReRefuge would be part of the Rocky MWildlife Refuge complex, the necesswould be limited to the needs of on-simpacts would be minimized by co-lopublic use facilities, and by constructare already disturbed or degraded, anwildlife habitat. Objective 6.2 – OpeFacilities has been revised to include disturbances. The Service has expresRefuge offices and/or visitor facilitieMuseum, if such a museum is establithe Refuge entrance. 

Rocky Flats National Wildlife Refuge 133 Comments and Responses on the Draft Enviro
Rocky Flats National Wildlife Refuge 134 Comments and Responses on the Draft Enviro

Comment 

# Letter #34 continued Respon

34-10. In accordance with the Servic

those management objectives pertainmanagement and protection would taactivities. 

34-11. Thank you for your comment
3. Responses to Individual Comments

This section includes general responses to individual comments, listed by the comment number in

the following table. Each individual’s comments are characterized in the following table

(Individual Comments on the Draft CCP/EIS). Responses to substantive comments or comments

that asked for specific clarification on the CCP/EIS begin on page 140. While the Service

appreciates comments supporting the Refuge or individual components of the CCP/EIS, these

comments are not substantive and are not included in the responses.

HOW TO FIND RESPONSES TO INDIVIDUAL COMMENTS

x Comments are organized by topic in the following table. Find the appropriate number for

the comment.

x Numbers identified with a “*” are considered to be substantive. Only substantive

comments have responses.

x Look up the numerical code for the substantive comment/issue of interest, beginning on

page 140, to find the comment and the Service’s response.

PUBLIC COMMENTS BY ISSUE

Substantive comments are indicated with an “*” and are responded to in the following pages. The

number of comments received does not include petitions and form letters, which are addressed in

Chapter 4.

Comment Number of Comments

1000 Purpose and Need

1000 Purpose and Need

1005 Requests additional information regarding why Refuge is needed 2 <1%

1006 Supports Refuge designation 11 4%

1007 Does not support Refuge designation 9 3%

1010 Comment about legal and policy guidance 8 3%

1011 Comment that the Service should amend national policies 2 <1%

to manage contaminated sites

1020 Comment about Refuge Vision and Goals 3 <1%

2000 Alternatives

2000 Alternatives

2001 General comment about alternatives 1 <1%

2002* Specific comment about alternatives 4 1%

2100 Alternative Preference

2101 Comment in support of Alternative A 37 12%

Comments and Responses on the Draft Environmental Impact Statement 135
2102 Comment in support of Alternative A, with modifications 2 <1%

2104 Comment in support of Alternative B (See also Form Letters) 68 22%

2105 Comment in support of Alternative B, with modifications 16 5%

2107 Comment in support of Alternative C 18 6%

2108 Comment in support of Alternative C, with modifications 4 1%

2110 Comment in support of Alternative D 3 <1%

2111 Comment in support of Alternative D, with modifications 1 <1%

2150 Public Use Objectives

2151 General comment about public use programs (See also Form Letters) 1 <1%

2152* Specific public use comment 19 6%

2153* Specific comment: "Keep Rocky Flats closed" (See also Form Letters) 11 4%

2154* Comment opposed to public access/use (See also Form Letters) 102 33%

2155 Comment supporting public use 33 11%

2156* Comment suggesting longer time frame for public use 15 5%

2157* Comment suggesting shorter time frame for public use 3 <1%

2158* Comment opposing hunting program (See also Form Letters) 24 8%

2159 Comment supporting hunting program 21 7%

2160* Comment proposing model glider use on Refuge 6 2%

2161 Comment about types of permitted access/uses 9 3%

2162* Suggested revisions to public use programs 1 <1%

2163* General comment about trail and facility configuration 7 2%

2165* Comment suggesting north-south trail on east side of Refuge 7 2%

2166 Comment suggesting north-south trail along west access road 3 <1%

2167* Comment suggesting north trail connection to City of 5 2%

Boulder/Boulder County trails

2168* Other suggested revisions to trail and facility configuration 7 2%

2169 Comment supporting equestrian access and facilities 11 4%

2170 Comment supporting regional trail connectivity 10 3%

2171* Comment that visitors should be required to sign 3 <1%

informed consent statement

2172* Comment opposed to use as a playground/play area for children 2 <1%

2173 General comment about Visitor Center 1 <1%

2174 Comment supporting Visitor Center at Refuge 8 3%

2175* Comment opposing equestrian access to Refuge 5 2%

2176* Comment opposed to off-trail use 2 <1%

2200 Education and Interpretation Objectives

2201 General comment about education and interpretation programs 1 <1%

2202* Specific comment about education and interpretation programs 1 <1%

2203 Comment supporting proposed education and interpretation programs 3 <1%

2204* Comment opposing proposed education and interpretation programs 1 <1%

2205* Comment supporting signs or other means of conveying 13 4%

history of Rocky Flats

2206* Suggested revisions to education and interpretation programs 1 <1

 2207* Comment suggesting/supporting expanded education programs 5 2

2210 Habitat Management Objectives

2211 General comment about habitat management 5 2%

136 Rocky Flats National Wildlife Refuge
Responses to Individual Comments

2212* Specific comment about habitat management 4 1%

2213* Comment about habitat restoration 18 6%

2214* Comment opposing the use of prescribed fire 11 4%

2215 Comment supporting the use of prescribed fire 11 4%

2216* Comment opposing the use of managed grazing 5 2%

2217 Comment supporting the use of managed grazing 6 2%

2218 Comment about weed management 16 5%

2221* Comment advocating for minimal habitat fragmentation 2 <1%

2226 Comment supporting revegetation of unused roads 5 2%

2230 Wildlife/T&E Species Objectives

2231 Comment about wildlife management 8 3%

2232* Specific comment about wildlife or T&E management 4 1%

2233 Comment about Preble's habitat management 1 <1%

2235 Comment about prairie dog management 6 2%

2236* Comment questioning the need to restrict prairie dog expansion 2 <1%

2237* Comment supporting prairie dog relocation from off site 6 2%

2238* Comment opposing prairie dog relocation from off site 2 <1%

2239* Comment that all living things, including wildlife, 6 2%

should be excluded from site

2240 General comment about species reintroduction 2 <1%

2242 Question the need for culling 2 <1%

2250 Safety Objectives

2251 General comment about safety objectives 1 <1%

2254* Concern about safety signage 2 <1%

2260 Communication, Partnerships, and Research Objectives

2261 General comment about communication, partnerships, and research 1 <1%

2263* Comment suggesting a shared-use facility with Cold War Museum 6 2%

2264 Comment supporting coordination with local jurisdictions/agencies 6 2%

2265 Comment supporting ongoing research on Refuge 1 <1%

2266 Comment about partnerships 1 <1%

2280 Cultural Resource Objectives

2282* Specific comment about cultural resource objectives 3 <1%

2284 Comment supporting removal of Lindsay Ranch structures 2 <1%

2285* Comment opposing removal of Lindsay Ranch structures 2 <1%

2286* Comment requesting Native American reburial access 1 <1%

2290 Fencing

2291* General comment about fencing 1 <1%

 2293 Comment in support of proposed barbed wire boundary fence 1 <1%

2294* Comment proposing security fence at Refuge boundary 19 6%

(See also Form Letters)

2300 Staffing and Budgets

2301 General comment about staffing and budgets 1 <1%

2302* Specific comment about staffing and budgets 2 <1%

2310 Comment supports proposed staffing and budget 1 <1%

Comments and Responses on the Draft Environmental Impact Statement 137
2320* Comment that proposed staffing and budget are insufficient 6 2%

2400 Reasonably Foreseeable Activities

2402* Specific comment about reasonably foreseeable activities 6 2%

2410* Comment about adjacent urban development 6 2%

2431* General comment about mineral rights and mining 1 <1%

2432* Comment about the recognition of private rights to minerals 2 <1%

2433* Comment supporting federal acquisition of private mineral rights 3 <1%

2434* Comment about reclamation of mined lands 1 <1%

2435* Comment about private utility, ditch, and pond access 3 <1%

2443 Comment about other open space and trails 6 2%

2444* Comment about regional open space conservation 8 3%

2450 General comment about Cold War Museum 2 <1%

2451* Comment suggesting the protection of wildlife corridors 4 1%

3000 Affected Environment and Environmental Consequences

3050 Soils

3052* Specific comment about soils 1 <1%

3053 Relevant comment about residual soil contamination levels 3 <1%

3054* Concern that recreational activities could re-suspend residual 9 3

soil contamination

3055* Concern that prescribed fire could re-suspend residual soil 1 <1%

contamination

3060* Concern about the effect of prairie dogs or other burrowing 12 4%

animals on contaminated soils

3100 Water Resources

3102* Specific comment about water resources 1 <1%

3110* Concern about surface water quality 2 <1%

3200 Vegetation Communities

3201 General comment about vegetation communities 2 <1%

3202* Specific comment about impacts to vegetation communities 4 1%

3240* Concern about weed management 3 <1%

3260* Concern about impacts of public use/facilities on vegetation 3 <1%

3261* Concerned that trails will excessively impact riparian habitat 1 <1%

3262* Concern about the impacts of off-trail use 2 <1%

3263* Concern about habitat fragmentation due to trails 1 <1%

 3300 Wildlife

3302* Specific comment about wildlife 3 <1%

3303* Comment about the effects of residual soil contamination on wildlife 3 <1

3304* Comment about the analysis of deer tissue 1 <1%

3311* Concern about impacts to mule deer 1 <1%

3312* Concern about impacts to raptors 1 <1%

3330* Concern about impact of trails and facilities on wildlife 6 2%

3340 Concern about cumulative impacts on wildlife 1 <1%

3341 Comment about deer tissue analysis 1 <1%

138 Rocky Flats National Wildlife Refuge
Responses to Individual Comments

3500 Cultural Resources

3501 General concern about cultural resources 1 <1%

3600 Recreation and Trails

3610* Concern about public use risk from prairie dog diseases 1 <1%

4000 Draft Compatibility Determinations

4000 Compatibility Determinations

4002* Specific comment about compatibility determinations 1 <1%

4010* General comment about hunting CD 3 <1%

4011* Believes that hunting is not compatible at the Refuge 2 <1%

5000 Issues outside of Scope of EIS

5010 Memorandum of Understanding 2 <1%

5020 DOE Retained Area 42 14%

5030 Site Characterization (See also Form Letters) 71 23%

5031 Comment about the uptake of contamination by plants 1 <1%

5040 Cleanup Standards/Risk Assessment (See also Form Letters) 60 19%

5050 General Cleanup (See also Form Letters) 90 29%

5051 Comment that the entire site should be fenced off and paved over 5 2%

or capped

 5060 Long-term Monitoring and Stewardship 19 6%

5061 Comment supporting additional research on effects of 12 4%

contamination on wildlife and plants (See also Form Letters)

5062 Comment favoring ongoing research on cleanup technologies

(See also Form Letters) 3 <1%

5070 Potential Health Effects (See also Form Letters) 31 10%

5080 Cleanup principles/approach (See also Form Letters) 30 10%

5090 Contamination History 55 18%

6000 Comments about process

6000 CCP/EIS process

6011 General comment about CCP/EIS process 3 <1%

6012* Specific comment about CCP/EIS process 2 <1

6020* Comment about NEPA process 7 2%

6030 Comment about agency consultation and coordination 1 <1%

6040 Comment about public process 11 4%

6302* Specific comment about CCP/EIS 5 2%

6303* Comment that the Service appears to have already made its decision 10 3%

6304* Suggested changes to maps 2 <1%

6100 Scoping Process

6110 Comment on the format of public scoping meetings 3 <1%

6300 Draft CCP/EIS

6301 Comment about Draft CCP/EIS document 8 3%

6303 Comment that the CCP/EIS appears to be pre-decisional 10 3%

6310 Comment about public hearings on Draft CCP/EIS 3 <1%

Comments and Responses on the Draft Environmental Impact Statement 139
1000 – PURPOSE AND NEED

Some of the comments addressed issues about the general purpose of National Wildlife Refuges,

the designation of this particular Refuge, and Service policies governing Refuge management.

None of these comments were deemed substantive because they did not specifically address the

Draft CCP/EIS and dealt with issues that are outside of the scope of this CCP/EIS. Other

comments about the vision and goals for the Refuge were noted, but are not responded to because

they supported rather than questioned the vision and goals for the Refuge.

2000 – ALTERNATIVES

COMMENT 2002: SPECIFIC COMMENT ABOUT ALTERNATIVES

2002a: Only Alternatives A and C will enable the preservation of the rare and imperiled species

and biological communities that have made the land worthy of Wildlife Refuge status.

Response 2002a: The Service believes that Alternatives B and D also would facilitate the

protection of rare and imperiled species. Public use facilities were designed to avoid and

minimize impacts to sensitive habitat areas. Due to a lack of pro-active management capacity,

the Service believes that Alternative A provides the least protection to sensitive biological

communities on the Refuge.

2002b: Please come up with a 5th alternative that reflects no public access.

Response 2002b: As described in Section 2.9 – Alternative Considered But Eliminated, a

“custodial management” alternative, with no access by the public, was considered during the

planning process, but was eliminated. Alternative A, the No Action Alternative, would not

change the existing public uses, which is public access by pre-arranged, guided tours only.

2002c: Use the less pre-disturbed land as a complete wildlife refuge with no public access, while

you use about 5% of the land for educational purposes, and a ranger station.

Response 2002c: All of the public use facilities would have minimal environmental impacts, and

existing roads and disturbed areas would be used to the greatest extent possible. Public use

facilities in Alternative B would encompass less than 1% of the total Refuge area.

2150 – PUBLIC USE OBJECTIVES

COMMENT 2152: SPECIFIC PUBLIC USE COMMENT

2152a: Voice control access for dogs would be nice, or off-leash dog areas.

Response 2152a: Dogs would not be permitted on the Refuge in any alternative.

2152b: Dogs should be on leash.

Response 2152b: Dogs would not be permitted on the Refuge in any alternative.

2152c: Considering the extent of groundwater contamination at the Flats, fishing is probably

not a wise idea.

Response 2152c: DOE would retain most of the ponds at Rocky Flats for long-term monitoring.

The Lindsay Ponds on Rock Creek are not contaminated, and would be managed for native fish

restoration. Recreational fishing would not be permitted anywhere on the Refuge.

2152d: Since the biodiversity of the site is very sensitive to disturbance, public uses are not

compatible with the mission of the National Wildlife System Administration Act, and should be

denied.

Response 2152d: Proposed public use facilities have minimal environmental impacts on

biological resources, while proposed restoration efforts would enhance those resources. The

Service believes that the proposed public uses are compatible with the Refuge purposes and the

mission of the NWRS.

2152e: I would like to see some restrictions on the mileage and usage of the proposed trails.

140 Rocky Flats National Wildlife Refuge
Responses to Individual Comments

Response 2152e: Trails in the Rock Creek area would be restricted to seasonal use, in order to

protect environmental resources. The trail density in Alternative B would be less than many of

the other open space areas in the region (Table 14).

2152f: If there are no studies or other evidence (other than guesswork) indicating the need for

culling, the FWS should let the mountain lions, coyotes, and the occasional bobcat do their jobs

and keep the (deer) population in check.

Response 2152f: Culling by CDOW or Service staff would not be used unless deemed

necessary to control populations and protect habitat. A limited hunting program is proposed in 

Alternative B, which would provide a compatible wildlife dependent recreational activity and

would also be a population management tool. Public hunting would be managed so population

levels would not be adversely affected, and would be used as a population management tool

before culling is considered.

2152g: Equestrian use – a twice a month clean up is the contingency – via what means?

Response 2152g: The Draft Compatibility Determination for Alternative B stipulates that

equestrian use would be contingent on volunteer service agreements with equestrian user

groups to remove horse manure. Specific methods would be subject to future planning.

2152h: No horses...Horses damage the ecosystems by increasing erosion and they cause the

spread of weeds through their scat.

Response 2152h: While there is disagreement in the scientific and recreation communities

about the extent that equestrian use is responsible for erosion and the spread of weeds, the

Service has taken these issues into careful consideration. In Alternative B, equestrian use

would be limited to a portion of the trails with a stipulation that manure is picked up by user

groups. The Service believes that, with these restrictions, limited equestrian use would not

result in significant erosion or weed dispersal.

2152i: You shouldn’t allow hunting if the population is getting too low.

Response 2152i: The proposed hunting programs would be limited, and would not be allowed

to adversely affect population levels.

2152j: I note no opportunities for waterfowl hunting in the documents, but short and tall grass

prairie environments are great opportunities for a planted bird scenario for upland game.

Response 2152j: Most of the ponds at Rocky Flats will be retained by the DOE for long-term

monitoring, and are not suitable for waterfowl hunting. There is not an upland bird population

at this time that is suitable for hunting, and the Service is not proposing to establish one for the

purposes of providing hunting. Hunting opportunities that are proposed for the Refuge would

be highly managed for the purposes of maintaining target deer and elk populations and the

provision of wildlife dependent recreation.

2152k: The document forbids the presence of dogs in all alternatives. That is unfortunate as

trained hunting dogs would be likely more under control.

Response 2152k: The Service does not believe that dogs would be compatible with the Refuge,

as they may pose unnecessary environmental impacts and would not be needed for the

proposed hunting program.

2152l: I suggest that the buildings (at the west entrance) could be used as an office/visitor

center and could eventually be provided with more municipal type utilities.

Response 2152l: The buildings at the west entrance are privately owned, and are currently

leased by DOE. The Service has expressed an interest in co-locating Refuge offices and/or

visitor facilities with the proposed Cold War Museum, if such a museum is established within

close proximity to the Refuge entrance.

2152m: I cannot find any statement regarding closures of, or restricted use of the off-trail area

during nesting season.

Response 2152m: Objective 2.2 – Public Access stipulates that off-trail use would be

prohibited, except between October and April.

Comments and Responses on the Draft Environmental Impact Statement 141
2152n: Plan B will allow many visitors. How will water be provided?

Response 2152n: Potable water for Refuge operations and visitors would be imported to the

Refuge by truck, and stored in an on-site cistern.

2152o: We’d like to see you allow equestrians on the main trail that goes along the northeast

corridor.

Response 2152o: The Service has received mixed support for equestrian access and has

concerns about the potential ecological impacts related to additional weed sources, increased

trail erosion, and user conflicts. For these reasons, the Service’s limitation of equestrian access

in Alternative B is intended to provide a separation of uses and to be conservative with regards

to ecological impacts.

COMMENT 2153: SPECIFIC COMMENT: “KEEP ROCKY FLATS CLOSED”

(Specific language from Form Letter A, or individual comments using the text of Form Letter A.)

Response 2153: This comment was made in the context of site cleanup issues that predicate

Refuge management and is out of scope of the CCP/EIS. It is clear that the comment opposes

public access or use of the Refuge, the response to which is addressed by comment 2154.

COMMENT 2154: COMMENT OPPOSED TO PUBLIC ACCESS/USE

(Comment generally made in reference to contamination issues, though some commentors were concerned about

the impacts of public use on wildlife and habitat quality.)

Response 2154: The draft CCP includes four alternatives ranging from maintaining the

existing minimal guided public access (Alternative A) to extensive open public use opportunities

(Alternative D). The National Wildlife Refuge System Improvement Act outlines six priority

public uses to be considered on refuges if they are determined to be compatible. Several of

these uses, including hunting, wildlife observation and photography, and environmental

education and interpretation are proposed in the draft CCP. As described in the Final

Compatibility Determinations in the FEIS for Alternative B, hiking and access by bicycles or

horses is considered to be a means of access by which visitors can engage in the priority public

uses.

The environmental consequences of public access to the Refuge are anticipated to be minor to

moderate, with the exception of some trail configurations in Alternative D, which may have

major localized impacts to some wildlife species. The Service believes that the low level of

anticipated impacts from public use facilities in Alternative B, the proposed action, would be an

acceptable consequence of providing priority public uses.

In regards to concerns about residual contamination, the implementation of any alternative is 

predicated by the completion and certification by the EPA and CDPHE that the cleanup is

sufficient to ensure the safety of any proposed public uses on the Refuge. An expanded

discussion of issues related to cleanup and residual soil contamination is included in Section 1.8.

COMMENT 2156: COMMENT SUGGESTING LONGER TIME FRAME FOR PUBLIC USE

(Comment generally made in reference to contamination issues, or concerns about the impacts of public use on 

wildlife and habitat quality.)

Response 2156: The Service believes that 5 years would be a reasonable time frame to expand

proposed public access beyond the Lindsay Ranch trail in Alternative B. Delaying extensive

public use for 5 years would allow for initiation of restoration of roads and disturbed areas,

continued noxious weed control, and continued monitoring of the effects of public use on

vegetation and wildlife. DOE also would complete it’s first 5-year review of post-cleanup

monitoring with the EPA and the CDPHE. The Service would take an adaptive approach to

facility development and access, and would extend the timeframe for Refuge-wide facility

142 Rocky Flats National Wildlife Refuge
Responses to Individual Comments

development if new information suggests that it would be prudent to do so. Specific concerns

about contamination issues are addressed in Section 1.8 of the FEIS.

COMMENT 2157: COMMENT SUGGESTING SHORTER TIME FRAME FOR PUBLIC USE

Response 2157: The Service appreciates the interest from some members of the public to both

access the Refuge itself and use enhanced regional trail connections across the Refuge.

However, the Service is also obligated to address ecological concerns related to noxious weeds

and the revegetation of unused roads on the Refuge. By focusing staffing and budgetary

resources on habitat restoration in the first 5 years, the Service would be able to reduce the

severity of noxious weed infestations, and initiate road restoration before public trail use would

introduce a new disturbance onto the landscape.

COMMENT 2158: COMMENT OPPOSING HUNTING PROGRAM

(Commentors were generally opposed to hunting in general, public hunting on the Refuge as a management tool,

or had concerns about the safety of hunting at Rocky Flats.)

Response 2158: The National Wildlife Refuge System Improvement Act established hunting as

a priority public use if it is compatible with the Refuge purposes. The Service believes that a

limited, highly managed hunting program would be a form of wildlife dependent recreation on

the Refuge, and would complement other tools for managing ungulate populations, if necessary.

As described in the Final Compatibility Determinations in the FEIS for Alternative B, the

proposed hunting program is compatible with the Refuge purposes. Objective 1.6 – Deer and

Elk Management, and Objective 2.10 – Hunting Program have been revised to better correlate

the establishment of target populations with the hunting program. In addition, in the interest

of safety, the Service has made modifications to the type of weapons that would be allowed.

COMMENT 2160: COMMENT PROPOSING MODEL GLIDER USE ON REFUGE

Response 2160: The Service does not believe that model glider use would be compatible with

the purposes of the Refuge or the NWRS. Consequently, model glider use was not

incorporated into any of the alternatives.

COMMENT 2162: SUGGESTED REVISIONS TO PUBLIC USE PROGRAMS

2162a: [Prefer that] visitors will remain under the supervision of Refuge staff so no one harms

animals.

Response 2162a: The Service is confident that visitors engaging in unsupervised, wildlifedependent recreation on the Refuge would not adversely impact individual animals or wildlife

populations. Wildlife harassment is against Service policies and would be addressed

appropriately.

COMMENT 2163: GENERAL COMMENT ABOUT TRAIL AND FACILITY CONFIGURATION

(Generally concerned about environmentally sensitive trail design, and the overall magnitude of trails.)

Response 2163: In all alternatives, the Service designed a trail system that would avoid

sensitive habitat and minimize impacts to the environment. Existing roads would be used for

trails to the greatest extent possible, and trails through sensitive habitat areas would subject to

seasonal closures. The trail density in Alternative B would be less than many of the other open

space areas in the region (Table 14).

COMMENT 2165: COMMENT SUGGESTING NORTH-SOUTH TRAIL ON EAST SIDE OF REFUGE

(Such a proposed trail exists in Alternative D, but not in Alternative B.)

Response 2165: The Service considered the addition of a north-south trail along the east side of

the Refuge, and has elected to not add such a trail to Alternative B. For several reasons, the

proposed action does not include such a trail. These reasons include uncertainties surrounding

Comments and Responses on the Draft Environmental Impact Statement 143
the potential transfer of land along Indiana Street for regional transportation improvements,

the desired level of trail facilities that would be consistent with the Service’s goal of balancing

habitat protection and public use, and public perceptions and concerns about contamination

issues.

The Service will continue to work with adjacent jurisdictions to encourage the establishment of

trails that compliment the Refuge trails system in Alternative B. In addition, the Service will

consult with CDOT and other agencies to incorporate trail connections into any future

transportation improvements, and to mitigate the effects of those improvements on the Refuge.

COMMENT 2166: COMMENT SUGGESTING NORTH-SOUTH TRAIL ALONG WEST ACCESS ROAD

(Comment proposes a separated trail, about 3⁄4 miles long, to ensure the safety of trail users by separating them

from motorists.)

Response 2166: The Service has added to Alternative B and D a north-south trail adjacent to

the access road between the south multi-use trail and the visitor contact station.

COMMENT 2167: COMMENT SUGGESTING NORTH TRAIL CONNECTION TO CITY OF

BOULDER/BOULDER COUNTY TRAILS

Response 2167: The Draft CCP/EIS acknowledges that there is no proposed connection

between trails in the Rock Creek portion of the Refuge, and the existing and proposed trails to

the north of the Refuge along Highway 128. The rationale for not completing this connection is

that the Rock Creek drainage is the most ecologically sensitive portion of the Refuge, and

would only support seasonal, hiking-only trails. A multi-use through trail in this area would

hamper the Service’s ability to manage access and seasonal closures. In addition, a trail

connection to the north would need to ascend steep slopes below Highway 128, and would

compromise the Service’s ability to manage trail access and use in the sensitive Rock Creek

drainage. Other constraints to a trail connection in this area includes the potential for

expanded mining operations, and safety issues related to the adjacent National Wind

Technology Center.

COMMENT 2168: OTHER SUGGESTED REVISIONS TO TRAIL AND FACILITY CONFIGURATION

2168a: I would suggest that an ADA mounting ramp be included with trailhead parking plans.

Response 2168a: The Service has added a handicap-accessible mounting ramp to the proposed

facilities at the visitor contact station in Alternatives B and D.

2168b: Include equestrian use for both north and south area trails.

Response 2168b: The Service’s limitation of equestrian access in Alternative B is intended to

provide a separation of uses, and to take a conservative approach to the potential ecological

impacts of equestrian use.

2168c: Historically, it would be very fine to have at least part of one of the trails utilize

segments of the (historical railroad grade)... a good segment candidate is in the minor

drainageway northwest of Lindsay Pond #2.

Response 2168c: The historical railroad grade was considered during the trail planning

process, but it was determined that grade does not run in an orientation where trail access is

needed or desired.

2168d: My concern is the implication that horses or their riders are in some way more

damaging or disturbing to the wildlife environment or other uses than bicyclists or pedestrians

are.

Response 2168d: There is considerable disagreement in the scientific and recreational

communities about the extent that recreationists in general and equestrians in particular

impact the environment. Given that uncertainty, the Service believes that it is reasonable to

discuss the potential effects that may result from equestrian or other uses, and does not intend

to imply that equestrian use is always more damaging than other uses.

144 Rocky Flats National Wildlife Refuge
Responses to Individual Comments

2168e: We recommend moving the northern most trail head west along Highway 128 on mile to

where the Coalton Trail comes down to 128.

Response 2168e: The north trailhead was not located across from the Coalton Trail because the

adjacent slopes are too steep for an ecologically sensitive trail connection onto the Refuge, any

such trail would be subject to seasonal closures within the sensitive Rock Creek drainage, and

the Service does not believe that it would be able to effectively enforce the seasonal and modal

trail closures that would be necessary to protect those sensitive resources.

2168f: You should plan for a restroom at each parking lot.

Response 2168f: In Alternative B, restroom facilities would be provided at the main parking lot

and visitor contact station. Outlying parking areas would not have restroom facilities.

COMMENT 2171: COMMENT THAT VISITORS SHOULD BE REQUIRED TO SIGN AN INFORMED

CONSENT STATEMENT

(Comment made in the context of issues related to residual contamination.)

Response 2171: The CCP/EIS is written under the premise that the land to become the Refuge

would be safe for the Refuge worker and visitor. The Refuge will not be established until the

EPA certifies that the cleanup is complete and is safe. The FEIS includes an expanded

discussion of cleanup issues and residual soil contamination in Sections 1.8 and 3.2. As shown in

Figure 4, soil contamination levels in the areas that are likely to become the Refuge are

currently low enough, prior to cleanup, to not require any response actions. Therefore, the

Service would not require visitors to sign an informed consent statement. Informational signs 

would convey the history of the site.

COMMENT 2172: COMMENT OPPOSED TO USE AS A PLAYGROUND/PLAY AREA FOR CHILDREN

(Comment made in the context to concerns about contamination issues.)

Response 2172: None of the CCP alternatives include playground facilities. Alternative D 

includes an outdoor classroom, consisting of a primitive shelter over a hard surface, which

would be used for interpretive and education programs for both children and adults.

Alternative B, the Service’s proposed action, would not include any programs for students

below the high school level. It is acknowledged that this comment may have been made as a

metaphor for any recreational use of the Refuge, which is addressed by comment 2154.

COMMENT 2175: COMMENT OPPOSING EQUESTRIAN ACCESS TO REFUGE

(Generally opposed to equestrian use on a philosophical basis or because of potential environmental impacts.)

Response 2175: While there is common speculation that horses can contribute significantly to

the spread of weeds, the Service also recognizes that there is disagreement with the scientific

and recreation communities on that issue. Many people expressed a desire to include

equestrian access as a means to engage in compatible wildlife-dependent recreation on the

Refuge and regional connectivity to other trail systems. The Service believes that it has taken

a conservative approach in allowing equestrian access under the conditions outlined in the

Compatibility Determination (Appendix B).

COMMENT 2176: COMMENT OPPOSED TO OFF-TRAIL USE

Response 2176: Off-trail use would be limited to pedestrian access only, on a seasonal basis, to

avoid disturbance to ground-nesting birds and other wildlife species. The Service believes that

the off-trail use area in the southern portion of the Refuge would provide a reasonable

opportunity for amateur naturalists, wildlife photographers, and others to access their subjects

and would not result in significant impacts to wildlife or their habitat.

Comments and Responses on the Draft Environmental Impact Statement 145
2200 – EDUCATION AND INTERPRETATION OBJECTIVES

COMMENT 2202: SPECIFIC COMMENT ABOUT EDUCATION AND INTERPRETATION PROGRAMS

2202a: Is there already one, and is the interpretation and environmental education facility

shown on the Alternative D map?

Response 2202a: The proposed environmental education facility is shown on the Alternative D 

map as an “Outdoor Education Center” adjacent to the Rock Creek overlook. It would be a

new facility.

COMMENT 2204: COMMENT OPPOSING PROPOSED EDUCATION AND INTERPRETATION

PROGRAMS

(Comment made in reference to contamination concerns.)

Response 2204: The EPA and CDPHE indicated that all of the proposed Refuge management

activities, including education and interpretation, will be safe for the Refuge worker and

visitors of all ages. The FEIS includes an expanded discussion of issues related to cleanup and

residual soil contamination in Section 1.8.

COMMENT 2205: COMMENT SUPPORTING SIGNS OR OTHER MEANS OF CONVEYING HISTORY OF

ROCKY FLATS

(Comment generally made in reference to contamination concerns, as well as the general history of the site.)

Response 2205: The Service acknowledges that, as a former nuclear weapons production

facility, Rocky Flats has a rich and often controversial history. This controversy has extended

to the nature and extent of cleanup efforts that will precede the establishment of the Refuge.

The Service believes that is important to convey the history of the site as both an interpretive

and as a safety tool.

COMMENT 2206: SUGGESTED REVISIONS TO EDUCATION AND INTERPRETATION PROGRAMS

2206a: Education facility should be open to student groups of all ages.

Response 2206a: As described in Objective 2.8 – Environmental Education Planning, the

Service determined that there is less of a need for elementary and middle school environmental

programs while there is a greater need for natural resource study sites for high school and

college level research. The Service would continue to provide programs for younger students at

the Rocky Mountain Arsenal NWR.

COMMENT 2207: COMMENT SUGGESTING/SUPPORTING EXPANDED EDUCATION PROGRAMS

(Comments that support education programs for younger students in Alternative D, and suggest that the

programs in Alternative B should be expanded as such.)

Response 2207: As described in Objective 2.8 – Environmental Education Planning, the

Service determined that there is less of a need for elementary and middle school environmental

programs while there is a greater need for natural resource study sites for high school and

college level research. The Service would continue to provide programs for younger students at

the Rocky Mountain Arsenal NWR.

2210 – HABITAT MANAGEMENT OBJECTIVES

COMMENT 2212: SPECIFIC COMMENT ABOUT HABITAT MANAGEMENT

2212a: USFWS has not provided the public with a substantive definition of “pre-settlement”

(conditions).

146 Rocky Flats National Wildlife Refuge
Responses to Individual Comments

Response 2212a: The term “pre-settlement” condition is intended to imply a condition before

livestock grazing and modern use and disturbance of the site. The FEIS has been clarified and

a definition has been added to the glossary.

2212b: Monitoring “every few years” seems far too insufficient to maintain and oversee plant

and animal communities.

Response 2212b: Service biologists would have an ongoing management presence at the

Refuge and would be constantly “informally” monitoring ecological conditions. Some resources

would require a scheduled monitoring program, but the Service believes that it is premature to

commit to a scheduled monitoring program. The Service would conduct some monitoring as

part of refuge operations, but on most refuges, wildlife are not always monitored.

2212c: The use of toxic herbicides seems dangerous to the Rocky Flats environment.

Response 2212c: Due to the extent of noxious weed infestations at Rocky Flats and the effect

that weeds have on native ecosystems, the Service believes that it would be important to retain

a full suite of pest management tools, including chemical herbicides. Chemical herbicides are

commonly used to control noxious weeds, and if they are applied properly, the benefits of weed

reduction would outweigh the effects of herbicide application on native plants and animals.

COMMENT 2213: COMMENT ABOUT HABITAT RESTORATION

(Generally comprised of comments supporting the concept of restoration efforts.)

Response 2213: Comment noted. Due to issues related to noxious weed infestation, existing

disturbances, and road revegetation, habitat restoration would be an important component of 

all alternatives.

COMMENT 2214: COMMENT OPPOSING THE USE OF PRESCRIBED FIRE

(Generally due to concerns about residual soil contamination.)

Response 2214: Prescribed fire would be one component of a comprehensive vegetation

management strategy that may be used, in concert with other techniques, to restore native

grasslands, reduce the risk for unplanned wildfire, and where appropriate, reduce weed

infestations. Both the EPA and CDPHE have indicated that the use of prescribed fire outside

of the DOE retained area would not pose a significant risk to firefighters, Service personnel, or

the general public (Appendix D). The Service does not propose using prescribed fire on the

eastern portion of the Refuge between Walnut Creek to the north and Woman Creek to the

south (Figure 8). In accordance with Service policy, any unplanned wildfires would be

aggressively extinguished.

COMMENT 2216: COMMENT OPPOSING THE USE OF MANAGED GRAZING

(Comments generally opposed to the principle of grazing on the Refuge.)

Response 2216: The use of grazing by cattle or sheep would be used as a management tool for

weed management and/or ecological restoration. Grazing would be managed to minimize

adverse ecological impacts.

COMMENT 2221: COMMENT ADVOCATING FOR MINIMAL HABITAT FRAGMENTATION

Response 2221: Habitat fragmentation is recognized by many biologists to be one of the

primary threats to habitat quality and biological diversity. However, the effects of 

fragmentation depends on the species. An insect or small mammal could be impacted by

fragmentation from a road or a trail, while deer and other species may not. Under present

conditions, Rocky Flats is a highly fragmented landscape with over 70 miles of roads traversing

the site. For this reason, it is the goal of the Service to reduce habitat fragmentation by

removing and revegetating unnecessary roads throughout the Refuge, and by reducing the

width of road impacts where roads are to be converted to a trail. Using average habitat patch

Comments and Responses on the Draft Environmental Impact Statement 147
size as an indicator of fragmentation, fragmentation in all alternatives would be less than

existing conditions (Table 11).

Another factor influencing the effects of fragmentation is the location and use of proposed

trails. During the planning process, the Service sought to locate trails along existing roads to

the greatest extent possible, and in locations where trail use would not fragment sensitive

habitat. The trail density in Alternative B would be less than many of the other open space

areas in the region (Table 14). While the Service acknowledges that Alternative C would

minimize habitat fragmentation, Alternative B, the proposed action, would reduce habitat

fragmentation on the Refuge while allowing for a moderate level of wildlife dependent public

use.

2230 – WILDLIFE/THREATENED AND ENDANGERED SPECIES OBJECTIVES

COMMENT 2232: SPECIFIC COMMENT ABOUT WILDLIFE OR THREATENED AND ENDANGERED

SPECIES MANAGEMENT

2232a: If the (deer) population must be controlled, use techniques such as herding or fencing

off or sharpshooters.

Response 2232: The Service would retain a variety of tools for managing the deer and elk

population. If the population is to be reduced, the Service would prefer reducing the population

through the proposed limited hunting program before staff sharpshooters would be used.

COMMENT 2236: COMMENT QUESTIONING THE NEED TO RESTRICT PRAIRIE DOG EXPANSION

Response 2236: In all alternatives, the Service has set thresholds for the maximum area of

prairie dog expansion that would be allowed on the Refuge. While 2,460 acres of potential

prairie dog habitat exist on the Refuge, the Service proposes to limit prairie dog expansion to

750 acres in Alternative B, 500 acres in Alternative C, and 1,000 acres in Alternative D. About

10 acres of prairie dog colonies currently exist at Rocky Flats. While the Service recognizes the

important role that prairie dogs play in the grassland ecosystem, as well as their status as a 

candidate for listing under the ESA, it is also important to manage prairie dog populations in 

balance with other wildlife species and vegetation communities. A sustainable expansion of

prairie dog colonies can contribute to the health and diversity of grasslands, but an

overpopulation of prairie dogs across the entire Refuge could threaten the viability of other

native species, as well as the rare xeric tallgrass community in the western portions of the

Refuge. Alternative B would allow for a large increase over the current population size, which

the Service believes is sufficient for a sustainable and dynamic prairie dog population.

Another reason that the Service intends to restrict unlimited expansion of prairie dog colonies

is due to concerns related to residual, subsurface contamination. Any subsurface contamination

would be limited to the portions of the DOE retained area that will not become the Refuge. The

DOE will be responsible for the protection of the remedy facilities within the portions of the

DOE retained area where subsurface contamination will remain, which includes preventing

prairie dogs or other burrowing animals from accessing subsurface contamination. While the

Service is not responsible for prairie dogs within the DOE retained area, and while subsurface

contamination should not be an issue on the Refuge, as a management partner with the DOE it 

is prudent for the Service to maintain a sustainable prairie dog population and to keep those

populations away from the retained area.

COMMENTS 2237 AND 2238: COMMENT SUPPORTING/OPPOSING PRAIRIE DOG RELOCATION

FROM OFF SITE

Response 2237: In Alternative D, the Service would evaluate the suitability of accepting

unwanted prairie dogs from other jurisdictions. In the other alternatives, including the

proposed action, the Service would not accept prairie dogs from off site. As discussed above in

148 Rocky Flats National Wildlife Refuge
Responses to Individual Comments

the response to comment 2236, the Service proposes to allow natural expansion of existing and

adjacent prairie dog populations in a manner that is ecologically sustainable.

The Service would not consider prairie dog relocated from off site to be a reintroduced species,

because they are not extirpated from the site.

COMMENT 2239: COMMENT THAT ALL LIVING THINGS, INCLUDING WILDLIFE, SHOULD BE

EXCLUDED FROM THE SITE

(This comment was made in the context of contamination issues.)

Response 2239: The Service would not exclude wildlife or other biota from the Refuge. The

EPA and CDPHE have indicated that all of the proposed Refuge management activities would

be safe for the Refuge worker and visitor. The FEIS includes an expanded discussion of issues

related to cleanup and residual soil contamination in Section 1.8.

2250 - SAFETY OBJECTIVES

COMMENT 2254: CONCERN ABOUT SAFETY SIGNAGE

(Comment made in reference to concerns about contamination.)

Response 2254: The Refuge would include signs and displays conveying the history of the site.

These would be developed in a step-down Visitor Services Plan.

2260 – COMMUNICATION, PARTNERSHIPS, AND RESEARCH OBJECTIVES

COMMENT 2263: COMMENT SUGGESTING A SHARED USE FACILITY WITH COLD WAR MUSEUM

Response 2263: The Service has expressed that it would prefer to co-locate Refuge offices

and/or visitor facilities with the Cold War Museum, if such a museum is established and it is 

within close proximity to the Refuge entrance.

2280 – CULTURAL RESOURCE OBJECTIVES

COMMENT 2282: SPECIFIC COMMENT ABOUT CULTURAL RESOURCE OBJECTIVES

2282a: (Favor preservation of) rock structure near the Woman Creek/Indiana Street

intersection.

Response 2282a: In all alternatives except for Alternative C, the rock structure would be left

intact. However, the rock structure is within or adjacent to the right-of-way for transportation

improvements described in the Refuge Act (see Section 4.16), and could be destroyed by future

transportation improvements along the Indiana Street corridor.

2282b: The Antelope Springs Ranch (and stagecoach stop?) should be noted and made

accessible to the public, just like the Lindsay Ranch area.

Response 2282b: In Alternatives B and D, interpretation of the cultural resources at Antelope

Springs from the trail would be considered in a step-down interpretive component of a Visitor

Services Plan. No additional facilities are planned to provide physical access to the area.

2282c: At a minimum, a historic marker...should be placed at the (historical) railroad fill.

Response 2282c: Interpretation of the historical railroad grade would be considered in a stepdown interpretive component of a Visitor Services Plan.

COMMENT 2285: COMMENT OPPOSING REMOVAL OF LINDSAY RANCH STRUCTURES

Response 2285: In Alternative C, the Service would remove all Lindsay Ranch structures to

restore the site to a pre-settlement condition. In Alternative B, the barn would be stabilized

while the other structures could be removed. After evaluating the condition of the other

structures, the Service has concluded that the farm house is deteriorated beyond repair, and

Comments and Responses on the Draft Environmental Impact Statement 149
that appropriate restoration would significantly detract Refuge resources away from other

management needs.

As stated in the rationale for Alternatives A, B, and D under Objective 6.4, the Service would be

willing to work with partners and consider stabilizing the house if resources could be found

through partnerships or grants to undertake such a project. Even if the house does not remain,

the Service believes that the house can be interpreted through a variety of media such as

interpretive panels. The EIS has been revised to reflect this. The Service is concerned about

the house becoming an attractive nuisance if it is fenced off, and the type of security fencing

that would be required to keep visitors away could detract from the visual qualities of the area.

COMMENT 2286: COMMENT REQUESTING NATIVE AMERICAN REBURIAL ACCESS

Response 2286: The Refuge is to be managed in accordance with Service policy and the

purposes expressed in the Refuge Act. Native American reburial is not compatible with these

purposes and will not be pursued under any of the alternatives.

2290 – FENCING

COMMENT 2291: GENERAL COMMENT ABOUT FENCING

(Comment that cattle fencing should be part of Alternative B.)

Response 2291: In all alternatives, the existing barbed-wire boundary fence would remain.

COMMENT 2294: COMMENT PROPOSING SECURITY FENCE AT REFUGE BOUNDARY

(Comment generally made in the context of contamination concerns and the exclusion of all public and/or

wildlife access.)

Response 2294: During the planning process, the Service considered the feasibility and

environmental impacts of installing a 6-foot chain-link security fence around the perimeter of

the Refuge (see Section 4.15–Fencing Considerations). The Service did not recommend a

security fence for any alternative because of the estimated cost ($4 million), its impacts on

wildlife movement and habitat conditions, and its visual impacts.

2300 – STAFFING AND BUDGETS

COMMENT 2302: SPECIFIC COMMENT ABOUT STAFFING AND BUDGETS

2302a: Concerned about having hunting at the Refuge two weekends a year for a grand total of 

20 people at an estimated cost of $250 per person.

Response 2302a: The Compatibility Determination on Hunting (Appendix B) estimates that the

hunting program would cost about $5,000 per year to operate. This cost estimate is based on

the staff time that would be allocated to the program and would not result in additional costs or

staffing. The estimated cost of the hunting program is less than 1% of the estimated annual

operations budget for the Refuge. The Service believes that this is a reasonable expense to

provide a priority public use on the Refuge.

2302b: It seems that a per-use fee would be a logical means by which to help support use of the

facility.

Response 2302b: While the Service may consider incorporating a fee-based access system in

the future, such a system will not be pursued during this CCP.

COMMENT 2320: COMMENT THAT PROPOSED STAFFING AND BUDGET ARE INSUFFICIENT

(Generally concerned that staffing would not be sufficient for fire monitoring or restoration programs, or law

enforcement would not be able to protect visitors from contaminated areas.)

150 Rocky Flats National Wildlife Refuge
Responses to Individual Comments

Response 2320: The Service believes that the proposed staffing levels would be sufficient to

implement the proposed Refuge management activities. Fire management would have it’s own

staff and budget that is separate from the general Refuge budget. The Service does not

anticipate a constant law enforcement presence on the Refuge. The EPA and CDPHE have

indicated that public access to all portions of the Refuge, not just the trails, will be safe.

2400 – REASONABLY FORESEEABLE ACTIVITIES

COMMENT 2402: SPECIFIC COMMENT ABOUT REASONABLY FORESEEABLE ACTIVITIES

2402a: For Section 16, you should strongly suggest to the Colorado State School Land Board

that they do no more gravel pitting, coal mining, or claystone extraction.

Response 2402a: The Service does not have jurisdiction over the management of adjacent state

lands.

2402b: Section 16 (should) become permanently part of the Rocky Flats Refuge.

Response 2402b: While the disposition of Section 16 or any other lands are outside of the

Service’s jurisdiction, the Service will work with local governments in support of regional

conservation opportunities.

2402c: When highways have more increased traffic, you should consider having underpasses or

better fences at 93 and Indiana for wildlife.

Response 2402c: The Final CCP/EIS includes recommendations, such as wildlife crossings and

fencing, that could minimize or mitigate the effects of transportation improvements

surrounding the Refuge (Section 4.16).

2402d: I understand that sand and dust from mining is damaging various lands in the wildlife

refuge. I would recommend immediate action...to stop this from occurring.

Response 2402d: The Final CCP/EIS explains that the Service would work with the mining

operators and the appropriate regulatory agencies to minimize and mitigate the effects of

windblown soil deposition on the Refuge.

COMMENT 2410: COMMENT ABOUT ADJACENT URBAN DEVELOPMENT

(Wildlife corridors as more development occurs, and impacts due to development in the south.)

Response 2410: The FEIS includes an expanded discussion of urban development that is 

anticipated to occur near the Refuge, including the planned Vauxmont development to the

south. The potential impacts of this development to the Refuge are included in the cumulative

impacts discussions in Chapter 4.

COMMENT 2431: GENERAL COMMENT ABOUT MINERAL RIGHTS AND MINING

(Concern about impacts of adjacent mining to Refuge.)

Response 2431: See response to comment 2433. In addition, the cumulative impact discussions

in Chapter 4 include a discussion of potential impacts to the Refuge from adjacent mining.

Groundwater and air quality on the Refuge are protected by stipulations in the mining permits.

The Service will work with the mining operators and regulatory agencies to minimize the

impacts of adjacent mining on the Refuge and its resources.

COMMENT 2432: COMMENT ABOUT THE RECOGNITION OF PRIVATE RIGHTS TO MINERALS

Response 2432: The Refuge Act (Appendix A) specifies that the establishment of the Refuge

would not limit any valid, existing property right at Rocky Flats that are owned by any person

or entity, including, but not limited to mineral rights, water rights or related easements, or

utility facilities or rights-of-way. The Service acknowledges the existence of these private

property rights and intends to allow continued reasonable access to those areas. For example,

the layout of the proposed Refuge access roads in all alternatives is designed to facilitate future

Comments and Responses on the Draft Environmental Impact Statement 151
access to existing easements and other property rights on the Refuge. The Service would

continue to coordinate with outside entities to best facilitate reasonable access to private

property rights in a manner that minimizes impacts to Refuge resources and/or operations.

(See response to comment 2433 for a more specific discussion of mineral rights.)

COMMENT 2433: COMMENT SUPPORTING FEDERAL ACQUISITION TO PRIVATE MINERAL RIGHTS

Response 2433: As recognized in the Refuge Act (Appendix A), most of the subsurface mineral

rights associated with lands along the western edge of Rocky Flats are privately owned. Most

are permitted for surface mining, and some are being actively mined. These private mineral

rights are in an area where their full development would adversely affect the rare xeric

tallgrass community and wildlife movement corridors. These effects are discussed in various

locations in Chapter 4 under Cumulative Impacts.

The final disposition of the lands associated with private mineral rights is still under discussion.

As described in Section 3.8 of the FEIS, it is the Service’s position that because of the adverse

effects that surface mining would have on the Refuge, the Service would not be able to manage

the Refuge to meet the requirements of the Refuge Act if those areas are included in the

Refuge. Therefore, the Service would not accept those lands into the Refuge until the mineral

rights are secured, or those areas have been fully reclaimed following mining operations.

COMMENT 2434: COMMENT ABOUT RECLAMATION OF MINED LANDS

Response 2434: See response to comment 2433. In addition, reclamation of mined lands is 

governed by stipulations in the mining permits that are issued by the State of Colorado.

COMMENT 2435: COMMENT ABOUT PRIVATE UTILITY, DITCH, AND POND ACCESS

Response 2435: The Service would allow reasonable access to all private property rights on the

Refuge. See response to comment 2432 for a more detailed discussion.

COMMENT 2444: COMMENT ABOUT REGIONAL OPEN SPACE CONSERVATION.

Response 2444: The Service appreciates that Rocky Flats is surrounded by open space on

three sides, and that the conservation of Rocky Flats to a National Wildlife Refuge plays a 

pivotal role in tying together the efforts of multiple jurisdictions towards regional open space

conservation. Recognizing the importance of the Refuge in a larger context, the Service is

committed to work with neighboring jurisdictions to coordinate natural resource management

and public use opportunities. This commitment is illustrated throughout the Goals and

Objectives in Chapter 2.

COMMENT 2451: COMMENT SUGGESTING THE PROTECTION OF WILDLIFE CORRIDORS

(Concerns related to nearby transportation improvements.)

Response 2451: The FEIS includes a discussion in Section 4.16 that provides recommendations

to protect wildlife corridors and other Refuge resources that could be affected by nearby

transportation improvements.

3000 – AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

3050 – SOILS

COMMENT 3052: SPECIFIC COMMENT ABOUT SOILS

3052a: (The Service) must be extremely careful when it considers road obliteration and

revegetation.

Response 3052a: The EPA and CDPHE have indicated that all proposed Refuge activities,

including road removal and restoration, will be safe for Refuge workers and visitors. Sections

152 Rocky Flats National Wildlife Refuge
Responses to Individual Comments

1.8 and 3.2 include expanded discussions of issues related to cleanup and residual soil

contamination. As shown on Figure 4 none of the area that will become the Refuge is 

contaminated to the extent that cleanup will be required.

COMMENT 3054: CONCERN THAT RECREATIONAL ACTIVITIES COULD RE-SUSPEND RESIDUAL

SOIL CONTAMINATION

Response 3054: The EPA and CDPHE have indicated that all of the proposed Refuge

activities, including recreational activities, will be safe for both Refuge workers and visitors.

The contamination levels in the area to become the Refuge are currently low enough (prior to

cleanup) to not require any response actions. In response to public interest and concern, the

FEIS includes an expanded discussion of issues related to site cleanup and residual soil

contamination in Section 1.8 and 4.2.

COMMENT 3055: CONCERN THAT PRESCRIBED FIRE COULD RE-SUSPEND RESIDUAL SOIL

CONTAMINATION

Response 3055: See response to comment 3054. In addition, the Service does not propose

using prescribed fire on the eastern portion of the Refuge between Walnut Creek to the north

and Woman Creek to the south (Figure 8).

COMMENT 3060: CONCERN ABOUT THE EFFECT OF PRAIRIE DOGS OR OTHER BURROWING

ANIMALS ON CONTAMINATED SOILS

Response 3060: The EPA and CDPHE have indicated that subsurface contamination does not

exist in the area that will become the Refuge. The DOE will be responsible for the protection of

the remedy facilities within the portions of the DOE retained area where subsurface

contamination will remain, which includes preventing prairie dogs or other burrowing animals

from accessing subsurface contamination. While the Service will not be responsible for prairie

dogs within the DOE retained area, and while subsurface contamination should not be an issue

on the Refuge, as a management partner with the DOE it would be prudent for the Service to

keep prairie dog populations away from the DOE retained area.

3100 – WATER RESOURCES

COMMENT 3102: SPECIFIC COMMENT ABOUT WATER RESOURCES

3102a: I would recommend working with Arvada to get water up to (the Refuge).

Response 3102a: At this time, the Service does not plan to pursue the extension of municipal

facilities to the Refuge because the costs of purchasing water. The Service believes that we

would be able to meet Refuge needs as outlined in the CCP. The Service will retain the existing

raw water pond, as well as the water line between the pond and Building 60, in the event that

water is purchased at a future date.

COMMENT 3110: CONCERN ABOUT SURFACE WATER QUALITY

(Concerns about surface water contamination, and potential impacts from adjacent development.)

Response 3110: The EPA and CDPHE have indicated that all of the area to become the

Refuge, including surface water, will be safe for Refuge visitors and workers. Potential impacts

to surface water from nearby development are discussed in the cumulative impacts section of

Chapter 4.

Comments and Responses on the Draft Environmental Impact Statement 153
3200 – VEGETATION COMMUNITIES

COMMENT 3202: SPECIFIC COMMENT ABOUT VEGETATION COMMUNITIES

3202a: Why were the recommendations in Essington, et al. 1996 and Kettler, et al. 1994 not

used more fully in developing the alternatives and in describing the consequences of each

alternative.

Response 3202a: Both of the referenced Colorado Natural Heritage Program reports were

very useful in understanding the resources of the Refuge, as described in Chapter 3 – Affected

Environment, and were closely considered in developing the alternatives and evaluating the

effects of those alternatives. However, other factors that influenced the alternatives included

the Refuge purposes, Service policies, and knowledge gained from other studies and

management.

3202b: The deficiencies of the Draft are apparent throughout Chapter 4. Relevant research is

also neither cited nor used to reach evidence-based conclusions.

Response 3202b: The evaluation of impacts in Chapter 4 is based on the Service’s

understanding of site conditions described in Chapter 3, the professional knowledge and

experience of Service and planning team staff, knowledge gained from DOE’s site management,

and best available scientific studies on particular types of impacts (such as public use impacts).

Scientific studies were cited appropriately when they were available to support impact

assessment. The biological resources of the Rocky Flats site have been thoroughly studied over

the last 20 years. For that reason, no additional empirical studies were conducted to prepare

the FEIS.

3202c: Despite the USFWS’s plans to restore/revegetate areas and take actions to enhance

wildlife habitat, Alternatives B and D will only “partially satisfy” (the wildlife and habitat

management) goal.

Response 3202c: The Service believes that the overall effects of public use in Alternatives B

would be minor, and would not diminish the ability of Alternative B to satisfy the wildlife and

habitat management goal. The proposed public use facilities, including trails on existing roads,

would affect less than 1 percent of the Refuge area.

COMMENT 3240: CONCERN ABOUT WEED MANAGEMENT

(Comment specific to whether horses are more or less responsible for the spread of weed seeds.)

Response 3240: While there is common speculation that horses can contribute significantly to

the spread of weeds, the Service also recognizes that there is disagreement with the scientific

and recreation communities on that issue. However, the Service believes that it is a reasonable

assessment to assume that horses are among the potential vectors for weed dispersal.

Recognizing this uncertainty, the Service proposes to allow limited equestrian access under the

conditions outlined in the Compatibility Determination (Appendix B).

COMMENT 3260: CONCERN ABOUT IMPACTS OF PUBLIC USE/FACILITIES ON VEGETATION

Response 3260: All of the public use facilities were located considering ecological impacts, and

existing roads and disturbed areas were used to the greatest extent possible. The proposed

public use facilities, including trails on existing roads, would affect less than 1% of the Refuge

area, and the anticipated effects from the use of those facilities would be minor.

COMMENT 3261: CONCERN THAT TRAIL WILL EXCESSIVELY IMPACT RIPARIAN HABITAT

Response 3261: During the planning process, the Service planned trail configurations to avoid

and minimize impacts to riparian habitat. Of the 16.2 miles of trails that are planned for

Alternative B, 0.4 miles, or 3 percent of trail would be within riparian habitat areas. Most of

those trails would be located on existing roads, and subject to seasonal closures.

154 Rocky Flats National Wildlife Refuge
Responses to Individual Comments

COMMENT 3262: CONCERN ABOUT THE IMPACTS OF OFF-TRAIL USE

Response 3262: The Service believes that the potential impacts of off-trail use would be minor

and would not adversely affect vegetation communities or wildlife. Any indications of overuse

or impacts to sensitive resources would be mitigated through education, signage, and/or

closures as appropriate. The service believes that seasonal off-trail use provides reasonable

access for naturalists, wildlife photographers, and others to engage in compatible wildlifedependent public uses.

COMMENT 3263: CONCERN ABOUT HABITAT FRAGMENTATION DUE TO TRAILS

Response 3263: See response to comments 2221 and 3260.

3300 – WILDLIFE

COMMENT 3302: SPECIFIC COMMENT ABOUT WILDLIFE

3302a: No information is available about current populations of deer and elk that inhabit the

property beyond the discussion of population targets. Likewise, you make no comments about

any predators or any other limiting factors on these big game populations.

Response 3302a: Current populations of deer and elk, as well as their anticipated predators

are described in Section 3.5 – Wildlife Resources.

3302b: We also have clear evidence...that both raptors and songbirds are negatively impacted

by trail use.

Response 3302b: The Service is aware of the potential effects of trail use on raptors and

songbirds. These impacts were considered during the trail planning to minimize these potential

impacts by avoiding riparian habitat areas and by using existing roads to the greatest extent

possible. Some trails in the Rock Creek area and off-trail use would only be open during the

winter months, which would greatly reduce the potential for impacts to both raptors and

songbirds. Other closures may be implemented as needed to reduce impacts to wildlife.

COMMENT 3303: COMMENT ABOUT THE EFFECTS OF RESIDUAL SOIL CONTAMINATION ON

WILDLIFE

Response 3303: The Service does not believe that residual soil contamination has adversely

affected wildlife at Rocky Flats. See also the response to comment 3304.

COMMENT 3304: COMMENT ABOUT THE ANALYSIS OF DEER TISSUE

Response 3304: Tissue samples, including edible meat tissues, of deer harvested at Rocky

Flats in 2002 have been analyzed for contaminants. The results of the analysis indicate that

there is no significant uptake of contaminants by deer or other wildlife species at Rocky Flats.

COMMENT 3311: CONCERN ABOUT IMPACTS TO MULE DEER

(Concern related to the effects of hunting.)

Response 3311: See response to comment 2158.

COMMENT 3312: CONCERN ABOUT IMPACTS TO RAPTORS

(Concern related to the impacts of off-trail use.)

Response 3312: The Service believes that the density and frequency of off-trail use would be

low enough to not adversely affect the use of potential raptor nest areas in the southern portion

of the Refuge. None of the proposed trails impact known raptor nest sites. If such a conflict

occurs in the future, the Service would evaluate whether further actions are needed to reduce

impacts to nesting raptors.

Comments and Responses on the Draft Environmental Impact Statement 155
COMMENT 3330: COMMENT ABOUT IMPACT OF TRAILS AND FACILITIES ON WILDLIFE

Response 3330: See response to comment 3260. In addition, the Service is confident that

visitors engaging in unsupervised, wildlife-dependent recreation on the Refuge would not

adversely impact individual animals or wildlife populations.

3600 – RECREATION AND TRAILS

COMMENT 3610: CONCERN ABOUT PUBLIC USE RISK FROM PRAIRIE DOG DISEASES

Response 3610: Service staff will monitor prairie dog colonies for outbreaks of plague. If

outbreaks occur, the Service would take appropriate measures to protect both the prairie dogs

and any visitors who may come into close proximity to the affected colonies.

4000 – DRAFT COMPATIBILITY DETERMINATIONS

COMMENT 4002: SPECIFIC COMMENT ABOUT COMPATIBILITY DETERMINATIONS

4002a: Multiple public uses... may harm fragile wildlife found at the site, suggesting that any

public use is incompatible, and shall not be allowed.

Response 4002a: The Service believes that the overall effects of public use in Alternative B

would be minor, and would be compatible with the purposes of the Refuge. The proposed public

use facilities, including trails on existing roads, would affect less than 1 percent of the Refuge

area, and the anticipated effects from the use of those facilities would be minor. The Service

acknowledges that most public uses would result in some resource impacts. Stipulations have

been made in each Compatibility Determination to reduce and mitigate for unacceptable

impacts, but impacts alone do not make a use incompatible.

COMMENT 4010: GENERAL COMMENT ABOUT HUNTING CD

(Comments generally opposed to hunting.)

Response 4010: See response to comment 2158.

COMMENT 4011: COMMENT THAT HUNTING IS NOT COMPATIBLE WITH THE REFUGE

Response 4011: See response to comment 2158.

5000 – ISSUES OUTSIDE OF SCOPE OF EIS

During the public comment process, there was considerable interest and concern about issues

related to present contamination at the Rocky Flats site, and the cleanup process that is

underway. These issues are outside the scope of this EIS. The CCP/EIS was written under

the premise that the area to become the refuge will be certified to be safe prior to the

establishment of the Refuge and the implementation of the CCP. The EPA and CDPHE have

indicated that all of the proposed Refuge activities will be safe for the Refuge worker and

visitor. If post-cleanup conditions change these assumptions, then the CCP will be revised

accordingly prior to any public use of the facility.

In response to concerns about issues related to cleanup and residual soil contamination, the

FEIS includes an expanded discussion of cleanup in Section 1.8, of residual soil contamination

levels in Section 3.2, and any potential effects of Refuge activities on those soils in Section 4.2.

Comments about issues related to cleanup and contamination were grouped into the following

categories, but are not considered to be substantive.

156 Rocky Flats National Wildlife Refuge
Responses to Individual Comments

6000 – COMMENTS ABOUT CCP/EIS PROCESS

COMMENT 6012: SPECIFIC COMMENT ABOUT CCP/EIS PROCESS

6012a: (The Vegetation Management Plan and Fire Management Plan) should be finished and

presented to the general public for review and approval.

Response 6012a: The Service would complete step-down management plans after the Refuge

is established, and will consider a public review process during the completion of each. Both the

Vegetation Management Plan and the Fire Management Plan would go through a public review

and comment period.

COMMENT 6020: COMMENT ABOUT NEPA PROCESS

(Concern about whether NEPA process was followed, whether it is appropriate to complete the CCP/EIS prior

to final cleanup decisions, and if the EIS sufficiently analyzed effects to the human environment.)

Response 6020: The Service is confident that all aspects of the CCP/EIS process have followed

NEPA requirements. Congress directed the CCP process in the Refuge Act. The Service has

collaborated with the DOE during the CCP planning process and has been apprised of the

approximate boundaries of the lands that will be retained by DOE for long-term monitoring

and stewardship. While the exact boundaries are likely to change prior to Refuge

establishment, the Service is confident that the general nature of the lands and resources that

will be included in the Refuge (including levels of contamination, if any) will not change. For

these reasons, the Service is confident that it is both reasonable and effective to complete the

CCP/EIS process at this time.

In response to concerns about issues related to cleanup and residual soil contamination, the

FEIS includes an expanded discussion of cleanup in Section 1.8, of residual soil contamination

levels in Section 3.2, and any potential effects of Refuge activities on those soils in Section 4.2.

Environmental concerns, including the health of Refuge workers, visitors, and the general

public, have been considered throughout the decision making process. Based on the cleanup

assumptions that must be met prior to Refuge establishment, as well as the levels of residual

contamination in the lands that will become the Refuge, the Service concurs with the EPA and

CDPHE that the proposed Refuge activities will not have an adverse effect on the quality of the

human environment.

6300 – DRAFT CCP/EIS 

COMMENT 6302: SPECIFIC COMMENT ABOUT DRAFT CCP/EIS

6302a: [Regarding species list] there should be a long-tailed weasel; where are the

invertebrates – such as butterflies, moths, and beetles?

Response 6302: The species list has been updated to include a more comprehensive inventory

of plant and animal species. While the Refuge is within the overall range of the long-tailed

weasel, it has not been identified at Rocky Flats and is not on the species list. Over 1,000

invertebrate species have been identified at Rocky Flats. While these species are not listed in

the EIS, the Service does have a database that includes all of them.

6302b: The EIS has to evaluate the effects of this particular action on the human environment.

The Draft EIS fails to do that.

Response 6302b: Under the Refuge Act, no portions of the site can become a Refuge until the

EPA certifies DOE has completed a cleanup that will be protective of the future Refuge worker

and visitor. The CCP/EIS is written under the premise that cleanup and certification will occur

prior to Refuge establishment. However, residual soil contamination levels in the lands that are

most likely to become the Refuge are already low enough to not require any active cleanup. In

response to public interest and concern about contamination issues, the FEIS includes an

expanded discussion of cleanup in Section 1.8. The Service concurs with the EPA, CDPHE,

Comments and Responses on the Draft Environmental Impact Statement 157
and DOE that environmental concerns, including the health of Refuge workers, visitors, and

the general public, have been considered throughout the decision-making process and that the

proposed Refuge activities would not have a significant effect on the quality of the human

environment.

COMMENT 6303: COMMENT THAT THE SERVICE APPEARS TO HAVE ALREADY MADE ITS

DECISION

(Regarding concerns about the identification of a Proposed Action early in the EIS process.)

Response 6303: In accordance with NEPA, the Service developed a range of alternatives

responsive to the issues and concerns identified during scoping. All four alternatives were

given equal merit and consideration in the FEIS. The Service identified Alternative B as its 

Proposed Action. Service planning policy requires that a Proposed Action be identified early in

the planning process, to give the public an early indication of the Service’s preferences.

However, the identification of a Proposed Action does not change the consideration of public

comments, or further analysis or consideration of the other alternatives. The Record of 

Decision will document the Service’s decision on the CCP alternative.

COMMENT 6304: SUGGESTED CHANGES TO MAPS

6304a: The amoeba on all the maps gives the impression that no part of the property retained

will be suitable for any use and has no wildlife refuge value.

Response 6304a: In the DEIS, the DOE retained area was shown as an opaque polygon to

illustrate that those areas will not become part of the Refuge and will not be subject to the

management plans outlined in the CCP. However, the Service also acknowledges that the lands

and resources within the retained area are inextricably linked to the future refuge lands. The

mapping has been revised to include a transparent polygon for the DOE retained area that

gives a better indication of resources in that area.

6304b: (Regarding Welton Reservoir...) Information indicates that it is Fortune Reservoir.

Also, it is no longer “dry.”

Response 6304b: The Consolidated Mutual Water Company website indicates that it is 

“Welton Reservoir”, though some documents prior to the completion of the project referred to

it as “Fortune Reservoir.” The maps have been updated to reflect that it is no longer dry.

158 Rocky Flats National Wildlife Refuge
4. Petitions and Form Letters

The Service received four different kinds of mass correspondence commenting on the Draft

CCP/EIS:

1. No Public Use

2. Object to Hunting

3. Support Alternative B

4. Keep Rocky Flats Closed

FORM LETTER 1: NO PUBLIC USE

The Service received this form letter with the following language, “My reasons for no public use of

the Rocky Flats Wildlife Refuge:

1. The whole Rocky Flats site is contaminated...

2. Plutonium in the environment is a permanent danger...

3. No one knows how contaminated the site is...

4. A cheap cleanup endangers lives...

5. The best possible cleanup is not happening...

6. Cleanup to wildlife refuge standards endangers future generations...

7. Local people reject the cleanup being done...

8. Risk-based cleanup is dead wrong...

9. Genetic effects of plutonium on wildlife are poorly understood...

10. A contaminated environment is a high price to pay for open space...”

Four recommendations from the Rocky Mountain Peace and Justice Center on future use of the

Rocky Flats Wildlife Refuge:

a. Moratorium on public use...

b. Research on health effects...

c. Technology development...

d. Citizen oversight...”

The Service received four copies of this letter, which was assigned the following issue codes:

x 2154 Comment opposed to public use

x 2270 Call for citizen oversight of Refuge activities

x 5030 Site characterization

x 5040 Cleanup standards/ risk assessment

x 5050 General cleanup

x 5061 Comment supporting additional research on effects of contamination on wildlife and

plants

x 5062 Comment favoring ongoing research on cleanup technologies

x 5070 Potential health effects

x 5080 Cleanup principles/approach

Comments and Responses on the Draft Environmental Impact Statement 159
FORM LETTER 2: OBJECT TO HUNTING

This petition was circulated with the following language, “The following object to any recreational

sport hunting at the Rocky Flats National Wildlife Refuge!”

The Service received this petition with 89 signatures. There were 23 signatures with incomplete or

illegible names. Form Letter 2 was assigned the following issue code:

x 2158 Comment opposing hunting program

FORM LETTER 3: SUPPORT ALTERNATIVE B

This petition was circulated with the following language, “The following individuals support the U.S.

Fish and Wildlife Service’s Proposed Action (Alternative B) for the Rocky Flats National Wildlife

Refuge...We are also confident that the cleanup and closure of Rocky Flats will be fully protective

and safe for the proposed future land use described in Alternative B.”

The Service received this petition with 25 signatures, which was assigned the following issue codes:

x 2104 Comment in support of Alternative B 

x 2151 General comment about public use programs

x 5040 Cleanup standards/ Risk Assessment

FORM LETTER 4: KEEP ROCKY FLATS CLOSED

The Service received numerous form letters with the following language, “I am writing to express

my opposition to allowing recreation at Rocky Flats. Just clean it up, fence it off and keep Rocky

Flats closed.”

The Service received 815 copies of this letter. There were 178 letters with incomplete or illegible

names. Form Letter 4 was assigned the following issue codes:

x 2153 Specific comment: “Keep Rocky Flats closed”

x 2154 Comment opposed to public access/use

x 2294 Comment proposing security fence at Refuge boundary

x 5050 General cleanup

160 Comments and Responses on the Draft Environmental Impact Statement
5. Public Hearing Testimony

Comments and Responses on the Draft Environmental Impact Statement 161
 1 

 1 PUBLIC HEARING ON  2 THE DRAFT ENVIRONMENTAL IMPACT STATEMENT  3 AND COMPREHENSIVE CONSERVATION PLAN  4 FOR THE ROCKY FLATS NATIONAL WILDLIFE REFUGE  5  Wednesday, March 10, 2004  6 6:30 p.m.  7 at  Front Range Community College  8 College Hill Library  3645 West 112th Avenue  9 Westminster, Colorado  10  11  Panel Members: Richard Trenholme  12 Mike Hughes  Laurie Shannon  13 Dean Rundle  Jody Erikson  14  15  16  17  18  19  20  21  22  23  24  25 

 2  1 INDEX  2 INTRODUCTION BY MR. HUGHES.........................3  3 INTRODUCTION BY MS. SHANNON........................9  4 COMMENTS MADE BY THE PUBLIC.......................17  5 QUESTION AND ANSWER PERIOD........................40  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25 
 3 

 1 MR. HUGHES: Let me begin by thanking all  2 of you for attending tonight's public hearing on the Draft  3 Environmental Impact Statement and Comprehensive  4 Conservation Plan for the National Fish & Wildlife Service.  5 My name is Mike Hughes and I'm part of the  6 planning team. And I want to say just a couple of words  7 about tonight's agenda, before I turn the floor over to  8 Laurie Shannon, and tell you a couple of things about the  9 formal public hearing. We have a court reporter behind me,  10 as you see, so that we can create a verbatim transcript of  11 the comments that people make about the Draft Environmental  12 Impact Statement and the Draft plan.  13 Given that it's a formal hearing, what we're  14 trying to do is provide an equal opportunity for everyone  15 who has issues to speak and limit as to how much time  16 everyone receives as they speak. So we're going to ask, in  17 terms of ground rules, that you give everyone the same  18 opportunity to be heard that you will want when you step to  19 the microphone.  20 In order for us to manage that, we ask that  21 you sign up to speak. We have a speaker sign-up sheet in  22 the back, we'll be reading the names for that sign-up sheet,  23 we'll ask you to come to the microphone and we want, as  24 you're listening, to respect the opportunity for that person  25 to have their say by not interrupting them, and then those 

 4  1 of you who are at the microphone, respect the time of the  2 person behind you by staying to the time allotment, which is  3 three minutes. So we've allotted three minutes of time for  4 each person to speak.  5 What we ask that you do, as you make your  6 comments, is focus on the plan itself. So again, this is a  7 hearing in response to the Draft, we ask that you bring your  8 comments to the content of the Draft. If there are specific  9 places in the Draft where you have information that is  10 divergent from the information that's in the Draft, we'd  11 like to have that information and want to make sure that you  12 point that out to us.  13 The adequacy of the analysis, if there's any  14 place where you believe the analysis needs to be deepened  15 before the final Draft Environmental Impact Statement or  16 final plan, we ask that you make the comment in that way.  17 Laurie will talk in just a few minutes about  18 the alternatives. We would like, if it's your wish, to have  19 you speak to the alternatives, and obviously, particularly,  20 the proposed act, the preferred alternative.  21 So with that, the agenda will include  22 questions, but we'll be focusing primarily on those public  23 comments.  24 I want to say, before we get to tonight's  25 comments on the Draft, that this is not the only means to 
 5 

 1 provide input to the Draft by any stretch, so we're not  2 limiting you to three minutes, we're just asking you to  3 limit yourselves to three minutes tonight. There are many  4 other ways to communicate your concerns about or questions  5 about or comments on the Draft.  6 The comment period itself is open until April  7 26th. You can submit your comments in writing on the forms  8 that we have here tonight, so if you didn't get one on the  9 table outside and wish to have one, we'll make sure that you  10 have one, and we'll just ask that we have it by the 26th.  11 Also, there is the opportunity for those of  12 you who have access to computer resources to do so online.  13 So the website is here on your agenda and so you can go to  14 that website and make your comments and have those  15 downloaded. Also it's on the green sheet you have as well.  16 So with respect to questions, my hunch is,  17 from the number of sign-ups I've seen so far, is we'll have  18 time to do that. It's possible that in one of the four  19 meetings that we'll be doing for public hearings we'll be  20 doing, we'll have so many people that wish to speak that the  21 three minutes will exhaust our agenda. However, for a group  22 of this size and the number of sign-ups, it's quite likely  23 that we will be able to have a question and answer period,  24 so I will give the floor to Dean at that point and then  25 we'll open up the possibility of questions. 

 6  1 Let me talk a little bit about the agenda in  2 that light and then a bit about how we'll do that. I'm  3 going to give the floor to Laurie Shannon in just a second  4 who is going to present the highlights of the Draft  5 Comprehensive Conservation Plan and Environmental Impact  6 Statement, focusing particularly on what has changed since  7 you last saw the alternatives in the public forum when we  8 all came together to do that, for those of you who have been  9 with us over and over again.  10 We want to highlight particularly the key  11 elements of the preferred alternative, but also any changes  12 that have been made that are of significance and then we'll  13 turn to the public comment period.  14 Jody, sitting right here in the front, is the  15 one that's going to help us with time. So she'll be  16 standing there next to you reminding you that your three  17 minutes is up and remind you to have a seat. And again,  18 we've got some guidelines for you with respect to the  19 comments.  20 As you can see from the italicized item  21 there, if there is time for questions, and again I think  22 that there will be, what we will do is make sure we document  23 the question itself so that we can retain the question  24 itself that you're asking. What we ask that you not do is  25 use that time to add to the three minutes you already had. 
 7 

 1 So I'm going to ask that you not preface your question with  2 a speech, and then the foundation for the question, simply  3 ask the question and we'll get to it. That's again in the  4 interest of fairness so that everyone has the same amount of  5 time.  6 And again, we're expecting larger meetings,  7 we'll exhaust the time with the three minutes. We will end  8 the meeting at 8:30 and that takes care of the agenda.  9 One of the things that we've talked about on  10 the planning team that is a focus of a great deal of  11 attention in the comments we've received online or  12 individual conversations we've had with many of you, cause  13 us to want to go through this explanation. And so I'm just  14 going to spend a couple of minutes talking about the steps  15 by which a refuge in established, and this is in the act  16 that started this Comprehensive Conservation Plan and  17 Environmental Impact Statement process.  18 First of all, the Fish & Wildlife Service  19 completes its final Comprehensive Conservation Plan and  20 Environmental Impact Statement and then issues a record of  21 decision. That's the first decision point that takes us  22 down this path.  23 The second one is that the Department of  24 Energy completes its site cleanup, except for its ongoing  25 OM, its ongoing operation and maintenance of the retained 

 8  1 areas or any of the activities, the monitoring that it will  2 do on site, et, cetera, et cetera, but completes its cleanup  3 efforts at the site. And then EPA and the Colorado  4 Department of Public Health and Environment certify the  5 completion of that cleanup. That's another key decision  6 point that must be passed for the possibility of a refuge to  7 exist.  8 At that point it is then possible, under the  9 legislation for the DOE, Department of Energy, to transfer  10 that land to the Department of the Interior so that the  11 refuge can be created. And then with that the Department of  12 Interior would establish the refuge officially and then the  13 Service would then begin its management.  14 The key item in all of that chronology is  15 this; that the EPA certification is required before the site  16 can become a refuge. So the Comprehensive Conservation Plan  17 and the Environmental Impact Statement has been written in  18 the context of a certified site, written as if that decision  19 were made, and therefore, then how to operate the refuge,  20 and will not take effect until the certification itself is  21 complete.  22 So there have been lots of question about how  23 the Department of Interior and the Fish & Wildlife Service  24 attended to the site's current state and the DOE cleanup  25 operation and that's how it's being done. The Environmental 
 9 

 1 Impact Statement is written in that context. So with that,  2 Laurie.  3 MS. SHANNON: Thanks, Mike. Good evening. I  4 want to just spend a couple of minutes going over the four  5 alternatives. And I know that many of you probably know  6 them very well, but in case we have some that are not as  7 familiar and everybody knows what we're here to discuss, I'm  8 just going to highlight the four alternatives, and  9 particularly I want to go over what has changed since we  10 presented them last May to the public.  11 So to begin, I'm going to start with our  12 proposed action, because that's what we are proposing here,  13 and we'll move on to the other ones. Some of the things  14 that we heard from the public last May, a couple of key  15 things, is that the public told us that they wanted to see  16 some horseshoes on the site. We had only proposed that in  17 Alternative D and they had asked that there be some  18 allowances for horse access. So one of the changes that we  19 made was in the southern part of the site is that we have  20 provided for some horse access down here. The northern part  21 of the site would stay the same.  22 This multiple use trail that's up here, that  23 would be bikes and pedestrians only. The trails down here  24 would be for horse, bike and pedestrians, and then off to  25 the north it would continue to be pedestrian only. And some 

 10  1 of even this far northern site would be a seasonal trail,  2 depending on the needs of wildlife.  3 The other thing that the public -- we heard  4 from the public was that they wanted to see some increased  5 connectivity. So we made some attempts down here to make a  6 loop and also try to improve the connectedness down here.  7 The other thing that we heard from many  8 people who said that they wanted us to focus more on  9 restoration of the site before we provided public use. So  10 in that respect, what we are proposing now is that after  11 refuge establishment, we would open a trail down to the  12 Lindsay Ranch soon after establishment. But for  13 the first five years we would focus our efforts on  14 restoration of the site, wildlife habitat management and try  15 to get our budget established before we would begin to  16 implement the use of the public program. But by year 15 all  17 of the public use program would be implemented.  18 One other thing I want to point out, a lot of  19 people wanted us to make this connection in the annum, the  20 north-south connection, and we still feel very strongly that  21 if there is an improvement to the road corridor along  22 Indiana, that we would like to see that connection made in  23 that process or made by the communities to the east, and not  24 so that we're trying to squeeze in a trail between the DOE  25 retained lands and the transportation corridor and that sort 
 11 

 1 of thing.  2 Under this alternative we are proposing a  3 contact station as opposed to a full-fledged visitor center,  4 which would be in Alternative D. The other change that we  5 made under this alternative is with respect to hunting. And  6 it currently still is as we presented it in May. There  7 would be a very limited hunting program open to youth and  8 disabled and it would be highly managed two weekends out of  9 the year and the rest of the refuge would be closed. It  10 would be low-impact weaponry, such as archery, muzzle  11 loading and shotgun shells and that would still stay, but  12 what we did change was, after two years we would at least  13 look at whether we could open the program to abled hunters.  14 And the reason for that is that -- that's so if we're not  15 meeting our target population goals for deer and elk, we  16 could do that.  17 Let me think if there's any other major  18 changes. The other things that we did, we tried to look at  19 the restoration of the stream crossing and tried to improve  20 those so they fit the goals of each alternative. We  21 added -- kind of figured out what we're doing about fire  22 management under all the alternatives and recognized what we  23 needed to do there. We better define the prairie dog  24 habitat out on the site, and as I explained, the hunting  25 program. 

 12  1 The other thing about the Alternative B that  2 I should have mentioned is that we call this alternative the  3 wildlife habitat and public use alternative. And that has  4 what we -- how we define that is it has a real strong  5 emphasis on wildlife and habitat management while allowing  6 the moderate amount of use and also providing for some  7 compatible scientific research that's focussed on wildlife  8 habitat and public use.  9 And we feel that this is the alternative that  10 best meets both our agency, the National Wildlife Refuge  11 system missions and goals, it meets what we -- how we  12 interpret the refuge legislation and also it reflects what  13 we heard from the public during the comment period to date.  14 Alternative A is what we call the no action  15 alternative. And under this alternative it would be  16 basically continuing the current management regime with most  17 of our focus of wildlife and habitat being in the Rock Creek  18 area, which is the northern part of the site. There would  19 be almost virtually no public use, except for very limited  20 VIP-type tours. And as you can see, there are no facilities  21 shown there.  22 Alternative -- oh, one change that we made  23 with Alternative A that is different is that we used to have  24 a chain-link fence around Alternative A when we presented it  25 back in May, and since then, after looking at it a little 
 13 

 1 bit deeper, we have taken that out of that alternative,  2 primarily because it changes it into an action alternative.  3 And after looking at it, we decided that it was not  4 something that we really felt like was something we wanted  5 to do. It's very expensive, it precludes wildlife movement  6 corridors and we didn't really find a lot of support in the  7 community for it by putting up a big chain-link fence around  8 the site.  9 Alternative C is what we call the ecological  10 restoration alternative. And that alternative is trying to  11 maximize wildlife and habitat restoration and management to  12 the degree possible and providing just for a minimal amount  13 of public use on the site and also providing for, again,  14 compatible scientific research that's focussed strictly on  15 wildlife and habitat.  16 So as you can see, this is the public use  17 part of it. It would only entail having a very short trail  18 that would go out to an overlook, and that would be a  19 guided -- it would be again a very small usage of the site  20 during the year.  21 Under all the alternatives, the only access  22 by vehicle would be through the west through Highway 93.  23 That's what this line is, where these four, B, C and D.  24 Okay.  25 Alternative C is the one alternative where we 

 14  1 take out the Lindsay Ranch and obliterate that. And we  2 would record that with photographs and recordation for it in  3 terms of preserving it.  4 Alternative D is what we call the public use  5 alternative. And this is again trying to say we're going to  6 have a strong emphasis on wildlife and habitat management,  7 but we're going to maximize the amount of public use that we  8 can put on this site that we can feasibly do as our agency.  9 So this one has about 19 miles of trails whereas Alternative  10 B has about 16. What you see the differences are are in the  11 types of facilities. Alternative D has a visitor center, a  12 full-fledged visitor center, where Alternative B is just a  13 contact station with a few offices in there.  14 Under both B and D there would be no dogs  15 allowed on the site. None of the alternatives would allow  16 dogs, leashed or unleashed.  17 Under this alternative we also try to respond  18 to some of the things that we heard from the public about  19 improving some of the trail connectivity and making it more  20 looped. And under this alternative, horses would be also  21 allowed in the southern part of the site and on the northern  22 part of the site.  23 And, Dean, I think that pretty much  24 highlights what I have to say about that and I'll just turn  25 it over to you. 
 15 

 1 MR. HUGHES: For those of you who just came  2 in, if you wish to speak, the sign-up sheet is there, go  3 ahead and do that so we can get you on the list.  4 To recap quickly, Jody, who is standing there  5 in the back, is going to help you be mindful of how long  6 three minutes is. So she'll let you know when you're  7 approaching the end of that three minutes for your comment  8 period. When you come -- as we go down the list, Jody will  9 call both the name of the first speaker and the name of the  10 person who should go next and we'll do that on down the  11 line.  12 When you come to the microphone, we ask that  13 you give us your name so that is contained as part of the  14 transcript. Part of our requirements under NEPA is to make  15 the Environmental Impact Statement -- to fulfill our  16 obligation for the Environmental Impact Statement. So we  17 want you to give your name and then we'll ask you to take  18 those three minutes and Jody will let you know when three  19 minutes is over.  20 Since what you're doing is making comments  21 about the plan that the Fish & Wildlife Service is putting  22 out in draft form, so we've asked them to sit here so you  23 can actually speak to them. If your comment includes a  24 question, don't worry about that, I'll catch it and then  25 we'll come back to that when we get to the question and 

 16  1 answer portion. So Laurie you've met.  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25 
 17 

 1 MR. RUNDLE: I'm Dean Rundle, the project  2 leader and refuge manager for the Rocky Flats project.  3 MR. TRENHOLME: I'm Richard Trenholme with  4 ERO Resources and we're a part of the planning team.  5 MR. HUGHES: We have other members of the  6 planning team, they are out there in the lobby helping to  7 get organized.  8 Jody, go ahead and we'll do this three  9 minutes at a time.  10 MS. ERIKSON: LeRoy Moore and then Bini  11 Abbott.  12 BY MR. LEROY MOORE:  13 My name is LeRoy Moore, I'm a consultant with  14 the Rocky Mountain Peace and Justice Center in Boulder. I'm  15 also a member of the board of directors of the Rocky Flats  16 Cold War Museum, which is in the process of being created.  17 My remarks tonight focus on the relationship between the  18 wildlife refuge and the museum. I speak not on behalf of  19 the board of the museum, but only on behalf of the Rocky  20 Flats Peace and Justice Center.  21 The Peace and Justice Center strongly  22 supports the intention of Fish & Wildlife to, quote, work in  23 collaboration, the words from the EIS, with the proposed  24 museum and commemorating a site of historical significance.  25 Just as Fish & Wildlife is committed to 

 18  1 caring for the flora and fauna of the wildlife refuge, the  2 museum is committed to telling the full story, both of the  3 production of nuclear weapons at Rocky Flats and the  4 response to this activity by people from the outside.  5 A collaborative endeavor between Fish &  6 Wildlife and the museum should lead logically to them being  7 housed in a common facility. The appropriate location for  8 such a facility is along Highway 93, what is now called the  9 West Gate to Rocky Flats. This high upwind location  10 provides a good vantage point for observing much of the  11 Rocky Flats property as well as the mountain backdrop, the  12 surrounding communities and Denver beyond.  13 It is an ideal location for overlook  14 platforms from which visitors can view the wildlife on the  15 refuge and the location of the former Rocky Flats plant.  16 Fish & Wildlife will want to have  17 interpretive information about the flora and fauna of the  18 site, while the museum will want photographs and diagrams  19 depicting the appearance of the site at different stages in  20 its history as a weapons production plant and beyond to  21 cleanup and closure.  22 The key activities to preserving open space  23 at Rocky Flats and commemorating the historical significance  24 of bomb production at the site, that's a great interruption,  25 can be fulfilled. These two things can be fulfilled without 
 19 

 1 endangering members of the unsuspecting public by allowing  2 them to engage in risky activities on a contaminated site.  3 We at the Peace and Justice Center prefer no  4 public access to the refuge because of the dangers of the  5 contamination there; however, we can also support Fish &  6 Wildlife Service Alternative C, ecological restoration, as  7 the one option processed by Fish & Wildlife that best meets  8 the goals of both preserving open space and commemorating  9 the site's historical significance. Thank you very much for  10 the opportunity to speak.  11 MS. ERIKSON: Bini Abbott and Jacqueline  12 Brever.  13 BY MS. BINI ABBOTT:  14 My name is Bini Abbott. I live at 9190  15 Elkhire, Arvada, but I'm on the West Shore of Standley  16 Lake. And what I am not is not belonging to any peace  17 groups, I am not belonging to any of the animal rights  18 groups, but what I am is very concerned about having hunting  19 at the refuge two weekends a year for a grand total of 20  20 people, which at the estimated cost is $250 per person of  21 those 20 people and the rest of the refuge would be  22 completed closed.  23 The goals of the U.S. Fish & Wildlife, I  24 realize, are hunting and fishing are two of their primary  25 purposes for the refuge, but I think you'll find that the 

 20  1 public is appalled when they find out that hunting would be  2 allowed at what they think is going to be a refuge. And the  3 definition of refuge in the dictionary and so on is a place  4 of safety. And if we're going to give safety to these  5 animals, the deer and the elk, through the rest of the year  6 and then suddenly to plunk at them for two weekends, I think  7 is conflicting interests and I would hope it would not  8 happen.  9 According to the EIS, they will reevaluate  10 the need for culling or reevaluate their program on hunting  11 in 15 years, which is the year 2019. I probably won't be  12 around and able to still express my feelings at that time.  13 I've talked to both the wildlife managers with Boulder City  14 Open Space who owns land on both the north and the west of  15 this refuge and to Boulder County Open Space which owns land  16 to the north of the refuge. Neither of those entities have  17 any problem with overpopulation.  18 And so, if at some time the animals have to  19 be culled because of chronic wasting disease or so on, I  20 would hope that instead it would be sharp shooters from the  21 Division of Wildlife and not having either handicapped  22 people or youth, having a reasonable chance of success, is  23 the way it's put down in hunting.  24 In closing, I would just like to say that I  25 think the perception is going to be more important than 
 21 

 1 reality as to what people think of what U.S. Fish & Wildlife  2 intends to do at this location. And the perception will be,  3 what, you're going to kill the animals after you're saving  4 them and you're building these blinds so we can observe  5 them? And I would suggest that we instead watch the  6 wildlife through binoculars, through a camera, and not  7 through the cites of a gun. Thank you.  8 MS. ERIKSON: Jacqueline Brever and Erin  9 Hamby.  10 BY MS. JACQUELINE BREVER:  11 My name is Jacque Brever. I'm a former  12 plutonium worker from Rocky Flats and I'm now an  13 environmental scientist with experience in Superfund  14 cleanups and reuse plans. I speak from personal knowledge  15 at Rocky Flats as well as from my training in this field.  16 DOE admits its leaving plutonium in the soil  17 and Fish & Wildlife Service wants to allow activities that  18 would stir up plutonium when one little speck of plutonium  19 can cause cancer and genetic defects.  20 It looks like the EIS, CCP describes some  21 pristine open space that would be available for people to  22 romp around in rather than a former nuclear weapons facility  23 about to become a National Wildlife Refuge.  24 Therefore, I want to register my opposition  25 to your statutory mandates and your compatibility 

 22  1 determination.  2 The entire site is contaminated. There is  3 such a thing as informed consent. Not only do I oppose  4 public access at Rocky Flats, I think that if public access  5 is allowed, then people should be required to sign informed  6 consent statements prior to entering the property. I think  7 hunters should sign informed consent documents before they  8 are allowed to bring home the venison, so to speak, and  9 allow their families to eat the contaminated meat.  10 Inhalation and ingestion of radioactive  11 materials causes cancer and many other adverse health  12 effects. The plutonium left in the ground at Rocky Flats  13 will remain dangerous for a quarter million years. Can you  14 guarantee that Rocky Flats will remain a National Wildlife  15 Refuge with institutional control for a quarter million  16 years?  17 There is a first time for everything, such as  18 turning a nuclear weapons facility into a National Wildlife  19 Refuge with a priority recreational access. There may be a  20 first time for turning a National Wildlife Refuge into a  21 housing development. The cleanup standards were set to be  22 protected only over of wildlife refuge worker, not a family  23 living at Rocky Flats, drinking the water, working the  24 ground and perhaps to grow food for the animals.  25 DOE admits that Rocky Flats cleanup is to be 
 23 

 1 used as a prototype for cleanup of the other properties in  2 the nuclear weapons complex. DOE also admits that the  3 cleanup at Rocky Flats is not as protective of human health  4 as it could be.  5 I don't think we should be presented with  6 only the options of whether to choose between hunting or  7 horseback riding at Rocky Flats, I think the public should  8 be allowed to choose whether or not to have public access at  9 all at an inadequately cleaned nuclear facility. Just clean  10 it up, fence it off and keep Rocky Flats closed.  11 MS. ERIKSON: Erin Hamby and then Iggy  12 Litaor.  13 BY MS. ERIN HAMBY:  14 My name is Erin Hamby and I'm with the Rocky  15 Mountain Peace and Justice Center, a community organization  16 dedicated to the principles of nonviolence. We support a  17 plan that would deny public access and recreation at the  18 Rocky Flats National Wildlife Refuge. We support a  19 management plan that focuses on research.  20 The site could be used in a positive way to  21 develop new and more effective remediation technologies.  22 Genetic studies could also be encouraged to collect data on  23 the plutonium body burning of wildlife on the site and on  24 the basis of which extrapolations can be made to the genetic  25 effects on wildlife and potential effects on humans at or 

 24  1 near the site.  2 We believe that the refuge managed with  3 ecological restoration, research and human health and safety  4 all in mind, can and would satisfy the mission and purpose  5 of the Rocky Flats National Wildlife Refuge as well as the  6 missions and goals of the National Wildlife Refuge system.  7 These same mission statements and goals can  8 also be set aside without allowing public access or  9 recreation. Of the alternatives presented by the U.S. Fish  10 & Wildlife Service, the only one acceptable to the Peace and  11 Justice Center is Alternative C, though we would prefer the  12 elimination of the single trail and overlook.  13 We are disappointed that Fish & Wildlife  14 refuses to consider issues surrounding the level of cleanup  15 at the site. It is understood that Fish & Wildlife have no  16 control over cleanup levels or amounts, but you do have  17 control over the amount of public access allowed at Rocky  18 Flats.  19 With known contaminants being left behind, it  20 is irresponsible to manage the site as if they were not  21 there at all.  22 The Department of Energy retained industrial  23 zone, the most dangerous part of the site, is within the  24 boundary of the refuge, like the hole of a donut. With the  25 seamless preserve, this hole becomes indistinguishable from 
 25 

 1 the rest of the site, which is unacceptable.  2 Fish & Wildlife has a responsibility to the  3 public to plan and act with respect to known contaminants  4 contained within the boundaries of the planned Rocky Flats  5 National Wildlife Refuge. Thank you.  6 MS. ERIKSON: Judith Mohling and Iggy Litaor.  7 BY MS. JUDITH MOHLING:  8 I'm Judith Mohling and I'm Colorado born and  9 bred and I think that hiking through tall grass prairie is  10 among life's loveliest experiences that I can think of.  11 Absolutely rich with wildlife and new beauty with every  12 step. If only we were here 60 years ago and that the land  13 was going to be yours to manage and you had these wonderful  14 alternatives and that beautiful Draft EIS, before Rocky  15 Flats became contaminated from the manufacturer of plutonium  16 pits, it would be wonderful.  17 The Draft is just beautiful, the ideas are  18 thoughtful. The photographs are compelling and make me  19 think of wearing protective clothing and a face mask when  20 hiking on the trail if they come to pass. However, all of  21 my education about Rocky Flats tells me that no one knows  22 how contaminated the site really is. All the accidents and  23 fires have left their powdery contaminants. It is known  24 that there were nighttime burns of waste in unknown spots.  25 The DOE is bequeathing to your management 

 26  1 land that has never been fully characterized. No one has  2 gone yard by yard, square yard by square yard to figure out  3 what's there.  4 In the Draft EIS, on the first page in the  5 summary under refuge significance, you say that congress  6 identified several significant qualities about Rocky Flats.  7 And the first one is the majority of the site has generally  8 remained undisturbed since its acquisition by the  9 government, and maybe congress thinks that, but it's just  10 not so. It's been disturbed for 50 years, if only by a  11 gentle sifting of plutonium ash, plus all of the other  12 contaminants that have been dribbled onto it.  13 Instead Rocky Flats needs to be closed to the  14 public for a century or two. The plants and animals, the  15 air, water and soil scrutinized and monitored for  16 contamination effects and scientists in many fields for the  17 next 200 years need to apply their knowledge and skills to  18 that lovely land to create technologies even beyond what we  19 now know, to bring about the lowest possible levels of  20 contamination for all of the generations to come which F&W  21 is deeply involved in.  22 Is there room for negotiating yet another  23 alternative with you that includes what I've just been  24 talking about, plus careful remediation and environmental  25 care and a comprehensive museum that traces the entire 
 27 

 1 history of Rocky Flats, including the point of view of peace  2 activists and cleanup activists? If that isn't possible,  3 then I vote for Alternative C because it comes closer,  4 although I don't understand why the Lindsay Ranch has to be  5 obliterated. Thank you very much for this opportunity.  6 MS. ERIKSON: Ron Hellbusch and Mike  7 Fenerty.  8 BY MR. RON HELLBUSCH:  9 My name is Ron Hellbusch. I'm director of  10 Public Works and Utilities with the City of Westminster.  11 Just want to make some general comments regarding the land  12 use proposed as a wildlife refuge. Westminster City Council  13 strongly supports the National Wildlife Refuge use as a land  14 use for this particular site.  15 The cities of Westminster and Northglenn and  16 Thornton utilize the Standley Lake water supply downstream  17 from the site for its water supply for those three  18 communities, and generally agree that the nondevelopment  19 wildlife refuge used for that site is compatible with the  20 water supply concerns the cities have collectively with the  21 surrounding open space that the City of Westminster manages  22 and the trail system.  23 Our city council and staff members have been  24 active since 1990 with DOE and the various health agencies  25 in the cleanup process and are equally involved with the 

 28  1 Rocky Flats Coalition, Local Governments and the planning  2 process with the Fish & Wildlife Service.  3 City council will have an official briefing  4 by the Fish & Wildlife staff in April. Following that  5 briefing, city council will issue comments relative to the  6 specific alternatives. But the City supports this  7 particular type of land use, nondevelopmental land use for  8 this particular site and the City appreciates the openness  9 and the cooperation Fish & Wildlife has extended to the  10 cities.  11 MS. ERIKSON: Mike Fenerty and then Anne  12 Fenerty.  13 BY MR. MIKE FENERTY:  14 Mike Fenerty. I object to the use of this site,  15 the alternative of opening up the site at all and feel it  16 should be closed off as most of the previous speakers talked  17 about.  18 To put it in perspective, I'd like you to  19 imagine the owner of a small gas station prosecuted by the  20 EPA for a leaking underground tank, hauled into court for  21 refusing to do a full cleanup, places a fence, but most of  22 the contamination is more than three feet underground. He  23 then offers to abandon the site with the leaking tank and  24 turn the gas tank into a wildlife refuge. The owner clearly  25 would be laughed out of court, fined and possibly jailed. 
 29 

 1 The Rocky Flats has many square miles of  2 contaminated compounds of plutonium, uranium, volatile  3 chemicals and beryllium, which I have personal experience.  4 Only the surface will be cleaned up to a supposedly safe  5 level. Little cleanup is planned below three feet.  6 The government it contracted expects a bonus  7 of hundreds of millions of dollars for early completion.  8 Congress mandated the creation of the wildlife refuge, and  9 open access to the public is a real possibility on this  10 grossly contaminated site.  11 I find it truly amazing that many local  12 residents and many of the local government representatives  13 seem so unconcerned. Thank you.  14 MS. ERIKSON: Anne Fenerty.  15 BY MS. ANNE FENERTY:  16 I'm Anne Fenerty. I'm reading this for  17 Professor Iggy Litaor from Tel-Hai Academic College in  18 Galilee, Israel. An open letter to the US Fish & Wildlife  19 Service concerning its Draft plan for the Rocky Flats  20 National Wildlife Refuge.  21 I served as a senior soil scientist for EG&G  22 Rocky Flats from 1990 to 1995 studying the fate and  23 transport of actinides in the soil environs of RFP. This  24 work yielded 14 publications in the leading scientific  25 journals of my field. These studies clearly mapped the 

 30  1 extent of the contaminants around the defunct plutonium  2 processing plant and investigated the processes that govern  3 the mobility of plutonium and americium in the soil  4 environs.  5 The actinides in the soil environs of RFP  6 resulted from accidents such as the '57 and '69 fires and  7 poor management of an internal waste site locally known as  8 the 903 Pad. Most of the actinides were transported across  9 the landscape by wind. Once the contaminants were deposited  10 on the soil, their mobility was greatly reduced, unless the  11 topsoil is disturbed and dust is generated, hence, any  12 activity that may generate dust in the areas east, southeast  13 and northeast of RFP should be avoided. Other potential  14 transport mechanisms that were investigated included runoff  15 and groundwater flow.  16 Under normal and selected simulated  17 conditions, the actinides are stable and will not travel  18 significant distances to groundwater and/or to streams.  19 However, under the somewhat unusual climatological  20 conditions experienced in the spring of '95, we observed  21 significant actinides movement down the soil profile and  22 across the soil landscape. In particular, the runoff  23 generated during the May 17, 1995 rainstorm yielded at least  24 10 millicuries, which is 10 billion picocuries, of plutonium  25 that traveled more than 100 meters down slope. Increased 
 31 

 1 levels of plutonium and americium were even observed in  2 Woman Creek. Once the results became known, DOE promptly  3 terminated the project using the convenient pretext of the  4 massive layoffs that were administrated by Kaiser-Hill  5 during this period. And I must say that the capture of this  6 rainfall event in the soil and on the surface was my best  7 research to date using a highly sophisticated advanced soil  8 monitoring system that was installed in the soil and on the  9 surface specifically designed to capture such an unusual  10 event.  11 The results of this work were never published  12 because Kaiser-Hill and DOE refused to give me crucial  13 geological data without which I could not finish the  14 groundwater simulations and mass flow calculations.  15 The fate and transport of actinides in the  16 soil environment of Rocky Flats is still an open question.  17 During my tenure with Rocky Flats, I collected more than 700  18 surficial soil samples and excavated more than 45 deep soil  19 pits in the buffer zone and beyond. It was a common  20 occurrence that my personal protection equipment was found  21 hot by the end of the day and was discarded into the hot  22 contaminated bin.  23 On the basis of my personal knowledge and  24 experience, I strongly recommend that the buffer zone around  25 RFP highly limited to public use. I'm in favor of 

 32  1 Alternative C that allows for ecological restoration,  2 environmental studies and permits limited and supervised  3 access to the public, mainly in the Rock Creek drainage.  4 MR. HUGHES: That completes those who signed  5 up. Now, anyone who has not signed up before and is  6 interested in doing so, you have the opportunity to take  7 three minutes. When you come to the front, if you can just  8 say your name.  9 BY MR. JOHN GEAZENTANNER:  10 My name is John Geazentanner and I just  11 wanted to say that I'm in favor of Alternative B mostly. I'm  12 assuming that it is going to be open to public access. I  13 wouldn't mind if it was closed off, like a lot of people  14 have been saying, but assuming that it is, I'm mostly in  15 favor of B with a few exceptions.  16 The Service identified like about 2,460 acres  17 of habitat for prairie dogs, but B is proposing to limit  18 them to 750 acres. And as far as I can tell from the plan,  19 that was just because of a staffing issue, that it would be  20 too hard to keep them under control if they got close to the  21 maximum or something like that. But so I wonder if that's  22 not fair for the prairie dogs. I don't know.  23 I wish that the alternative would consider  24 allowing relocations from off site. That's allowed in D and  25 I don't know why it's not in B. There's a plague issue, but 
 33 

 1 I think that would be screened for easily enough.  2 I understand it would allow -- consider  3 allowing locations from off site of B and also with hunting.  4 I agree with the woman who spoke earlier, if it is necessary  5 to environmental degradation from over-grazing, then I think  6 they should use professionals and not children. I don't  7 think youth and disabled people need more opportunities to  8 shoot things, but I don't think that's compatible with the  9 mission of the refuge. I just -- and it's not just really a  10 refuge if you're not being shot at or if you are being shot  11 at.  12 And I also question about the off-trail use  13 in certain portions of the refuge, because it -- maybe it's  14 just too different for me, because all the open space, you  15 always have to stay on the trail and it prevents erosion and  16 damaging plant life and stuff like that, and it said it  17 would be minimized because it would only be in the winter.  18 But given the number of people that are expecting to use the  19 refuge, it seems to me there would be a lot of people  20 walking around trampling things. And I would hope that at  21 least the refuge does just fine, but there's a lot of damage  22 being caused, that they would reconsider that. So I guess  23 that's about all I've got.  24 MR. HUGHES: Anyone else who wants to take  25 that opportunity for three minutes? We have some time left 

 34  1 between now and 8:30 and what that gives us the opportunity  2 to do is first give the floor to Dean and then to open up  3 the floor for some questions and answers.  4 Not knowing how many questions will come,  5 many of you may have come to ask a question, what we're  6 going to do is just write them down. So just lob the  7 questions out, we'll write them down and then we'll ask Dean  8 the ones that are relevant to the CCP and EIS.  9 MR. RUNDLE: As I said earlier, My name is  10 Dean Rundle. I'm the refuge manager for the Rocky Flats  11 project. And first I want to thank everyone for coming  12 tonight. This is a great turnout and I really appreciate  13 the interest so many people have in the planning process and  14 the comments you made earlier.  15 There's been a lot of stuff in the newspapers  16 lately about Rocky Flats. We're getting a lot of  17 communications from the public and there's some people,  18 perhaps some of you are concerned or perhaps frustrated  19 about the scope of our plan and the legal process and I  20 wanted to take a few minutes to address that issue.  21 We have said from the beginning of this  22 process that the cleanup of Rocky Flats is outside the scope  23 of our plan, that is true. In the end, as Laurie mentioned  24 earlier, it will be a record decision signed by our regional  25 director that will set this plan and get it approved. He 
 35 

 1 doesn't have the authority to effect cleanup issues and  2 neither do I.  3 Very clearly, the cleanup of Rocky Flats is  4 the responsibility of the Department of Energy with  5 oversight from the Environmental Protection Agency and the  6 Colorado Health Department. And that is as it should be and  7 that should make you happy. Because cleaning up these sites  8 like this or making nuclear weapons is not a core business  9 of the United States Fish & Wildlife Service, managing  10 National Wildlife Refuges is part of our core business.  11 One of the issues that we're facing here is  12 this time line. This is not a typical time line for a doing  13 CCP. It's very unusual for us to do a Comprehensive  14 Conservation Plan for a piece of property that we have not  15 already acquired. We're here at this phase in this plan  16 because of a special law that was passed and statutory  17 requirements passed by congress that we complete this plan  18 by December of 2004. There are some other important things  19 to know in that legislation.  20 Number one is that cleanup always trumps  21 refuge activities. We're being required to prepare this  22 plan before all the cleanup decisions are made, before  23 institutional control plans are approved, before there are  24 remedial investigations and feasibility studies conducted,  25 and before we've even done some of the things we normally do 

 36  1 like our Level 3 contaminant survey.  2 We are basing this plan, presenting these  3 alternatives to you with the pretext and understanding that  4 there are decisions that are made in a public process that  5 we have input to and all of you have input to and the site  6 will be certified by the Environmental Protection Agency  7 prior to transfer. The plan we have presented tonight is  8 the plan we would implement following that cleanup and  9 certification. And it's been talked about that this could  10 happen in 2006 to 2008 time frame. If the certification is  11 not done until 2012, we won't get this land, we won't  12 implement that plan until such time that that becomes  13 effective.  14 Now, because of all these other things going  15 on, that may change things. For example, we have proposed  16 this hunting program, we have collected tissue samples from  17 26 deer last year. Right now they are on their way to a  18 laboratory to be analyzed for radionuclide contamination.  19 If it comes back that those deer would not be safe to eat,  20 that's definitely going to impact what we find here.  21 The characterization of potential  22 contamination in lands that are to be transferred to the  23 Service or proposed to be transferred is not yet complete.  24 We have asked to, along with the EPA and State and DOE, have  25 agreed to take significant additional sampling of the soils 
 37 

 1 in the buffer zone. I think they're going to grab  2 500-something more locations. Is that going on right now,  3 Mark?  4 MR. SATTELBERG: Yes.  5 MR. RUNDLE: This plan is written with the  6 knowledge we have today. It we get different knowledge that  7 there is in fact dangerous levels of contamination in these  8 lands that may be transferred, that obviously is going to  9 affect what ideally has to do with cleanup and how it will  10 affect the refuge.  11 So this is going to be an ongoing  12 discussion. I would encourage all of you to participate  13 with the RFCA parties who will make the decisions about the  14 cleanup and that process. There are appropriate places to  15 do that that are not within the scope of our  16 responsibilities or with the CCP.  17 I wish that this many people would come to  18 the Citizen's Advisory Board meetings where last month the  19 DOE was there to present their status reports, and I think  20 there was two people there. So I encourage you to  21 participate through the Citizen's Advisory Board which meets  22 monthly and is a formal advisory committee through the  23 Department of Energy. You can also take things directly to  24 DOE, EPA, State or to, if you live in one of the Rocky Flats  25 communities, to your local elected officials who represent 

 38  1 you at the Rocky Flats Coalition of Local Governments. So  2 there are, I think, good venues for these things to be  3 raised to the appropriate decision makers.  4 There have been several statements tonight  5 about, and we perceive, about the dangerous nature of the  6 entire site. And we certainly want to consider that. What  7 we know today -- my understanding is, and from contaminants  8 folks reviewing the data, that we have no scientific data  9 right now that indicates that there's dangerous levels of  10 contaminants in the lands outside what DOE has proposed to  11 retain here. There is some, there's very little level.  12 I don't believe that EPA or the CCP is  13 actually requiring any remediation of any sites that are  14 proposed to transfer to the refuge. Is that correct, Mark?  15 MR. SATTELBERG: That's correct.  16 MR. RUNDLE: So there's nothing in the lands  17 that this plan would apply to that has levels of  18 contaminants that we know today that are high enough to  19 require a cleanup to be protective of the most exposed  20 person, which is the refuge board.  21 So the last thing I'll say is that I was  22 happy to learn today that DOE has decided to sponsor an  23 additional public workshop to address some of the questions  24 that you have that have been directed to us in that they are  25 better prepared to answer and respond to. I'm sure they'll 
 39 

 1 make public notification that I understand will be held at  2 3:00 in the afternoon on April 14th at Building 60.  3 And that's my statement I need to make. And  4 we'll try to answer questions that runs within the scope of  5 our process. Thank you.  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25 

 40  1 MR. HUGHES: So if you have questions, we'll  2 write them down and we will get a cluster of them.  3 MR. RUNDLE: There were some questions during  4 the comments.  5 Q. I have two questions. Is the 6,200 acres,  6 does that include any of the part that DOE is retaining, or  7 in other words, how many acres are you working with?  8 MR. RUNDLE: 6,238 acres is the extent of the  9 federal ownership on the site. Everything. I don't have  10 the exact measurement of this. And the shape of this may  11 change slightly based on these cleanup decisions that  12 haven't been made.  13 I believe the DOE is projecting now is about  14 1200. I think that's about right, about 1200 acres. And of  15 course this includes terminal ponds, that's where the  16 landfill that they're going to have to keep, and I believe  17 this is a 7 picocurie line that goes out here towards  18 Indiana from the 903 Pad.  19 The current data, most all the rest of this,  20 is 5 or less from the data that's been collected so far.  21 Q. And my second question, are you aware of the  22 projected growth of homes? It would be 2,000 homes that the  23 builders are hoping to get directly south of the plant.  24 MR. RUNDLE: We're anticipating that the  25 southern boundary will develop into a southern interface 
 41 

 1 boundary with housing or some other type of commercial  2 development. We'll open public land up here, mostly public  3 land to the west and to the east, but we are aware that  4 there are plan developments on the southern boundary.  5 Q. You said the radiation is low. How low is  6 low? How many picocuries or curies is it putting out?  7 MR. RUNDLE: The most I've seen is, this is  8 a 7 line, 7 picocuries the DOE will retain and everything  9 outside that is 5 or less. But we are taking additional  10 samples.  11 Q. What did they say was acceptable for humans  12 to be in contact with? How much?  13 MR. RUNDLE: Well, we're getting into stuff  14 that you need to address to the health physicists or the  15 State and I'm not qualified to answer that. But I can tell  16 you this, that ideally we will retain all the properties  17 where institutional controls will be required in order to be  18 protected.  19 Like I said, our plan is based on the idea  20 that this cleanup will be certified and that EPA is not  21 going to certify if it's not safe for people to do the  22 things that we're proposing.  23 We did have a question in one community, a  24 couple of individuals suggested relocating prairie dogs on  25 the site. We're not proposing to do that for a couple of 

 42  1 reasons. Number one, prairie dogs are an animal, one of the  2 burrowing animals that would have the potential to impact  3 the maintenance of the refuge because we're going to have  4 stuff left subsurface in here. So we don't want to  5 exacerbate any issues we may have with prairie dogs leaving  6 the refuge.  7 The other issue is that there's a biological  8 issue with prairie dog conservation. The National Wildlife  9 Refuge does not serve as dumping grounds for unwanted  10 wildlife. And we know that's a difficulty for many of the  11 municipalities around here. I don't think accepting these  12 animals into the refuge system assists jurisdictions and  13 developers and the conservation community in resolving that  14 issue and leaving the prairie dog conservation throughout  15 the lands.  16 Q. What's the status of the MOU? And my  17 concern is mineral rights. I know you said you're adamant,  18 you don't want land transferred to you that has mineral  19 rights, but if that does happen, will that reopen the CCP to  20 deal with the environmental impact?  21 MR. RUNDLE: First of all, the statute also  22 requires us to do the CCP. We write the MOU with the  23 Department of Energy over what land is to be transferred.  24 It's my understanding that the assistant secretary is not  25 happy with some of the language, we're going to have to come 
 43 

 1 back to it and I don't know where that's at right now.  2 The mineral rights are preserved by the  3 statute outside of the property lines that existed at the  4 time that the law was passed or preserved. Our position is  5 that we don't want to accept -- on these maps indicates  6 areas that are currently permitted by the State of Colorado  7 and Jefferson County for gravel mines. We're not  8 necessarily opposed to the transfer of, why isn't that still  9 outstanding, private mineral rights such as coal, gas or  10 oil, we do not want to bring lands into the refuge system,  11 put up boundary signs and then have that destroyed by strip  12 mines. That's an unresolved issue at this point.  13 Q. Two simple questions. One is, as a user of  14 an area, which I have some questions about wanting to go  15 there, is there a method for me to monitor the amount of  16 dust, stuff in my bicycle tires that I might be bringing  17 home to my family? It's one thing to clean up a space such  18 as this, but to clean up, you know, once the stuff goes into  19 the dryer it affects all my clothes and everything else.  20 So I guess the question is, is there a means  21 of measuring these picocuries or energy that this stuff is  22 emitting so that I, in my own mind, can be safe that I'm  23 below some threshold? Like when you go on site, are you  24 wearing a tag?  25 MR. RUNDLE: No. 

 44  1 Q. How do you know -- because a worker who works  2 out there, they would be wearing a tag.  3 MR. RUNDLE: Well, the way we ask the  4 question about medical -- like at the arsenal they are on a  5 medical monitoring program where our employees are not on a  6 medical monitoring program at Rocky Flats. And I think the  7 only people who are are actually the people that work in the  8 highly contaminated plutonium buildings.  9 And again, to answer your question, I don't  10 know. I'm assuming there's technology to do that. I don't  11 know how much it costs or where to get it, but if there's  12 not a certification that it's safe for these uses, there's  13 not going to be a refuge and we're not going to have the  14 trails open either.  15 I think we talk about in the plan, we do have  16 a safety goal. I think that we do want to tell people with  17 signage and materials about the history of the site and  18 people know what the site used to be. We haven't got  19 down -- that's a real step-down plan when we get into  20 writing the text with signs and things like that, but  21 whether you use the signs or not, of course will be your own  22 choice. But we're basing this on the fact that it will be  23 clean and safe to use with what we're allowing.  24 Q. You mentioned that there's contaminants that  25 you tested for. I was wondering what those were, the 
 45 

 1 chemicals exactly, and how deep was your testing?  2 MR. RUNDLE: That's really outside the scope  3 of the plan. I think that the most contaminants of concern  4 are what people refer to as radionuclides, mostly plutonium,  5 and the exact extent of the testing, I would engage you to  6 go to DOE's open house and ask them that question.  7 Q. Mine is kind of two part, but the CCP, EIS,  8 when was that published in the Federal Register and what was  9 wrong with it that it got -- the date got pushed farther  10 out?  11 MR. RUNDLE: Laurie, what was the initial  12 date it was published?  13 MS. SHANNON: It was published on February  14 19th and the glitch was that it got published in the Federal  15 Register, but it didn't get published by the EPA. And the  16 EPA's action starts the clock on the public comment period.  17 So it's been published. We expect the EPA notice to go in  18 on Friday, so it's actually a benefit to the public because  19 it is extended to April 6th.  20 MR. RUNDLE: Any comments submitted  21 immediately on February 19th, in that initial publication,  22 are going to be received and considered.  23 We're not going to shorten it on the front end that way.  24 Q. Two quick questions. One, if you could  25 explain what a Level 3 contaminant survey is, and then the 

 46  1 second is, what actions will Fish & Wildlife take in order  2 to prevent the seasonal off-trail hiking from going into the  3 retained area? I know that DOE will have some  4 responsibility for the institutional control, but what will  5 Fish & Wildlife do?  6 MR. RUNDLE: Good question. First question  7 was what was a Level 3 contaminant survey. Department of  8 Interior policy requires that we do a contaminant survey  9 prior to acquisition of any lands into the National Wildlife  10 Refuge system. So we do this when you farm land or any  11 other lands that come into the system.  12 A Level 3 survey is the highest level and  13 actually involves a plan that includes analytical type of  14 testing of either byota or soils and water by our  15 contaminants biologist. Mark Sattelberg in the back will be  16 the design lead on that. Level 1 survey is the refuge  17 manager walks around, looks for leaking drums and things  18 like that.  19 So part of the Level 3 we are doing is the  20 testing of these deer tissue and organ samples. And there  21 will be some additional biotesting and it will probably be  22 later this summer when that's taken care of. It gives us an  23 opportunity that if there are things we are interested in,  24 we're going to be looking at that stuff.  25 Q. Are you testing deer only? 
 47 

 1 MR. RUNDLE: Right now we've got the deer  2 samples. 26 animals were harvest -- sorry, I jumped out of  3 order. Chronic waste and disease testing, last year we took  4 five tissue samples from each of those deer, and Mark, I  5 don't know what your plans are for other biotesting.  6 MR. SATTELBERG: We haven't really developed  7 areas. Right now we're looking at areas of potential  8 concern that DOE may not have looked at before or have  9 looked at and not sampled that we think should be sampled.  10 So we're in the process of reviewing all the historical  11 data, looking at areal photographs and things like that.  12 MR. RUNDLE: I didn't get to her second  13 question, which was how do we control people --  14 Q. With the off-trail hiking, seasonal off-trail  15 hiking.  16 MR. RUNDLE: There was kind of a question  17 during testimony as to why we would have this off-trail use  18 allowed. And that goes back to the public uses of the  19 refuge, which include things like wildlife photography and  20 wildlife observation. So if you're going to invite people  21 or allow serious bird-watching, it makes it tough to  22 restrict that person who wants to take a picture of a  23 wildflower or get to a good view on that small bird to  24 always just stay on the trail. And we will have to watch  25 how much of that stuff occurs. 

 48  1 Every refuge that I'm aware of, and I've  2 worked a lot of them, has closed areas. Areas that are  3 closed for wildlife sanctuary purposes or may be closed to  4 protect cultural resources or areas around our facilities  5 and things like that. We control that through signage,  6 brochures, regulations and active law enforcement. We have,  7 I think, a pretty good deal of experience doing this.  8 I can give you what I think is a good  9 example. The last refuge I was at in Southern California,  10 the Tijuana Slew Refuge, had several critically listed  11 endangered species, had very hazardous areas, the waters at  12 the Tijuana Estuary presented a significant biohazard to  13 human contact because of effluent coming off the Mexican  14 side. Our biologists had to be inoculated for hepatitis and  15 typhus and all types of diseases, but still we were still  16 able to have public access on trails for people to do  17 bird-watching and things like that down there. And we'd  18 control that with signs and law enforcement, I think very  19 effectively.  20 We did not have problems with people passing  21 signs and swimming in the river. So that's what we will  22 do.  23 Q. Dean, as a lot of people, I'm also concerned  24 about the fact that Fish & Wildlife will not address the  25 contamination on the site and that the Draft EIS speaks 
 49 

 1 about the pristine site, that it could be on the Southern  2 California side rather than a nuclear weapons plant. And  3 you are the lead agency under the NEPA law, and as a lead  4 agency under the NEPA law, you do have to look at the  5 effects of this particular action, the CCP on the human  6 environment. In other words, you do have some  7 responsibilities. And I do realize that this is something  8 that Fish & Wildlife wanted to acquire, like so many of the  9 beautiful wildlife refuges, but it is still, under the law,  10 a requirement that you do look at public safety.  11 This is just a comment I would like to make.  12 And then I have a couple of questions. I'm very pleased  13 that you're finally analyzing the deer that you have in your  14 freezer. I would like to know what you're going to analyze  15 it for, which part of the tissue. The muscle is the part  16 that people would eat, if they will be hunting on the site.  17 I know the gonads and other parts have been analyzed. Are  18 you going to analyze the muscle tissue?  19 MR. RUNDLE: Mark, you wrote the specs on  20 that, you want to answer that question.  21 MR. SATTELBERG: The five tissues that we  22 collected were the lung, liver, kidney, muscle and bone  23 that we're looking at, particularly the muscle and the liver  24 for human consumption. We're looking at the bone because  25 that's typically where the plutonium will end up, and also 

 50  1 the lung because of inhalation. So see what kind of  2 inhalation loads they're getting and kidneys will also  3 accumulate americium and uranium.  4 Q. And the last question I have for you, if you  5 look at the DOE maintaining the area which you call the  6 blob, which just looking at it, I would say it's within one  7 fourth to one third of the total area, and I'm really  8 concerned about the fact that due to that fact that we don't  9 have an MOU, we do not know what's happening in this large  10 area of your refuge. We don't know about signs. There is  11 talk about a seamless refuge.  12 What is there to prevent children from one of  13 the trails south of that getting into the equipment, water  14 treatment, this type of thing?  15 MR. RUNDLE: I think the answer to that is  16 that the institutional control plan is not complete yet and  17 we all need to engage the parties with a robust discussion  18 of what those institutional controls will be on that site.  19 So that will not be our decision. I can tell  20 you that for now we definitely want that site to be  21 marked -- boundaries to be marked as permanently as  22 possible.  23 Q. But you keep talking about a seamless refuge.  24 MR. RUNDLE: I said we need it to be marked  25 so that we and the public know where the two boundaries are 
 51 

 1 clearly. And if it's safe, we would prefer that that  2 boundary not preclude the movement of wildlife across the  3 site. So I think that's a discussion about what types of  4 signage and monuments or markers or fencing will be required  5 there. And I think that is something that all of us need to  6 engage the RFCA parties about that area.  7 We do know in that area there's going to be  8 residual contamination left. It's a concern to us, it's a  9 concern to you. And I think personally, I'm not too  10 concerned that the surface of the refuge is going to be  11 unsafe for us to work on or for you to walk on when the  12 cleanup is done. But 30, 40, 50 years down the road, I  13 think long-term stewardship is what we all need to be  14 concerned about and we all need to engage in that  15 discussion, but it's not within the scope of this plan.  16 MR. HUGHES: I've got other questions so I  17 want to move on.  18 Q. I would like to have one follow-up, and that  19 is, the prairie dogs do go down seven feet, isn't that  20 right?  21 MR. RUNDLE: Yes.  22 MR. TRENHOLME: Dean, you've used the term  23 RFCA.  24 MR. RUNDLE: I'm sorry. The cleanup is being  25 conducted under an agreement between the Department of 

 52  1 Energy, the EPA and the State of Colorado that's call the  2 Rocky Flats Cleanup Agreement. And the RFCA parties, the  3 decision makers are the DOE, the EPA and the State of  4 Colorado.  5 Q. I live in Boulder across the street from the  6 National Institute of Standard Technology and we've had for  7 years, they've kind of had an open flow-through policy of  8 access through that area and now we're looking at a fence  9 opportunity of 8-foot-high metal stakes every 12 inches  10 apart. And this appears to be a nice place to put a wall of  11 stakes eight to ten feet high to inhibit areas -- this  12 retained area full of contaminated ground. I'd have the  13 kind of marker, a fence, to inhibit flow of traffic through  14 it.  15 MR. HUGHES: Is the question, why isn't there  16 a fence?  17 Q. Is there going to be a fence and is it going  18 to be eight feet high?  19 MR. RUNDLE: I don't know how to answer that  20 question. It's not our decision. It's not within the scope  21 of this plan.  22 Q. You said it was seamless earlier.  23 MR. RUNDLE: We have said that we would  24 prefer a seamless landscape that would not prohibit the  25 movement of wildlife. Now, that's based on whether the RFCA 
 53 

 1 decision makers decides whether that's a safe thing or not.  2 If the EPA, DOE and State Health Department say there needs  3 to be a concrete wall with glass shards on the top of it,  4 that trumps anything we do in that plan. And that's what  5 will be there.  6 MR. HUGHES: I want to ask again that we  7 stick to the question, because that's what this portion of  8 the agenda is for. And I'm going to ask you to hold the  9 preface part.  10 Q. I just want to have you clarify that it is  11 the Fish & Wildlife's jurisdiction or authority to decide  12 whether to put a fence or signs or whatever the  13 boundary demarcation might be. The buffer.  14 MR. RUNDLE: No, that is not our decision,  15 responsibility or authority to make that decision. We will  16 provide input to those decision makers about what we think  17 is appropriate, but that input will also come from you and  18 many other people.  19 We will decide what goes around the perimeter  20 of the property that becomes National Wildlife Refuge and  21 all four proposals call for the maintenance of the current  22 five-strand barbed wire stock fence that surrounds the Rocky  23 Flats property. It will be posted with National Wildlife  24 boundary signs that say National Wildlife Refuge boundary,  25 all unauthorized entry prohibited. Unauthorized be the key 

 54  1 word.  2 Q. I'm curious about the criteria for hunting  3 two weekends out of the year, low impact weapons. What is  4 the origin of that idea? What's the reasoning behind it?  5 MR. RUNDLE: Okay. That's a good question.  6 That's germane to the plan. The National Wildlife Refuge  7 system is what we call a primary system of public lands.  8 We're not multiple use like the forest land. The organic  9 legislation, like the Refuge Improvement Act of '97,  10 congress designated six priority public uses of the National  11 Wildlife Refuge system that are all wildlife dependent.  12 They include hunting, fishing, wildlife observation,  13 wildlife photography, interpretation and environmental  14 education. All these things need abundant and diverse  15 wildlife to conduct.  16 We hunt on refuges for two reasons. One is  17 to provide a wholesome outdoor recreation experience for  18 people who want to do that, and particularly large ungulates  19 such as deer and elk to control populations and make sure we  20 don't have habitat damage caused by overpopulation.  21 Because it is a priority public use, we are  22 mandated by that organic law to provide those priority  23 public uses whenever they are compatible with the purposes  24 of the refuge, meaning they don't materially detract from  25 our ability to manage and restore ecosystems and preserve 
 55 

 1 endangered species and preserve research and preserve native  2 flora and fauna, which is the purpose of Rocky Flats.  3 So we would propose that we would have  4 limited hunting that would provide some recreational  5 opportunities for some groups and also help us maintain deer  6 and elk populations at a sustainable level for the habitat  7 out there.  8 We are particularly concerned about not  9 wanting to have the establishment of any resident elk  10 population that comes down to the prairie and stays on the  11 prairie. This is happening other places along the Front  12 Range. There's a lot of conflict that results from that.  13 We hope we'll have corridors where large  14 ungulates can move on the prairie and back up to the  15 mountains, but we don't want to have the situation that  16 we've got up in Loveland where we've got hundreds of elk  17 that are moving out to suburban areas and staying there all  18 the time. They would have the ability to greatly impact the  19 important endangered species habitat and the rare shores of  20 Rocky flats.  21 Q. Would you consider using cross-striping or  22 something like for the DOE area so you can see through it?  23 Because a lot of your maps have some very good data on it,  24 but you can't see through that green blob in the middle.  25 MR. RUNDLE: You want to see what the habitat 

 56  1 types are under the blob?  2 Q. Right.  3 MR. RUNDLE: We don't know how to answer that  4 because we don't know what the final regrade and revision  5 plans are going to be.  6 Q. Somebody should know, because I think it  7 would help people see continuity of the site.  8 MR. RUNDLE: So you'd like to present in the  9 future or in the final planning, a map that would show the  10 existing habitat out there, including the DOE retained land?  11 Q. It's not so much a comment as a question as  12 to why you didn't do it that way?  13 MR. RUNDLE: We didn't do it that way because  14 we tried to make it clear to the public that this plan does  15 not apply to that retained property. We didn't want that  16 confusion.  17 Q. As more information comes in from your 500  18 steps towards better characterization of the site and the  19 Level 3 plan and from other sources, DOE, and if you witness  20 that no plan is perfect, then will you blend these plans or  21 will you come up with yet another plan? How hard and fast  22 are these four alternatives?  23 MR. RUNDLE: Well, the four alternatives that  24 we're presenting to you, we believe is -- any one of these  25 could achieve the purposes of the refuge, the intent of 
 57 

 1 congress and the Refuge Act and missions and goals of the  2 Refuge Act and also the requirements for safe uses and  3 things like that.  4 We've proposed Alternative B. I guess we  5 always try to practice -- it's a new word for us in refuges,  6 but adaptive management. As new information comes forward,  7 the safety of the sites from the contaminant level, new  8 invasive species, we have to adjust to do those things. If  9 we get that information after a record of decision is  10 signed, I think we have to take a look at how much of the  11 plan that would impact and determine whether we have to  12 reopen that rod and come back to the public for another  13 process or if it was a minor adjustment. It might be just a  14 simple matter of, this is not going to work over here, we're  15 not going to do that part. I think it depends on the extent  16 and nature of that new data.  17 Q. It's not a follow-up, but it's a separate  18 little question. It's probably easily answered, but why in  19 Alternative C does Lindsay Ranch have to be obliterated?  20 MR. RUNDLE: Because that is a legitimate  21 alternative for meeting the goals of the Act which says,  22 preserve it in accordance with the National Historical  23 Preservation Act. The site is not national registered  24 eligible. It's an aesthetically pleasing site, it's  25 pleasing to people in the local community, it's not a 

 58  1 historical significant site.  2 Also, Alternative C is, to the extent  3 possible, returns this site to pre-settlement conditions.  4 Pre-settlement there was no buildings on that site and there  5 was no pond there, so that's why they were removed in that  6 alternative.  7 Q. What's been presented, I've got a  8 contaminated area, I'm going to have a contaminated area in  9 the middle and a nice clean area around it. Now, how has  10 Fish & Wildlife looked at how they would prevent a prairie  11 dog or an ant or a deer or anybody else carrying this  12 contaminated material across that line?  13 MR. RUNDLE: DOE is going to be responsible  14 for probably institutional controls. We haven't signed up  15 for any participation in institutional controls at this  16 time. I think we do have an obligation to help protect that  17 site from what we can and so we would not do things to  18 encourage prairie dog movement.  19 There are prairie dogs on the industrial area  20 now. We provide recommendations to DOE about their  21 revegetation of the industrial area following demolition,  22 we're encouraging them to use appropriate native vegetation  23 that would discourage prairie dog colonization of the site.  24 And I don't know what the institutional  25 control plan will be. I'm assuming we'll recommend 
 59 

 1 certainly that it requires regular inspection to look at  2 burrowing animals, particularly on landfills and things like  3 that, but we haven't signed up yet to assist DOE with those  4 types of things in the future.  5 Back to the question about relocation,  6 because we know that we don't want burrowing animals in that  7 area, so we don't want to encourage them to expand and we  8 also don't want prairie dogs to expand in the tall grass  9 ecosystem where the black tail is not a native species, and  10 could actually impact that special tall grass area on the  11 west.  12 Q. How do you control the overpopulation, or is  13 there any, of the Rocky Mountain Arsenal? And if there  14 isn't a problem, maybe there wouldn't be a problem also at  15 Rocky Flats.  16 MR. RUNDLE: The equivalent plan for the  17 Rocky Mountain Arsenal is a CNP, but it's basically the same  18 thing. They changed their name in '97. And that allows us  19 to use culling, sharp shooting to control deer populations,  20 if needed, but it also has a provision for hunting to occur  21 after the cleanup is completed over there. That's still an  22 Army-owned site, we expect some land to be transferred to us  23 later this month, but we would not implement that hunting  24 provision until later.  25 Q. Have you had to cull up to this point? 

 60  1 MR. RUNDLE: We have culled in the '90s.  2 Recently in the last several year, the coyotes have been  3 doing a good enough job keeping the population down.  4 Q. What quantity of chemicals have you found in  5 the soil, such as carbon tetrachloride?  6 MR. RUNDLE: That's outside of the scope of  7 the plan, but I'm only aware that there are some hazardous  8 wastes in the industrial area. There's a carbon test plume  9 that's being treated with a groundwater treatment system.  10 It doesn't affect the land that we expect to be transferred  11 to Fish & Wildlife Service.  12 Q. Would cost be a consideration in selecting  13 one of these alternatives, like if you don't have any money  14 you would just --  15 MR. RUNDLE: One guidance I gave to the plan  16 team was let's make plans that are reasonably achievable  17 given budget environments. We're funded by annual  18 appropriations, like other federal agencies, and there is a  19 funding chart and what we expect all these alternatives to  20 cost. I think A was the cheapest, C was the most expensive,  21 or D was the most expensive, C was the next most expensive,  22 and the preferred alternative was the second most expensive,  23 B. The proposed alternative would be a staff of four and  24 would cost $16 million, approximately, over the 15 years of  25 the plan, about a half million dollars operating budget. 
 61 

 1 MR. TRENHOLME: The decision makers --  2 MR. RUNDLE: The regional director.  3 MR. TRENHOLME: The regional director will  4 look at the cost of all the alternatives and use that  5 information in making their final decision.  6 MS. SHANNON: Just one other thing, we're  7 required to put sort of like a caveat paragraph in the front  8 that we need to do this planning, but by virtue of having  9 the plan doesn't guarantee that we'll get the funding that  10 we want.  11 MR. RUNDLE: The next two years will be  12 really bad, so.  13 Q. How does the -- I'm curious how the  14 process -- you said you had to come up with an alternative  15 by December 2004?  16 MR. RUNDLE: The statute says we will  17 complete this process and have an approved CCP within three  18 years of the passage of the law, which was signed by  19 President Bush on December 28th, 2001. So our three years  20 expires December 28th.  21 Q. How do the rest of the communities weigh in?  22 This is a public comment section now, how are the  23 communities, their city council or how --  24 MR. RUNDLE: That's a good question. We had  25 some special things we had to do because of the special law, 

 62  1 so we started the process in February 2002 meeting with the  2 representative governments in the Rocky Flats Coalition of  3 Local Governments. We had to consult with all of those  4 seven governments, plus the cities of Thornton, Northglenn,  5 Golden, Lafayette and Louisville with the governor's office,  6 the Office of the Attorney General, State Health Department,  7 EPA and Citizen's Advisory Board to develop a public  8 planning process for Rocky Flats. That was accomplished in  9 June of 2002.  10 This is the third round of public meetings we  11 had. We had the scoping sessions in September of 2002 and  12 we presented these alternatives from public comment last  13 May, so this is -- and that was all to develop this Draft  14 plan. So now we've got the Draft, we're in a public comment  15 period. When the public comment period is over, the  16 planning team will go back, we'll consider the info we've  17 had, prepare final documents. At that time the CCP and EIS  18 will be split so there will be two booklets at the end, the  19 Comprehensive Conservation Plan and Environmental Impact  20 Statement records. And we --  21 Q. Did you go to each specific government and  22 ask them -- the city councils and ask them for their  23 alternatives?  24 MR. RUNDLE: Absolutely. We made a  25 presentation last month at the February meetings of the 
 63 

 1 Rocky Flats Coalition and Local Governments, to the  2 Citizen's Advisory Board, and said throughout the process,  3 we will meet with anybody at any time to discuss that.  4 We've answered questions for presentations to optimist clubs  5 and open space advisory boards and if you have a group that  6 would like us to come and talk to you, we will be happy to  7 do that.  8 MS. SHANNON: $16 million is Alternative D,  9 Alternative B is $8.6 million. Dean is not usually wrong,  10 so.  11 MR. RUNDLE: But I am sometimes.  12 Q. A while ago Anne Fenerty read Iggy Litaor's  13 letter. Iggy Litaor was the scientist working at Rocky  14 Flats that discovered in the spring of '95 significant  15 movement of plutonium on the site. He had added a P.S. to  16 his letter that Anne read a moment ago that I think is  17 pertinent for many things.  18 MR. HUGHES: Have you got a question?  19 Q. Yes, I do. I have a comment.  20 MR. HUGHES: We did that part.  21 Q. I have a recommendation to make.  22 MR. HUGHES: I want to make sure we get all  23 the questions and answers so we can finish that piece.  24 Q. I'll put his P.S. in the form of a  25 question. He wondered why your maps, your color maps that 

 64  1 are attractive to look at didn't provide useful information  2 regarding the actual condition of the site. And he  3 wondered, in fact, why there are no maps showing  4 the probability of exceedance of various plutonium  5 concentrations which would represent thresholds at different  6 levels.  7 And one could imagine, if we could web this  8 to the comment made earlier, recommendations made earlier  9 about informed consent, that people could see maps like  10 those, that Iggy Litaor proposes, showing all of the buffer  11 zones, however, less picocuries, I'd consent to my children  12 and myself going there. I'd make that as a recommendation.  13 The others, of course, are questions for you.  14 MR. RUNDLE: Well, the question I heard was  15 why don't our maps show that right now, and the answer to  16 that question is, like I said, they designate what they're  17 going to retain. The land would require institutional  18 controls to be protective. We're going on the understanding  19 that the lands that their plan applies to would be safe, but  20 we certainly accept that comment and we'll consider those.  21 Q. One thing I want to verify, you said that  22 Alternative B, you anticipated a staff of four?  23 MR. RUNDLE: That's correct.  24 Q. And Alternative D, do you know what the  25 staffing level is for that? 
 65 

 1 MR. RUNDLE: D was eight, C was five, A was  2 two. And let me caveat that those are new FTEs assigned to  3 Rocky Flats, all alternatives. Let's assume that this is  4 part of a refuge complex, and then for example, the law  5 enforcement support, administrative support, maintenance  6 trade-type support, heavy equipment operation is a shared  7 possible staff of Rocky Mountain Arsenal, so there would be  8 other people within my complex that would help at Rocky  9 Flats, but there will be four new personnel positions.  10 Q. So they would be U.S. Fish & Wildlife people  11 exclusively for this site and they would be able to draw on  12 resources, regional resources, as an example?  13 MR. RUNDLE: At my level they draw within my  14 refuge complex, but we do help each other out quite a bit.  15 And that does not also include FDE personnel, that would be  16 funded through the special fire program. Those firefighter  17 types would be additional to that.  18 Q. According to all the input to date, what is  19 the ratio of people that want open access, as in Alternative  20 D, as to the people that never want a human to step foot on  21 the site?  22 MS. SHANNON: We have tried to get away from  23 a vote. Now, it's not 500 people versus 20 people, because  24 that's not what NEPA is about. It's really looking at the  25 whole issue, you know, all the issues involved. But I will 

 66  1 say that to date we have had more people who have supported  2 the alternatives that have public use associated than not.  3 Q. People on either side of me are asking how do  4 you get this book. Did you bring extra ones tonight?  5 MS. SHANNON: If you want a copy of the  6 Draft, why don't you leave your name with us and we'll send  7 you a copy or you can download it off the web if you want to  8 see it immediately. Or if you want to wait a few days, I  9 can mail a copy to you.  10 Q. Can I suggest you bring some to the other  11 meetings, at least a few?  12 MS. SHANNON: What we would do, if people  13 want to have a hard copy, please give us your name and  14 address and we'll send you one over. We also have CDs  15 available so if someone wants a CD. The thing is this is a  16 pretty complex document, not everybody wants to read this.  17 So for some people, it's too much material, other people  18 it's not enough. So we'll respond in whatever you need.  19 Q. I think it's just been so well done and with  20 the index and everything, people, because they could ask  21 better questions and know more than just the superficial  22 part.  23 MR. RUNDLE: If folks want one, we'll send  24 them to you as long as they last. There's also copies in  25 this library and the public libraries in Arvada, Broomfield 
 67 

 1 and Boulder; is that correct?  2 MS. SHANNON: All the main ones, yes.  3 MR. RUNDLE: So they are available in  4 libraries.  5 MS. SHANNON: Lakewood and Golden too.  6 Q. You said that it's safe. Now, will you  7 re-test occasionally? Will you re-test for radiation  8 because it will spread with wind and stuff?  9 MR. RUNDLE: We're not proposing to do that  10 here. I think that's something you need to bring up with  11 the RFCA parties. When it comes to long-term stewardship, I  12 think long-term stewardship is logical. Really the most  13 critical thing to all of us is, is that stuff going to stay  14 for a long time.  15 Q. I thank you for your fair and openness and  16 exchange of information, but the fact that you provide us  17 four options implies that somebody somewhere -- that  18 somebody is going to make a choice or vote.  19 MR. RUNDLE: That's correct. Well, it won't  20 be a vote. That record of decision that the regional  21 director will sign will say that this is the plan.  22 Q. So he'll be the one to pick from these four?  23 MR. RUNDLE: He will pick a final decision.  24 It may be one of the ones that's up there, it may be one of  25 the ones that's up there now with modifications based on 

 68  1 what we heard during this public process. I can tell you  2 that the planning team, I'll make a recommendation. That  3 doesn't mean he has to accept it, but I think what the  4 planning team brings forward will have a significant impact.  5 MR. TRENHOLME: And the record of decision  6 will describe the basis for the decision.  7 MS. SHANNON: Just so you know, the order  8 thing is the next thing that will happen after we get --  9 the public comment period closes and we decide what we're  10 going to do. We will prepare the final EIS and then that  11 will be mailed out. And it's a 30-day period before it can  12 become -- you can implement it or whatever.  13 MR. TRENHOLME: 30 days between the final EIS  14 and the decision.  15 MS. SHANNON: Once we issue the record of  16 decision, then we'll prepare the final Comprehensive  17 Conservation Plan. So the CCP will be the last document to  18 come out.  19 MR. RUNDLE: And this particular plan we also  20 have to make a special report to congress, which you don't  21 normally have to do, so that will come out also.  22 Q. I was just wondering if you could clarify, on  23 the public comments, were these individually sent in or were  24 they sent in groups? Like who is in the most support of  25 recent -- 
 69 

 1 MR. RUNDLE: What I would recommend, do we  2 have extra copies of the scoping report?  3 MS. SHANNON: Yes.  4 MR. RUNDLE: I would encourage you to go to  5 that website and pull down the scope and reports. It's a  6 much shorter document. The scope of the report details the  7 comments that we got at our public scoping meetings, which  8 were diverse, and represent everything that's been stated  9 here tonight. And it also summerizes all the written  10 comments that were received either by letter or by E-mail  11 and does identify the individuals, organizations or  12 governmental agencies that made those written comments. And  13 I think that will be a good synopsis for you to kind of see  14 what we got in the last -- we recorded over 1800 comments  15 and that doesn't mean that it was 1800 letters, but we might  16 have got one letter and picked out of that six or eight  17 comments. Whether they were numbered or not, that could  18 have been several people who also said the same thing that  19 was recorded on a tear sheet at one of the public scoping  20 meetings and that was a comment.  21 So that's how -- but I would encourage you to  22 look at that scoping report for that type of information.  23 MR. TRENHOLME: You might mention, we'll do  24 something similar in the final EIS. We're going to go  25 through all the public comments we got and respond to all 

 70  1 the subsequent comments that were received and they'll be  2 either responded to categorically or we'll respond to the  3 letters from agencies and organizations individually.  4 Q. How heavily are those weighed, like in your  5 decision making process?  6 MR. RUNDLE: Well, I think they're very  7 important.  8 Q. I know like other situations where public  9 comments didn't necessarily go to how the decision weighs.  10 MR. RUNDLE: It's not a vote. The law  11 requires our agency to make a decision about the CCP and  12 that is not a vote because that's not the way the laws are  13 set up. But I think that the public comments are very  14 important to us. Everything that we hear. Just because a  15 recommendation is made, if that's not the decision, that  16 does not mean that that comment wasn't heard and considered.  17 And we clearly made changes to our  18 alternatives from when we brought those alternatives to the  19 public, and Laurie went over some of those. If you look,  20 there's one map in there that shows areas where we've  21 proposed several alternatives where we can use grazing or  22 prescribed fire as a management technique and designated an  23 area where we say we would not do that. And part of that is  24 that strip along Indiana because we know that's where 903  25 Plume was, we know there's a public concern about, or 
 71 

 1 perception for those types of activities to stir up residual  2 contamination. And part of the reason that's not drawn in  3 there is because of the comments we had from the public  4 about that particular issue.  5 MR. HUGHES: We've also gotten feedback on  6 our side, on the process side, about our ability to be fair  7 to everyone, give everyone the same amount of time, for  8 example, to comment. That's why the three minutes tonight  9 and why I'm asking people not to add comments, because  10 people are looking at whether or not everyone has exactly  11 the same opportunity to comment.  12 So the three minutes, we didn't just pick  13 that out of a hat, we wanted to give everyone as equal an  14 opportunity as we can. And that's why we made that rule.  15 MS. SHANNON: And we have to look across four  16 public meetings. So even though this is a small, relatively  17 small group tonight, if we end up -- we don't know if 200  18 people are going to show up or 50 people, so if we end up  19 with a situation where we have 200 people show up, we still  20 need to give everybody three minutes.  21 MR. RUNDLE: I will say this, that the  22 manner that the comments are made does not make an impact on  23 the effect or how seriously we'll take them. Clearly verbal  24 comments that we hear tonight are taken seriously, someone  25 sends us an E-mail tomorrow, their comments will be given 

 72  1 the same consideration.  2 Q. Now I'm curious. You said the regional  3 director will make the final decision?  4 MR. RUNDLE: That's correct.  5 Q. How much impact will he have or input or  6 pressure from politicians, from congress, or are those  7 obstacles or pressures, are they weighted evenly with what  8 the public wants versus what a politician or a government  9 official wants?  10 MR. RUNDLE: We have a beautiful system that  11 separates executive branch and the legislative branch.  12 We're here because congress passed a law and we're the  13 executive branch and we have to execute that law. Congress  14 doesn't have to go through NEPA to pass a law, they just  15 make it a law and then that's it. NEPA applies to decisions  16 of the executive branch.  17 In this case, statute, regulation and policy  18 delegate the authority to sign this record decision to the  19 regional director. We brief him at each step along the way.  20 Before this document was released, it had to be approved for  21 release by the director's office of the Fish & Wildlife  22 Service and I can assure you that there are political  23 appointees within the Department of Interior that review  24 this before it goes out to the public.  25 And I can tell you, we maintain a regular 
 73 

 1 dialogue with the elected representatives as well in terms  2 of your congressional leaders, so anything is possible. But  3 I don't anticipate that there will be unusual political  4 pressure to go one way or the other on this.  5 Congress spoke pretty clearly about what they  6 expected when they passed this statute, said this will be a  7 refuge, you will manage these things. Wildlife dependent  8 public uses will be the priority public uses of the site.  9 So I think the intent of congress was pretty clear.  10 Q. Are you going to reopen for comments after  11 you get the research back on your soil samplings and game  12 samplings? Because I think a lot of the reasons -- people  13 are uneducated and that's one reason that they're not able  14 to comment. Are you going to make those available to the  15 public?  16 MR. RUNDLE: Well, any documents that we have  17 are public records. And if they're not unreleaseable  18 because of privacy concerns, we'd certainly share those with  19 folks, the results. And again, I'd have to go back and say  20 how that will effect -- what we're doing now will effect on  21 the extent of that new information. But there is no further  22 public comment period on this plan after April 26th.  23 Q. Could I make kind of an announcement,  24 something that's coming up? You kind of referred to it a  25 second ago. There's going to be a series of meetings on 

 74  1 comprehensive risk assessment and this is actually the  2 document that's much more important than what we're hearing  3 tonight as far as contamination is concerned. This is the  4 report that's going to have all of that material in it, all  5 the maps that show the contamination, all of the results of  6 the tests and everything else. This is something in the  7 public process, and it's been attended by four or five  8 people, a lot of the meetings. It would be fantastic to  9 have a group like this at one of those meetings. So I just  10 urge people if they're interested in that, that might be a  11 better venue.  12 MR. RUNDLE: Thank you.  13 MR. HUGHES: I want to thank you all for  14 coming. I know the planning team greatly appreciates your  15 efforts.  16 . . . WHEREUPON, the public hearing was  17 concluded at 8:20 p.m.  18  19  20  21  22  23  24  25 
 75 

 1 CERTIFICATE OF DEPOSITION OFFICER  2 STATE OF COLORADO )  )  3 COUNTY OF DENVER )  4  5 I, SANDRA A. SMITH, Certified Shorthand Reporter  and Notary Public, State of Colorado, certify that said  6 public hearing was stenographically reported by me at the  time and place heretofore set forth, and was reduced to  7 typewritten form under my supervision as per the foregoing;  8 That the foregoing is a true and correct  transcript of my shorthand notes then and there taken;  9  That I am not a party to nor in any way connected  10 with any of the parties to said action nor otherwise  interested in the outcome of this action.  11  My commission expires May 23, 2005.  12 IN WITNESS WHEREOF, I have affixed my  signature and seal this 22nd day of March, 2004.  13  14  15 ___________________________________  Sandra A. Smith  16 BOVERIE, JACKSON, BUSBY & LA FERA  1735 East 16th Avenue  17 Denver, Colorado 80218  303-329-8618  18  19  20  21  22  23  24  25 
 1 

 1 PUBLIC HEARING ON  2 THE DRAFT ENVIRONMENTAL IMPACT STATEMENT  3 AND COMPREHENSIVE CONSERVATION PLAN  4 FOR THE ROCKY FLATS NATIONAL WILDLIFE REFUGE  5  Thursday, March 11, 2004  6 6:30 p.m.  7 at  East Recreation Center  8 5660 Sioux Drive  Boulder, Colorado  9  10  11 Panel Members: Richard Trenholme  Mike Hughes  12 Laurie Shannon  Dean Rundle  13 Jody Erikson  14  15  16  17  18  19  20  21 TAKEN BY: SANDRA A. SMITH, CSR  22  23  24  25 

 2  1 INDEX  2 INTRODUCTION BY MR. HUGHES.........................3  3 INTRODUCTION BY MS. SHANNON........................7  4 COMMENTS MADE BY THE PUBLIC.......................15  5 QUESTION AND ANSWER PERIOD........................73  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25 
 3 

 1 MR. HUGHES: If I could ask everybody to  2 take a seat, we'll get started. For those of you who are  3 just coming in, we want to make sure that you get signed up  4 and we'll get started as soon as you sign up.  5 I want to thank all of you for coming tonight  6 and welcome you to our formal public hearing on the Draft  7 Environmental Impact Statement and Draft Comprehensive  8 Conservation Plan for the Rocky Flats National Wildlife  9 Refuge.  10 My name is Mike Hughes and I'm part of the  11 planning team and I want to say just a couple of words about  12 how tonight will proceed. We have agendas here at the door,  13 so as you're coming in, feel free to grab one, follow along  14 and I'll explain a little bit about how tonight is going to  15 go.  16 We got a lot of feedback about previous  17 public meetings and what we ought to do in terms of this  18 one. Many people say that what we needed was what NEPA in  19 fact tells us we ought to do, which is a formal public  20 hearing. We have a court reporter, as you can see, so we  21 will have a verbatim transcript of the comments made here  22 tonight.  23 And one of the other things that we heard is  24 we should provide an opportunity for speakers to be heard,  25 so no small groups, and that everybody should get the same 

 4  1 amount of time to comment.  2 So here's what that means. Each of you will  3 be given three minutes. And since I don't know how long  4 three minutes is while I'm talking, we'll help remind you of  5 how long three minutes is. So as you're speaking, making  6 the comments on the Draft Environmental Impact Statement and  7 the Draft Comprehensive Conservation Plan, we will give you  8 notice of when it's two minutes left, when it's a minute  9 left, and then 30 seconds left and then when you have  10 exceeded the three minutes. And each of you will have the  11 opportunity to do that.  12 The best way to do that is to sign up. The  13 sign-up sheet is there if you wish to speak. If you haven't  14 signed up yet, please do so and we will call two people at a  15 time so you know who's next.  16 In terms of making that successful, we do  17 actually want everyone to be heard for the entire three  18 minutes and so it will be important that you give your  19 respect to the speaker by allowing them to be heard to  20 completion. And then we're going to ask that they do the  21 same for you, so giving everyone an equal opportunity to  22 speak and to be heard. So please stay within the time  23 limits and not add your voice to the voice that's working up  24 here.  25 We ask that you focus your comments on the 
 5 

 1 documents, the Draft Comprehensive Conservation Plan and the  2 Draft Environmental Impact Statement for the refuge. This  3 is comments to the Fish & Wildlife Service on those  4 documents, but it is not the only way that you can make  5 comments. So it isn't just three minutes or nothing, there  6 is a website, which is on your agenda, so feel free to add  7 comments there. We have written comment forms so if you  8 choose not to speak tonight or wish to add to what you say  9 tonight, you can do that in writing.  10 So the comment period is open through April  11 26th. So you have up until that time to send us E-mails, go  12 to the website, send comment forms in writing, by whatever  13 means, as well as your three minutes tonight.  14 We have left ourselves a bit of a safety  15 valve, depending on the number of people that sign up and  16 the size of the group, that if there is time left, everyone  17 who wishes to take their three minutes has done so, if  18 there's time, we can do some question and answer. We had  19 that opportunity last night. We may not depending on how  20 many of you sign up, but we'll see.  21 As soon as I'm done, I'm going to give the  22 floor to Laurie Shannon. So if you look on the agenda  23 there's a presentation here in just a minute where Laurie  24 will highlight the Draft Comprehensive Conservation Plan and  25 the Draft Environmental Impact Statement focussing 

 6  1 particularly on what has changed since the alternatives were  2 in the public forum, in fact in this building not all that  3 long ago. So that's where she'll spend most of her time and  4 attention. That will be beginning at approximately 7:00  5 where the three-minute time will begin to happen.  6 And again, what we're looking for are  7 questions you have about the accuracy of the information in  8 the document, questions that you have with the adequacy of  9 the environmental review, reasonable alternatives other than  10 those four that you see there, any information or any  11 concerns you have that should, in your mind, trigger some  12 change in revision to the Draft. Then we'll adjourn at  13 8:30.  14 A couple of things I want to say as  15 preliminary items. The context within which the Draft  16 Environmental Impact Statement was written and what happens  17 once we leave here tonight, and presuming that the Draft  18 moves by the deadline to its final completion, that's the  19 first step here.  20 The Service would complete the final  21 Comprehensive Conservation Plan and Draft Environmental  22 Impact Statement working from the Draft and issue a record  23 of decision.  24 The second thing that would have to happen  25 after that, before a refuge occurs, before there could be a 
 7 

 1 refuge, is that the Department of Energy would have to  2 complete its site cleanup, except for whatever ongoing  3 operation the Department of Energy will continue to maintain  4 there. So their cleanup would have to be completed.  5 Third, the Environmental Protection Agency  6 and the Colorado Department of Public Health and Environment  7 would have to certify the completion of that cleanup. So  8 without that certification, we don't go further to a refuge.  9 If that certification exists, when it exists, step four is  10 for the Department of Energy to transfer the land to the  11 Department of Interior.  12 Fifth, the Department of Interior would then  13 establish a refuge and the Service would begin its  14 management. So all of those things have to happen in  15 sequence in order for there to be a National Wildlife  16 Refuge.  17 The EPA certification is required before the  18 site can become a refuge. And I want to focus on this last  19 statement. The Comprehensive Conservation Plan and the  20 Environmental Impact Statement are written in the context of  21 a certified site, that is, as if step 3 were complete, and  22 obviously will not take effect, the refuge itself, until  23 that certification is approved. So that's the context and  24 I'm going to give the floor to Laurie.  25 MS. SHANNON: Thank you. Good evening. Can 

 8  1 everyone hear me all right? Some of you probably know the  2 alternatives well enough and a few of you have been at  3 enough of these presentations that I think that you could  4 probably do this.  5 So that everybody is on the same page, I'm  6 just going to briefly highlight the alternatives, and I want  7 to focus on what has changed since last May when we first  8 presented these alternatives. And first I do want to say  9 where we came up with these alternatives and where they came  10 up in our process.  11 We began drafting the alternatives in the  12 late fall of 2002, the November, December time frame, and  13 that was following our scoping period in September of 2002.  14 And what we took into consideration when we developed these  15 alternatives was what we had heard from scoping, the  16 significant issues that came out of our scoping process. We  17 also looked at the mission of the National Wildlife Refuge  18 system and all of our policies and our goals and all those  19 things. And then we also took into consideration the Refuge  20 Act itself, what the Refuge Act says.  21 So after looking at that, we came up with  22 four alternatives, which we first presented last May, and  23 then since then we've been busy writing and this is actually  24 the Draft plan.  25 I am going to start with Alternative B, which 
 9 

 1 is a proposed action. That's what we're proposing and I  2 think that's what here most people are looking at to  3 consider whether they like it or they don't or whether they  4 like one of the other alternatives. And I want to start by  5 showing a little bit of what we changed and not so much  6 about every little detail about it.  7 Last May the public told us -- one of the  8 things that the public told us was they wanted to see horse  9 access. We heard from a lot of users that wanted to see  10 some allowance for horses to come onto the site. So what we  11 did on the southern part of the site, the trails down here,  12 we turned those multiple use trails into access for  13 pedestrians, horses and bikes.  14 And the other thing that we did down here,  15 some folks wanted to see a little bit more of the loops down  16 here and a little bit more connectivity, so we tried to work  17 on that a little bit. In the northern part of the site, it  18 remains like it was last May. This northern multiple use  19 trail that's up here would only be access for bicycles and  20 pedestrians, and then to the north of that there are a  21 couple of foot trails up there. And one of them, the far  22 northern one, would only be open on a seasonal basis.  23 The other big thing that we heard last May  24 was a lot of people told us they thought that we should  25 focus on restoration of the site before we started opening 

 10  1 it for public uses. So what we did is we are proposing that  2 we would open a trail down to the Lindsay Ranch soon after  3 we establish the refuge, but after that we would wait until  4 after year five before we began to implement the rest of the  5 public use program. And during that time period it would  6 allow us to work on restoration and picking up roads and  7 those kinds of things and also getting our budget together.  8 After year five we would then implement the  9 rest of the public use program, and by year 15, we would  10 complete the plan and then we would have to revise again.  11 Another thing we heard last May was that  12 folks wanted us to make this connection, this north-south  13 connection. And that is one thing that we have not done.  14 And the reason why is because we would like to see -- we  15 still would like to see if there is some sort of improvement  16 to Indiana, that connection being made as part of that  17 project, or we'd like to see the communities outside of the  18 refuge make that connection, but it's just hard for us to  19 work with the unknowns of the corridor and the DOE retained  20 lands and try to get everything in there. So that's our  21 preference, not to do that.  22 Under this alternative there is just a  23 seasonally staffed contact station as opposed to Alternative  24 B, which I'll explain, will have a full-blown visitor  25 center. The other thing that we changed on Alternative B is 
 11 

 1 that change to the hunting program. And most of it remains  2 the same as it was and that is that it's targeted towards --  3 it's a very limited managed hunting program that would be  4 targeted toward youth and the disabled and it would be  5 low-impact weaponry such as archery, muzzle loading or  6 shotgun. It would be only two weekends out of the year. We  7 would close the refuge down. And the reason for that is to  8 provide a wildlife recreation opportunity and also assist us  9 in our own management of the deer and elk populations on the  10 site.  11 Under none of the alternatives would we allow  12 dogs. So I just want to make sure I don't forget to say  13 that.  14 Moving on, I think that's the main things I  15 wanted to point out. Moving on to Alternative A, we only  16 made one change on Alternative A. And Alternative A is what  17 we call the no action alternative. And that is basically  18 carrying on the current regime of management habitat in the  19 northern part of the site which is called the Rock Creek  20 area. And the rest of the site would be very limited  21 management action.  22 The one change that we made was that we had  23 proposed putting a chain-link fence around the entire site.  24 And after evaluating that closely, we took that out and is  25 no longer under any of the alternatives. We have analyzed it 

 12  1 in Chapter 4 of the Environmental Consequences, that is not  2 being considered by us as an alternative.  3 Alternative C is what we call the ecological  4 restoration alternative. And this alternative focuses on  5 the maximum restoration of the site that can be done and  6 very minimal public use on this site. In fact, the only  7 public use on the site would be a trail that would go out to  8 this overlook and that would be it. It would be guided and  9 that would probably be less than 1,000 people a year out on  10 the site.  11 On all the -- under all the alternatives,  12 this little road here would be the only vehicle access into  13 the site and it would only -- people could come a short ways  14 and have to park.  15 Alternative D is what we call the public use  16 alternative. And this alternative also focuses on habitat  17 and restoration, really focussed on certain plant  18 communities, while at the same time trying to maximize the  19 amount of public use that we could do. And under all four  20 of these alternatives, any one of them is feasible for us to  21 do, but this alternative looks at trying to do as much  22 public use as we could do within our own funding constraints  23 and those sorts of things.  24 The changes that we made to Alternative D,  25 basically we tried to improve some of the trail 
 13 

 1 connectivity, again tried to improve loops along in here and  2 tried to make it work for people a little bit better than  3 the way we had it last May. And I think that's about it for  4 the major changes. Since there's a lot of people here that  5 want to speak, we're going to get right to that.  6 MR. HUGHES: In order to do that, I'm going  7 to ask Laurie to come up front, also Richard and Dean. As  8 you're speaking, you are speaking to the people that worked  9 on and are preparing the Environmental Impact Statement and  10 the Comprehensive Conservation Plan, so I'm going to ask the  11 three people that you're being addressing to introduce  12 themselves.  13 And now that everyone is in and settled, I  14 want to just do a quick announcement about another  15 opportunity for you to speak about Rocky Flats, and that's  16 an open house that the Department of Energy will sponsor on  17 April 14th at 3:00 in the afternoon, Building 60.  18 MR. TRENHOLME: I'm Richard Trenholme with  19 ERO Resources, I'm part of the planning team.  20 MR. RUNDLE: My name is Dean Rundle, I'm the  21 refuge manager for the Rocky Flats project.  22 MS. SHANNON: And I'm Laurie Shannon,  23 planning team leader for this project.  24 MR. HUGHES: Again, Jody will help you with  25 the three minutes. Jody, first speaker. 

 14  1 MS. ERIKSON: Jane Uitti and Anne Fenerty.  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25 
 15 

 1 BY MS. JANE UITTI:  2 I'm Jane Uitti with the Boulder County  3 Commissioner's Office. Boulder County is a member of the  4 Rocky Flats Coalition of Local Governments and has always  5 supported the passage of the Refuge Act and supports a  6 transfer of use of this land from a former weapons site to a  7 wildlife refuge pursuant to the Rocky Flats National  8 Wildlife Act; however, we believe that there should be no  9 rush to open this land to the public and that the methodical  10 oversight and planning procedures do need to be in place  11 before the opening.  12 Our final comments will be submitted to Fish  13 & Wildlife prior to April 26th and we're also going to put  14 them on our County website.  15 Boulder County supports proposed Alternative  16 A as our first priority, with Alternative C as our second  17 priority. Both of the alternatives permit far reduced  18 access than Alternative B, which Fish & Wildlife is  19 proposing, or Alternative D. And our reasons for this  20 support is as follows.  21 Number one, Boulder County believes that the  22 public should not be allowed access to facilities in the DOE  23 zone. That's that upside down prairie dog shaped thing on  24 the plan, such as the monitoring station, retention ponds or  25 landfill caps. 

 16  1 We're sure that both Fish & Wildlife and  2 Department of Energy are in agreement on this. However  3 neither DOE nor Fish & Wildlife in their current plan have  4 outlined how they intend to keep the public from fishing,  5 swimming or exploring these areas. Before they are allowed  6 on the refuge, Fish & Wildlife and DOE need to clarify  7 specifically how they're going to keep the DOE lands off  8 limits to the public.  9 While the Fish & Wildlife plan reiterates its  10 goals of safety on page 3 and 4, for example, we feel that  11 you folks have not been given sufficient resources to  12 guarantee the plan. Commissioner Paul Danish recommended  13 last week to the deputy assistant secretary for policy in  14 the Department of Interior, that Cold War sites and prior  15 nuclear weapons sites that are being converted to wildlife  16 refuges should be treated and staffed in a fundamentally  17 different manner from other wildlife refuges that do not  18 have the same kind of contamination history, and therefore,  19 the funding for the Department of Interior and for Fish &  20 Wildlife should thus be increased accordingly.  21 I have some other comments that are not going  22 to be able to be covered in this three minutes.  23 Our conclusion is, while we support the  24 conversion of this land to a refuge, we see no need to rush  25 the status by permitting premature access to the public. 
 17 

 1 Take the time to make sure the public access to lands are  2 clean and safe and that DOE and Fish & Wildlife give us a  3 plan to keep the public out of the contaminated areas.  4 Thank you.  5 MS. ERIKSON: Anne Fenerty and Amy Mueller.  6 BY MS. ANNE FENERTY:  7 Thank you. My problem is with the process.  8 I feel that the process is not really complying with the  9 mandates of the NEPA law under which the DEIS has been done.  10 DEIS is to evaluate the effects of the action on the natural  11 and human environment. It has to state how to avoid or  12 mitigate adverse impacts of the planned action and to  13 provide sufficient information on the proposal so the public  14 can participate effectively.  15 And the DEIS is about pictures of flora and  16 fauna and omits to mention that the refuge is a Superfund  17 site briefly referring to it as activities outside the  18 scope, yet because NEPA is a public disclosure law and the  19 EIS is the most comprehensive environmental document, it has  20 to lay out not only the full range of environmental impacts,  21 but also the full spectrum of appropriate mitigation.  22 The MOU, memorandum of understanding, between  23 the two agencies, the DOE and Fish & Wildlife, has not been  24 signed yet. The people don't know how much of the land,  25 which part of the contamination is going to remain in DOE 

 18  1 control. DOE may have as much as one-third to one-fourth of  2 the total site. The question is, what's going to happen to  3 landfills, the surface contamination east of the 903 pad,  4 the groundwater treatments and the toxic landfills? How  5 will the counts be monitored?  6 Hydrologists recently found 10 billion  7 picocuries of plutonium on the site which was in 1995. I  8 have the report here. Same researchers found extensive  9 contaminants in the supposedly pristine buffer zone. Please  10 explain the effects of this action on the human  11 environment. All right.  12 And then the other question I have is there's  13 no public access to the DOE retained land, is a quote from  14 the DOE. The quote that Rocky Flats will be a seamless  15 property with no or few visual differences between the  16 refuge and the retained land and is contradicted missions.  17 What types of fencing, warning signs will  18 there be? How do you intend to control the prairie dogs so  19 they do not dig down to the customary seven feet of soil and  20 bring up the contaminated soil? How will Fish & Wildlife  21 keep these prairie dogs and burrowing animals from the  22 refuge? Extremely high levels of radionuclides will remain  23 in the soil at the three- to six-foot depth interval where  24 concentrations of up to 3 millicuries of soil will be left.  25 And NEPA states that the cooperating agencies 
 19 

 1 cannot opt out entirely of the duty to cooperate on the EIS.  2 And so I would like to have DOE and the cooperating agents  3 ensure that public protection from the remaining  4 contamination on the site will be safe.  5 In other words, we just found a 32-foot tall  6 buried incinerator. The site has not been properly  7 characterized and people should not be allowed on a site  8 like this unless you know what's at the site. Thank you.  9 MS. ERIKSON: Amy Mueller and then Jacque  10 Brever.  11 BY MS. LISA MORZEL:  12 Good evening. My name is Lisa Morzel and I'm a  13 resident of Boulder. I have followed Rocky Flats' issues  14 for over the past 25 years and I was a former council member  15 for the City of Boulder in which I represented the City of  16 Boulder for seven years on Rocky Flats, including the Rocky  17 Flats local impacts initiative, and was a founding member of  18 the Rocky Flats Coalition of Local Government. I am  19 currently an ex-officio member of the Coalition.  20 Tonight I'm speaking on behalf of council  21 member Shaun McGrath, Boulder's new representative to the  22 Rocky Flats Coalition of Local Governments. Shaun is out of  23 town today, so I am presenting the City's comments.  24 I should emphasize that the comments that I  25 will be presenting are not intended to serve as the complete 

 20  1 or final position of City of Boulder, rather I am here  2 tonight to highlight some areas of critical importance to  3 the City on any refuge plan. The City intends to provide  4 written -- formal written comments prior to the April  5 deadline.  6 First, to the general policy, the City has  7 long advocated foreclosure and cleanup of the weapons  8 production facility at Rocky Flats. We continue to work  9 with other local governments in the area through RFCA to  10 argue for federal funding and attention to the issue.  11 Proper cleanup of this site remains our very first priority.  12 Beyond the cleanup and closure, the City  13 supported the Udall-Allard legislation in 2001, which  14 resulted in designating the site as a wildlife refuge. This  15 was important to the City not only to protect the site from  16 future development, but was an important part of our mission  17 for the landscape given the efforts made by Boulder and  18 Boulder County in setting aside open space adjacent to the  19 site.  20 Federal ownership was also critical in our  21 view to address the uncertainty of public health issues and  22 we want to make sure any problems that are detected 20 years  23 from now, the liability will be with the federal government,  24 not with local communities.  25 Second, as previously stated by the City, we 
 21 

 1 support the wildlife refuge as desirable and compatible with  2 our community goals. As a neighboring landowner, the City  3 supports Draft goals which include conserving and enhancing  4 native ecosystems, plant communities and wildlife species.  5 The proximity of the refuge lands to other  6 open space lands provides an extraordinary conservation  7 opportunity. The refuge lands will make important  8 contributions to regional efforts to protect the values of  9 native grasslands, shrub lands and the foothills right here  10 in the area.  11 The City maintains that the focus of  12 management planning should be, one, that unique conservation  13 opportunity of preserving a large and rare habitat unmatched  14 anywhere along the Front Range corridor.  15 Two, the preservation and restoration of  16 native plant and animal communities. Management actions  17 should focus on the following: We need to plan conservation  18 areas and visitor facilities with regional focus that  19 considers connections with surrounding trail systems.  20 We need to work to restore lands that have  21 been degraded. This is our first priority. And we need to  22 make sure that we monitor and make sure that the systems,  23 the monitoring systems that we have put in place are  24 actually working effectively.  25 Finally, we need to make sure that no further 

 22  1 fragmentation of the landscape occurs, is kept to a  2 minimum. The City right now is proposing Alternative C and  3 that is about as far as we're willing to go. I think people  4 need to recognize that this property is not just any open  5 space, but that it has a legacy of being a nuclear weapons  6 site in the past 50 years. Thank you. And if anybody wants  7 to comment, we have them.  8 MS. ERIKSON: Jacque Brever and Bini Abbott.  9 BY MS. JACQUE BREVER:  10 My name is Jacque Brever. I'm a former  11 plutonium worker from Rocky Flats. I'm now an environmental  12 scientist. I also have years of experience with other DOE  13 Superfund and reused sites.  14 I strongly oppose public access to and  15 recreation in any form at Rocky Flats. It appears as if the  16 Fish & Wildlife Service is offering us a stacked deck and  17 the public really has no option other than to decide which  18 kinds of recreation it would like to have at Rocky  19 Flats. The way I read the CCP, EIS, it seems like there is  20 little opportunity to oppose recreation at Rocky Flats.  21 I was a plutonium worker there for ten years,  22 I know it's too dangerous to be used for recreation. I know  23 from personal experience and review of government documents  24 that they do not even know where all the contamination is,  25 so it cannot properly be cleaned up. 
 23 

 1 I know that much of the data on which they  2 are basing their decisions have been falsified. The agent  3 that led the raid on Rocky Flats says -- the FBI agent who  4 led the raid on Rocky Flats says the investigation was  5 obstructed and that Rocky Flats is too dangerous to ever be  6 used for recreation. The foreman of the grand jury that  7 investigated Rocky Flats for three years says Rocky Flats is  8 too dangerous to ever be used for recreation.  9 The government admits that they will clean up  10 Rocky Flats as well as it could, the DOE admits it made  11 trade-offs to save money. If that's the case, then it  12 shouldn't be open for recreation.  13 It's my opinion that Rocky Flats will never  14 be safe for children, the elderly, to have access to the  15 former nuclear weapons facility.  16 Here is a book that proves what we say. It's  17 called the Ambushed Grand Jury. And I want to submit this  18 book to the public record. It's written by the foreman of  19 the grand jury with the help of the FBI investigator, myself  20 and a volunteer lawyer. I am entering it in the record  21 because it provides proof that the U.S. Justice Department  22 has covered up the truth about contamination at Rocky Flats.  23 I'm not alone in my opinions, some other  24 people and I have formed an organization titled United To  25 Keep Rocky Flats Closed. It's an organization that opposes 

 24  1 recreation at Rocky Flats. We've been collecting comments  2 from people who also oppose recreation at Rocky Flats. I  3 have here 152 petitions to submit for the record in addition  4 to the 121 petitions that I've already sent through the U.S.  5 Mail to Fish & Wildlife and representative Mark Udall.  6 Congressman Mark Udall. I have more comment forms if people  7 would like to sign them.  8 And finally, I would like to ask whether the  9 Fish & Wildlife would please notify me of how many comment  10 forms they ultimately receive. Thank you.  11 MS. ERIKSON: Bini Abbott and Harvey Nichols.  12 BY MS. BINI ABBOTT:  13 My name is Bini Abbott and I live on the West  14 Shore of Standley Lake. First I'd like to tell you about  15 what I am not. I am not a member of a peace group, I am not  16 a member of an animal rights group, but what I am is against  17 hunting in inappropriate places four days out of the year  18 while the other 361 days are used to protect the wildlife.  19 The definition of a refuge is a place of  20 safety, shelter, a safe retreat. I have taken from this  21 book, which is the thick book about the proposed refuge,  22 made my own chart, and reading from it, the goals of the  23 U.S. Fish & Wildlife is to provide the public with safe,  24 high quality and my underlining, compatible wildlife  25 dependent public use. 
 25 

 1 Such uses include hunting, fishing, wildlife  2 observation, wildlife photography, environmental education  3 and environmental interpretation. Now, they have four parts  4 under environmental interpretation. One is habitat  5 restoration, the second one is concerning wildlife, colon,  6 wildlife take refuge at Rocky Flats.  7 The third one is wildlife and people, colon,  8 wildlife comes first. And then history. I feel with the  9 plan of hunting at Rocky Flats with having 20 people, a  10 total of 20 people, two weekends out of the year, would be  11 in direct opposition, and closing the whole rest of the  12 refuge for anyone else, I think would be wrong.  13 They state that it will cost about $5,000 to  14 provide those four days of hunting and that's $250 per  15 person. They intend to start the hunting within the first  16 two years, according to this book, but not set a population  17 goal of what wildlife needs to be culled until three years.  18 They also did not intend to reevaluate until  19 15 years have gone by, which is the year 2019. Is there a  20 need for culling? I don't believe so, according to Boulder  21 City Open Space and Boulder County Open Space who border the  22 lands, they have found no need for culling. If there is a  23 need, I feel that it should be sharp shooters from the  24 Division of Wildlife, not youth and disabled people sitting  25 with blinds and plunking away at the animals that have 

 26  1 gained a confidence for us to have good wildlife observation  2 and so on.  3 In closing, I'd like to say that I think the  4 perception of U.S. Fish & Wildlife's management of the Rocky  5 Flats refuge will be more important than actual reality if  6 they allow the hunting. And also I hope they will watch the  7 wildlife through binoculars and cameras and not through the  8 cites of a gun. Thank you.  9 MS. ERIKSON: Harvey Nichols and Nathan  10 Bufe.  11 BY MR. HARVEY NICHOLS:  12 I brought my own timer. Harvey Nichols, I'm  13 a professor of biology at CU Boulder, but I'm speaking as  14 just a citizen of Boulder. I want to recommend no action,  15 Alternative A. This would mean essentially no public  16 access. The reason behind this, first of all, has to do  17 with -- the apologies to the people, the equestrians and the  18 cyclists and the hikers that can't wait to get out there, I  19 just have some information that I feel I have, as a matter  20 of responsibility, to partake to give you.  21 And basically in the 1970s, I had a DOE  22 funded contract for 18 months which led me, actually, in  23 fact, to do environmental measurements out at the Flats, and  24 what I discovered, apparently I got some unique data. This  25 had to do with a snowfall study. I won't go into it, but 
 27 

 1 basically I happened to capture the effluent from the  2 chimneys, the plutonium articulate effluent coming out of  3 the chimneys during snowfalls. And apparently, in fact,  4 with the admission or the helpful comment by Dean Rundle  5 here, nobody else in the 50 years of the plant's operation  6 has done such a study.  7 So what I found was that the entire site has  8 a fine dusting of tiny particles of plutonium over the  9 entire buffer zone, the refuge to be, as well as the  10 industrial area. This has been supported by the Health  11 Department study by Dr. John Till whose data indicates that  12 over 600 million fatal or harmful doses of these tiny  13 particles of plutonium was laid down over the entire site  14 over the years.  15 My own study is even greater numbers than  16 that, astronomical numbers, and some element of those  17 particles must still remain on the soil, and to some extent,  18 in or on the vegetation.  19 The problem is that wind dusts can lead to  20 inhalation. A sudden gust of wind, breathing in the  21 dust and a potential for long-term illness.  22 The vegetation must be analyzed  23 independently. We have claims repeatedly from the officials  24 out there that there's been no study showing uptake of  25 plutonium. A whole series of studies that we've traced, and 

 28  1 since I'm really coming close to my time, I'm against the  2 prairie burning because of the hazards of plutonium in the  3 smoke. It's cheapest and safest, I believe, to keep it  4 closed.  5 And right at the end, I want to recommend to  6 you a couple of newspapers that happen to be in piles  7 outside. The Colorado Boulder Weekly, there's an absolutely  8 dynamite story today and another one from last week all  9 related to Rocky Flats. I please recommend that you look at  10 them. Thank you.  11 MS. ERIKSON: Nathan Bufe and then Erin  12 Hamby.  13 BY MR. NATHAN BUFE:  14 My name is Nathan Bufe. I'm a student at the  15 University of Colorado and a resident of Boulder. And first  16 of all, for the record, I'd like to say that I also propose  17 Alternative A, no action, for the reasons that the people  18 before me have discussed, because I don't have time to  19 discuss them myself.  20 And the question I'd like to raise is why  21 does the Service have a proposed alternative? Why are they  22 proposing Alternative B? Basically my question is, why  23 isn't this -- well, what I'm saying is that basically where  24 it says Alternative B, wildlife habitat and public use is  25 proposed, they say because of the major issues identified 
 29 

 1 during public scoping and that it's consistent with sound  2 Fish & Wildlife management, and I'm wondering, why  3 isn't this more of a public decision?  4 What this says to me is that basically the  5 Service has already made up their mind and that they're not  6 going to take the other proposals as seriously.  7 So pretty much my question is, why is the  8 Service going into this with a preexisting bias? Why aren't  9 they leaving this completely open to a public decision?  10 And also, it's been said already, but I would  11 like to emphasize the problems of having the refuge being a  12 seamless property with no visual division between the  13 central DOE part and the outer public access part, and I  14 believe, as the previous speakers have said, that the  15 proposed cleanup is in fact impossible because of the  16 uncertainty involved, that people don't know the extent of  17 the contamination on site and that it is dangerous to let  18 people go on the site. And that's certainly dangerous to  19 leave the central DOE site, the most contaminated area, with  20 no boundary at all, no fences, no warnings. It just seems  21 irresponsible.  22 And I'm wondering why there is no proposal  23 for a fence at least. And I guess that's all I have to  24 say. Thank you.  25 MR. RUNDLE: Mark, are you going to capture 

 30  1 all of these questions so hopefully if people stick to their  2 three minutes, we'll be able to try and answer these later?  3 MS. ERIKSON: Erin Hamby and Beverly Lyne.  4 BY MS. ERIN HAMBY:  5 My name is Erin Hamby. I'm speaking as a  6 resident of Boulder. I'm in love with the scenery and  7 landscapes of this Front Range community. The mountains  8 touch the prairie and leave me breathless. Knowing that  9 6,000 acres of this beautiful landscape was used and tainted  10 in the production of nuclear weapons also leaves me  11 breathless.  12 The idea of reclaiming this land for Colorado  13 and the nation is a wonderful thing. The reclamation of  14 this should not include public access though. Fish &  15 Wildlife is being asked to manage a refuge which encircles a  16 highly contaminated tract of land. Even if one believes  17 that the buffer zone is safe or uncontaminated, it's  18 irresponsible and wrong to believe that known and unknown  19 remaining contaminants will remain within the borders of the  20 DOE retained land.  21 The National Wildlife Refuge system mission  22 statement says, to administer a national network of lands  23 and waters through the conservation management and where  24 appropriate restoration of fish, wildlife and plant  25 resources and their habitats within the United States for 
 31 

 1 the benefit of present and future generations of Americans.  2 This guiding principle can be achieved  3 without allowing public access. I am in favor of a modified  4 version of Alternative C. Modifications should include  5 denial of public access to any part of the site, guided or  6 unguided, for at least 100 years. Proposed research should  7 focus on new remediation technologies and research the full  8 health effects of radionuclides and other hazardous  9 materials found on the site.  10 Recreation can and will stir up plutonium.  11 Animals could disturb plutonium in the ground. The winds on  12 the site do stir up plutonium. Protect the wildlife,  13 protect me, protect future generations and keep Rocky Flats  14 closed. Thank you.  15 MS. ERIKSON: Beverly Lyne and LeRoy Moore.  16 BY MS. BEVERLY LYNE:  17 I'm Beverly Lyne. I'm a public health nurse  18 and I teach public health nursing for the University of  19 Colorado Health Sciences Center; however, I'm here as a  20 Boulder resident speaking. I was an original member of the  21 Rocky Flats Citizen's Advisory Board, and as chair of the  22 health committee for the board, we commissioned an  23 independent review of the environmental monitoring systems  24 in place at the site and historically in place at the site.  25 The review revealed, among other things, that 

 32  1 there was no soil monitoring program. It is my  2 understanding that soil contamination has not yet, at this  3 date, been fully characterized. So it is my belief and my  4 opinion that until the soil contamination is fully  5 characterized and remediated, there should be no public  6 access to this site.  7 So if I had to choose one alternative, I  8 would be leaning toward Alternative C. Thank you.  9 MS. ERIKSON: LeRoy Moore and Gary Ball.  10 BY MR. LEROY MOORE:  11 Hello, my name is LeRoy Moore, recently  12 retired from teaching at the University of Colorado, a  13 consultant with the Rocky Mountain Peace and Justice Center  14 in Boulder. When the cleanup underway at Rocky Flats is  15 completed, the Rocky Flats site will be divided into two  16 parts, the more contaminated part that will remain under DOE  17 control, and the less contaminated part which will be  18 managed by Fish & Wildlife Service as a wildlife refuge.  19 The agencies responsible for the Rocky Flats  20 cleanup use in their work a 1999 kriging map, that's a  21 white-knuckle term, talking about the way they sample the  22 site, they use this 1999 kriging map that shows, to the best  23 of their knowledge, plutonium concentrations in the soil at  24 the Rocky Flats site.  25 According to this map, the entire portion of 
 33 

 1 the site that will become the wildlife refuge is  2 contaminated with plutonium up to a level of 5 picocuries  3 per gram of soil. Five picocuries of soil is 125 times the  4 .04 picocuries per gram average background deposits of  5 plutonium from global fallout along the Front Range here in  6 Colorado.  7 Fish & Wildlife Service proposes to allow  8 members of the public, including children, to hike, bike,  9 hunt and ride horses in an area contaminated with plutonium  10 at this level. Any one of those activities could stir up  11 tiny particles of plutonium, that if inhaled or ingested  12 could create health problems at some later time.  13 Plutonium is no respecter of our official  14 standards for what is safe. Numerous studies and bodies of  15 numerous individuals, including some former Rocky Flats  16 workers, indicate that exposure to plutonium in amounts well  17 below official standards for permissible exposure can cause  18 cancer, harm to the immune system, genetic damage and  19 instability.  20 I propose, therefore, that Fish & Wildlife  21 Service incorporate into their EIS the 1999 kriging map  22 showing plutonium concentrations in the Rocky Flats soil.  23 Further, if they decide to allow recreational  24 activities at Rocky Flats, I propose that Fish & Wildlife  25 require people entering the site to sign an informed consent 

 34  1 statement indicating that they have read the map and consent  2 to going onto a site contaminated at these levels.  3 Finally, I pose a question to Fish & Wildlife  4 personnel. Why take the risk of endangering the health of  5 people, particularly children, when it isn't necessary to do  6 so? Thank you.  7 MS. ERIKSON: Gary Ball and Betty Ball.  8 BY MR. GARY BALL:  9 My name is Gary Ball. I was born and raised  10 in Denver. I'm currently a resident of Boulder and I'm here  11 to speak about the precautionary principle and I have a  12 suggestion to make. And I probably won't even need my three  13 minutes, whoever the timekeeper is, to do it, but it just  14 seems to me that the EIS has already focussed in a  15 particular direction, and this is to me strange just from  16 the get-go because of both the nature and the longevity of  17 the contamination.  18 I don't think that you have convinced me and  19 I don't know that you could convince me that anyone knows  20 the long-term effects of this contamination and I don't know  21 why one alternative that isn't there should be, that this  22 thing should be fenced off, paved over and hermetically  23 sealed so that no contamination spreads off site either by  24 wind or by water and that it should remain in that condition  25 for a quarter of a million years it's going to take for that 
 35 

 1 contamination to go away.  2 Now, the precautionary principle would say, I  3 don't have to prove to you that this thing is dangerous, you  4 have to prove to me that it's safe. And I don't think that  5 you've done that. And so what the precautionary principle  6 would say is if you can't prove to me that it's safe then  7 let's not take the chance.  8 But since we're already going in this  9 direction, I have to say, I feel like probably what I'm  10 going to say is probably going to be ignored anyway, but  11 since we're already going in this direction, I can only say,  12 it seems to me like that's a gamble and it's a very serious  13 gamble, and that in earth time, all the years we know the  14 earth has existed, this contamination has happened in the  15 blink of an eye.  16 And given the length it's going to last, even  17 in earth time that's a significant portion of time. No one  18 can possibly know what the effects of this contamination  19 really are. To monitor the vegetation and wildlife and  20 certainly any effects on people for at least 100 years, if  21 not 500 years, to get an inkling of what the effects are.  22 But if we're going to take this chance, then it seems to me  23 we need a fail safe position.  24 So I would propose to you that somebody put  25 up a bond. We're not cleaning it up to background levels 

 36  1 now because there's no money. Somebody needs to put up a  2 bond, whether it's a tax or the government or Kaiser-Hill or  3 all of us together, there's got to be a bond. So that if we  4 fail and we suddenly realize, oh, yeah, this place is in  5 fact serious and we need to do something about it, then at  6 least at that point we would have the money to do what needs  7 to be done. Thank you.  8 MS. ERIKSON: Betty Ball and Janelle Knox.  9 BY MS. BETTY BALL:  10 Hi, my name is Betty Ball. Thank you for  11 this opportunity to be able to speak to this proposal. I've  12 lived in this area since 1960. I've been very aware of the  13 things that have happened at Rocky Flats over the years.  14 The accidents, the fires. I'm very aware that this site has  15 not been characterized. Nobody knows where all the  16 contamination is, nor the extent of it.  17 So first of all, I'd like to say that I don't  18 think we should get passed number 3 up here on the schedule  19 of events until a lot more work has been done and the  20 contamination there is taken a lot more seriously and we do  21 a lot more studies and we don't let budget constrain us for  22 those studies. This is serious. What we've done here is  23 serious and it's leaving quite a legacy for the future. So  24 that's first of all.  25 Second of all, if we do get to the point 
 37 

 1 where the portion is turned over to Fish & Wildlife, then I  2 think that we do have to follow the cautionary principle as  3 Gary Ball just mentioned. When you have uncertainty that  4 leads to a threat of harm, then you act with precaution.  5 And it's not -- the burden is not on the  6 public to prove that this is unsafe, the burden is on the  7 government, in this case, to prove that it's safe. That has  8 not happened. So therefore, if we do move forward with the  9 Fish & Wildlife taking over the land, then I would recommend  10 Option A. Thank you.  11 MS. ERIKSON: Janelle Knox, Jim McKee.  12 MR. HUGHES: If I could ask, we've got an  13 hour's worth of speakers and I want Dean to give a final  14 statement and answer whatever questions he can, so if you  15 could just step up, that would be great.  16 BY MS. JANELLE KNOX:  17 Hello, my name is Janelle Knox and I am a  18 concerned citizen of Boulder County. I am a concerned  19 citizen because I have studied the history of this site and  20 I know the levels of contamination that have gone into this  21 site. I also know that it has not adequately been sampled  22 or characterized to be determined safe.  23 I think that the U.S. Fish & Wildlife Service  24 has prepared a lovely packet for the public here, and in all  25 honesty, these photos look beautiful. This looks like a 

 38  1 pristine site where we would all like to go and recreate,  2 but the problem is it states a preference, it does not once  3 mention the history of Rocky Flats or the contamination that  4 has gone into this site.  5 It is deceptive to consider this a pristine  6 refuge without considering the history and the contamination  7 on the site. I think if the public is to make an educated  8 and informed decision, it has a right to know what is at  9 that site, what has gone into it or what is not known about  10 the site and what the risks of families, animals and  11 children coming out there are.  12 Do we really want our children to come out  13 there, recreate, scrape their elbows and skin their knees in  14 plutonium filled soil? I support Alternative A. Thank you.  15 MS. ERIKSON: Jim McKee and Bruce Bland.  16 BY MR. JIM McKAY:  17 I'm Jim McKay. I'm speaking for the Boulder  18 County Nature Association and what I'm going to say is,  19 assuming adequate cleanup, and I'm not sure that that's been  20 demonstrated yet, but first importance is restoration and  21 conservation. Alternative C best accomplishes this.  22 Hunting is not feasible this near an urban  23 area because of both safety considerations and public  24 opposition. I would rank the alternatives as C, which  25 includes environmental restoration, then A, then B, with no 
 39 

 1 hunting, and as of the last priority, D, with no hunting.  2 Alternative D would have the maximum impact on wildlife at  3 the refuge. Whichever alternative is chosen, don't rush  4 public access. Establish baseline, do restoration,  5 establish a baseline on wildlife and the habitat before  6 there's any significant public access. That's all I have to  7 say.  8 MS. ERIKSON: Bruce Bland and Suzanne Webel.  9 BY MR. BRUCE BLAND:  10 Bruce Bland, I'm a resident of Boulder and  11 I'm speaking solely for myself tonight. The purpose of a  12 wildlife refuge, at least in the minds of most people, is to  13 provide a sanctuary for wildlife, a place that belongs to  14 wildlife first.  15 Alternative C clearly does this best.  16 Alternative A is also acceptable and it's the cheapest  17 alternative on the table. But judging by the addition of  18 more trails in the south and an interest in a north-south  19 corridor along Indiana when it's rebuilt, to Alternative B,  20 it sounds like Fish & Wildlife have listened to the  21 recreational people, but not to others who have asked for  22 less recreation than Alternative B originally allowed.  23 This is a problem with public process. There  24 has been no polling done to indicate what the public at  25 large thinks or values for this area. You have only heard 

 40  1 from activists, which the audience is full of tonight, and  2 myself am one of them, who come here to beg for one cause or  3 another.  4 You need to actually go back and poll the  5 citizens if you're really concerned about this. Both  6 Alternatives C and D allow too much recreation to be  7 consistent with wildlife preservation over the long term.  8 Wildlife are going to need a good sanctuary in the near  9 future as the impacts of global warming start to be seen.  10 If this much recreation is allowed in this  11 area, we're going to see a tremendous amount of use, because  12 this is an urban area and people will be drawn here by the  13 beauty of this place, as one speaker pointed out. Some of  14 them are going to disturb wildlife, a certain percentage  15 will do that, and the greater the number means that more  16 people will disturb them.  17 There's also going to be a collaboration of  18 social trails across this property and these dry grasslands.  19 Under no condition, however, should people be allowed on  20 this site until it's clear to all stake holders that the  21 site is clean and safe and extensive survey by a competent  22 independent consulting firm and overseen by a team of stake  23 holders and scientific professionals should be performed  24 before any public use should be considered.  25 So in conclusion, first make this a National 
 41 

 1 Wildlife Refuge, not a national recreation area by putting  2 wildlife preservation first. Wildlife species are  3 irreplaceable, recreation is not. We'll have plenty of  4 recreation in this area and there's more coming in the  5 region.  6 Second, correct the public process by doing a  7 formal scientific poll if you want to find out what the  8 public actually feels.  9 Third, do not allow anyone on the land until  10 it is clear to everyone that it's safe to do so. Thank you  11 very much.  12 MS. ERIKSON: Suzanne Webel and Eric  13 Vogelsberg.  14 BY MS. SUZANNE WEBEL:  15 I'm Suzanne Webel and I'm speaking on behalf  16 of the Boulder County Horse Association. I've lived in  17 Boulder County for 30 years and I've been involved in this  18 scoping process. I want to be the first person to commend  19 you on the thorough public process that you've caused to  20 happen up to this point and on the professional job you did  21 on this Draft CCP and EIS.  22 My comments also assume an adequate cleanup  23 job at the site. We support Alternative B with some  24 modifications. We want to thank you for allowing some  25 equestrian access on the property. I know that was a bold 

 42  1 move on your part, but we do appreciate it.  2 My question is, why are you proposing access  3 on the southern end? Most agencies consider equestrians  4 with pedestrians when they're making their trail plans.  5 Where hikers go, we usually can go.  6 We are okay with Alternative B with there  7 being some short pedestrian only trails, especially at the  8 northwest corner of the property.  9 If the concern is to do with weeds, the  10 entire site is already infested with noxious weeds. I want  11 this reserve to be as healthy an ecological community as it  12 can be. You can control the weeds with a budget and a staff  13 for weeds, not by denial of access by any user group. Do a  14 baseline study, monitor what you've got and then proceed  15 with adoptive management. Don't start out with a lot of  16 unnecessary regulations that affects one particular user  17 group.  18 Eric Lane, the state weed coordinator says  19 that horses are not a significant vector for weeds and in  20 fact are much less than wind, water, wildlife and truck  21 tires.  22 Specifically we recommend moving the northern  23 most trail head west along Highway 128 one mile to where the  24 Colton Dry trail comes down to 128. That would provide  25 better regional connectivity of trails with no change in 
 43 

 1 cost.  2 We'd like to see you add the north-south  3 trail back in your plan on the east side of the property.  4 And we'd like to see you allow equestrians on the main trail  5 that goes along the northeast corridor.  6 Rocky Flats is an important nexus for many  7 existing and planned regional trail systems. We need to get  8 across it in an east-west and north-south direction and so  9 the system we're recommending is basically a single  10 perimeter trail. Thank you. I do have a document that I'd  11 also like to submit for you guys for the record.  12 MS. ERIKSON: Eric Vogelsberg and Stacia  13 Goecke.  14 BY MR. ERIC VOGELSBERG:  15 Eric Vogelsberg. I am speaking for the  16 Boulder County Trails Coalition, I'm also a board member of  17 the Boulder Off Road Alliance, which is an mountain biking  18 organization which works with trail construction projects.  19 And I'd like to do something that a lot of the speakers  20 haven't done and actually talk about the EIS and what you're  21 proposing.  22 I'm going to assume from the beginning that  23 we're all the way down to the bottom of this thing and we do  24 have EPA certification. I'm confident that that process  25 will not expose the public to unreasonable danger or harm. 

 44  1 Having said that, I'd like to talk about the  2 proposed alternatives. We support the Fish & Wildlife's  3 proposal and the proposed Alternative B. We think it's a  4 reasonable effort to preserve the natural resources while  5 providing for public access and public education. We  6 observe, for example, that at least 50 percent of the site  7 will be closed to the public, because the northern portions  8 are closed, and because the DOE portions are closed.  9 We do think there's several enhancements that  10 could be made to Alternative B. We believe that there's a  11 real shortage of north-south connections in the trail  12 proposals. One thing we think would be valuable is a trail  13 along the side of the gravel road that connects the two  14 parking lots to the west so that there's a north-south trail  15 connection that doesn't require people getting onto the  16 gravel road. We would also like to see the northwestern  17 section of the property connected to the City of Boulder and  18 Boulder County Open Space Trail Systems. The Colton Road  19 connection is one that Suzanne mentioned.  20 Given that you don't want to do the  21 east-west -- pardon me, the north-south connection on the  22 east side now, I'd like the plan to have a clause in it  23 speaking to encouraging that connection to be made at the  24 time that the new highway alignment is put in place so that  25 doesn't become a, well, we somehow forgot about it and it 
 45 

 1 drops in the cracks.  2 I think the biggest comment I would make is  3 the five-year delay before we provide significant public  4 access. Seems to me to be a little unnecessary and  5 artificial. I'd rather see a phased implementation, for  6 example, perhaps when you do the restoration on the north  7 side of the property and then open the north side after two  8 to three years and then complete the restoration on the  9 south side of the property and then open the south side. Or  10 conversely, do it the other way. But waiting five full  11 years before we do anything seems to me to be a little bit  12 unnecessary and artificial.  13 I thank you again, I think you've done a nice  14 job here. I think the folks here have serious concerns, but  15 I think they're presenting them to the wrong people. Thanks  16 again.  17 MS. ERIKSON: Stacia Goecke and Sue Maslow.  18 BY MS. STACIA GOUCKE:  19 My name is Stacia Goucke and I'm a private  20 resident. I have several concerns about it being opened up  21 to the public so I'm supporting no action, Proposal A. The  22 reason for this is that there is a large amount of  23 uncertainty about the contamination that is on the site as  24 it is. According to a book by Burtell called, No Immediate  25 Danger For A Radioactive Earth, it says that zero to ten 

 46  1 REMs, which are biologically damaging energy units, can  2 cause premature aging, moderate risk of tumors and mild  3 mutation of offspring. This is minimal. So even with the  4 most minimal levels of contamination which may meet EPA  5 standards these still can cause these health risks to the  6 public.  7 If it is as apparently proposed from the Fish  8 & Wildlife Service that they do open it up to the public,  9 there needs to be proper signage so that the public can be  10 properly informed before they enter the site of what these  11 health risks are and they need to be vividly described as  12 premature aging, risk of tumors and the possible  13 carcinogenic effects of plutonium possibly on the site,  14 the seasonal gas by over 100 miles per hour, any sort of  15 residue left in the buffer zone that we may not be aware of  16 from the industrial zone.  17 Also, I would like you to rethink your taking  18 off the fence of the boundaries so that the public knows  19 what property they're going onto and that they're going onto  20 a former weapons site.  21 There are many other areas for open space  22 recreation in Boulder County. I do not feel that Rocky  23 Flats also needs to become a refuge. There are places that  24 equestrians, bicyclists can go where they're less likely to  25 go stir up contamination. Thank you. 
 47 

 1 MS. ERIKSON: Sue Maslow and Ian White.  2 BY MS. SUE MASLOW:  3 My name is Sue Maslow and I'm a citizen of  4 Boulder and also a student of the University of Colorado and  5 have been educated on the history of Rocky Flats and  6 everything that transpired there over the last several  7 decades. It is my strong feeling to support Alternative A  8 with a fence. And I'd like to know, if you go with  9 Alternative A, how you plan to keep the public safe from  10 this very contaminated site.  11 I feel that you've already made a decision  12 and you're almost working out the fine details, equestrians  13 wanting to go running through the place, bikers, et cetera.  14 I do believe also, like Janelle was saying also, when I  15 first looked at your EIS, it looks beautiful. You took  16 gorgeous pictures of healthy looking wonderful birds and it  17 looks great, but it's completely deceptive and it's a total  18 lie.  19 And I'm really sorry if I'm out of line, but  20 I firmly believe what you're doing is atrocious and I  21 believe the government allowing something like this to  22 happen is obscene and against American citizens.  23 For all of the workers that worked at Rocky  24 Flats and actually gave their lives for their country, this  25 is outrageous. And I'll give my two minutes to somebody 

 48  1 else, but I firmly believe in Alternative A. That's it.  2 Thank you.  3 MS. ERIKSON: Ian White and Wendy Vining.  4 BY MR. IAN WHITE:  5 Hello, my name is Ian White, I'm a senior  6 undergraduate student at CU. I used to also be a runner at  7 CU. I no longer am. I haven't been running too much these  8 days, but I used to run a lot. I ran a lot also at Marshall  9 and Downing Draw, which is on the way to Rocky Flats as  10 you're heading out 93. It's on the way there. And I  11 remember, it does get real windy sometimes when I run.  12 Sometimes I'll be running and I'm not running it's so windy  13 when I'm heading into it. It's an important thing to note.  14 And I think when you start talking about  15 children and disabled youth and talking about them spending  16 time on a very potentially, and we've heard from some  17 scholars here tonight who thinks it goes beyond potential,  18 goes beyond reality, when you talk about children and  19 disabled youth, that doesn't mean they're the strongest of  20 children either, and when you start putting them around  21 plutonium, that worries me.  22 I have no agenda. I'm not a part of any  23 student groups, activist groups, I'm just a citizen. And  24 I'm not a chemist either, but I do know that there's a  25 difference between cleaning up garbage trash sites and 
 49 

 1 cleaning up plutonium. I could be wrong here, but that's  2 some of the most complex chemistry, that's pinnacles of  3 achievement as far as technology goes, as far as America  4 goes. So it's no joke. I mean, because we don't even  5 necessarily know what's going to happen.  6 You know what else, I've got to pose a  7 question. I would not want to be a horse and eating grass  8 that has plutonium potentially on it. I love animals and I  9 would never want to do that.  10 So I'm just a citizen. I'm nothing. So you  11 guys are the ones that are deciding, you're the leader and  12 you guys are the team that are helping. You're the leader,  13 you guys are the team, and I just hope that we keep in mind  14 the future.  15 And knowing that we are in the midst of such  16 wonderful technology, there's also a double-edged sword to  17 that. And so I just say, please be cautious, please be  18 careful. I don't know if I'm going to be living in Colorado  19 the rest of my life, but I know a lot of you guys will and  20 probably you guys do too, so this is our state, this is our  21 city and it is beautiful. Colorado is beautiful and I just  22 hope it can be safe. Thank you.  23 MS. ERIKSON: Wendy Vining and MaryAnne  24 Scholl.  25 BY MS. WENDY VINING: 

 50  1 Hi, my name is Wendy Vining, I'm a student of  2 CU Boulder and also a resident currently. I'd like to say a  3 couple of things. I also have taken some classes on this so  4 I am educated with the background on Rocky Flats and just  5 the hazards that it has caused.  6 In 1989 Rocky Flats was officially added to  7 the Superfund National Priority List. This classification  8 was designed to induce remediation of abandoned waste sites  9 across the U.S. ; however, no one truly knows how  10 contaminated Rocky Flats is. The 1957 and 1969 fires  11 released unknown quantities of plutonium into the  12 environment.  13 This being said, I guess I would cite  14 numerous studies showing the toxicity and hazards of  15 plutonium. It's a known carcinogen and other health hazards  16 that it does pose. I'd say that these unmeasured releases  17 from these fires and other night burnings that we don't have  18 any idea about, they release unknown quantities of plutonium  19 into the industrial zone as well as the buffer zone.  20 I think there has not been enough ground  21 sampling tests to prove that the buffer zone is truly safe,  22 and the samples that have been taken from a concentrated  23 area that is not necessarily representative of the area  24 overall.  25 I believe that even if we say that the buffer 
 51 

 1 zone is not contaminated, there's still the problem of  2 proposed seamless boundaries. I don't know how you can keep  3 people or educate them that this area is contaminated. This  4 area is not without proper signage or even preferably some  5 sort of fence or boundary.  6 I also question whether Fish & Wildlife is  7 fully staffed to account for this problem and I think just  8 overall, since no one can definitely prove or predict the  9 long-term consequences of the hazards that have been proven  10 in that area, I support Option A, no public access.  11 MS. ERIKSON: MaryAnne Scholl and Andrea  12 Noble.  13 BY MS. ANN MARIE SCHOLL:  14 For the record, my name is Ann Marie Scholl.  15 I am a CU student, I'm also affiliated with the Children's  16 Wilderness Fund. I am a runner, an avid runner and mountain  17 biker and I can tell you now, I will never step foot on that  18 site and I will never allow for my children to step foot on  19 that site.  20 I would like to define refuge. According to  21 Webster's Dictionary it is a shelter or protection from  22 danger, distress or difficulty. A place that offers this.  23 Although some will say the buffer zone is relatively cleaned  24 up, most of you tonight will agree, the industrial zone  25 still presents many dangers and thus is not a refuge. 

 52  1 I believe one of the biggest problems with  2 opening Rocky Flats to the public is the proposed seamless  3 boundary. I believe the seamless boundary between the  4 buffer zone and industrial zone is completely impractical.  5 How is one supposed to know if they have entered across this  6 imaginary line, quote, unquote, tolerable amounts of  7 contamination to the former Superfund site.  8 I realize the trail will be well marked, but  9 people are destined to go off trails. The two main problems  10 are, number one, posting signs, and number two, there is not  11 nearly enough law enforcement proposed to keep people off  12 this land.  13 As for the first problem of the signs, what  14 will they say? Will they warn of health risks? Will there  15 be fines for crossing these boundaries? As for the second  16 problem of law enforcement, if there's not enough people to  17 prevent people from crossing this land, why shouldn't they  18 go on it, especially if they've been told that this land is  19 a refuge.  20 Additionally, Alternatives B and D allow for  21 off-trail hiking. Again, and this is a question that I ask  22 you to write down, how is one to know when they have crossed  23 this boundary, especially when the trails are covered in  24 snow?  25 This is only one of many reasons that I vote 
 53 

 1 for Alternative A. People should not be led to believe that  2 this place is a refuge when clearly it is not. Thank you.  3 MS. ERIKSON: Andrea Noble and Chris  4 Morrison.  5 BY MS. ANDREA NOBLE:  6 Hello, I'm Andrea Noble and I'm a resident of  7 Boulder. And I know that the Fish & Wildlife Service is  8 getting this land signed off as clean after the supposed  9 cleanup done by the DOE; however, I am concerned that this  10 cleanup will not last the test of time and will be a danger  11 to future generations. And because of this, I believe that  12 the history of this site cannot be separated from its future  13 management.  14 What we do with this site will set precedence  15 on what we do with other nuclear sites all over the country  16 and I think it's important that we look at this with the  17 utmost caution.  18 If we do not know the future, that  19 contamination may be brought back up through burrowing  20 animals, erosion or whatnot, it may be safe at the  21 beginning, but who knows 100 years down the road.  22 I'm particularly concerned with hunting being  23 allowed on the land. That it is -- I support programs such  24 as the ones that you are proposing on other properties, but  25 not at Rocky Flats because of these reasons. I come from a 

 54  1 family of hunters and I understand that it's an important  2 issue for a lot of people and I think that, however, at  3 Rocky Flats it should not be allowed because not only of the  4 risk of contamination, but also because it is near to roads  5 and communities. Especially hunting options that are being  6 proposed, such as bow hunting.  7 The deer that would be shot generally have a  8 long distance to run after a shot with an arrow and it could  9 run on top of a road or off the property or into the DOE  10 area, and that is an issue that concerns me.  11 So I support Option A, the no action, because  12 I think that there is too much that is unknown about the  13 future of this site and that we should be as cautious as  14 possible. Thank you.  15 MS. ERIKSON: Chris Morrison and Julia  16 Schwab.  17 BY MR. CHRIS MORRISON:  18 I'm Chris Morrison and I live in Boulder.  19 I've heard a lot of people act as if Rocky Flats is some  20 special area that is -- like radiation has been invented in  21 the last hundred years, et cetera. I wonder how many of the  22 people here know the radon levels in your home. We all live  23 with radiation, people have always lived with radiation, and  24 plutonium is not some special form of radiation. If you've  25 got a high level of radiation in your home, you need to 
 55 

 1 remediate it.  2 I support Alternative B because I believe in  3 accepting a reasonable level of risk, and I think this is a  4 reasonable level of risk. We've heard about the high  5 winds. A lot of the radiation was also blown out east of  6 Rocky Flats. Just because property is east of Indiana  7 Street does not make it exempt from any consequences of  8 radiation and we haven't had the kind of study on the lands  9 around the great western Reservoir, Standley Lake, et  10 cetera. And if there is going to be extensive monitoring,  11 there needs to be monitoring out there.  12 And you look east of Indiana and you see  13 fields where the horses have stripped the vegetation off,  14 that is more of a concern to me than a few trails in  15 Alternative B. I think that we can safely access this site  16 with Alternative B and we need to be -- we need to monitor  17 it, we need to be careful about how we access it, but I  18 don't think the plutonium on the site should automatically  19 preclude public access. Thank you.  20 MS. ERIKSON: Julia Schwab and Lynn Segal.  21 BY MS. JULIA SCHWAB:  22 I'm Julia Schwab. I'm an art therapist and  23 I'm here to represent the honesty and trust the children may  24 experience in having a safe environment in which to play and  25 to explore. 

 56  1 I did an exercise with kids creating ways  2 that they could describe how they felt to be true inside  3 themselves. And these are images that the kids painted in a  4 way of saying, this is how I see myself. And then what we  5 did is we talked about what it was like when we have to deal  6 with things that are not true.  7 So I'm going to read a poem here that's  8 called "False". And "False" is a collaboration between two  9 characters talking to each other about how absurd it is to  10 live where there's such deceit.  11 "The black sky shines in the morning. So,  12 the green sun shines on my hair. So, I walk on the purple  13 ground. So, my red lips shine on the plants. So, my pink  14 shoes shine on my glasses. So, my brown coins shine on the  15 garbage can. So, my yellow teeth shine on the water. So,  16 my orange eyes shine on the desk. So, my green ring lights  17 a fire. So, my blue fingernails shine on the blackboard.  18 So, my gray notebook shines on your nose. So, my red lips  19 shine on the clock. So, my silver eyes shine on the  20 ceiling. So, my violet car shines on the moon. So, my  21 purple green dress shines on the sun. So, my silver red and  22 black paper shines on the wall. So, my maroon body shines  23 on the flag." Signed, Jeannie Turner and Nancy Ortiz.  24 Rocky Flats is not a safe place. It is  25 false. Let's protect the opportunity for children to live 
 57 

 1 in an honest world. Thank you.  2 MS. ERIKSON: Lynn Segal and Scott Hatfield.  3 BY MS. LYNN SEGAL:  4 Lynn Segal, Boulder. I remember when we  5 lived in Salt Lake, at one point our family had to drink  6 powdered milk because the cows were eating grasses. They  7 were doing above-ground testing in the area and ten years  8 later a particular dormant phase for leukemia, to happen, my  9 mom died in Washington at 39 years of age.  10 So I'm not really impressed with the  11 situation at Rocky Flats, naturally. We have a fence in  12 Israel, folks heard about the fence, 30-feet high cement  13 fence, this is the kind of fence we need here. Actually,  14 this is a very expensive fence, I'll tell you, very  15 expensive. And you and I are paying for it,  16 actually. But in Israel, it's actually outside  17 of the green line where it's not supposed to be so it's  18 actually having to be torn down. We should put it up here.  19 That would keep animals out definitely. I don't see a deer  20 that could cross that.  21 No particulates need be redistributed.  22 That's why we need a fence of this magnitude. No humans on  23 the site for 240,000 years, times two. That's the half life  24 of radioactivity. Refuse the EIS, the Environmental Impact  25 Statement, and deny certification to the EPA for subsequent 

 58  1 wildlife refuge status.  2 I remember hearing about this at City  3 Council, the first time I heard wildlife refuge, I thought  4 the same way as the gal that said, refuge, what? No refuge.  5 This is a Superfund site. John Till's study  6 of the 32 picocuries per gram, we need much lower than that.  7 I remember my dad, he lost his wife this way, was  8 complaining that John Till's study was too liberal. I  9 suggest much less.  10 The precautionary principle must be  11 considered. The cascade of effects from the remaining  12 results of this weapons plant can never be adequately  13 assessed. There is not enough money and resources to do it.  14 And if there were, there would still be unknowns. That is  15 why the precautionary principle needs to predicate all our  16 considerations of diplomacy, foreign relations and global  17 trade policies and the USA Neo-Absolutism. This is a new  18 term I heard at the war colloquium at CU last week.  19 Neo-Absolutism is our abuse of power and  20 arrogance on virtually every country on the face of the  21 planet. Any foreseeable use of this land of any type, any  22 use, serves as a validation for the establishment of future  23 DOE nuclear weapons plants, which are being actively  24 considered by our administration.  25 Weed management, use the micro (phonetic) 
 59 

 1 recommended by Glen Ackland to reduce threat of fires, a  2 little bug that eats all the weeds and then dies and then  3 there cannot be airborne transport of the particulates.  4 Also, a sprinkler system on the entire area to include the  5 buffer zone for light use surrounding the wind, heavy wind  6 and fire threat days and assure that there's not too much  7 water use that that would be the medium for redistribution  8 in the aquifers. Thank you very much.  9 MS. ERIKSON: Scott Hatfield and Bob  10 Findlay.  11 BY MR. SCOTT HATFIELD:  12 Scott Hatfield, Boulder, Colorado. I urge  13 you to adopt the no action alternative and keep people out  14 of the area. There's a lot of hot spots that people don't  15 know about. In my opinion, they'll never find all the hot  16 spots, the memorandum sampling method, and there's just too  17 many places that haven't been hit or sampled.  18 Dow going out there in the '50s and such and  19 dumping, burying, hiding stuff, and they could have done a  20 good job of hiding some of that stuff.  21 Another concern is the incineration fallout  22 from unknown vast quantities of mixed radioactive waste.  23 The residues here, they're talking about 71,000 kilograms of  24 radioactive ash, just from the incineration. I think in the  25 subsequent hearings that's what it was down to, 36,000, but 

 60  1 that was the first figure I heard.  2 Also, I've been involved with this Rocky  3 Flats issue since 1983. There's a real problem with the  4 culture of secrecy and deceit. An incomplete cleanup is  5 going to cause a lot of problems too. You'll have long-term  6 migration problems, you have streams down gradient from the  7 DOE site. There's a problem with actinides. The  8 radioactive particles have been characterized by DOE as  9 staying near the surface and migrating laterally mostly with  10 rain.  11 So you have that accumulation and DOE is  12 saying that it doesn't infiltrate virtually into the soil.  13 So you have this accumulation up near the soil. So burns  14 shouldn't happen, you should control the weeds. You should  15 probably check for bioaccumulation, acceptable species,  16 maybe do some tissue tests. Wildlife will be contaminated,  17 that's going to be a problem, birth defects, mutation. You  18 get people on there, kids will be crawling around eating all  19 sorts of dirt with actinides near the surface. Dust needs  20 to be minimized. Access and development will increase that.  21 It seems like a big green washing effort to  22 just sweep the problems under the rug here, put a happy  23 bunny face on it. Look at the Rocky Mountain Arsenal.  24 You've got school kids intentionally exposed  25 to live nerve gas bomblets and these are in areas that the 
 61 

 1 Feds have already designated as being cleaned. It reminds  2 me of -- some people wanting to go there reminds me of  3 talking to homeowners in the '80s that lived there saying,  4 hey, doesn't bother me, can't see it, can't smell it. It's  5 all okay.  6 MS. ERIKSON: Bob Findlay, Mike Donley.  7 BY MR. BOB FINDLAY:  8 I'm Bob Findlay, a CU student. I trust the  9 EPA and Colorado Department of Health will make an accurate  10 risk assessment of the site. Therefore I support the  11 proposed access, but I believe the addition of a public  12 rifle range and a place to throw clays would be appropriate  13 to this site. A public rifle range would be a practical  14 alternative to hunting.  15 MS. ERIKSON: Mike Donley and Jim Morris.  16 BY MR. MIKE DONLEY:  17 I'm Mike Donley. I'm coming as a citizen of  18 Boulder and also as a CU student. I'd just like to say that  19 Plan A is definitely the best course of action as to what's  20 still left on the site and the safety of the people that are  21 interested in using the site. And I just want to say that  22 this feels -- your representation here feels awfully  23 reminiscent of misinformation of the past, especially when  24 it refers to the atomic fallout test that she talked about  25 in Utah, that were being exposed to downwind fallout. 

 62  1 If this were a real representation of the  2 site there, that big blob that says DOE retained would have  3 crisscross patterns of all the stuff that's been left  4 underground, in the pipes, between buildings. Building 771  5 should be a big star on there in the way the contamination  6 is still left at the site.  7 And I just think that it appears that once  8 the DOE says this is clean and Fish & Wildlife is so eager  9 to get its hands on it, that the Fish & Wildlife Service can  10 be held responsible for like -- the DOE can be absolved of  11 any doubt if they say it's clean. They give it to the Fish  12 & Wildlife Service and any sort of problems arise in the  13 future, who is to blame? Are you guys going to say that  14 that's contamination after the site was cleaned up? What if  15 it's you find on the lower end of the site in the buffer  16 zone that's coming close to Indiana Street, you find 300  17 picocuries in the soil, are you still going to do anything?  18 Are you going to have any fence whatsoever?  19 And that raises another question of a lot of  20 people to make an informed decision before entering the  21 site, having a sign there saying this site was exposed to  22 radiation, even in this spot, even in the buffer zone, they  23 are above normal background levels of radiation. And there  24 should be a sign that says, if your child falls, you should  25 wash his cuts, clean the child's clothes, wash the child 
 63 

 1 thoroughly once you get home. And you should also have  2 fences around the industrial zone showing radioactive signs  3 and you should allow people to make an informed decision on  4 if they want to use the park or not, but it should be an  5 unbiased sign stating the facts. Thank you.  6 MS. ERIKSON: Jim Morris.  7 MR. HUGHES: This is the last person that's  8 signed up to speak. Obviously we do have a little bit more  9 time for people who want three minutes. I've got the  10 sign-up sheets, you can meet me over there.  11 BY MR. JIM MORRIS:  12 There's some good news, like LeRoy Moore and  13 a bunch of the folks at the Peace Center managed to force  14 the DOE to clean up the soil. Before that they were going  15 for a much more dangerous level of plutonium. So if all of  16 you get upset and talk to your neighbors and write letters  17 to the editor and stuff, we can improve it, we don't have to  18 go through this dog and pony show with the Fish & Wildlife  19 people pulling the wool over our eyes.  20 Basically the DOE lies. It always lies.  21 It's got so much power and it wasn't regulated by  22 environmental laws until, I don't know whether it was the  23 '70s or something where finally the military started having  24 to obey some of the cleanup laws.  25 Just quickly, some of the things I've noticed 

 64  1 over time, like they fired Iggy, the scientist that was not  2 finding plutonium moving the soil and then when it rained  3 heavily one summer and the plutonium moved in the soil, they  4 fired him. And when they made concrete out of the toxic  5 pond sludge, it all melted. The oil drums of plutonium  6 leaked and incinerated, it caught on fire. Building 371  7 cost up-teen millions and it was contaminated when they  8 first started it.  9 They lied about midnight burning. They lied  10 about dumping radioactive substances and volatile organic  11 chemicals into the drinking water supplies for Broomfield  12 and Westminster. They just lie all the time.  13 They lie in other places. Like they drill  14 test wells and they drill them in solid rock where there  15 wasn't any water. There's supposed to be wells to test  16 water. They don't consider tornados, high winds, stream  17 beds moving, Arvada building housing, earthquakes, et  18 cetera. These guys are liars.  19 Just a sellout because they don't have to  20 clean it up as much if it's a wildlife refuge. That's the  21 reason they don't want to monitor or look anymore, because  22 if they find any more waste, they might have to clean it up  23 and get upset.  24 No access, Alternative A. Sample the rest of  25 the site, get them to post a bond, realize -- like the local 
 65 

 1 politicians, Romer, Lamb, Skaggsworth, they all supported  2 Rocky Flats at first until they were repeatedly lied to.  3 And after they were lied to, then they finally started  4 listening to the citizens.  5 So it's only when you guys get upset and then  6 DOE starts lying over and over to politicians and to us that  7 we'll find out how bad it is. They don't want us to find  8 out. They're just a criminal agency.  9 In the last year, last summer, they tried to  10 downgrade radioactive waste so it could be disposed of in a  11 normal sanitary waste, no special treatment. They also  12 tried to recycle radioactive waste. I don't know what else  13 I can say. It's criminal to do this working for the Fish &  14 Wildlife, it's criminal to work for the PR agency. You're  15 like tobacco lawyers.  16 MS. ERIKSON: Rich Andrews is the last one,  17 unless somebody else signs up.  18 BY MR. RICH ANDREWS:  19 I'm Rich Andrews. I'm an environmental  20 engineer. I worked in the uranium industry until I couldn't  21 stand it. And that was approximately 25 years ago,  22 approximately. I got out because there is no separation of  23 any aspect of the uranium or the fuel processing system or  24 cycles for weapons and we can't go on with this.  25 The Fish & Wildlife Service unfortunately has 

 66  1 become the pawn of the agency, ERDA, the DOE and all the  2 contractors that operated that place out there. You don't  3 have an alternative in your EIS that meets my views. My  4 views are close it, fence it, pave it over.  5 With all of the money that's been spent on  6 writing memos over the last 15 years, we could have already  7 closed this and paved it over permanently. And that's what  8 ought to be done with it.  9 It wasn't safe from the minute the Atomic  10 Commission stepped onto Rocky Flats, it wasn't safe when Dow  11 was there, when Rockwell was there or any operator since.  12 It is contaminated. It will be contaminated for more than  13 this human civilization has existed.  14 We cannot allow it to be used for anything  15 other than absolute closure. We should declare this site a  16 national sacrifice zone.  17 Rocky Flats is Colorado's erosion. Erect a  18 monument at the perimeter that says, this site is forever  19 closed. This monument stands to acknowledge mankind's low  20 point in its intellectual and social evolution. We can't --  21 and we commit to never go down that path again.  22 I ask you, the Fish & Wildlife Service, to  23 take heed. I say you are the pawns of all these other  24 people and I feel sorry for you because you've been put into  25 a horrible position. Close it, seal it. 
 67 

 1 MR. HUGHES: I'm going to ask Dean to come  2 take the microphone and say a few words in response to  3 anything that he heard as well as address the questions that  4 have been asked. And if we have time, there may be some  5 more.  6 MR. RUNDLE: I want to thank all of you for  7 coming out tonight and participating in our process. We  8 also appreciate the overwhelming support for the  9 alternatives. Actually, there is an important message I do  10 want to give you before I get into questions.  11 I know that many of you are frustrated about  12 the scope of a Comprehensive Conservation Plan. Many of the  13 testimony tonight addresses issues that are cleanup issues.  14 And I need to make it completely clear to everyone here that  15 U.S. Fish & Wildlife Service is not responsible, nor do we  16 have the authority to make cleanup decisions at Rocky  17 Flats. It is clearly and unequivocally the authority and  18 responsibility of the Department of Energy with oversight  19 from the Environmental Protection Agency and the State of  20 Colorado. You should be glad of that. You would not want  21 the Fish & Wildlife Service to be making cleanup  22 decisions on this site. Making nuclear weapons and the  23 cleanup aftermath is not our core business, our core  24 business is managing land for wildlife and wildlife habitat.  25 Early on Mike talked about one of the things 

 68  1 that's made this a challenging process for us, this time  2 line that we are given by law. And that is that this is  3 very unusual for us to be in this position of writing a  4 Comprehensive Conservation Plan before we acquire land.  5 The plan that we have presented to you, the  6 alternatives we have presented, are based on the pretext  7 that there will be a complete and effective cleanup of this  8 site and that the site will be certified as safe for  9 wildlife refuge use, protective of a refuge worker and  10 people who might be less exposed than the refuge worker.  11 And that will be certified by the public health agencies  12 that are overseeing the Department of Energy and the  13 cleanup.  14 Unfortunately, the way this cleanup is  15 progressing, it is an interim process and all those cleanup  16 decisions that will be made by the DOE, EPA and the State of  17 Colorado have not yet been made. There is no record of  18 decision at this time, the remedial investigation and  19 feasibility study is not yet complete. The comprehensive  20 risk assessment is not complete, yet we are required by law  21 to complete our planning process by December of this year.  22 So what that means is, these alternatives are  23 proposed with the understanding that this will be certified  24 as safe for those things when these things are done. If new  25 information comes to light before the refuge comes in, it's 
 69 

 1 very clear in the statute that cleanup trumps anything in  2 the refuge.  3 There is additional data collection that is  4 ongoing. We have deer tissue samples that are being  5 submitted to laboratories for analytical analyses for  6 plutonium, americium and uranium. If we find out from that  7 analytical test that there is contaminant tissue, of course  8 that will affect any final decision to implement this  9 proposed hunting plan.  10 The Fish & Wildlife Service agrees that more  11 characterization is needed. We have asked the Department of  12 Energy for this, they have supported us as this being done.  13 And I believe, Mark, at this time, over 500 additional  14 locations are being sampled in the buffer zone to look for  15 contaminants in the soil.  16 There are other -- it's great to see  17 everybody here tonight. In some of these situations I  18 believe you're not addressing your concerns to the people  19 who have the authority to make the decisions that you want  20 to see changed.  21 Questions about what type of boundary will be  22 between the DOE retained lands and lands that may be  23 transferred to the U.S. Fish & Wildlife Service will not be  24 made by the U.S. Fish & Wildlife Service, they will be made  25 by the Rocky Flats cleanup agreement parties, the DOE, the 

 70  1 EPA and the State of Colorado. We will provide input to  2 that, you also provide input to that too.  3 I think it's very unfortunate that one of the  4 Citizen's Advisory Boards, which is a formal group of  5 citizens that informs the Department of Energy, has their  6 meetings, there are one or two members of the public who  7 participate and address these types of questions and  8 concerns to DOE and EPA and the State Health Department when  9 they are present in those settings. So I would encourage  10 all of you to avail yourselves of the opportunities to talk  11 contaminated issues to contaminant decision makers.  12 Q. When is the next one?  13 MR. RUNDLE: I think they're the first  14 Thursday of every month.  15 Q. And where are they?  16 MR. RUNDLE: College Hill Library in  17 Westminster. Thank you.  18 Other opportunities for you to have input are  19 through your local elected officials who represent you on  20 the Rocky Flats Coalition of Local Governments, and I also  21 encourage you to make your comments and ideas directly to  22 the RFCA party agencies.  23 So cleanup trumps -- there's been a lot said  24 tonight about the overall dangerousness of the entire Rocky  25 Flats site. I can tell you that as of today, I think 
 71 

 1 earlier we were talking about 5 picocuries per gram maximum  2 contamination than the lands currently proposed to transfer  3 to Fish & Wildlife.  4 I don't know of any credible scientific  5 evidence of dangerous levels of contamination in the lands  6 that are proposed to be transferred. We'll take more  7 samples, if we find higher levels in this sampling,  8 obviously that will cause us to alter our plans or more  9 likely cause DOE to alter its cleanup plans and to expand  10 them.  11 I guess that about covers it. I think the  12 most important thing that we all have to do, Fish & Wildlife  13 Service and the public, is to engage the RFCA parties as  14 important decisions are going to be made about long-term  15 stewardship, the institutional control plans and how this  16 site is going to be monitored and how the remedy is going to  17 be maintained for the long term. Those decisions are  18 upcoming and we will be involved in that and I encourage all  19 of you to use the appropriate venues that are available to  20 you to communicate your concerns and desires about that.  21 The DOE will be responsible for those  22 institutional controls, not the Fish & Wildlife Service.  23 Before I go on, I'd just like to acknowledge  24 John Rempe. John would you like to say anything about the  25 refuge? John is with DOE. 

 72  1 MR. REMPE: For those of you who don't know  2 me, I'm John Rempe, R-e-m-p-e, I'm with the U.S. Department  3 of Energy out at Rocky Flats. We are the agency that is  4 responsible for the cleanup. We are the agency that will be  5 responsible for managing the retained lands after the  6 cleanup is over.  7 Really, the only thing I wanted to say  8 tonight, and not to take away from the purpose of the  9 meeting, we will be hosting an open house on April 14th.  10 Mike, can you write this down? Thank you. We'll be hosting  11 an open house regarding the cleanup on April 14th from 6:00  12 to 8:00 in the evening. We have yet to choose a location  13 for this and we will advertise that through a community  14 advisory through our local government action, but also on  15 our website, which is www.rfets.gov.  16 And quite simply -- we hope to see many of  17 you there, not all of you there, and be able to answer your  18 questions about the cleanup. Very simply this process has  19 evoked a lot of interest in the cleanup and we would like to  20 get a chance to tell you what we know about the site, how we  21 plan to clean it up and how we plan to take care of it  22 afterwards. So hope to see you there and thank you very  23 much.  24  25 
 73 

 1 Q. What's the phone number?  2 MR. REMPE: If you have specific questions  3 about the meeting place, why don't you just call me. My  4 number is (303) 966-6246. And we'll get you the information  5 you need.  6 MR. RUNDLE: Thank you, John. And we need  7 to make sure, if we can, to contact the people that were at  8 Westminster last night because the time that I had was 3:00  9 to 5:00 p.m., so hopefully we make sure we do that.  10 I'm going to try to answer questions that I  11 can that are within the scope of our plan and our decision  12 making pool. The first question from the testimony that  13 Mike captured was, why select Alternative B. And I think  14 there was a larger question there about why a preferred  15 alternative was proposed.  16 It's our responsibility to bring to you a  17 preferred alternative. This decision is an executive  18 decision made by the regional director of the U.S. Fish &  19 Wildlife Service, so the process we're engaged in now is to  20 get your input and feedback back on the proposal.  21 We believe at this point that Alternative B  22 is the best of the four plausible alternatives to meet the  23 intent of congress in establishing Rocky Flats as a future  24 National Wildlife Refuge, to meet the purposes of that  25 established in the legislation, the missions and goals of 

 74  1 the National Wildlife Refuge system and in concert with  2 feedback that we got during our public scoping process.  3 So we presented these alternatives, we're  4 required to present a preferred alternative, that is part of  5 NEPA, and that's what we've done. And we're accepting and  6 we'll definitely consider the comments that we're hearing  7 during this formal comment period.  8 The second question was, why take the risk of  9 exposing people to contamination. And again, I'll say that  10 this is -- this plan is predicated on a safe and effective  11 cleanup that is certified by the Environmental Protection  12 Agency. There is probably not zero risk, but the cleanup  13 levels that are being implemented now, are designed to be  14 protective of the most exposed people for the future use of  15 the site.  16 The future use of the site, as brought  17 forward by congress, is to be a National Wildlife Refuge.  18 The cleanup is to be based on protection of a refuge worker.  19 And I believe, Mark, the current levels and calculations are  20 three times ten minus the fifth or 1 in 300,000 chance of  21 cancer above background for refuge workers.  22 This is the minimum requirement for a cleanup  23 is 1 in 10,000 chance above background. So that's the risk  24 that we're talking about. Visitors would not be on the site  25 working on a daily basis would have the lowest risk. 
 75 

 1 The next question was about horse access and  2 why it would only be allowed in the southern part. And we  3 got a lot of feedback from the folks during scoping about  4 different types of access that they wanted. We had  5 originally proposed only foot and some limited bicycle  6 access on some trails, there was a large input requesting  7 the equestrian use be accommodated as well.  8 Part of what we do to try to avoid conflict  9 between different groups is use temporal space and zoning.  10 That was our thought on this case. Some people want to be  11 on those types of multiple use trails, some people want  12 pedestrian only, some people want bicycle. Only there's a  13 big mix and we were trying, in our proposals, to balance  14 that issue.  15 If Alternative A is selected, how do you keep  16 people out of the site. Once again, this is really outside  17 of the scope of our plan. If I recollect, we're talking  18 about out of DOE retained lands, and that's a decision that  19 will be reached by the RFCA parties and when the  20 institutional controls are determined at the time of the  21 final record of decision. So you'll have an opportunity to  22 engage in that public process with those decision makers.  23 How is one supposed to know when they've  24 crossed a boundary? We will be responsible for the external  25 boundary of the site after land is transferred. All our 

 76  1 proposals call for us to maintain the existing five-strand  2 barbed wire stock fence around the site. Our boundaries  3 will refer to National Wildlife Refuge boundary signs that  4 say National Wildlife Refuge, all unauthorized entry  5 prohibited. And they will be posted at appropriate  6 intervals around the site and corners marked as well.  7 Q. What is an appropriate interval?  8 MR. RUNDLE: Typically on rural sections we  9 use about a quarter mile, but an urban area, if there's a  10 lot of traffic, we may go closer than that. And we post  11 them on the corners. That's typical. And it would depend  12 on the use. Where we've got private pasture lands on the  13 south, where there's only one person at this time that has  14 access, I think it's a quarter mile is probably adequate, if  15 that land is developed later for residential use we probably  16 would put up signs a little bit down there.  17 If terms of the markers of the boundaries  18 between the two properties, again that's outside the scope  19 of this plan. We will be making recommendations to DOE on  20 this. We want this boundary to be clearly and as  21 permanently marked as possible.  22 If it's deemed safe by the RFCA parties, we  23 would prefer the boundary not preclude the movement of  24 wildlife between the two ownerships or unnecessarily detract  25 from the aesthetics of the site. But again, that's going to 
 77 

 1 be something determined by somebody else. And whatever the  2 institutional control plan calls for, we'll certainly  3 respect and live with that because cleanup trumps refuge in  4 all cases.  5 What if high contamination levels are  6 discovered in the buffer zone? We're going to be -- like I  7 said, there's more looking to be done. The institutional  8 control samples are being taken. We do what's called a  9 Level 3 -- excuse me, a Level 3 contaminant survey. We're  10 required by DOE policy to do a contaminant survey on all  11 lands before they're acquired in the U.S. Wildlife Refuge  12 System.  13 Level 1 survey is typically done when there's  14 farm lands. And that may be simply a check with the health  15 departments to see if there are any known dump sites. An  16 inoculate survey of the site is looking for old drums and  17 farmsteads and things like that.  18 The Level 3 survey is the highest level  19 survey and this involves collecting analytical data from  20 soil and byota, the sampling of deer tissue, we'll be  21 reviewing aerial photographs looking for disturbances that  22 are not documented to see if there's sites we need to test.  23 We heard a lot about clandestine  24 nighttime dumping, things like that. We at this point  25 aren't aware of any of that in the land proposed in the 

 78  1 National Wildlife Refuge. If you know where something is,  2 talk to Mark Sattelberg and point it out on the map and  3 we'll go look.  4 I think that's all the questions. DOE is  5 going to have to come and get anything that they left on the  6 site. We're not going to be responsible for picking up  7 anything. The only thing we'll be responsible for would be  8 any contaminants that we would cause to be released through  9 our management, such as if there was a misuse of an  10 herbicide or a spill of hydraulic fluid from a tractor while  11 we are managing a refuge, that would be our responsibility.  12 Q. One of your earlier responses to one of the  13 questions about the risk of exposure, you said EPA will  14 certify. Is that the same EPA that certified that downtown  15 Manhattan was safe after the two towers came down? I used  16 to work at EPA when it was an honorable association, but I  17 can't say that's true now, but if you're relying on them  18 now, you shouldn't either.  19 MR. RUNDLE: I don't think there was a  20 question there.  21 Q. Well, is it the same EPA?  22 MR. RUNDLE: To my knowledge, it's the same  23 Environmental Protection Agency.  24 Q. How often will your contaminant surveys be  25 done? 
 79 

 1 MR. RUNDLE: We will do a pre-acquisition  2 contaminant survey. DOE will be responsible for long-term  3 monitoring of the effectiveness of the remedy.  4 Q. In the buffer zone?  5 MR. RUNDEL: If it's required by the  6 long-term monitoring plan, which we don't decide, you  7 guys need to talk to the RFCA parties about that. I'll say  8 it again, the Rocky Flats cleanup agreement parties that  9 make the decisions are the Department of Energy, United  10 States Department of Energy, United States Environmental  11 Protection Agency, and the State of Colorado, Department of  12 Public Health and the Environment.  13 Q. Can you tell us how much resolve is being  14 paid, whether it comes out of your budget or DOE's budget?  15 MR. RUNDLE: I don't know the exact amount of  16 the contract, but I believe we can get that for you. They  17 are contracted to the U.S. Fish & Wildlife Service, DOE has  18 provided funding to us for the completion of this  19 Comprehensive Conservation Plan EIS.  20 Q. Are there staff members present here now?  21 MR. RUNDLE: We have three contractors.  22 Q. You had mentioned that you have taken deer  23 for sampling for americium and plutonium; is that right?  24 MR. RUNDLE: And uranium. The deer were  25 collected last year in a cooperative effort with the 

 80  1 Colorado Division of Wildlife for chronic wasting disease.  2 26 deer were taken for CWD testing, which we use that  3 opportunity to collect tissue samples from all those deer,  4 muscle, liver, bone, lung and kidney.  5 Q. My question is, has the muscle been  6 characterized for a volatile organic carbon tetrachloride?  7 MR. RUNDLE: We're not putting that in right  8 now. To our knowledge, there is a carbon test plume in the  9 industrial area, but it's a groundwater issue, to the best  10 of our knowledge.  11 Q. I understand that you're going to be testing  12 fauna. How about flora, are you going to do any vegetation  13 testing?  14 MR. RUNDLE: I don't know. The plan is not  15 complete yet.  16 MR. SATTELBERG: Right now the plan is not to  17 test any of the --  18 Q. Why not?  19 MR. SATTELBERG: Mostly because there's just  20 studies done by CSU.  21 Q. I've seen studies that say plants do uptake  22 plutonium into their roots.  23 MR. SATTELBERG: They do take some up, but not  24 very much. You have to look at which animals are going to  25 be eating the roots and whether or not they are going to 
 81 

 1 transfer through the food chain.  2 Q. And therefore no sampling is necessary?  3 MR. SATTELBERG: We may, it's just really up  4 to the DOE.  5 Q. At this point there's information on two  6 occasions, I don't know if Lisa Morzel is still in the room,  7 from Boulder City Council, she asked John Rempe to provide  8 samples of vegetation for analysis. He refused twice  9 without reasonable funding. I think this is a matter --  10 it's something we should insist on before you agree to burn  11 500 acres each and every year. You must do this out of  12 decency, for God sake.  13 Q. Why allow hunting?  14 MR. RUNDLE: Good question. As Bini put on  15 her chart here, there are -- the U.S. National Wildlife  16 Refuge is basically for two reasons. One is to provide a  17 wholesome outdoor recreational experience, and also for  18 population control of ungulates.  19 Our organic legislation, the National  20 Wildlife Refuge Improvement Act of 1997, identifies six  21 priority public uses for refuges, and they were listed --  22 and hunting is one of them. These are the things that  23 congress said we should provide to the public on National  24 Wildlife Refuges whenever it is compatible for establishment  25 purposes of the refuge. 

 82  1 Q. Hunting with a bow, like in Vermont, hunting  2 with a bow in a ten-year period left something like ten  3 times the number of injured deer than hunting with a gun. I  4 mean, I'm against hunting, but hunting with a bow leaves far  5 more injured animals. Surely there's more wholesome  6 activities like hiking rather than hunting and murdering  7 animals.  8 MR. RUNDLE: I'll take that as not a  9 question.  10 Q. I have a question about your soil survey from  11 the contamination. Are you going to at all account for hot  12 spot possibilities or will you be taking an overall average  13 of the hot spots?  14 MR. RUNDLE: What is it, Mark, it's 5 samples  15 and 4 more composite testing every 30 acres.  16 Q. Can you clarify what he said?  17 MR. RUNDLE: I'm sorry, Mark?  18 MR. SATTELBERG: The sampling calls for  19 gridding the entire site in 30-acre grids and then taking  20 five subsamples from each 30-acre grid and composite into  21 one sample.  22 MR. RUNDLE: So there will be about --  23 MR. SATTELBERG: Total subsamples will about  24 570. Those would be composited into about 115 samples  25 across the buffer zone. 
 83 

 1 MR. RUNDLE: And what would that -- or if you  2 can give me how much of that increase or knowledge of what  3 we have now in the buffer zone.  4 MR. SATTELBERG: The sampling plan is set up  5 to give us 90 percent confidence that we find everything  6 that's out there. There's only a 10 percent confidence that  7 we've missed something.  8 Q. My question is, I understand that the buffer  9 zone, the zone that's going to be turned into a refuge, will  10 have to be cleaned, certified cleaned before Fish & Wildlife  11 accepts it, but the zones that are going to be kept by the  12 DOE is still going to be contaminated. Everyone agrees to  13 that. How are -- how do you control for movement of that  14 contamination onto the Fish & Wildlife Service land?  15 MR. RUNDLE: This is really again a cleanup  16 question. We don't decide. But the surface, from my  17 understanding, is cleaned to a depth of three feet. So we  18 know there's going to be some residual contamination and  19 it's going to be a pathway cut off of three feet of clean  20 soil. So if someone did walk on the surface and where that  21 is, I really think as long as there's long-term stewardship  22 and how we maintain that remedy, and that's a decision that  23 RFCA parties will make, and we all need to engage it.  24 Q. If this site is opened for public use, what  25 type of information will be provided to the public about its 

 84  1 history and contamination?  2 MR. RUNDLE: I think that's a very good  3 question. And we do have a safety objective in all of the  4 alternatives about educating people. We have not gotten yet  5 to the specifics that of. I think that would be an  6 important thing for you to provide in written comments if  7 you have specific language that you think we should consider  8 when we do a sign plan out there, but there will be a safety  9 education component regardless of which alternative is  10 finally selected. And that may be signs, it may be  11 brochures, things like that.  12 Q. Are you aware that if there were five people  13 in a room and one is dead and one is running a temperature,  14 spiked temperature, and you took a composite or an average  15 of their temperatures, you'd have everybody alive. I think  16 it's not good to take a 30-acre site where there could be a  17 hot spot and then average it to other places where there  18 could be no contamination. And I put it into the form of a  19 question. Are you aware?  20 MR. RUNDLE: I am not. Again, that's  21 something that needs to be taken up -- I'm not an expert on  22 design and those types of samples.  23 Q. You said the DOE is responsible for the  24 cleanup decisions, is Fish & Wildlife providing comments and  25 guidance to the cleanup levels to protect from the 
 85 

 1 resources?  2 MR. RUNDLE: We are. We do have two  3 contaminant people working with DOE, we do review plans, we  4 do provide comments and suggestions to them.  5 Q. Nd are you providing the same comments you  6 would if it was a private company that was responsible for  7 the contamination?  8 MR. RUNDLE: Absolutely.  9 Q. My understanding is that while the  10 concentration has been on surface cleanup, there will be, in  11 fact by their admission, little or no cleanup below three  12 feet. And so I'm sure there are many, many industrial sites  13 that would fit into this category where the contamination is  14 below three feet. Think of a lot of gas stations, in  15 particular, using tanks. My question is, does this pose a  16 great new opportunity for Fish & Wildlife to expand their  17 operations across the nation by declaring these sites  18 wildlife refuges?  19 MR. RUNDLE: That's really outside the scope  20 of our plan. This site is designated as a future refuge by  21 congress.  22 Q. I would just be interested in hearing how you  23 feel about being placed in a position where you're  24 responsible for an area which you have not qualified  25 yourself as a qualified member of the DOE and the area that 

 86  1 is yours and managed by you and the contaminated area is  2 still the property of the DOE. How do you feel about that?  3 MR. RUNDLE: I'm not sure I understood.  4 Could you restate that briefly so I can give you an  5 answer?  6 Q. I'm interested in hearing how you feel about  7 your position in which you're maintaining the lands in which  8 you have not had any control in the standards of safety or  9 the signage between your lands and also the contaminated  10 lands that are nearby.  11 MR. RUNDLE: As I said before, we are not  12 providing cleanup. I do have considerably more trust in the  13 health agencies that are overseeing the cleanup than some of  14 the other people in this room. I'm not an employee of the  15 government, I work for you. And we're the executive branch.  16 Congress passes laws and we execute them to the best of our  17 ability.  18 Q. I think I missed it. What did you say the  19 Fish & Wildlife was considering as the dangerous level of PU  20 in the soil?  21 MR. RUNDLE: You know, we don't set that  22 standard. All I can say is that right now, to our  23 knowledge, the landscape outside that green blob, the  24 highest levels are 5 picocuries per gram. The State Health  25 Department and the EPA are not requiring any cleanup of any 
 87 

 1 of that land that is proposed to be transferred because they  2 don't think there needs to be cleanup there to be protected  3 of the most exposed person.  4 Q. I was actually wondering if you had started  5 to think about any sort of safety protocols similar to the  6 Rocky Mountain Arsenal, such as zero dust policy or constant  7 misting to kind of keep the soil from redispersing itself?  8 MR. RUNDLE: I believe they do have dust  9 control going on.  10 Q. I mean, when it was turned over to you and  11 you all are monitoring the area, do you have that for your  12 own safety protocols?  13 MR. RUNDLE: We have not been considering  14 doing that because we're not in the cleanup business. We  15 will not be cleaning up this site, it will be certified for  16 the uses that are proposed.  17 If you look at the back of the plan, we went  18 to the State Health Department and EPA and said, we're  19 considering using grassland management tools such as  20 prescribed fire, grazing, using tillage equipment to do some  21 site restoration. Is this safe? Can we do this? And there  22 are letters from both the State Health Department and the  23 EPA, and you can read those, and their answer was, yes, in  24 the areas that we anticipated would be transferred.  25 The intent that I've gotten from the State 

 88  1 and EPA is that the lands that will be transferred and not  2 required to be retained by DOE will not require any  3 institutional controls to be protected.  4 Q. I had a question. I'm concerned about  5 burrowing animals such as prairie dogs that may go below the  6 three-foot level that is certified as cleaned, and if you  7 plan on dealing with that situation?  8 MR. RUNDLE: Again, we're concerned about  9 that as well because we want this remedied to be state  10 protected in the long term. The exact requirements of doing  11 that again are part of institutional controls and outside  12 the scope of our plan, but we do address the issue and  13 concern about prairie dogs.  14 If you read about the prairie dog management,  15 that's proposed in the various alternatives. We do not  16 want to exacerbate the situation. We will not accept --  17 well, Alternative B would allow acceptance of relocating  18 prairie dogs. We'll do that with some municipal governments  19 to accept prairie dogs. Our proposal is that we not accept  20 any prairie dogs and we also want to manage our vegetation  21 to deter movement of prairie dogs toward the boundaries.  22 so we really need to be careful about where vegetation  23 heights are reduced to various grassland management  24 techniques.  25 We don't want to make it easy for prairie 
 89 

 1 dogs to invade the buffer zone. We have made  2 recommendations to DOE about the types of vegetation that  3 they should receive and to their retained lands and it's a  4 very important component of preventing prairie dog invasion  5 to maintain a robust and tall vegetative cover on these  6 sites.  7 Q. I'm confused. If you could help me  8 understand, I think I heard you say that -- you were just  9 referring to requesting permission to do fires in the buffer  10 zone. Is that --  11 MR. RUNDLE: We have proposed, in  12 several of the alternatives, that we would use prescribed  13 burning as a grassland management technique. Also, in  14 several alternatives we propose to use grazing, either  15 as a grassland management technique or using goats as  16 a weed control technique as part of integrative pest  17 management.  18 We also may, in some alternatives, use some  19 tillage to recede areas that are invaded with exotic  20 vegetation. So we went to the health agencies and asked  21 them about what they thought about those ideas and their  22 responses are in our plan.  23 Q. So it seems to me like I've also heard that  24 we're in agreement that there is not a very well understood  25 characterization of the contamination in the buffer zones. 

 90  1 Is that -- am I right?  2 MR. RUNDLE: Well, what I think I said is we  3 don't have any data right now that says there's dangerous  4 levels of contaminants out there.  5 Q. That's because we don't have data on it.  6 MR. RUNDLE: And as I said earlier, the  7 cleanup is more important than the refuge. And if we find  8 that there are levels -- we have to be done by December.  9 All these decisions are made by then. I don't know how long  10 it will be until land may be transferred. There has to be a  11 record decision, there has to be certification. It may be  12 in 2007 or '8, it may be a lot longer than that.  13 Q. If this is going to be entitled a wildlife  14 refuge and if those are the six goals of the wildlife  15 refuge --  16 MR. RUNDLE: Those are the priority public  17 uses of National Wildlife Refuges we allow, as opposed to  18 hang gliders or model airplanes, those are the goals of the  19 refuge.  20 Q. I'm just thrown by, all of a sudden if we're  21 talking about -- sounds like you're trying to manage it as a  22 cattle ranch again. And if you're going to be killing off  23 or discouraging things like prairie dogs which support about  24 160 other wildlife species, that doesn't sound like a  25 wildlife refuge. Assuming it's safe for humans or animals, 
 91 

 1 are you intending to just use this as an extension of a  2 cattle ranch or is it really a wildlife refuge?  3 MR. RUNDLE: Absolutely not. There are  4 several ecological factors that are important in the  5 evolution and the maintenance of healthy grasslands. One of  6 the natural ecological pressures on grasslands are grazing  7 by bison. If we use cattle grazing it will be as a  8 grassland management technique. It will be short rotation,  9 intensive grazing to emulate natural grazing patterns. So  10 we would be using cattle to manage grass, not grass to feed  11 cattle. Does that make sense?  12 Q. Yes. And I would hope that you wouldn't be  13 killing off predators.  14 MR. RUNDLE: No, we're not into that. The  15 prairie dog issue, as I said, we are concerned, we don't  16 want to exacerbate any problems with prairie dogs moving  17 towards the retained land. Also, the black tail prairie dog  18 is typically a short grass species. Rare habitats on the  19 western side of the Rocky Flats live in native tall grass  20 who are native-habitat types. We think that prairie dogs in  21 that portion of the refuge would not be part of the natural  22 environment because black tail prairie dogs are not a tall  23 grass prairie species.  24 Q. They're short grass?  25 MR. RUNDLE: That's correct. 

 92  1 Q. So you don't have any intentions of restoring  2 this to any short grass prairie?  3 MR. RUNDLE: If you look at this habitat  4 map up here, you can see that portions -- the short grass  5 is short and mixed grass, these green colors, so the  6 eastern part of the site is short and tall grass prairie.  7 We have a map that shows current prairie dog colonies, here  8 and here, so there's not a lot of prairie dogs on this site  9 now.  10 We went under the various alternatives  11 allowing to expand to certain acreages, but we don't want to  12 encourage them toward the DOE lands and we don't want to  13 encourage them toward the tall grass areas.  14 Q. I just want to thank you for making this  15 so much better than the scoping meetings where we really  16 could not have a discussion like we have now, which I  17 think resulted in a flaw to the EIS because it didn't  18 represent very many people and didn't represent good  19 informed opinion.  20 My question to you is, I've counted 30 people  21 who spoke to you here, and out of those 30, four people  22 supported your plan. Two of those represented, I think a  23 bicycle association and an equestrian association, so  24 basically less than 10 percent or around 10 percent of the  25 people supported your plan. What are you going to do about 
 93 

 1 it?  2 MR. RUNDLE: Well, we're going to complete --  3 first let me address what you said earlier. I appreciate  4 the comment. We did change our meeting format and I know  5 that some people, including yourself, have an opinion that  6 the scoping process was flawed. We do not accept or agree  7 with that. We believe the scoping process was appropriate  8 and effective.  9 One example I would give of that is  10 that last night there were 44 people at the meeting in  11 Westminster, only seven chose to speak. The way we did  12 our scoping, everyone was engaged. So we can argue that,  13 but I do not accept your assertion about the scoping  14 process.  15 That said, we are about a third of the way  16 through the public comment period on the Draft Environmental  17 Impact Statement, CCP, so we've heard a lot of good  18 testimony tonight. And much of that was not within the  19 scope of our plan and not within our decision making  20 authority.  21 We have two more public meetings to go. We  22 will be receiving comments, I'm sure, from many more people  23 through a written process or E-mail. We'll take all this  24 back and evaluate those, make recommendations for changes to  25 the regional director. Eventually a decision will be made 

 94  1 by the regional director of the Fish & Wildlife Service, and  2 the final document that comes out, the EIS and the CCP will  3 be split into two separate books. The Environmental Impact  4 Statement will include the comments that are made here and  5 our responses to those comments. So some will probably be  6 accepted and some will probably not and we will provide an  7 explanation of that in the final document.  8 Q. I have a question about water supply, a  9 two-part question. Who is planning to provide clean  10 drinking water for recreational uses, and if so, where are  11 you going to be pumping it in from?  12 MR. RUNDLE: I've never done a word search,  13 but I don't think the word play is in the CCP. There are no  14 picnic benches or jungle gyms and there are no watering  15 points, except if we have a visitor contact station, we  16 would provide water there. Probably at this point we'd have  17 to have that imported through a cistern, we're not going to  18 use groundwater.  19 Q. I would hope you wouldn't.  20 MR. RUNDLE: There frankly is not enough  21 groundwater on the site.  22 Q. If you're going to be letting handicapped  23 people in, you're going to have to stick with ADA rules and  24 all that. Does that bring up more -- does that bring up  25 more laws that you have to abide by? Do you have to provide 
 95 

 1 them with water or you don't have to?  2 MR. RUNDLE: We have to provide equal  3 opportunities for access. The one trail down through the  4 Lindsay Ranch will be a full accessible trail in terms of  5 grading and surfacing, so it will be wheelchair accessible.  6 I think all the alternatives, except A, provide a portable  7 toilet, which would have to be accessible on the site, but  8 there are no recreational facilities and neither are there  9 at most of the trail heads of the managed spaces in the area  10 either.  11 MR. TRENHOLME: Providing water isn't a  12 requirement of EPA.  13 MR. RUNDLE: This is wildlife recreation,  14 not city park recreation and we would expect people to be  15 prepared.  16 Q. In the newspaper it said that DOE and  17 Kaiser-Hill would get a $700 million bonus if they complete  18 the cleanup by 2006. If that's accurate, do you feel that  19 you might doubt whether they are scientifically honest when  20 they say the cleanup is completed.  21 The reason I'm asking that is, I've just been  22 reading a book called Science Under Siege and it talks  23 about, in various cases, like agency scientists will say  24 something about protecting tortoises in the desert or lakes  25 near Vail and they get their research trumped by the higher 

 96  1 political appointees within the agency. So since that seems  2 to happen within USGS and USWS, why wouldn't that happen at  3 the DOE and EPA?  4 Q. It goes with his question. And why wouldn't  5 you be concerned taking over such an endeavor?  6 MR. RUNDLE: That's really outside the scope  7 of our plan. There's nothing in our CCP about trusting  8 these agencies. I can say that in my experience working  9 four years at the Arsenal is that the State Health  10 Department is not a pawn of federal agencies when it comes  11 to enforcing cleanup. So I have a significant level of  12 trust in the regulatory agencies.  13 Q. I was wondering, once one of these  14 alternatives is decided on, what sort of sampling, if any,  15 would be taking place at the site and who would be in charge  16 of it or has that not been decided yet?  17 MR. RUNDLE: First of all, the final decision  18 may be none of the current alternatives, based on what we  19 hear from the public and during this process. In fact, I  20 would suppose that whichever is selected, there will be some  21 alterations or changes based on what we're hearing from you  22 tonight and at the other public meetings and any written  23 comments.  24 We will be directing our Level 3  25 pre-acquisition contaminant survey, surveys required after 
 97 

 1 that will be part of the long-term monitoring plan that you  2 should engage the Rocky Flats cleanup agreement parties  3 about. And thank you once again for coming this evening.  4 We appreciate it.  5 . . . WHEREUPON, the public hearing was  6 concluded at 9:00 p.m.  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25 

 98  1 CERTIFICATE OF DEPOSITION OFFICER  2 STATE OF COLORADO )  )  3 COUNTY OF DENVER )  4  5 I, SANDRA A. SMITH, Certified Shorthand Reporter  and Notary Public, State of Colorado, certify that said  6 public hearing was stenographically reported by me at the  time and place heretofore set forth, and was reduced to  7 typewritten form under my supervision as per the foregoing;  8 That the foregoing is a true and correct  transcript of my shorthand notes then and there taken;  9  That I am not a party to nor in any way connected  10 with any of the parties to said action nor otherwise  interested in the outcome of this action.  11  My commission expires May 23, 2005.  12 IN WITNESS WHEREOF, I have affixed my  signature and seal this 24th day of March, 2004.  13  14  15 ___________________________________  Sandra A. Smith  16 BOVERIE, JACKSON, BUSBY & LA FERA  1735 East 16th Avenue  17 Denver, Colorado 80218  303-329-8618  18  19  20  21  22  23  24  25 

 1 

 1 PUBLIC HEARING ON  2 THE DRAFT ENVIRONMENTAL IMPACT STATEMENT  3 AND COMPREHENSIVE CONSERVATION PLAN  4 FOR THE ROCKY FLATS NATIONAL WILDLIFE REFUGE  5  Wednesday, March 17, 2004  6 6:30 p.m.  7 at  The Arvada Center  8 6901 Wadsworth Boulevard  Arvada, Colorado  9  10  11 Panel Members: Richard Trenholme  Mike Hughes  12 Laurie Shannon  Dean Rundle  13 Jody Erikson  14  15  16  17  18  19  20  TAKEN BY: SANDRA A. SMITH, CSR  21  22  23  24  25 

 2  1 INDEX  2 INTRODUCTION BY MR. HUGHES.........................3  3 INTRODUCTION BY MS. SHANNON........................7  4 COMMENTS MADE BY THE PUBLIC.......................15  5 QUESTION AND ANSWER PERIOD........................46  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25 
 3 

 1 MR. HUGHES: We're going to begin. I  2 want to start by welcoming all of you here tonight. My name  3 is Mike Hughes, I'm with Resolve and I'm part of the  4 planning team. I want to say a couple of words about  5 tonight's agenda and the approach to tonight's meeting and  6 then I'll give the floor to Laurie Shannon who will talk  7 about the Environmental Impact Statement and the Draft  8 Comprehensive Conservation Plan for the Rocky Flats National  9 Wildlife Refuge and give you some information and then we'll  10 open up from there.  11 I hope that each of you brought an agenda and  12 so I'll say a few words about that. As you can see right at  13 the top of the agenda, tonight is a formal public hearing on  14 the Draft Environmental Impact Statement and Draft CCP.  15 We've been getting a lot of feedback from previous public  16 workshops and public engagement efforts that what we most  17 need to focus on is fairness, that is giving everyone the  18 same opportunity to speak.  19 So we will provide you with three minutes to  20 come to this microphone and speak about the Draft  21 Environmental Impact Statement and the Draft Plan, offer any  22 remarks that you have specific to information that you think  23 will alter some technical point in the Plan or in the  24 Environmental Impact Statement, specific comments about the  25 alternatives that we're evaluating, anything that's relevant 

 4  1 to the evaluation of its thoroughness, et cetera.  2 Once you've had that three minutes, and then  3 each person who wishes to have three minutes, will have that  4 opportunity to do that formal comment, then we'll turn to,  5 if there is time, questions, and I will give you the  6 opportunity to ask questions, get clarification. And in our  7 previous two meetings we have had that opportunity so we've  8 been able to move all the way through the speakers list and  9 provide question and answer.  10 Couple of ground rules right at the top for  11 the comment period and that feeds into the question and  12 answer period, we want everyone to have their full three  13 minutes. So even if you enthusiastically agree with what  14 they're saying, we want you not to interrupt what they're  15 saying so that they have the full benefit of their three  16 minutes. You might also hear things that you disagree with,  17 so we ask that you give the respect to the speaker and not  18 interrupt them in any way as they're giving their three  19 minutes.  20 Because we are providing this equal three  21 minutes, when we get to the question and answer period of  22 time, if there's time, we ask that you not get an extra  23 three minutes. So we will ask you to stop if what you do in  24 the question and answer period of time is make another  25 comment, offer some sort of preface to your question, we ask 
 5 

 1 simply that you ask the question and then we'll answer. So  2 you don't get an extra three minutes by jumping on the Q and  3 A.  4 I want to say a couple of things about where  5 we are in the process before I turn it over to Laurie, and  6 this is part of the public comment period and public comment  7 process on the Draft and that comment period is extended  8 through April 26th. So this isn't just that you have three  9 minutes and nothing else, you have opportunities to provide  10 written comments, you can go to the website, which is listed  11 here on the agenda, and provide comments.  12 MR. TRENHOLME: You might mention that it's  13 temporarily down.  14 MR. HUGHES: Temporarily you cannot do that.  15 The website is not available.  16 MS. ERIKSON: On those little green pieces  17 there's a fax number and a mailing address. If you didn't  18 get one of those you can get one on the way out.  19 MR. HUGHES: So fax, mailing address,  20 opportunities for you to provide those comments in other  21 ways other than having three minutes. So don't feel you  22 have to be limited in that manner.  23 A little bit about where we are in terms of  24 the process, and I'm going to refer to this information  25 behind me. These are the steps that are necessary in order 

 6  1 for there to be a National Wildlife Refuge at Rocky Flats.  2 First of all, the Service, that is the Fish & Wildlife  3 Service, would have to complete the work that you're part of  4 tonight, the Environmental Impact Statement and the  5 Comprehensive Conservation Plan, make those final and issue  6 a record of decision.  7 Then the Department of Energy is in the  8 process, as you all know, of completing its cleanup of the  9 Rocky Flats site. That cleanup will be concluded, except  10 for the ongoing operation and maintenance functions.  11 At that point, once they have deemed that  12 their work is complete, the Environment Protection Agency  13 and the Colorado Department of Public Health and Environment  14 would certify the completion of the cleanup.  15 At that point, DOE could transfer the land to  16 the Department of Interior, and then after that point, the  17 Department of Interior could establish the refuge and begin  18 its management. So we want to emphasize that EPA  19 certification is required before the site can become a  20 refuge.  21 And as you read the Draft, it's important to  22 know that both the Comprehensive Conservation Plan and the  23 Environmental Impact Statement are written in the context of  24 a certified site, the presumption that EPA certification is  25 complete, and obviously the refuge will not take effect 
 7 

 1 until that.  2 With that, I'm going to give the floor to  3 Laurie and then we'll turn to the three-minute comment  4 period. We don't have to let you guess how long three  5 minutes is, we'll help you with cards up here at two  6 minutes, one minute, and 30 seconds, and then remind you  7 that you need to give the microphone to the next speaker.  8 So we'll help you remember where the three minutes are.  9 With that, Laurie.  10 MS. SHANNON: Thank you. And good evening.  11 Can everyone hear me all right? I'm going to go from board  12 to board and it's hard to do with the microphone. The one  13 thing I want to say about our website, very quickly, is that  14 we do not know how long the web will be down. There has  15 been a court ordered check down of all the Department of  16 Interior Internet access right now and so it's not something  17 that we have done to our website so that you can't comment.  18 So we regret that that has happened, but we all managed to  19 do this before we had the Internet and you can fax or send  20 your comments in writing.  21 And also, if you need to have copies, again,  22 one of the advantages of having the Internet was people  23 could download the document off the Internet, and if you  24 need a hard copy, we either can offer you a CD tonight to  25 take home or if you sign up your name, I'll be glad to mail 

 8  1 you one and I'll mail them all out until they're gone. We  2 do have a limited number of hard copies. I don't want to  3 have them around after this, so if you need a copy, feel  4 free and I'll mail you one.  5 With that, I'm going to start and I'm going  6 to just briefly go through four alternatives so you all know  7 just basically what we're here to discuss this evening. And  8 I'm probably going to spend most of my time on Alternative  9 B, that is the proposed action that's before you.  10 All of the four alternatives have been  11 analyzed, that's what we're required to do under NEPA, the  12 National Environmental Policy Act, but NEPA also asks us to  13 come out with a proposed action and preferred alternative.  14 So Alternative B is our proposed action and this is -- this  15 alternative is what we call the wildlife habitat and public  16 use alternative. And what this does is that it has a strong  17 emphasis on wildlife conservation and habitat management,  18 while allowing for some moderate amounts of public use on  19 the site in the future.  20 And when we looked at deriving these  21 alternatives, we started to derive these alternatives late  22 in the fall of 2002 and what we took into place or what we  23 took into consideration before we came up with them was that  24 we looked at the Refuge Act and all the things that it said,  25 we looked at the mission of our own agency of the National 
 9 

 1 Wildlife Refuge system and we also looked at the comments  2 that we had received during a scoping period during the fall  3 of 2002. So those are the kinds of things that went into  4 these alternatives.  5 Alternative B, I really want to just  6 highlight the things that have changed since we first  7 presented these alternatives last May. And beginning with  8 the southern part of the site, we had a lot of comments from  9 the public that they would like to see some access for horse  10 users, not just pedestrians and bike users, but horses as  11 well. So on the southern part of the site we have made an  12 attempt to provide for some access down here.  13 The other thing that we tried to do was  14 improve the connectivity, the loop, the ability to do loops  15 and try to improve the connectivity a little bit. That was  16 something else that we had heard in May.  17 Going to the -- the other thing that we  18 changed a little bit is that we also heard from a lot of  19 people who wanted us to emphasize restoration of the site  20 first before we started getting into a lot of public use  21 programs. So what we would propose is that we would open a  22 trail down to the Lindsay Ranch as soon as we could after  23 the refuge was established and then we would wait for five  24 years while we picked up roads, picked up, you know, we  25 planted some seed and we got our budget and those kinds of 

 10  1 things going before we'd start full implementation of the  2 public use program. And that would go on through by year  3 15. We would implement all of it under any alternative.  4 Another change we made, a lot of the other  5 things that stayed the same were we continued to have  6 pedestrian only trails all the way up here in the north.  7 Some of them are seasonal, can only use them on a seasonal  8 basis. We continue -- this trail here continues to be a  9 multiple use trail for bikes and pedestrian access only.  10 Another thing that we didn't do is that we  11 had a lot of people who wanted us to make that connection  12 from north to south along Indiana and we -- our preference  13 is not to do that because we feel that if there is something  14 done with Indiana, with that road corridor, we would prefer  15 that that connection be made as part of that project or that  16 the communities would make it, because it's very hard to try  17 to get that road corridor and stay outside of the DOE lands  18 that the DOE will retain into the future.  19 Another minor change that we made dealt with  20 the proposed hunting program. And the proposed hunting  21 program is a limited program. It would be for very highly  22 managed, almost guided, it would be directed for youth and  23 disabled hunters. And that would be for the first two  24 years, and after two years we would look at whether we  25 needed to expand that program to include able-bodied 
 11 

 1 hunters. And the reason for that is so that we can better  2 meet our target population goals. If we're not meeting them  3 with the youth program and the disabled program, then we  4 would look to expand that a little bit. But it would always  5 be a very limited program. It would be based on target  6 populations.  7 Those are the basic things under this  8 alternative. We would only have a contact station  9 seasonally operated or weekends only, that kind of thing.  10 It varies from Alternative D, which is the other public use  11 alternative, in that Alternative D would have  12 a full-blown visitor center. All the other things pretty  13 much stayed the same in Alternative B as far as restoration  14 of the site.  15 Alternative A is our no action alternative,  16 and that really is looking at continuing management of the  17 site under how -- basically how the Department of Energy is  18 doing now with respect to managing their resources, and that  19 would be focussing mostly on the northern part of the site  20 in the Rock Creek area.  21 The one change that we made in Alternative A  22 was that we took out the option of putting up a chain-link  23 fence around the perimeter of the site. It is still  24 analyzed in the environmental consequences part of the EIS,  25 but is no longer part of any alternative. And the reason 

 12  1 for that is because the cost involved in doing that. Also,  2 we felt that it really doesn't meet our objectives in terms  3 of wildlife management. It precludes having wildlife  4 corridors and we didn't find a lot of support from the  5 community for having a chain-link fence around the site.  6 Alternative C is what we call the -- one  7 other thing I would mention in Alternative A, it's the one  8 that has the least amount of public use. It would be all  9 guided, just basically VIP-type tours, closed to public use  10 except for special visitors, and that would be the extent of  11 it.  12 Alternative C is what we call the ecological  13 restoration alternative in that this looks at the idea of  14 maximizing restoration, wildlife conservation and habitat  15 restoration on the site and minimizing public use. And  16 under this alternative, the only public use would be about a  17 3,000 -- a little over 3,000-foot trail that would go out to  18 an overlook and that would be guided. Again, it would be  19 special cases that we would take people out there.  20 Alternative C is the one alternative that we  21 looked at for getting rid of the Lindsay Ranch altogether  22 and preserving that with photos and recordation ways instead  23 of leaving it, because under this alternative we look at the  24 idea of restoring the site as much as we can back to  25 pre-settlement, really emphasizing restoration. 
 13 

 1 And then finally, Alternative D is what we  2 call the public use alternative. And this also looks at  3 having a focus on wildlife conservation and habitat  4 management, really on select plant communities, but trying  5 to maximize, to the extent that we can, as -- within our own  6 funding constraints, the amount of public use that we could  7 have on the site.  8 Now, we changed this alternative a little bit  9 based on the input that we received last May and again we  10 tried to improve some more connectivity, we tried to make  11 more loops. That's one thing a lot of people wanted to  12 have, more loops and that kind of thing. So we made a few  13 changes to that. And again, this is the one that would have  14 a full-blown visitor center that we analyze those kinds of  15 costs. So I think I covered it all. And we will answer any  16 questions that you may have later. Please feel free to ask  17 Dean, after we get through the testimony, and we'll answer  18 those questions. Thank you.  19 I forgot the no dog thing. Under none of the  20 alternatives we would avail to have a dog on the site,  21 leashed, unleashed or otherwise. Thank you.  22 MR. HUGHES: Great to see all the people who  23 are coming here. Each speaker will have the opportunity to  24 speak for three minutes. We ask that you give that speaker  25 the same respect that you would wish to have by not 

 14  1 interrupting, whether you agree or disagree with what  2 they're saying.  3 She's going to call out two names so that the  4 next speaker knows to perhaps come up here and be prepared  5 to step right up.  6 MS. ERIKSON: I'm going to have little cards  7 that tell you when you're at two minutes, one minute, 30  8 seconds and then a stop card. If you don't stop, I'm going  9 to stand up next to you and ask you to sit down.  10 Randy Olson and Amy Abbott.  11 BY MR. RANDY OLSON:  12 My name is Randy Olson. I'm here to  13 represent the Colorado Wheelin' Sportsmen and National Wild  14 Turkey Federation. I'm assistant state coordinator for the  15 Colorado Wheelin' Sportsmen. We are here in support of Plan  16 B. We think it's the best alternative for Rocky Flats in  17 the use of the conservation effort, and more so in allowing  18 the disabled and children or youth to get out and be in the  19 outdoors and experience the outdoor experience.  20 We have an organization here in Colorado  21 that's 300 members strong, Colorado Wheelin' Sportsmen.  22 There's also another organization called Outdoor Buddies  23 that we work with which is a very large organization.  24 The National Wild Turkey Federation in  25 Colorado is over 6,000 strong, the National Organization is 
 15 

 1 over half a million. We do partner with the U.S. Fish &  2 Wildlife Service, we do many activities with the disabled  3 and being in the outdoors, whether it's hunting, fishing,  4 wildlife watching, photography and that type of activity, is  5 a very, very important part to the disabled and to the youth  6 in this state.  7 We're very pro Plan B. We think that it's  8 the best alternative and we would like to see this plan  9 implemented. And you have the support of the Colorado  10 Wheelin' Sportsmen to help you do that in the conservation  11 effort and working with the children and the youth. And  12 also I'd like to see them open up more for youth activities  13 out on Rocky Flats. We do it already now with the Rocky  14 Mountain Arsenal, partners with bringing the handicapped  15 out, and even though it's once a year, it makes a very, very  16 important part of the disabled person or youth's life to get  17 out and experience the outdoors in any means. It's just so  18 important to have that opportunity and to make use of the  19 Rocky Flats and the area that's going to be utilized out  20 there.  21 MR. HUGHES: I failed to allow the two people  22 that are sitting next to Laurie to introduce themselves, so  23 let's do that.  24 MR. RUNDLE: My name is Dean Rundle. I'm the  25 refuge manager for the Rocky Flats project. 

 16  1 MR. TRENHOLME: I'm Richard Trenholme with  2 ERO Resources. I'm part of the planning team.  3 MS. ERIKSON: Bini Abbott and then Victor  4 Holm.  5 BY MS. BINI ABBOTT:  6 My name is Bini Abbott and I live on the West  7 Shore of Standley Lake. What I am not is an animal rights  8 person, I am not in a peace organization, I am not  9 anti-hunting, but what I am is opposed to recreational sport  10 hunting for four days out of the year of animals that are  11 protected 361 days out of the year and fairly used to humans  12 in order to have the good opportunities for photography and  13 wildlife observation.  14 The definition of a refuge is a place that's  15 safety, shelter, a safe retreat. This chart shows, down by  16 the U.S. Fish & Wildlife Service, yes, they can have  17 hunting, they can have fishing, but they also say that they  18 want these types of wildlife dependent projects to be  19 compatible, and I don't believe they are.  20 Under environmental interpretation, they have  21 under wildlife that the wildlife will take refuge at Rocky  22 Flats. And under wildlife and people, they have the  23 wildlife comes first. They intend to -- they think that  24 this case of hunting, they will allow ten youth on one  25 weekend and ten adults on another weekend to hunt. They 
 17 

 1 figure that will cost $5,000, that's $250 per person, and  2 nobody else would be allowed on the refuge at that time.  3 If there is a need to cull because of  4 population, too much population, then I think it should be  5 the sharpshooters from the Division of Wildlife, not people  6 out there trying.  7 I think you'll find the perception in this  8 case, perception of the U.S. Fish & Wildlife is more  9 important than actual reality and the perception is, what, a  10 refuge? And then you're going to shoot the animals that  11 become fairly used to humans.  12 Also, I'm hoping that in the future that we  13 will watch the wildlife through binoculars, through a camera  14 and not through the sites of a gun. Thank you.  15 MS. ERIKSON: Victor Holm, Clark Johnson.  16 There is a sign-up sheet outside so if you get the urge to  17 speak, you can sign up out back.  18 BY MR. VICTOR HOLM:  19 My name is Victor Holm and I'm a citizen of  20 Lakewood. I strongly support Alternative B. I think it's  21 the right combination of public access and ecological  22 restoration.  23 There are several suggestions that I would  24 like to make on it. One is, I think the visitor center and  25 a combination visitor center, museum, would be a real 

 18  1 improvement to Alternative B. And perhaps this visitor  2 center could be staffed primarily by volunteers, so it  3 wouldn't necessarily increase the cost. The building  4 already exists there and I think it would be a great  5 opportunity for getting the history and interpretation of  6 the environment at the same time.  7 The other thing that I would very much  8 encourage is, while the public access should be limited to  9 the refuge and not the DOE part, I would hope that the  10 Wildlife Service would spend part of their effort in  11 restoration and management of the entire 6,000 acres instead  12 of just the refuge. Thank you very much.  13 MS. ERIKSON: Clark Johnson, Anne Fenerty.  14 BY MR. CLARK JOHNSON:  15 Thank you. My name is Clark Johnson and I'm  16 from the City Manager's Office here in Arvada and I'm here  17 representing the City of Arvada.  18 First I'd like to thank the Fish & Wildlife  19 Service for all the work you've put in over the last year  20 with both the public meetings and working with the Rocky  21 Flats Coalition of Local Governments and staff members and  22 citizens throughout Arvada. We think what you've come up  23 with is a good product. And the main point I wanted to get  24 to tonight is that we support the proposed Alternative B,  25 with some minor modifications that you'll receive from us in 
 19 

 1 our written comments that will be forthcoming before the  2 deadline.  3 Another thing that I want to make sure gets  4 on the record, we really appreciate the work you've done  5 over the past several months with the open space and park  6 staffs for all of the surrounding communities, trail  7 connectivity, something that's been very important to us,  8 and create a system that both enhances our own existing open  9 spaces as well as the refuge. And I think that you've done  10 that with your Alternative B.  11 With regard to environmental concerns and  12 issues on the site, the City of Arvada does have  13 environmental issues and concerns about the site and we  14 always will; however, the public uses that are proposed, we  15 feel, are appropriate and safe for the human activity that's  16 planned. And I want to make sure that it's noted that we  17 are not aware of any credible data that would not support  18 the uses that you are proposing within the site.  19 That being said, we need you, and as a  20 community, we need to maintain vigilance over the industrial  21 area, make sure that the monitoring of the wells and the  22 groundwater systems are maintained through stewardship with  23 the Department of Energy and the Fish & Wildlife Service.  24 And as long as that is done, we feel that the uses that  25 you're proposing are both very suitable and will be an 

 20  1 amenity to the entire region.  2 Finally, just want to say that we're very  3 fortunate to have an existing working relationship with you,  4 albeit small, but important to us, wildlife refuge at Two  5 Ponds and we hope that the working relationship that we've  6 had with you at Two Ponds, especially recently, and our  7 vision of connecting our nature center to Two Ponds will  8 continue to grow and eventually we'd like to see the Two  9 Ponds National Wildlife Refuge connected to our trail system  10 to the Rocky Flats National Wildlife Refuge and we hope we  11 can partner with you to get that done. Thanks.  12 MS. ERIKSON: Anne Fenerty and Hildegard Hix.  13 BY MS. ANNE FENERTY:  14 I'm Anne Fenerty. My point is that the CCP  15 and the EIS needs to be two separate documents. The present  16 document puts the cart before the horse. The public was  17 asked to make a choice of what kind of recreation they want  18 at Rocky Flats, the alternatives, before they are given  19 sufficient information about the condition of the site.  20 The CCP needs to be -- needs to follow the  21 EIS. This is the NEPA process. The intent of NEPA, the  22 National Environmental Policy Act, process is to make the  23 EIS the most inclusive public disclosure document about this  24 proposed federal action.  25 The EIS has to evaluate the effects of this 
 21 

 1 action on the human environment. The EIS has to evaluate  2 the effects of this particular action on the human  3 environment. This Draft EIS fails to do that.  4 It also requires the memorandum of  5 understanding between DOE and the Fish & Wildlife Service.  6 The community does not even know the extent of contamination  7 in the area which will remain under DOE control or what kind  8 of monitoring or public protection, if any, will exist.  9 The EIS fails to disclose the fact that it is  10 dealing with an extremely contaminated Superfund site, a  11 previous nuclear weapons plant which was closed down by the  12 FBI for environmental crimes.  13 Looking at the EIS and EISs for similar  14 sites, such as Hanford, shows a total inaccuracy of this  15 document. I have now spoken with three environmental  16 lawyers who agree with this assessment. Thank you.  17 MS. ERIKSON: Hildegard Hix and Gary Ball.  18 BY MS. HILDEGARD HIX:  19 I'm going to have to read fast, so you need  20 to use your fast ears. When reading the CCP, EIS document,  21 it was hard to remember that we are not speaking about a  22 pristine piece of land. There was -- where was the  23 industrial history? Where was it mentioned that this highly  24 contaminated site may hold unseen and yet unfound hazards.  25 At the last two meetings we were told by Fish 

 22  1 & Wildlife that we could not discuss possible hazards as  2 cleanup levels were set by others and that they, Fish &  3 Wildlife, could only discuss their mission. When you are  4 dealing with a former nuclear weapons manufacturing  5 facility, that is not acceptable. People are being asked to  6 make decisions without all of the information.  7 Actually having done some research, I find  8 that this entire process should have been following the NEPA  9 regulations, in which case the open discussion would have  10 occurred and the public comments would have been published  11 in the EIS. To me it is obvious that the problems come not  12 from Fish & Wildlife here, not the people who did this good  13 job, it comes from the rule making in Washington D.C.  14 When a National Wildlife Refuge is to be  15 developed on a former nuclear site, or any Superfund site,  16 we need to have a different set of rules. To have  17 recreation a priority on the Superfund sites without first  18 having full and open public discussion is absurd. This does  19 not mean that the Superfund site should never be a refuge,  20 the refuge work in the area of restoration is invaluable.  21 The species list in the appendix of the CCP  22 is very important and it was very well done. I suggest we  23 have a number of public hearings, talk about them ourselves,  24 how they were established and what they mean. Then I would  25 like to see the site restored, the wildlife managed, 
 23 

 1 scientists on site and the public kept out for about 20 or  2 30 years until such time as we can evaluate what has  3 happened, how the weather affects the soil and the manmade  4 structures. And thank you very much.  5 MS. ERIKSON: Gary Ball and then Betty Ball.  6 BY MR. GARY BALL:  7 I'm not very good with science stuff, I'm  8 good with art stuff, so I think the main thing I have to say  9 is, I think that you're going by the amount of radiation  10 that you think is out there, 5 picocuries per gram, or  11 whatever it is, and you're not paying attention to the  12 nature of the radiation itself, whether it's plutonium where  13 one particle inhaled or ingested could possibly be lethal.  14 And I'm thinking about you all being out there every day and  15 what could be out there, I just had to write a little song  16 about it. I don't have time to sing the whole thing, but I  17 thought maybe I could get in a little bit of it and then  18 I'll give you copies and you can make copies for yourselves  19 and then you can sing it yourselves.  20 It sounds like this: I'm a Rocky Flats  21 ranger, pleased as I can be, and I'm glad to range you, in  22 my SUV. Roll the windows down, take a breath of air, 'palm  23 plants, God, I don't have a care, so it's just forget the  24 dam thing was there, yippy, i-o, ky-yay.  25 I'm a Rocky Flats ranger, and I'm telling 

 24  1 you, that there ain't no danger, in the job I do. Some say  2 that I'm exposed to plutonium, but the people who say it are  3 really dumb, because the DOE told me that the cleanup's  4 done, yippy, i-o, ky-yay.  5 I'm a Rocky Flats ranger, happy as a clam,  6 and there ain't no danger, working where I am. There's  7 plutonium dust as far as I can see, but I ain't going to let  8 that stuff bother me, besides it's way outside the scope of  9 my CCP, yippy, i-o, ky-yay.  10 MS. ERIKSON: Betty Ball and Ken Seaman.  11 BY MS. BETTY BALL:  12 Good evening, I'm Betty Ball. Thank you very  13 much for this opportunity to provide comments. I've lived  14 in unincorporated Boulder County for most of the time that  15 Rocky Flats has been here. I'm all too painfully aware of  16 many of the things that have occurred out at Rocky Flats,  17 more aware than I'd like to be. Actually, I wish everybody  18 in this room and everybody who is involved in this process  19 was as aware as I am of the things that occurred there, the  20 cover-ups that have happened, the lies that have been told,  21 the deceit that's happened, and maybe we'd be in a different  22 position today.  23 I wish it weren't true that this site is  24 contaminated. I wish it weren't true that they're not going  25 below -- three feet below ground level, surface level. I 
 25 

 1 wish it weren't true that contamination migrates through the  2 soil and the groundwater. But all those things are true.  3 And I am fearful if we go ahead with this proposal, with any  4 of these alternatives, before we get a much better cleanup  5 happening out there than we have now.  6 I am very fearful of what could result.  7 Actually, I hope that you don't get past number 3 on this  8 chart here. I hope that somehow, with our best efforts, we  9 can convince the Federal Government, the DOE to reassess  10 their thinking and to reassess this cleanup plan before it  11 ever gets to your hands and then you're responsible. So  12 thank you very much for this opportunity.  13 MS. ERIKSON: Ken Seaman and Dan Shier.  14 MR. HUGHES: If the remaining speakers would  15 do as they do and say your name, that would help us. Thank  16 you.  17 BY MR. KEN SEAMAN:  18 My name is Ken Seaman and I'm representing  19 myself and the Colorado Coalition for the Prevention of  20 Nuclear War and I'm not here to support Plan A or Plan B or  21 Plan C or Plan D. I'm here to oppose them all.  22 In 1983 I viewed a motion picture entitled  23 Dark Circle. The film described and depicted conditions at  24 and around the Rocky Flats nuclear weapons plant. And among  25 other horrors, the film showed farm and domestic animals 

 26  1 with various birth defects, animals born on properties close  2 to this nuclear facility. It was a most disturbing film, a  3 film that deserved wider circulation than it received.  4 Perhaps it should be revised -- or revived in light of the  5 current controversy of using Rocky Flats as a human and  6 animal playground.  7 Clearly there are facts and opinions on both  8 sides of this issue of whether or not Rocky Flats can be  9 sanitized to a level for human and animal creatures to  10 frolic and to enjoy, but that is the great unknown in this  11 life and death equation.  12 Experts on both sides press their claims and  13 have made -- but none seem to have the whole truth. So as  14 long as one seemingly insignificant shred of evidence  15 exists, evidence that living creatures might, and I repeat,  16 might be endangered by treading on this questionable land,  17 let us act on the side of caution. Let us not risk the  18 consequences of being wrong. Let us keep the injured place  19 closed forever. Thank you.  20 MS. ERIKSON: Dan Shier and Mag Seaman.  21 BY MR. DAN SHIER:  22 My name is Dan Shier. I live about 15 miles  23 south of Rocky Flats. And I have been a patrol, a volunteer  24 patrol for Jefferson County open space for the last two  25 years. I've done 300 hours on trails and I could say these 
 27 

 1 trails are getting used more each year. We need more  2 trails.  3 To make that comment, I generally support  4 Plan B. I think that the whole business of who is on the  5 trails, I think I can speak to that because as part of my  6 volunteer duties, I talk to people about the trails and how  7 they use them. And the fact is, the bicycle riders are the  8 people that intimidate. If you say, well, we're going to  9 have a trail up here, we're going to close it to horses, but  10 we're going to open to the bikes, I think you'll find the  11 average trail user thinks that isn't a very great idea.  12 A lot of trail users really do like the idea  13 of having some trails that are pedestrian only, and I think  14 that's the plan, that's a good idea, but I can't understand  15 why a trail would be open to a bike and not horses.  16 I would -- I haven't done any of the  17 economics, but I know that if you have that much trail, it  18 takes quite a bit of money to maintain it properly. And  19 maybe that's a trade-off with the visitor center, I don't  20 know. I don't know how many people would use the visitor  21 center.  22 The last point I would make is that I think  23 that the plan you've come up with with regard to the hunting  24 is an excellent one and I would certainly support that.  25 That is all I have to say. 

 28  1 MS. ERIKSON: Mag Seaman and Charlie McKay.  2 BY MS. MAG SEAMAN:  3 Good evening. My name is Mag Seaman and I'm  4 a concerned citizen who lives in Denver, Colorado. I am  5 opposed to the Rocky Flats so-called Wildlife Refuge. I  6 have been opposed to Rocky Flats since the '70s. It was  7 toxic then and it is worse now. It is not a person-friendly  8 place. It's the work of people who care not about  9 generations to come.  10 Those who are acquainted to Rocky Flats  11 workers know the dangers of the land. Many have suffered  12 from a variety of cancers. The land, the water, even the  13 air have been and are still polluted, polluted beyond the  14 level that any animal or human can sustain. We know some of  15 the studies that have been done here, this is not a place  16 for a wildlife refuge.  17 My appeal, then, is to close the area to  18 animals and to humans, especially to children. I know very  19 many wonderful innocent deer and uninformed people who will  20 surely be harmed by this lethal land. Thank you.  21 MS. ERIKSON: Charlie McKay and Andrew Ross.  22 BY MR. CHARLIE MCKAY:  23 My name is Charlie McKay with Church Ranch.  24 We all -- most or at least the total southern half of the  25 Rocky Flats plant back in the '50s was taken from us under 
 29 

 1 threat of condemnation, and I think one thing that we missed  2 tonight here is that a lot of this land was expanded in the  3 mid-'70s. Prior to the mid-'70s, it was in private  4 ownership. And I jokingly say, tongue in cheek, to the  5 Rocky Flats people, that the stuff on the southern end which  6 butts up against our present ownership, you guys haven't  7 owned it long enough to screw it up.  8 The core area, I mean, they've done a great  9 job by taking the big green area, the core area, and  10 treating that a lot differently, so that may address some of  11 the questions and points that were raised tonight.  12 One small point is on mining. That mining  13 definition that you have there is slightly incorrect and I  14 think I've sent you a memo on that. I'd also like to say  15 that I've worked with this department and they've been very  16 outreaching and very open and very willing to listen to my  17 concerns and they've also been good about not giving in on  18 everything but just listening and saying, okay, we'll take  19 that into consideration, and I appreciate that.  20 I would like to see the water rights through  21 the plant, not only private water rights, but City of  22 Westminster water rights, protected. We've talked about  23 noxious weeds and all the stewardship things and farmers and  24 ranchers, and we are still farmers and ranchers and we ranch  25 right next to the plant. We'd like to see you have the same 

 30  1 responsibilities we do to take care of noxious weeds, and  2 the prairie dogs. And presently we have the coyotes that  3 live on Rocky Flats that think that our cattle herd's calfer  4 is their restaurant, and hopefully somehow or another we can  5 address that instead of continuing to let it flourish.  6 Plan B I think is pretty good. It's a nice  7 compromise that allows people to use it and it addresses a  8 lot of the things that were talked about. No plan can be  9 perfect, but that's a pretty good one. Thanks for letting  10 me speak.  11 MS. ERIKSON: Andrew Ross and Judith Mohling.  12 BY MR. ANDREW ROSS:  13 My name is Andrew Ross, I'm a citizen of  14 Arvada. And firstly I'd just like to say, I think that the  15 fate of the A and B series ponds should have been considered  16 within the scope of the EIS, because whether or not the  17 ponds are left in place or taken out, it will have an  18 environmental impact upon the refuge. And I understand why  19 it was left out of the scope of the EIS, but I'd like you to  20 take into consideration putting that in the final Draft.  21 With that said, I'd just like to say, I'm  22 supporting Alternative B. I think it's a very good  23 alternative. I support the adding of equestrian uses, it's  24 compatible with the surrounding uses, especially the south  25 portion where there are a lot of horse properties; however, 
 31 

 1 as it was mentioned earlier, my own personal experiences in  2 the area, hikers, bikers and horses don't always mix very  3 well and maybe there can be some way that you could limit  4 that interaction, because sometimes it can be very emotional  5 interaction between horses and bikers and hikers.  6 Lastly, I'd just like to agree with Victor  7 Holm, Plan B could be enhanced by adding a visitor center at  8 the building at the West Gate. Thank you.  9 MS. ERIKSON: Judith Mohling and Doug Magee.  10 BY MS. JUDITH MOHLING:  11 Happy St. Patrick's Day. I'm Judith Mohling  12 and I'm grateful to speak a second time. In the whole  13 scheme of science, politics, Fish & Wildlife Service,  14 Environmental Protection Agency, the Colorado Department of  15 Public Health and the Environment, Department of Energy,  16 general public, and Rocky Flats, these hearings are a little  17 window of truth, I feel.  18 It may be that the people speaking who are  19 opposed to allowing public access onto that lovely but  20 eternally contaminated land, actually have a less bias, less  21 political view of Rocky Flats than those who have informed  22 decisions all along. And we who are opposed may have  23 knowledge about the contamination of Rocky Flats and the  24 dangers that will lurk there forever that you actually don't  25 know. 

 32  1 The little windows of the hearings is the way  2 our government lets us at least pretend that the decisions  3 are truly made democratically. I feel that the compelling  4 fantasy that the Fish & Wildlife seems to be living in, as  5 exemplified by the gorgeous and thoughtful Draft document,  6 has to pause for these hearings and the collective remarks  7 that come to you in our allotted time and everything that's  8 said at the hearings, you have to pause and really, really  9 listen.  10 And I heard, Mr. Rundle, that you said at the  11 second hearing last week that, quote, as of now the decision  12 has been made to go with Alternative B. And I hope that all  13 that means is that you had to have something in the  14 beginning and then you would listen to all of these remarks  15 and give it your sincere attention without having a closed  16 mind.  17 What are your intentions considering the  18 outpouring of statements that are opposed to public access  19 at Rocky Flats? There's no reason -- there's no reason or  20 necessity that the public ever has to be allowed onto Rocky  21 Flats. It lies within the mission of the Fish & Wildlife  22 Service to manage the land carefully and close it to the  23 public. Since there's so much controversy about it, why  24 don't we just keep it closed.  25 Plan C comes closest to what I'm talking 
 33 

 1 about, and I wish that you would work as hard as you can for  2 dedicated funds for long-term stewardship, and I wish that  3 you would manage and restore it without people as  4 thoughtfully as you produced this wonderful plan. Thank  5 you.  6 MS. ERIKSON: Doug Magee, Thomas Rauch.  7 BY MR. DOUG MAGEE:  8 My name is Doug Magee, I'm a resident of  9 Arvada and I'm also the coach here of the Arvada Park  10 Advisory Committee, but my comments tonight are my own and  11 not of the committee. Thank you for the opportunity to make  12 my comments.  13 I think the document was very well done, easy  14 to read. I support Alternative B. I think it's the best  15 balance between restoration, public use and also  16 environmental education and outreach. I do like the fact  17 that you're using mostly existing roads and not creating new  18 trails throughout the site. I'm encouraged by the proposed  19 trail connectivity between the proposed refuge and the  20 various municipalities that surround Rocky Flats. Arvada  21 trails would connect into it Westminster, Boulder as well.  22 The hunting program, there's been a number of  23 comments, and I have to disagree with Bini, I do believe  24 that the hunting program would work, but I really do oppose  25 it going to able-bodied individuals. I would really 

 34  1 encourage that it stay with youth and dis -- people with  2 disabilities. And if you have to add another weekend to do  3 that, I would encourage that and not go to able-bodied  4 hunters.  5 I do propose or suggest that you eliminate  6 the off-trail usage that would be permitted seasonally on  7 the south end. I think you're going to get that anyway, but  8 I wouldn't encourage that. I would propose you keep it all  9 on the trails.  10 And my final comment is about limiting your  11 prescribed burns. I would hope that you could find other  12 weed management, weed control methods that you would use  13 first before you used prescribed burns. Thank you.  14 MS. ERIKSON: Thomas Rauch and Jim Morris.  15 BY MR. TOM RAUCH:  16 Good evening, I'm Thomas Rauch, I've lived in  17 Denver since 1966. As a long time peace activist and  18 opponent of the production, possession and use of nuclear  19 weapons, I celebrated when Rocky Flats' mission as producers  20 of nuclear weapons components officially ended in 1992. I'm  21 grateful to all the men and women who have done and continue  22 to do the dangerous and demanding work of cleaning up the  23 radioactive and other hazardous materials in the  24 contaminated buildings and land at Rocky Flats since 1992.  25 I look forward to celebrating the completion 
 35 

 1 of the current cleanup work in 2006. Even some of its  2 citizens have pressed for a more complete cleanup.  3 What do I want for the future of the Rocky  4 Flats property, first I want no public access to the  5 property because of the remaining contamination of the site  6 with radioactive and other hazardous and toxic materials.  7 The Department of Energy admits that such  8 materials will remain in the soil and water even when the  9 current cleanup work is completed, and no one knows the full  10 extent of this contamination because it has not been  11 thoroughly studied.  12 Second, I want the U.S. Government to provide  13 resources for continuing to identify and remove the  14 remaining contaminants from the property. Third, I want the  15 property to be preserved as a wildlife refuge for the  16 present with ongoing research on the effects of the  17 contamination on the wildlife to determine if the Rocky  18 Flats site can be a safe wildlife refuge for the long term.  19 I know the question always comes up, well,  20 your ideas may sound great, but where do we get the money  21 for it given the budget situation and the looming deficits.  22 The answer lies precisely in the political and military  23 arena that created Rocky Flats in the early years of the  24 Cold War. The U.S. was turned away from its policy of world  25 military and economic domination, including the domination 

 36  1 of outer space.  2 The U.S. must take the leadership in  3 assuring that all the nations, including our own, destroy  4 the weapons of mass destruction and assuring that no more  5 weapons are produced. This can be accomplished by a truly  6 international and verifiable process, a process that will  7 require extensive and intrusive international inspections of  8 all nations, including our own, possessing or seeking to  9 possess weapons of mass destruction. If we did this, we  10 could cut our military budget at least 75 percent and  11 perhaps more.  12 Visionary, idealistic, of course it is, but  13 that's what most so-called reasonable people said when other  14 human beings began urging the ambush of slavery or when a  15 small band of women demanded the same rights as men in this  16 country, rights guaranteed to all by the Constitution, but  17 never afforded to women after that time.  18 If human beings have the ability to create  19 weapons of mass destruction, and we do, surely we have the  20 ability to get rid of them, if we ever will. Thank you.  21 MS. ERIKSON: Jim Morris and David Maxwell.  22 BY MR. JIM MORRIS:  23 I'm Jim Morris and I'm worried about the  24 cleanup. I don't trust DOE's promise to clean it up when  25 they gave it to you. And my experience over the years has 
 37 

 1 led me to doubt whether DOE is trust -- worth trusting.  2 Some of the recent articles have talked about  3 the chairperson of the grand jury, two of the workers at the  4 plant, and the FBI agent that led the raid all claiming that  5 the DOE lied and said there was no midnight burning, they  6 lied when they said they were not polluting the water  7 supplies by dumping stuff that was radioactive substances  8 and solvents into the water supplies.  9 My own history of watching the plant and  10 going to hearings has been, sometimes it seems as people  11 were speaking to me also. I'd be told there was monitoring  12 and that the samples were always being analyzed and then a  13 month or two later I was told there was no money to analyze  14 the samples, the deer samples weren't being monitored.  15 I had friends who told me rumors that  16 plutonium is moving into the groundwater toward Marshall  17 Landfill. Iggy Litaor, the Israeli scientist that said  18 plutonium was moving in the soil, they fired him right after  19 he found it moving. They kept giving him grants and then  20 there was a huge rainfall one summer and it moved a lot,  21 they fired him.  22 So I just have this theory that DOE doesn't  23 speak truthfully or doesn't know what it's saying when it  24 speaks. So I don't think you can rely on the plant to be  25 clean. So I really want the plant cleaned below three feet. 

 38  1 I think it should be surveyed so you can find what's there  2 and we should have -- maybe you can think of something, a  3 bond or something to try to guarantee that DOE is going to  4 pay for the cleanup.  5 Like if it's 10 years from now or 30 years  6 from now, nobody is analyzing either in the known dump sites  7 or the other places maybe appearing as streams moving or we  8 have heavy rainfall or lots of prairie dogs dig down,  9 whatever it is that's occurring. Where is the money going  10 to come from? Is it going to come -- I'd like the money --  11 I'd rather have the money go to you than DOE. I'm sorry,  12 I'm not saying this right. I don't want your budget, the  13 general budget of Fish & Wildlife to be cut. And maybe  14 because something has to be cleaned up here because DOE  15 dumped it on you.  16 So people here have fought successfully to  17 stop the highway being built through the contaminated area,  18 fought to have better cleanup levels, and I hope that you'll  19 join us and I hope that all of us will speak up to try to  20 get a better cleanup.  21 MS. ERIKSON: David Maxwell.  22 BY MR. DAVID MAXWELL:  23 Good evening. I'm David Maxwell, I am a  24 resident of Arvada for 20 years. My background is air  25 quality meteorology. And in the '80s my neighbors used to 
 39 

 1 ask me, what's going on at Rocky Flats, thinking that I know  2 all the answers, even though I wasn't employed by them, and  3 I said, I don't know. I really don't know what's going on.  4 There's a lot of secretive stuff going on. And then after  5 the FBI raid in 1989 and the removal of the contractor at  6 the time, I ended up being hired by EG&G in 1990 to help  7 with the cleanup of Rocky Flats in the air quality field,  8 make air quality assessments of what was going on inside the  9 facility, inside the ductwork and hazardous and contaminated  10 buildings with plutonium, americium and uranium as well as  11 the monitoring networks outside, the facility on the plant  12 boundary and the ring around the industrial areas as well as  13 in the communities.  14 And after six and a half years at Rocky  15 Flats, I was pleasantly surprised that at least the air  16 quality inside the buildings was maintained there. There  17 was nothing or very little going outside of the buildings or  18 the stacks pertaining to hazardous chemicals or radioactive  19 materials. The reclamation going on at the facility and our  20 air monitoring showed that there was well below any serious  21 levels, that doesn't mean there aren't any problems.  22 In short, I would support Alternative B to  23 make it a wildlife habitat and public use. There's nine  24 square miles in the buffer zone and I think there's a lot of  25 good activity. I support the monitoring that will continue 

 40  1 and adequate funding to make sure that some of the points  2 other people have brought up about contamination outside  3 Rocky Flats downstream, places like where I live and others,  4 are at least we had the opportunity to see data and examine  5 results and had periodic hearings to see how things are  6 going.  7 So anyway, I do offer some expertise and I am  8 satisfied at least that the cleanup is going properly. And  9 my time there in the early and to the mid-'90s, it was a  10 good time and I felt very good about the air quality at the  11 site. That's what I can address, the air quality, both on  12 the site and in the communities, was at a safe level. Thank  13 you for letting me speak my mind here.  14 MS. ERIKSON: The last two are Shaun McGrath  15 and Lisa Morzel.  16 BY MR. SHAUN MCGRATH:  17 My name is Shaun McGrath. I'm a Boulder City  18 Council member and the City of Boulder's representative on  19 the RFCLOG. I want to make some initial comments on the  20 Draft Comprehensive Conservation Plan, but I want to first  21 emphasize that these comments are not intended to serve as  22 the complete and final position of the City, rather I'm  23 going to highlight some areas of critical importance to the  24 City in any refuge plan. The City intends to provide formal  25 written comment prior to the April deadline. 
 41 

 1 First, a general policy, the City has long  2 advocated for closure and cleanup of the weapons production  3 facility at Rocky Flats. We continue to work with the other  4 local governments in that area through the RFCLOG to argue  5 for federal funding and attention to these issues. Proper  6 cleanup of the site remains our first priority.  7 Beyond the cleanup and closure, the City  8 supported the Udall-Allard legislation in 2001 which  9 resulted in having the site designated a wildlife refuge.  10 This was important to the City of Boulder not only to  11 protect the site from future development, but also preserve  12 federal ownership of the site. Protection from development  13 was an important part of our vision for the landscape given  14 the efforts made by Boulder and Boulder County in setting  15 aside open space adjacent to the site. Federal ownership is  16 critical in our view to address the uncertainty of the  17 public health issues and so that if any problems are  18 detected 20 years from now, the liability will be with the  19 federal government, not local communities, to address those  20 problems.  21 Second, to the specific refuge proposals, as  22 previously stated by the City we support the wildlife vision  23 as desirable and compatible with our community goals. As a  24 neighboring landowner, the City supports the Draft goals  25 conserving and enhancing native ecosystems, plant 

 42  1 communities and wildlife species. The proximity of the  2 refuge lands to other open space lands provides an  3 extraordinary conservation opportunity. The refuge lands  4 will make important contributions and regional efforts to  5 protect the values of native grasslands, shrublands and  6 foothill riparian areas.  7 The City maintains that the focus of  8 management planning should be, one, the unique conservation  9 opportunity of preserving a large and rare habitat unmatched  10 anywhere along the Front Range of Colorado, and two, the  11 preservation and restoration of native plant and animal  12 communities.  13 Management actions, therefore, should focus  14 on the following: Plan conservation areas and visitor  15 facilities, work to restore lands that have been degraded,  16 conduct management in the context of elevated soil  17 contamination levels, and keep any further fragmentation of  18 the landscape to a minimum.  19 The City supports Alternative C, which we  20 believe strikes the best balance for a refuge setting. This  21 alternative calls for limited public use and minimal  22 facility development focussing instead on restoration and  23 management activities to try to replicate pre-settlement  24 conditions.  25 Jumping ahead, other comments, we would like 
 43 

 1 to know the status of the DOE, Fish & Wildlife Service --  2 actually, I'm at stop so I will provide you with my comments  3 as a part of the record, if I may. Thank you.  4 MS. ERIKSON: Lisa Morzel.  5 BY MS. LISA MORZEL:  6 I'm Lisa Morzel and I'm a resident of the  7 City of Boulder. For the past seven years I've been an  8 elected representative of Boulder and been a founding member  9 of the Rocky Flats Coalition of Local Governments. Tonight  10 my comments are my personal comments and don't reflect the  11 City of Boulder or the Coalition.  12 I've always supported having Rocky Flats  13 cleaned up properly to the highest standards reasonable in  14 establishing Rocky Flats as a wildlife refuge. Knowing the  15 complexities of this site and its past use, a wildlife  16 refuge maintained under federal control is the best future  17 use for this former nuclear weapons site.  18 In considering any scenario or alternative,  19 it is important to proceed slowly and with caution. One of  20 the objectives of any plan must include ecological  21 restoration of the site to open the site to the public  22 without first -- this first being accomplished would be  23 short-sighted and would not serve the broad, long-term  24 community interest. It's very important for the public to  25 fully appreciate that the open space that will be left on 

 44  1 Rocky Flats is not just any open space, but one that  2 developed nuclear weapons for close to 50 years and there is  3 a legacy left from that.  4 In the end state agreement signed by five  5 members of the seven-member Coalition, the decision was made  6 to focus the cleanup more on surface remediation than on the  7 subsurface. Specific areas in the subsurface of the DOE  8 retained lands are contaminated and will be left as such.  9 Caps and other monitoring systems will be put in place.  10 Prior to allowing access to the site, DOE and Fish &  11 Wildlife must clearly state how access to the DOE retained  12 lands will be restricted. The purpose is to ensure that no  13 one plays in the pond, walks on the caps, damages the  14 groundwater and surface water monitoring stations.  15 These important controls will be retained by  16 DOE and we want to ensure that visitors to the refuge stay  17 clear of these systems. It is important to proceed with  18 caution and to have ample time to ensure these caps and  19 other monitors are working as envisioned. It is also  20 critical that time be given to ensure that the assumptions  21 made by the regulators of the site are proven correct.  22 I urge citizens living near Rocky Flats to  23 support this former nuclear weapons plant to be converted  24 into a wildlife refuge. I personally support Alternatives A  25 and C, but more important than any specific alternative is 
 45 

 1 that we proceed slowly and with caution on opening the site  2 to the public, that the site be ecologically restored and  3 that time be given on the order of 15 years to ensure caps  4 and other monitors for contamination are working. No reason  5 exists to rush this. It took 50 years to contaminate this  6 site, it will take at least 15 from now to ensure public  7 exposure on this site will be safe. Thank you.  8 MR. HUGHES: Anyone else want that  9 three-minute opportunity? If not, then we'll turn to  10 questions. I'll ask Dean to come to the microphone and if  11 there are factual questions, pieces of information that you  12 have in the Draft Environmental Impact Statement, we can  13 take those questions now.  14  15  16  17  18  19  20  21  22  23  24  25 

 46  1 Q. My question relates to all the alternatives  2 and that it is not answered in any of these documents,  3 physically what is going to isolate the industrial area from  4 the rest of the facility? Are you going to put up a fence?  5 Are you going to put up a wall? Are you going to put up a  6 sign? Physically what's going to be out there so if you  7 adopt Alternative B, how do people know they're not supposed  8 to go into the industrial area?  9 MR. RUNDLE: That's a real good question.  10 Before I field that question, I do want to make a general  11 statement. I know that many members of the public have  12 indicated a frustration about the scope of this plan, that  13 it does not answer questions about the cleanup. And there  14 is very good reason for that. And the reason for that is  15 that U.S. Fish & Wildlife Service is not a decision maker  16 when it comes to some of the issues.  17 Among those issues are the ones that you just  18 raised about how the exact delineation of the retained lands  19 will be. I think that's something you should be happy  20 about, in that cleanup of nuclear weapons former production  21 facilities, is not the core business of the U.S. Fish &  22 Wildlife Service, that is the responsibility of the  23 Department of Energy with oversight from the other parties  24 to the Rocky Flats cleanup agreement which are the State of  25 Colorado, Department of Public Health and Environment and 
 47 

 1 the U.S. Environmental Protection Agency. And those  2 agencies have a great deal more expertise than we have in  3 terms of cleanup.  4 We are not disinterested in the cleanup, and  5 let me emphasize that. We are going to be working out  6 there, we want to have a safe landscape for our workers and  7 any visitors that are invited out there. At this time,  8 although there are -- have been several statements about  9 widespread and dangerous residual contamination throughout  10 the entire site, boundary to boundary, we do not know of any  11 credible scientific evidence that there are dangerous levels  12 of plutonium or the types of contamination in the vast  13 majority of the buffer zone. Indeed at this point the  14 regulatory health agencies are not even requiring lands  15 proposed to be transferred to the refuge to need remediation  16 to make them safe for use by refuge workers or visitors who  17 will be much less exposed.  18 Now, we are in a different situation with  19 this planning process than typical. This is very unusual  20 for us to be preparing a Comprehensive Conservation Plan for  21 a National Wildlife Refuge before we have actually acquired  22 the property. Typically when we're going out to use our own  23 land acquisition funds to buy a piece of property, we go  24 through a NEPA process to decide whether or not a refuge  25 should be established. 

 48  1 In this case, that's not necessary because  2 Congress said there shall be a National Wildlife Refuge.  3 It's required in the statute. The time line provided in  4 that statute was for us to complete this process by December  5 of 2004. So we are on a statutory time line and we're going  6 to do our best to execute that law that your elected  7 representatives brought forward in the congress of the  8 United States.  9 And we understand all of the cleanup  10 decisions made by those cleanup decision makers will not be  11 made by the time that we have to finalize our plans. So  12 this plan, as Mike said at the beginning, is based on the  13 premise that in the context that lands that will be  14 transferred to the U.S. Fish & Wildlife Service that will  15 become part of the National Wildlife Refuge system, will  16 have been effectively cleaned up to levels that are safe for  17 refuge workers and any less-exposed people which would  18 include visitors.  19 We are gathering more data. We have deer  20 tissue samples that were taken last year that are going in  21 to be analyzed to see if there are contaminants, americium,  22 plutonium or uranium in those deer tissues. If we find out  23 that there are, clearly that will affect the final decision  24 on some of the uses that are proposed for this site.  25 Additional soil samples are being taken in 
 49 

 1 the buffer zone as we speak. Much better characterization  2 than we currently have. Currently we don't have any  3 evidence of dangerous levels in the buffer zone. We're  4 continuing to look, and if that scientific data indicates  5 that our plans are not safe or not appropriate, obviously  6 those plans will have to change.  7 So although I really appreciate all the great  8 attendance we're getting at these meetings and input we're  9 getting from folks, it's important for all of us to talk to  10 people who make decisions about cleanup, about cleanup  11 issues, as opposed to refuge management issues. And there  12 are good venues to do that. The Rocky Flats Citizen's  13 Advisory Board, which is a formal group of citizens to  14 advise the Department of Energy on the cleanup of this site.  15 I wish as many people attended those meetings on the first  16 Thursday of every month. So there's an opportunity there.  17 That Rocky Flats Coalition of Local Governments meets  18 monthly, if you live in Jefferson or Boulder County, those  19 municipalities have elected governments, or the Department  20 of Energy and the regulatory agencies.  21 We have very important decisions that are  22 upcoming that many of you mentioned tonight, and that is,  23 how are we going to ensure long-term stewardship of residual  24 contamination that will remain in the DOE retained lands.  25 I'm confident that if we have closure, the 

 50  1 pathways for that will be cut off and we won't be exposed to  2 things three feet underground. I think it's important that  3 we work with the RFCA parties to make sure they stay where  4 they are.  5 So back to your question, sir, the decision  6 on that is outside the scope of our plan because the  7 demarcation of that boundary between the ownerships will be  8 made by the RFCA parties, not by the Fish & Wildlife  9 Service. We will have input to that. Our input will  10 include, and we haven't formalized it yet, that that  11 boundary be very clearly and as permanently marked as  12 possible so that anybody, anyone on the site legally or  13 illegally would know whether they were on National Wildlife  14 Refuge or Department of Energy stewardship property.  15 I think we would prefer that if it's deemed  16 safe, that the boundary not be a barrier to the movement of  17 wildlife across the landscape or not create an unnecessary  18 disruption in the visual characteristics of the site. But  19 that remains to be seen and that will be decided by the RFCA  20 parties in their institutional control plan. And I would  21 encourage you all to participate with the CAB and the RFCLOG  22 and DOE decision makers about that.  23 Before we go to further questions, I would  24 like to ask Joe Lagare, with the United States Department of  25 Energy, just to come up for a minute. I'm not going to ask 
 51 

 1 Joe to field questions tonight, but I think he has some  2 things he'd like everybody to listen to tonight. Thank you.  3 MR. LEGARE: Good evening and Happy St.  4 Patrick's Day. My name is Joe Lagare, I worked out at Rocky  5 Flats since 1986. I actually showed up the day our cleanup  6 agreement was signed and I've had the principal  7 responsibility of implementing the agreement. Additionally,  8 I was one of the chief combatants for DOE and the revised  9 soil action levels working with the State Department and EPA  10 and the communities.  11 We had a lot of issues, specific community  12 meetings in those past eight years and the organizations  13 that Dean mentioned, if you go to those meetings, you'll get  14 right into a pretty detailed issue about a landfill or  15 groundwater monitoring or something like that.  16 One thing is certain, in my experience, over  17 eight years, which is relatively short compared to some of  18 your involvement with Rocky Flats, we've made better  19 decisions because of community involvement. Sometimes we  20 hate to admit that because everybody likes to be right, but  21 we really have, particularly with the soil action  22 discussion.  23 One of the things we wanted to offer up here,  24 and it doesn't have to be a one-time deal, Dean had  25 mentioned to me, you know, we're getting a lot of cleanup 

 52  1 questions and we want to talk about how we're going to  2 manage the refuge. Obviously there's a series of checks and  3 balances before it ever gets to be a refuge. We need  4 certification from the EPA and the State Health Department,  5 for example, it's not just a, trust us with a whistle and a  6 prayer, here, Dean, here's the title, there's actually quite  7 a lot of process and public process to ensure that the  8 refuge is, when we turn it over, is as represented.  9 Having said all that, it's difficult now to  10 get into a meeting where there's the broad view again. Tell  11 us again the big picture about the cleanup and how that  12 relates to how Dean is going to manage the refuge. So what  13 we're talking about and what we've scheduled April 14th, but  14 specifically for that purpose we have the Fish & Wildlife  15 Service, the DOE and quite probably the other parties to the  16 cleanup agreement, State Health Department and the EPA, in  17 the same room where we can talk about those issues of  18 transition and explain to me again why you think this is  19 safe for a refuge.  20 So clearly you heard some of those comments  21 tonight, you heard them as part of the written comments that  22 came in at the previous meetings, so we want to provide the  23 opportunities in a forum. This meeting in particular will  24 be at Broomfield City Hall and they've agreed to host that  25 meeting, 8:00 to -- excuse me, 6:00 to 8:00, and so please 
 53 

 1 come out if you have those questions. You're not a regular,  2 so to speak, at our cleanup meetings and you're looking for  3 a forum to get your big picture questions answered. Explain  4 to me how you're going to tell me that the cleanup is safe.  5 Explain to me what the site looks like when you leave,  6 surface and subsurface. Tell me who is going to be there.  7 In fact, he's here right now. Dave Winus (phonetic) is from  8 Legacy Management of DOE, he's running the team that's going  9 to take over from environmental management some time in the  10 future here.  11 So just an unpaid, unpolitical announcement  12 for coming out for. Those of you that have an interest and  13 maybe some of the discussions we have in the other forums  14 are just to focus on the specific remediation. Come out on  15 April 14th. If we have a large turnout, who knows, maybe  16 we'll have another one. We'll see how it goes. Maybe we'll  17 have another one, but I just wanted to offer that up.  18 MR. RUNDLE: Before you ask any more  19 questions, I caught one question during testimony that I did  20 want to address. There was a statement made that I had said  21 at Boulder the other night that Alternative B has been  22 selected. And I want to clarify if there was any  23 misunderstanding.  24 Last Thursday a comment was made, a question  25 was asked, why are you proposing this alternative at this 

 54  1 point. And my response to that, and somebody correct me if  2 I'm wrong or misspoke it again, but we are required to bring  3 to you a preferred alternative during this Draft phase.  4 This does not mean that there's a decision made at all.  5 We are getting a lot of very good valuable  6 comments. I would be very surprised if the final decision  7 is exactly any of the current alternatives that are being  8 presented tonight. Every stage we have made modifications  9 based on the input we have received from the public and from  10 local governments and other government agencies. So  11 Alternative B is our preferred alternative. The law  12 requires us to tell you what we're proposing to do so that  13 we can get your feedback on that.  14 It is not a decision at this point at all.  15 So I hope that's clear.  16 MR. HUGHES: For those of you who like  17 meetings that go in a straight line, you're in the wrong  18 one. We're going to go back to a three-minute comment  19 period. We've had someone join us who wants that  20 opportunity for three minutes. The meeting isn't over yet,  21 so we're going to ask he or she to come forward. We'll do  22 that now, if that's okay. We'll give you three minutes and  23 then we'll get back up here with questions.  24 BY MS. PAULINE REETS:  25 My name is Pauline Reets and I'm a 
 55 

 1 representative of the Audubon Society for Denver. We have  2 worked over at the Rocky Mountain Arsenal dating back in the  3 late '80s when the Arsenal was being considered as a  4 wildlife refuge. And so some of the issues are similar.  5 There was a contaminated area, there was a lot of wildlife,  6 there was some -- there's a lot of value in preserving that  7 wildlife, and so we work to have that area kept as a --  8 designated as a refuge, which it was in 1991. As a future  9 refuge, I should say, not right away.  10 So I guess my -- I have a couple of  11 questions. First of all, I have to admit, I have not been  12 able to access the full plan. I got on the website and I  13 got to the summary and the next day I went back and it was  14 down. So I haven't read the full thing. Therefore, my  15 comments are pretty preliminary.  16 We feel that overall the most important thing  17 is public health and safety. And once those issues are  18 settled, if they can be, then the question of public use  19 comes up. This is actually not a very big area. It's going  20 to have open space on three sides, which is wonderful,  21 unlike the Arsenal, which is going to be completely  22 surrounded sooner of later. So our feeling about public use  23 is, you'll phase it in, the public would probably do  24 something like Alternative 3. I don't know if you can  25 combine alternatives, that's one of my questions. 

 56  1 Can you in fact say, we'll do Alternative 3,  2 which is very limited public use, only tours, only one trail  3 open, very restricted public use, very supervised for the  4 first 10 or 15 years? Then we can move to perhaps somewhat  5 more use, something along the line of Alternative B.  6 In any case, I think a visitor center would  7 be a really useful item no matter what alternative you  8 decide on. It can educate people about the site, about the  9 natural features of the site, but also about the history of  10 the site as a nuclear bomb plant. And I think that's really  11 important. People don't want to lose that. They certainly  12 didn't want to lose it at the Arsenal.  13 I think the key word in any of this is going  14 to be flexibility of management, because you have to be able  15 to open and close areas if you get any nasty surprises, you  16 will also have to close areas if you have nasty rafters,  17 want to keep trails out of the creek bottoms, and I would  18 say, in general, you need to really manage that site to  19 prevent erosion, degradation of the site.  20 So that's what we're concerned about once the  21 public health and safety issues are taken care of. Thank  22 you.  23 MS. ERIKSON: Just for those of you who may  24 come in, her comment about the website, the website is in  25 fact down. 
 57 

 1 MS. SHANNON: You know, if you need a copy of  2 the Plan, you want a hard copy, please, we have a sheet out  3 here, you can sign up your name, I'll be glad to mail you  4 one. Or we have some available now, we'll give you those.  5 But again, we apologize, but the Department of Interior, we  6 have been -- it's a court order, it has nothing to do with  7 Rocky Flats or anything else, but all Department of Interior  8 is shut down right now for Internet access. Thank you.  9 MR. RUNDLE: So you know how to get a hard  10 copy then? There was a question that she asked during the  11 last statement which was, can you combine alternatives. And  12 the answer is, absolutely. Any of these alternatives can be  13 modified before a final decision is made.  14 We're required, and what we try to do is  15 present a range of reasonable alternatives. Any of these  16 alternatives we believe can meet the purposes of the refuge  17 established in the special legislation, the missions and  18 goals of the National Wildlife Refuge system and be  19 responsive to at least portions of the public comment that  20 we've heard during scoping.  21 So any of these are plausible. Like I said,  22 I won't be surprised if the final decision is exactly any  23 one of these right now. The final decision is made by the  24 regional director of the United States Fish & Wildlife  25 Service. And after the public comment period, we'll go 

 58  1 back, we'll look at the totality of the comments, we'll  2 discuss that, we'll prepare a final Draft at that time, the  3 CCP will be separated from the EIS. They will be published  4 as two separate companion books. I guess at this rate  5 they're going to be books when we get done. And the  6 regional director will make the final decision on that and  7 it will be published in the Federal Register.  8 Q. Is it too early to ask about what the trail  9 surface would be initially? What are you looking at?  10 MR. RUNDLE: What we are proposing is to use  11 existing roads and disturbed areas for almost all the  12 trails. I think there's one small foot only loop on the  13 north side that would require a small amount of new trail  14 construction.  15 We typically, on other refuges, use  16 crushified (phonetic) as hard trail surfaces and I would  17 think that at the Flats we probably would use that on some  18 trails, or depending on the seasonality of the use and the  19 slopes and things like that. We do want to minimize erosion  20 impacts definitely.  21 Q. So you're not looking at like in the City  22 parks open space where they have the concrete trails for the  23 hikers and bikers and the dirt trails for the horses?  24 MR. RUNDLE: We won't have -- I don't want --  25 it would be extremely unlikely that we would have impermeant 
 59 

 1 surface trails.  2 Q. What would be the purpose of separating out  3 multi-use and equestrian?  4 MR. RUNDLE: Well, the reasons that we  5 have -- I think Bini took her sign down, but the priority  6 public uses of the National Wildlife Refuge system are  7 wildlife dependent. So we viewed horses and bicycles as a  8 means of access to engage in bird-watching or wildlife  9 photography or wildlife interpretation. We're not opening  10 just to provide the recreation that is inherent in bicycling  11 or riding on horseback.  12 Now, we're not going to go arrest people if  13 they jog on the trails and don't stop and look at a bird,  14 but the purpose for providing this access is to provide  15 access for wildlife dependent recreation.  16 We have proposed -- we got some feedback from  17 the public, well, all three uses can go on the same trail,  18 it's okay, some people say, well, I don't mind the horses,  19 but I don't like the bicycles, they're too fast. Other  20 people say the bicycles are fine, but I don't like the  21 horses. And we frequently use temporal or zoning strategies  22 to separate users, give people a choice of what type of  23 conflict they may want to be interested in, what types of  24 conflicts they'd be willing to accept or what.  25 I don't know if that -- in the Draft plan 

 60  1 there are Draft compatibility determinations and one of  2 those involves the multi-use trails in our plan that are  3 proposed. And I can tell you that the whole issue of the  4 equestrian and bicycle use within a National Wildlife Refuge  5 is one of considerable debate on a regional and national  6 scale.  7 Q. I was wondering, on your main trail on the  8 south and kind of your only trail, why does it go so close  9 to the DOE zone? Is it because of topography or present  10 roads? Why not stay more along the perimeter?  11 MR. RUNDLE: That's a good question. Well,  12 the proposed trails are cited for -- a couple of things went  13 into that. One was, where are there existing roads that are  14 already disturbed sites that we don't have to do additional  15 disturbances. We tried, in most cases, to avoid the steeper  16 slopes where erosion problems would occur and we also tried,  17 since there's not a lot of off-trails, mostly on-trail uses  18 proposed, we tried to provide trails that did provide  19 interesting vistas and opportunities to look down.  20 You won't see many trails in the right  21 corridor running adjacent to streams, but those are some of  22 the more picturesque and wildlife -- heavily used parts of  23 the site by wildlife, so a trail looking up on a ridge top  24 looking down and into those riparian areas, that was part of  25 the process. 
 61 

 1 So that trail you see would be on the edge or  2 near the north edge of the impediment on the south side of  3 Woman Creek, and it's really not as close as it looks. You  4 have to remember the scales of these maps we're talking  5 about. That's a 6,000-acre site, so while there's only half  6 an inch on this map, it's actually hundreds of yards on the  7 ground.  8 Q. My question was, you made reference to the  9 buffer zone, the refuge area, the DOE area, is the buffer  10 zone part of that or beyond that?  11 MR. RUNDLE: That's an excellent question.  12 Generally, when we talk about Rocky Flats, we talk about the  13 industrial area which is a fenced 400-acre site that's kind  14 of -- and actually it's really about like this, okay. And  15 that's industrial and the rest of the site was referred to  16 as the buffer zone.  17 One person in testimony earlier mentioned  18 about the expansion of Rocky Flats in the 1970s, the  19 original site from up until 1974, was only 2500 acres, about  20 like this. And these additional lands were acquired from  21 the 1968 fire. I think that was in '70, '71, I believe  22 that's right. So when we talk about the buffer zone, we're  23 talking about outside that fence.  24 Now, you'll notice that the DOE proposed  25 retained lands, and it is true that the final definition of 

 62  1 those lands has not been completed yet, won't be until the  2 cleanup is done, but it includes the industrial area where  3 there will be contaminants left below grade in the  4 industrial area. It also -- we call it the upside down  5 fetal prairie dog shape, but these legs go out, there's a  6 landfill here, sanitary landfill here that's going to be  7 retained. This leg goes out and covers the settling ponds,  8 the A and B series ponds in the Woman Creek branch that we  9 talked about, and this is where -- this area is I believe a  10 7 picocurie per gram line for residual surface soil,  11 contamination of plutonium.  12 The main contamination that actually escaped  13 the industrial area is called the 903 Pad. In other words,  14 the wind blew, the plutonium blew to the east. Plutonium  15 levels in most of this out here are like less than 1  16 picocurie per gram. There may be more contaminant stuff,  17 but we're talking about the buffer zone outside where --  18 that is not exactly the same as the land that DOE wants to  19 retain.  20 Q. This kind of green area?  21 MR. RUNDLE: Yes.  22 Q. Real quick, you said 6,000 acres, does that  23 include the industrial acreage?  24 MR. RUNDLE: The entire site is about 6,238  25 acres, I believe. And if you remember, that current DOE 
 63 

 1 land, that's about 1200 acres once we have a 5,000-acre  2 refuge.  3 Q. You talked about trails for horses and  4 bicycles and able-bodied people, how is the U.S. Fish &  5 Wildlife going to access the property, if that should come  6 about, for the mobility impaired?  7 MR. RUNDLE: The DOE portions of the trail  8 system, that would be 100 percent ADA accessible in terms of  9 grade, slope and surface. Not all the trails, particularly  10 the one going out to the Lindsay Ranch and overlooking the  11 Rock Creek Reserve, would be wheelchair accessible.  12 Q. I think you said last week that you  13 anticipate having a staff of four for Plan B and eight for  14 Plan D. How can you realistically expect to keep people on  15 the trails, when there's so many miles of trails and out of  16 the DOE retained area, with such a limited staff and  17 especially considering your goal of having a seamless  18 boundary for transition of wildlife --  19 MR. RUNDLE: That's a good question. We  20 aren't thickly staffed in the National Wildlife Refuges. I  21 feel pretty good about the proposal in that regard for a  22 couple of reasons. One is, I do use personally a lot of the  23 open space trails and the trails in the national forest. I  24 think compliance by the public using this area is pretty  25 good. The leash law compliance is not very good, but the 

 64  1 staying on the trail compliance is pretty good.  2 This is not the only site that we manage that  3 has hazards in it. I can give you examples. The last place  4 I worked, the Tijuana Slew Refuge in Southern California, we  5 had really significant biohazards in the estuary there  6 because of raw sewage and things coming in from Mexico, and  7 we had a very small staff there as well, but we had very  8 good compliance with signage and active law enforcement.  9 And I think that that will be adequate.  10 Now, the staffing that's proposed here that  11 we think we need to run Rocky Flats, it's also augmented by  12 law enforcement, full-time law enforcement personnel over  13 the Rocky Mountain Arsenal complex who will work both sites,  14 and also by maintenance personnel, administrative staff at  15 the complex headquarters at Rocky Mountain Arsenal. We're  16 not going to duplicate two full refuge staffs at stations  17 that are so closely located together. So there actually  18 would be more than four people on the site at different  19 times. And, Laurie, your input.  20 MS. SHANNON: The only other thing I'd add is  21 under B and D where you have public use, we also have  22 volunteer programs. And while volunteers don't do law  23 enforcement, they certainly tell you what's going on out  24 there and they certainly advise the refuge as to things they  25 see or hear. 
 65 

 1 MR. RUNDLE: We probably won't have as many  2 as we've got now at the Arsenal program, but we do not have  3 a problem with people leaving trails and passing signs that  4 say area closed. It's not a significant issue for us. So  5 most urban refuges, we have a bigger problem probably in  6 rural refuges where the primary uses are seasonal hunting  7 and things like that.  8 Q. In all the alternatives you're going to do  9 restoration and enhancement to the Preble Meadow Jumping  10 Mouse habitat, what do you know about existing populations  11 or numbers or vitality, anything as far as that?  12 MR. RUNDLE: It's not a large population. I  13 don't know. Mark, do you remember what the max estimate  14 was?  15 MR. SATTELBERG: I've seen numbers anywhere  16 between 20 to 100.  17 MR. RUNDLE: And that's typical with small  18 mammals. You can go survey for them one season and find  19 zero or two and several months later or the next year you  20 may find hundreds just because of their reproductive  21 ecology.  22 The heaviest concentrations are in the Rock  23 Creek range, but there are also occupied habitats in the  24 Walnut and Woman Creek drainages. So I think the real  25 significance to the site, Prebles, it's only one of two 

 66  1 federally-owned sites.  2 Q. Do you have any data on the large predators,  3 like mountain lions and things like that that are out there?  4 MR. RUNDLE: We just have anecdotal  5 information on those. We do know that because of the  6 current count activity, that all that open space you  7 mentioned, that that's one of the qualities we see at Rocky  8 Flats, even though, as you said, it's a reasonably small  9 future refuge, is that you do have -- you still have  10 movement of large mammals from the Rocky Mountain Front  11 Range. Bears have been photographed on the site, that's  12 usually a late summer or early fall hyperphasing thing.  13 There are a pretty good population of fruited shrubs and  14 things in the riparian areas that draw berries. I'm sure  15 lions occur there occasionally. I don't know if we got any  16 pictures, but I think there's some track anecdotal stuff.  17 Elk, we're not sure what's going to happen  18 with elk. In the past they've been occasional visitors  19 coming down in the wintertime. Last summer I think we had  20 11 cows, 9 cows, something like that, a small number of  21 calves down on Rocky Flats. That is a concern to us. We'd  22 like to help move in and out of seasonally, we're not -- we  23 don't want to see a resident elk population develop at Rocky  24 Flats out on the planes next to the suburban areas, that  25 won't be good for the elk or for the people around. 
 67 

 1 Q. Is it okay to give two quick remarks and a  2 question?  3 MR. HUGHES: Can you just give a question?  4 We wanted to give everybody exactly the same bite at that  5 apple.  6 Q. What is your relationship -- what is the  7 relationship of Fish & Wildlife to a possible museum?  8 MR. RUNDLE: That's a good question. We are  9 very open to partnering with a future museum. I think we do  10 have partnership goals for each objective, so I think that  11 there's a good potential. If a museum is established, we  12 could have a very close working relationship with them.  13 We do not have a formal role in the  14 establishment of a museum. A museum exists, it is a 501-C3.  15 At this point in time, the Refuge Act says that the  16 Secretary of Energy may establish a Rocky Flats Cold War  17 museum, so there's really decisions being made there by the  18 Secretary of Energy. And however that goes, we do  19 participate in board meetings of the museum, Cold War  20 museum. I think Laurie goes to most of them. So we would  21 be interested in partnerships with them for site  22 interpretation regardless of where the facilities are.  23 Q. Besides tracking and relocating, what other  24 methods will be used to exclude prairie dogs from the  25 habitat area? 

 68  1 MR. RUNDLE: I think we have to be really  2 careful about where we use certain grassland management  3 techniques at certain times of the year. One of the best  4 ways to prevent unwanted prairie dog invasions is to  5 maintain a robust and tall thick vegetative cover. So, for  6 example, that would impact where and how short-term grazing  7 was used to emulate bison grazing or where fire lines were  8 put for prescribed fires so that we know there's a burn  9 area, or if there's a wild fire you can get rapid prairie  10 dog invasion into that new burn area. So we'd have to plan  11 those areas to not encourage prairie dogs into the site. So  12 they don't like thick dense grass.  13 We make recommendations to DOE about the  14 re-vegetation of industrial areas and the retained lands and  15 we encourage them to do things like plant shrubs around the  16 site that would perhaps make it less likely for prairie dogs  17 to invade those areas and also to do the best they can to  18 ensure a tall robust stand of native grasses on those sites.  19 MR. HUGHES: Before I go back to anybody who  20 has already asked a question, are there any of you who have  21 not asked one who want a shot?  22 Q. When you capture and then publish this public  23 comment, would you provide us with copies of Mr. Ball's  24 song?  25 MR. HUGHES: Can they have copies of the song 
 69 

 1 when you print the final?  2 MR. TRENHOLME: Yes. The public transcript  3 will be in the final EIS.  4 MR. RUNDLE: And we will respond in writing  5 to these comments, both verbal and the written ones.  6 MR. TRENHOLME: Substantive comments.  7 MR. RUNDLE: If we get 50 identical  8 substantive comments that are basically the same, we may  9 respond to them in one response acknowledging where the  10 comments came from.  11 MR. HUGHES: Any other new questions?  12 Q. Are there plans for underpasses going under  13 Highway 93 or Indiana or to the north under 128, both for  14 people and animals? And who pays for them?  15 MR. RUNDLE: Right. Good question. I think  16 we acknowledged the desire for the maintenance of corridor  17 activity with the surrounding open space, but since those  18 highways are not going to be part of the National Wildlife  19 Refuge, that decision is outside the scope of this plan.  20 But we will work and are working with highway planners, for  21 example, were involved in the scope on the Northwest Parkway  22 and we certainly will work with their neighbors and C-DOT as  23 those plans occur. We don't have the money nor the  24 authority to say, thou shall put in an underpass under  25 Highway 93 or 128. 

 70  1 MR. HUGHES: I'd like to make a little  2 announcement about an open house. The Northwest Corridor  3 Environmental Impact Statement will have three public open  4 houses to look at the universal alternatives for the  5 Northwest Corridor Transportation. They are April 14th,  6 same time, and April 15th and April 21st. And in one of the  7 alternatives you will see cul-de-sacs 93 about there, that  8 eliminates this section of 93, takes the road around that  9 way to connect the wildlife habitat on both sides. I don't  10 know that that alternative will survive, but it was proposed  11 and it's active at the universal alternative phase.  12 Golden is April 15th or 14th. Arvada, this  13 location, this very building, April 15th, and then  14 Broomfield. And I don't know where -- we don't have a  15 location for Broomfield on April 21st. The Colorado  16 Department of Transportation's website has an EIS link for  17 the Northwest Corridor EIS. So you can go there, propose  18 that alternative or any other one you want.  19 Q. Are you thinking eventually of managing the  20 grasslands with prescribed burns and do you have any idea  21 what problems you might have with that?  22 MR. RUNDLE: The answer is yes. And I think  23 in Alternative B and Alternative C we do propose in those  24 alternatives to use prescribed fire as a grassland  25 management tool. It also -- does A too? And Rock Creek 
 71 

 1 mostly.  2 Alternative D would preclude prescribed  3 burning or grazing as grassland management tools. There's a  4 lot of issues with managing prescribed fire, particularly  5 urban or suburban landscape, everything from smoke  6 management and impacts to highways, and of course, at this  7 site we know that because of the past uses of the site there  8 are particular concerns. We, during the development of this  9 Draft, went to the Environmental Protection Agency and the  10 Colorado Health Department and said we would like to be able  11 to use prescribed fire and grazing as grassland management  12 techniques, can you tell us, with your knowledge of the  13 site, if that will be a safe thing to do. And their letters  14 and response are appendices in the back of the Draft and we  15 got the concurrence from the health agencies saying it would  16 be safe with certain conditions.  17 We also know, because of the sensitivities,  18 that even if they said it's safe, there might be some areas  19 where it might not be a good thing to do. And if you look  20 up here, there's a map that shows areas where we would not  21 use prescribed fires, mostly along this east side where even  22 though the levels of surface plutonium were very low, they  23 are higher than in the rest of the proposed refuge lands and  24 it's also because of the smoke issues. So we're saying we  25 would not use prescribed fire in that area. 

 72  1 Q. How is grazing restored to -- who is going to  2 be doing the grazing?  3 MR. RUNDLE: Good question. Grasslands  4 evolve under a variety of ecological conditions that drove  5 their evolution and our grasslands here. Fire and grazing  6 by bison made of ungulates were primary factors in driving  7 grassland ecosystem health.  8 To really restore grasslands, you need to  9 restore the ecological functions and values that drove the  10 development of those ecosystems. So we have proposed, in  11 Alternatives B and C, I don't know about A, is there grazing  12 in A? In Alternatives B and C we could use grazing for a  13 couple of purposes. One would be the use of sheep or goats,  14 specifically as a weed control effort to use a biological  15 control of weeds. We also would use, as biological control  16 agents, insects as well as herbicides, fire, as well as a  17 pest management program.  18 We would also propose that we could use short  19 rotation intensive grazing by cattle to emulate bison  20 grazing on the site. And this would not mean permanent  21 cross fencing that you can do with electric fences and solar  22 chargers, and what you do is overstock your pasture with a  23 large number of animals for a very short period of time, let  24 them do what the bison did, which was move through every  25 year or two, basically graze it down to nothing and trample 
 73 

 1 new sheet into the ground and then get them back out.  2 So we would not use similar grazing systems,  3 for example, that you might see on border open space, there  4 are different goals there, but their cultural heritage that  5 they're trying to emulate, we would probably do it  6 differently than they do it.  7 Q. So you're not going to bring bison back?  8 MR. RUNDLE: No. There's no proposal in any  9 of the alternatives. This is a small site and there are  10 some parts of natural environment that probably are not  11 feasible to restore given the context of the lands.  12 Q. You're going to be investing a lot of  13 resources in restoring the prairie, ecosystem, revegetation  14 activities, is there a possibility that -- you talked  15 previously about, you can work with them, but you can't  16 force them to do something, that they can do something on  17 their property that would have detrimental impacts on your  18 trying to restore the prairie system?  19 MR. RUNDLE: There's certainly a potential if  20 they don't do it right. Let me add, when we talk about  21 prairie restoration, for the most part of the site we're  22 very fortunate. This was ranch land and not farmland prior  23 to government acquisition, so the sod along most of this  24 land has never been broken and we have the full genetic  25 biological makeup of the native floor along this site. So 

 74  1 restoration is really driven more by control of noxious  2 weeds and the restoration of these natural environmental  3 processes, such as grazing and fire, and in some cases there  4 will be, under B and C, the kind of tan area, the southwest  5 corner, that is a tame hay meadow that was put in, and under  6 those alternatives we would restore that to native species  7 using tillage perhaps or actually getting seed, hopefully  8 local eco-type seed and killing that smooth grass and  9 receding that native.  10 DOE is not doing restoration, they are  11 revegitating. I think if they do it right they can provide  12 a habitat cover that's not necessarily emulating the exact  13 native prairie, but would provide habitat for ground nesting  14 birds and things like that. If it's not done right and if  15 we don't -- we need to work with the legacy management, that  16 when Kaiser-Hill leaves, if we don't have a good stand  17 advantage out there, the damage could be that it would  18 become a source of invasive weeds, if we don't get a good  19 stand of revegetation on the site.  20 So it would be hard for us, if we go -- if  21 DOE -- I don't want to knock their stewardship, they've done  22 a good job at weed control, it's not over with yet, but they  23 have not been silent. They have been stewards of this  24 landscape controlling the spread of noxious weeds, EM has,  25 and we look forward to them continuing that. So we hope 
 75 

 1 it's successful.  2 MR. HUGHES: It's 8:30, the Arvada Center  3 isn't going to throw us out if there any other questions.  4 Q. What are the plans for the wildlife to do to  5 enhance the raptor population and song birds? You talked  6 about big animals and stuff, but birds are my concern.  7 MR. RUNDLE: That's really a good question.  8 When I started with this outfit, we did a lot of enhancement  9 work and we don't do a lot of enhancement work anymore. In  10 terms of trying to make the land produce more than it -- or  11 trying to change the landscape by, for example, putting in  12 nest boxes and nest platforms or extra hawk perches and  13 things like that.  14 What we would like to see is restore the  15 habitat to as close as it was before settlement and try to  16 enhance, not species richness by bringing in more species,  17 but enhance it for the native species that belong there.  18 I think on most prairie refuges we probably  19 have too many Red-Tail Hawks and not enough Swainsons and  20 Ferruginous Hawks. So we're not planning any enhancements  21 in terms of artificial structures or planting of additional  22 trees to encourage tree nesting or anything like that, what  23 we want to do is make it the best habitat it can be for  24 those bird species that were native to the prairie Front  25 Range interface. 

 76  1 Q. The chunk of land that's in the southwest  2 corner is currently used for grazing, that's not part of the  3 refuge?  4 MR. RUNDLE: Section 16, the state school  5 section.  6 Q. And so you talked previously about that there  7 is availability through the land and what's it called, land  8 conservation?  9 MR. RUNDLE: Land and Water Conservation  10 Fund.  11 Q. And using that money to purchase additional  12 acreage to expand the refuge. And I was wondering if there  13 was any thought to obtaining that property so we don't have  14 maybe Rocky Flats the amusement park someday that can  15 possibly be built on there. So in order to protect that, is  16 there any possibility of any added grassland to the refuge?  17 MR. RUNDLE: Well, we're not proposing any  18 additional fee land acquisition in the CCP. And one thing  19 that we cannot use Land and Water Conservation money for is  20 to acquire land that's owned by a state. We can buy private  21 land, we can buy land from municipalities and local  22 government, if they're willing sellers. The only way that  23 Section 16 would ever be acquired will be on a willing  24 seller basis through a land exchange with the State of  25 Colorado. That's not being proposed by us at this time. 
 77 

 1 Doesn't mean that it can never ever, ever happen, but that  2 is land managed by the State Land Board and I think your  3 resource there is to talk to the State Department of Natural  4 Resources about whether or not that land should be part of  5 their trust or something like that.  6 They do have a trust, a conservation trust, I  7 think it's maxed out right now, but there is a potential of  8 working with State folks to put that land into a  9 conservation status.  10 MR. TRENHOLME: You might mention that part  11 of that Section 16 has been mined for aggregate.  12 MR. RUNDLE: There's also private water  13 rights there. The lakes are going to stay there, that's  14 privately owned, basically, even though it's on State land.  15 MR. HUGHES: Other questions? Dean,  16 anything?  17 MR. RUNDLE: I'd just like to thank everybody  18 for coming out tonight. We're getting really good  19 attendance and great questions. Thanks for the opportunity  20 to answer those. And we'll be at Broomfield tomorrow  21 night.  22 . . . WHEREUPON, the public hearing was  23 concluded at 8:40 p.m.  24  25 

 78  1 CERTIFICATE OF DEPOSITION OFFICER  2 STATE OF COLORADO )  )  3 COUNTY OF DENVER )  4  5 I, SANDRA A. SMITH, Certified Shorthand Reporter  and Notary Public, State of Colorado, certify that said  6 public hearing was stenographically reported by me at the  time and place heretofore set forth, and was reduced to  7 typewritten form under my supervision as per the foregoing;  8 That the foregoing is a true and correct  transcript of my shorthand notes then and there taken;  9  That I am not a party to nor in any way connected  10 with any of the parties to said action nor otherwise  interested in the outcome of this action.  11  My commission expires May 23, 2005.  12 IN WITNESS WHEREOF, I have affixed my  signature and seal this 29th day of March, 2004.  13  14  15 ___________________________________  Sandra A. Smith  16 BOVERIE, JACKSON, BUSBY & LA FERA  1735 East 16th Avenue  17 Denver, Colorado 80218  303-329-8618  18  19  20  21  22  23  24  25 
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 1 

 1 PUBLIC HEARING ON  2 THE DRAFT ENVIRONMENTAL IMPACT STATEMENT  3 AND COMPREHENSIVE CONSERVATION PLAN  4 FOR THE ROCKY FLATS NATIONAL WILDLIFE REFUGE  5  Thursday, March 18, 2004  6 6:30 p.m.  7  at  8 Broomfield Recreation Center  Lakeshore Room  9 280 Lamar Street  Broomfield, Colorado  10  11  12  Panel Members: Richard Trenholme  13 Mike Hughes  Laurie Shannon  14 Dean Rundle  Jody Erikson  15  16  17  18  19  20  21 TAKEN BY: CHERYL M. ROBINSON  22  23  24  25  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 2  1 INDEX  2 INTRODUCTION BY MR. HUGHES..........................3  3 INTRODUCTION BY MS. SHANNON.........................7  4 COMMENTS MADE BY THE PUBLIC........................18  5 COMMENTS BY MR. RUNDLE.............................52  6 COMMENTS BY MR. LEGARE.............................55  7 QUESTION AND ANSWER PERIOD.........................59  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 MR. HUGHES: We're going to begin. My  2 name is Mike Hughes, and I'm a member of the planning  3 team that's been working on the public process as well as  4 the Draft Comprehensive Conservation Plan and Draft  5 Environmental Impact Statement.  6 So I want to start by saying thank you all  7 for coming. And I want to say a couple of words about  8 the agenda, the way the meeting will proceed tonight, and  9 then we'll get started.  10 You can see from the agenda that we've got  11 some ground rules at the top, and then I'm going to go  12 through the individual sections of the agenda. Tonight  13 is a hearing where, as you can see, we are recording  14 verbatim the comments that you're here to make on the  15 Draft Environmental Impact Statement and the Draft  16 Comprehensive Conservation Plan.  17 Now, we've been asked to ensure that there  18 is balance and fairness in how that is done. And so what  19 we've decided is that everyone will get precisely the  20 same amount of time to make their comments. So each of  21 you will get three minutes to comment on the Drafts and  22 we'll -- again, we'll be recording all of those comments.  23 In order that each of you has the full use  24 of that three minutes, we ask that you not interrupt one  25 another while you're speaking. So, whether you agree or  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 4  1 disagree, we want you to simply hear the comments as  2 they're being spoken and not interrupt in any way, that  3 includes with applause if you agree with something. We  4 want people to get their full three minutes. So we ask  5 that you give them the respect of letting them finish  6 what they have to say. We're going to ask that they  7 offer you that same respect in turn to give you the full  8 benefit of those three minutes.  9 At the end of each time, when each person  10 who has signed up to speak has had that opportunity, we  11 will, time permitting -- and I think time will permit --  12 turn to some question and answer. So Dean Rundle, the  13 refuge manager will come forward and say a few words, but  14 then also give you an opportunity to ask questions of  15 clarification about the Plan and the Draft Environmental  16 Impact Statement.  17 What we ask that you not do is use that  18 time to get three more minutes. So we're going to ask  19 that you actually ask questions, rather than make  20 additional statements.  21 So we'll do that, take the time until  22 questions run out or until 8:30 or something in between,  23 and then adjourn the meeting.  24 I want to say a couple of things about  25 what we ask you to comment on, and then a little bit  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 about the premise that underlies the Draft Plan and Draft  2 Environmental Impact Statement.  3 First of all, the kinds of comments that  4 we're looking for: Questions about the accuracy of the  5 information contained in the Environmental Impact  6 Statement or the plan. So if there's some factual --  7 some piece of information that you come with that  8 contradicts or amplifies or alters in some way the  9 information that's in the plan, that's useful.  10 The adequacy of the environmental analysis  11 would be something that would be useful for you to  12 comment on, the reasonableness of the alternatives. So  13 if there are aspects of the alternatives that you think  14 don't comport with that analysis that you think ought to  15 be altered in some way, that's useful and helpful  16 information.  17 And then, obviously, changes or revisions  18 that you would recommend in the documents themselves. So  19 we ask that you stick to the plan and your comments on  20 it.  21 Let me just say something about the basis  22 for that plan, and I'm referring to this second board  23 here (indicated): The steps to refuge establishment.  24 The service -- the U.S. Fish & Wildlife Service, that is,  25 is in the stages of this meeting as a part of their  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 6  1 completing the final Comprehensive Conservation Plan and  2 the final Environmental Impact Statement that will carry  3 with it, when it's done, a record of decisions. In order  4 for that -- for Rocky Flats to become a refuge, the  5 following steps also have to happen once that record has  6 been signed. The Department of Energy has to complete  7 its work on Rocky Flats -- its cleanup efforts.  8 Obviously, the Department of Energy will continue to  9 monitor and be part of the site, but their cleanup will  10 have to end.  11 Then the Environmental Protection Agency  12 and the Colorado Department of Public Health and  13 Environment will have to certify that cleanup. Then DOE  14 would be free at that point to transfer the land to the  15 Department of the Interior for the creation of the  16 refuge.  17 At that time, the Department of the  18 Interior would formally establish the refuge, and then  19 the U.S. Fish & Wildlife Service can begin implementing  20 the plan in its final form and managing the refuge.  21 So the document is written from this  22 perspective, as if the site certification has occurred;  23 that is, that the EPA certification is complete. So  24 that's that premise that underlies the draft itself.  25 It's written from the perspective that that has occurred.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 So, with that, I'm going to give the floor  2 to Laurie. She's going to say a few words about changes  3 that have happened since we last met in a public forum in  4 the Draft Plan and the Draft Environmental Impact  5 Statement. And then we'll give you three minutes for  6 each of you who have signed up three minutes for the  7 comments.  8 MS. SHANNON: Thanks, Mike. Good evening.  9 The first thing I want to let everyone know is that the  10 comment period has been extended to April 26th, as our  11 one board shows up there.  12 And, also, as of early this week, you can  13 no longer get to our website because of the Department of  14 the Interior -- there's been a court-ordered shutdown of  15 all the Department of the Interior's Internet access. So  16 it has nothing to do with Rocky Flats, but,  17 unfortunately, you can't get to our website right now.  18 So I know some of you who might be trying to get online  19 and trying to submit their comments, unfortunately,  20 can't.  21 And we all lived at one time without  22 Internet and we managed to get through public process at  23 that -- in those days, and so we will continue to be able  24 to do that. So people can either write their comments to  25 me or they can fax them to me or they can deliver them in  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 8  1 person. Whatever works. Please give us your comments,  2 we'd love to have them.  3 Or -- and the other thing I'd like to  4 mention, if you want a hard copy -- the beauty of having  5 the website is people who want to go look at the plan can  6 get online and download it and get copies. So if you're  7 not able to do that and you'd like a copy, we do have  8 some compact discs out on the sign-in table, and if you  9 really would like to have a hard copy, I will give those  10 out until they're gone. I have a limited number and  11 please sign up and let us know, and I'll mail one out to  12 you, if that works.  13 So with that, I'm going to talk about  14 the -- briefly talk about the four alternatives that  15 we're here to discuss tonight. I'm not going to go into  16 long depth about them, just so we're all on the same  17 page -- briefly what each one contains. And I want to  18 highlight the things that have changed since we first  19 presented those last May.  20 What else with respect to that? Okay. To  21 start with, what went into our alternatives? How did we  22 generate them? Back in the fall of 2002, we held what we  23 call our scoping period, where we went out and we had  24 people tell us what the issues were. And following that  25 process in late fall, we began to develop the  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 alternatives for the refuge.  2 And the things that went into creating  3 those alternatives included what we heard out of scoping,  4 what the Refuge Act says, and what our mission and policy  5 of the national wildlife refuge system is. So there's  6 kind of -- those kind of components went into crafting  7 these alternatives. And we did present a draft set of  8 them last May, and we received comments on those. And  9 then really what this is about is, is looking at the full  10 Draft Plan and Environmental Impact Statement.  11 So I'm going to start with Alternative B,  12 because it is our proposed action. And under the  13 National Environmental Policy Act, we are required to  14 look at all reasonable alternatives and to evaluate those  15 all objectively, but we are required to come out with a  16 preferred or a proposed action, and that's what we have  17 before you.  18 Our proposed action is Alternative B.  19 It's what we call a wildlife habitat and public use  20 alternative. This alternative -- it looks at trying to  21 have a very strong emphasis on wildlife and habitat,  22 while allowing for some moderate opportunity for public  23 use and access on the site. We feel that that's kind of  24 a middle-of-the-road from all the things that we've  25 heard -- from what people have told us.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 10  1 What I'd like to start with is just a  2 little bit of what we've changed since last spring. And  3 one of the primary things that we changed, and based on  4 public comment, was that people told us that they wanted  5 to have some horse access. And so we did -- one of the  6 things we did was in the southern part of the site, the  7 trails down here (indicated) would provide for horse  8 access, bike access, and pedestrian access. And that has  9 changed, we didn't have that before.  10 Up to the north, the pedestrian-only  11 trails are still there. This multiple-use trail over  12 here (indicated), this is also a multiple-use trail, that  13 is the same, it's a bike and pedestrian-only access.  14 The other thing that we did change is that  15 we -- as soon as we established the refuge, we would look  16 at putting a trail down to the Lindsay Ranch fairly soon  17 after. But then, because we heard from a lot of people  18 that they wanted us to look at restoring the site first  19 and really focus on habitat conservation, that we would  20 look to wait for five years and then implement the rest  21 of the public use program. And it would all be  22 implemented by year 15.  23 That would give us a chance to focus on  24 wildlife and habitat birds, and it would give us a chance  25 to get our budget together, funding, and those kinds of  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 things.  2 This alternative offers a visitor contact  3 station; we would have a few offices there. Whereas,  4 Alternative D, which I'll explain in a minute, has a  5 full-blown visitor center. It's one of the differences  6 between the two.  7 One thing that people told us they wanted  8 us to do was to put in a north-south trail. And we would  9 still prefer not to do that, because we know that there's  10 going to be some changes along Indiana, likely, in terms  11 of the transportation corridor. And if there is  12 something done, we would like to see that done as part of  13 that project. Or, we would like to see the community put  14 it in. But it's very difficult for us to put in a trail,  15 try to make -- next to the transportation corridor, and  16 next to the DOE-retained land, and try to fit all that  17 in. So that is our preference, we do not make that  18 change.  19 We did try to -- one of the other things  20 we changed is that people told us they wanted to see a  21 little more loop -- loops -- people to be able to make  22 loops and some connectivity, and we tried to work on  23 those kinds of things as well.  24 I think that covers that. Oh, one other  25 thing: Hunting. I know Bini is going to shoot me here  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 12  1 if I miss this one. We -- as in -- as we presented last  2 May and as you will find in the document now, we do  3 propose a limited hunting program. And we did make some  4 modifications to that.  5 What we are proposing is that it would  6 continue to be a very limited, managed program that would  7 only be for a couple of weekends out of the year; and it  8 would be targeted towards the first two years towards  9 youth and the disabled. And as Bini has -- is in our  10 compatibility determination, we would look at having  11 about ten hunters a year.  12 After two years, if we are not meeting our  13 target population goals, we would look to expand that to  14 able-bodied hunters as well. It's not a done deal; it's  15 just that we would look to see if that could be  16 accommodated.  17 All right. I'm going to move on to  18 Alternative A. Alternative A is our no-action  19 alternative. And it basically would look at focusing our  20 habitat and restoration efforts primarily in the Rock  21 Creek Reserve, the northern part of the site. And pretty  22 much very limited management, the rest of the site -- the  23 rest of the refuge.  24 The one change that we made on Alternative  25 A is that when we proposed it last spring, we proposed  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 having a chain-link fence all the way around the site,  2 and we took that option out. We have analyzed that in  3 Chapter 4 of the Environmental Consequence chapter, but  4 we found that (a) it's too expensive to do that; (2) we  5 did not have -- there was not community support, or very  6 little community support; and (3) it really precludes  7 wildlife from being able to move from adjacent open space  8 and onto the refuge and back out again. So it's  9 really -- it's not good for wildlife from our  10 perspective.  11 Alternative C is the ecological  12 restoration alternative. And this alternative --  13 somebody's phone's ringing -- Alternative C is the  14 alternative that focuses on ecological restoration of the  15 site and offers very, very little public use on the site.  16 Alternative A is similar in terms of public use as being  17 very limited, guided -- just almost no public use except  18 for kind of VIP-type tours.  19 The difference between A is under  20 Alternative C we would have a trail that would overlook  21 the former Lindsay Ranch. And under Alternative C, we  22 would take out the whole Lindsay Ranch buildings under  23 that alternative, because our focus would be on trying to  24 restore the site to -- as much as we could to a  25 presettlement condition.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 14  1 We really didn't make much changes to  2 Alternative C from last May.  3 And then under Alternative D, which is the  4 public use alternative -- that's what we call it -- this  5 would be trying to focus on certain plant communities and  6 wildlife species, really trying to target -- target those  7 species, but, at the same time, being able to maximize  8 the amount of public use that we would have on the site.  9 And, as I said earlier, under this  10 alternative, we looked at having a full-blown visitor  11 center on the site. We did make some changes from last  12 May. We tried -- based on the input we had, we tried to  13 improve some of the loops that people could do and also  14 some connectivity in that as well.  15 I think those are the main points. Did I  16 miss anything, Bini?  17 MS. ABBOTT: I think it was 10 of disabled  18 youth -- or of youth, and 10 disabled, making a total of  19 20, I think.  20 MS. SHANNON: She knows. Okay. One of  21 the other things that I save her -- for part of her three  22 minutes is that -- and these are Bini's graphics.  23 They're great, too.  24 MS. ABBOTT: Except the underlines are  25 mine; you can't blame them for that.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 MS. SHANNON: We have six priority public  2 uses that the Fish -- that in our Improvement Act, in our  3 organic act, that Congress has said that the Fish &  4 Wildlife Service should try to provide. And those six  5 uses are: Hunting, fishing, wildlife observation,  6 wildlife photography, environmental education, and  7 environmental interpretation.  8 And while our purposes of the national  9 wildlife refuge system are geared towards wildlife  10 conservation and habitat management, Congress has said  11 that it is appropriate to have public uses on national  12 wildlife refuges. And that those are the six priority  13 ones and that, if you can, you should try to provide  14 those.  15 So, with that, does that help you?  16 MS. ABBOTT: Yes, thank you.  17 MR. HUGHES: Dogs?  18 MS. SHANNON: Dogs. There's my other cue.  19 Dogs. Under none of the alternatives would we allow dogs  20 onto the site, leashed or otherwise. So that's not up  21 for discussion tonight.  22 MS. ABBOTT: And what is the reason that  23 you don't want dogs?  24 MS. SHANNON: Can you hold that question?  25 MR. HUGHES: Let's hold that one. We'll  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 16  1 write it down as a question; we'll get to it.  2 MS. SHANNON: All right. Thanks, Mike.  3 MR. HUGHES: Okay. Again, particularly  4 for those of you who've come in since the start of the  5 meeting, here's how we are going to handle the next part  6 of the meeting. This is formal comment on the Draft  7 Environmental Impact Statement and the Draft  8 Comprehensive Conservation Plan, three minutes per  9 speaker. Again, we ask that you let each speaker have  10 their full three minutes by not interrupting them, and  11 we'll ask them to do the same for you when it's your  12 turn.  13 Since you'll be speaking about the plan to  14 the people who are responsible for producing it, we've  15 asked three of the lead staff to come here -- and I'll  16 give them a chance to introduce themselves in just a  17 couple of minutes -- so that you can speak directly to  18 them about your response to the content of the plan.  19 Since none of us have that internal clock  20 that tells us exactly when three minutes is up, Jody is  21 going to help with that. So she'll remind you when you  22 have two minutes, when there's a minute left, and when  23 you have 30 seconds left. And then she has a nice little  24 red sign that says, Stop. She'll stand up and stand next  25 to you, should that be necessary, once you've reached the  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 stop point. When Jody stands up, you know what that  2 means.  3 We ask that when you come to give your  4 comments that you use the microphone, despite the fact  5 that the room is relatively small, and my voice certainly  6 fills it. So we ask that you come to the podium, speak  7 to the staff here, and give your name first.  8 Lastly, this isn't the only way to provide  9 comments. Laurie talked about mail, fax, and  10 hand-delivering. We have written comment forms here. So  11 if taking this three minutes isn't your preferred method  12 of providing comments, that's fine; there are lots of  13 ways to do that. And so you're free to add written  14 comments.  15 MS. ERIKSON: And the address and the fax  16 number are on these little yellow or green sheets on your  17 chair.  18 MR. HUGHES: So, I'll ask the three people  19 here to introduce themselves, and then Jody will read two  20 names, and we'll get started.  21 MR. RUNDLE: My name is Dean Rundle. I'm  22 the refuge manager for the Rocky Flats refuge project.  23 MR. TRENHOLME: I'm Richard Trenholme with  24 ERO Resources. I'm part of the planning team.  25 MS. SHANNON: And you all know me. I'm  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 18  1 Laurie Shannon, the planning team leader here.  2 MS. ERIKSON: Mike Bartleson and then Bini  3 Abbott.  4 BY MR. MIKE BARTLESON:  5 My name is Mike Bartleson. I'm an  6 employee of the City and County of Broomfield. I've been  7 involved in Rocky Flats' issues since I started with  8 Broomfield in 1973, over 30 years.  9 There are many aspects of the refuge plan  10 that we have reviewed. We've looked at all of the  11 documents. We have full-time staff that thoroughly  12 reviews all documents with not only the refuge, but with  13 the cleanup process.  14 Based on our review, we see Alternative B  15 as being a rational approach to a good balance between  16 wildlife and habitat issues and use by the public. It is  17 a very valuable resource to not only the City and County  18 of Broomfield residents, but all of the residents along  19 the front range.  20 So I want to thank you, the Service, for  21 being responsive to our comments, particularly the  22 connectivity input with the trails that will connect  23 Broomfield's future trails with this area. Thank you.  24 MS. ERIKSON: Thanks, Mike. Bini Abbott  25 and Lisa Gill.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 BY MS. BINI ABBOTT:  2 My name is Bini Abbott, and we live on the  3 west shore of Standley Lake. What I'm not is a member of  4 a peace group or an animal rights person. I'm also not  5 antihunting. But what I am is opposed to recreational  6 sport hunting of the deer four days out of the year while  7 they are protected 361 days out of the rest of the year,  8 so that people can have a good opportunity for wildlife  9 observation and photography.  10 Under the environmental interpretation,  11 they had four subtitles, and those are: "Habitat  12 Restoration." And under Wildlife, colon, they have,  13 "Wildlife take refuge at Rocky Flats." This is from the  14 big book that's published for this case. Then under C,  15 under Wildlife and People, colon, "Wildlife comes first."  16 And I underlined first.  17 The definition of a refuge in most  18 people's minds and in the dictionary is a place of  19 safety, shelter, or a safe retreat. The large book  20 states that they are figuring that the hunting for these  21 20 people, two weekends a year, will cost annually about  22 $5,000, which is $250 per person. And they intend to  23 close the whole rest of the refuge at that time, which I  24 think is unfair to spend that much money for those few  25 people, and nobody else gets to use the refuge. I also  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 20  1 think it will be a shock as people are taking the trails  2 and, all of a sudden, find out, Whoops, can't go on it  3 today.  4 If there is a need to cull because of the  5 overpopulation, I feel the animals should be shot by a  6 sharpshooter from the Division of Wildlife.  7 And, according to the open space that's  8 surrounding it, I've talked to Boulder -- Boulder City  9 and Boulder County, and neither one has had an  10 overpopulation problem so far. And what bothers me is  11 they're going to try to have the hunting program the  12 first two years, but not do a population check until the  13 third year, and then not change things until 15 years.  14 I think the perception is going to be that  15 it is not good for fish and wildlife. I also have a  16 letter signed by Mark Udall and Wayne Allard regarding  17 the shooting range that they had at Rocky Flats, and  18 Sheriff Stone was asking that they be retained.  19 Okay, I'll be really quick.  20 So I'm hoping that you -- instead, the  21 people see pictures and look at wildlife through  22 binoculars, through a camera, but not through the sights  23 of a gun. Thank you.  24 MS. ERIKSON: Thank you, Bini. Lisa Gill  25 and LeRoy Moore.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 BY MS. LISA GILL:  2 Hi. My name is Lisa Gill, and I'm a  3 resident of Rock Creek. I'm here to talk about -- I  4 understand that Alternative B is probably the most likely  5 outcome of these meetings, and I have a question: Why  6 are -- why is the refuge allowing humans to use the site  7 when we're trying to save the animals? The refuge is  8 meant as a home for species all around Colorado, and if  9 we let humans use trails and horses -- well, we're  10 causing a disturbance to the environment. We're  11 promoting invasive weed dispersal.  12 And, also, I understand that throughout  13 most of the alternatives, fire is going to be used as a  14 mitigation to reduce invasive species. So, in effect, by  15 letting humans use these trails and by constructing  16 buildings, we're promoting invasive species, but then we  17 are trying to use fire to reduce them. So I don't  18 understand how those two come together.  19 And, also, I do not want equestrian use of  20 the refuge. If I were to go out to Rocky Flats, I would  21 like a place where I don't have to step into horse  22 manure. There are other parts of the front range or  23 other parts closer to Boulder, Broomfield that allow  24 horse use -- equestrian use, sorry. So I think that  25 Rocky Flats should be for us to enjoy if we are going to  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 22  1 be allowed that opportunity. Thank you.  2 MS. ERIKSON: LeRoy Moore and David  3 Waddington.  4 BY MR. LEROY MOORE:  5 I'm LeRoy Moore with the Rocky Mountain  6 Peace and Justice Center, a consultant with that  7 organization.  8 I would like to commend and resolve the  9 Fish & Wildlife for a process that's being used in these  10 meetings, that I think it's considerably improved over  11 the last round when you did the scoping hearings.  12 There are two organizations that -- there  13 are a number of them -- but, actually two organizations  14 that make studies of radiation exposure and make  15 recommendations to U.S. government agencies. One of them  16 is called the International Commission on Radiological  17 Protection, headquartered in London. The other one is  18 the National Council on Radiation Protection and  19 Measurements, a U.S. organization located in Washington.  20 I happen to be a member of two of that body's committees.  21 Both of these organizations do all of  22 their work regarding radiation standards -- setting of  23 radiation standards. They do all of their work on the  24 premise that there is no such thing as a safe dose of  25 radiation. Now, stated differently, what that means is  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 that any exposure can be harmful.  2 And in the case of Rocky Flats, we're  3 talking especially about plutonium. It is known -- it's  4 admitted by the government agencies itself, that the  5 plutonium -- tiny particles of plutonium were dusted over  6 the whole of that site. Plutonium has a half-life of  7 24,000 years; it will remain dangerous for a quarter of a  8 million years. In the environment, it's a permanent  9 danger.  10 It is dangerous in very tiny amounts. Not  11 dangerous if you don't get it inside your body, but if  12 you get it inside your body -- a particle of plutonium,  13 the smallest amount you can take in can cause cancer at  14 some later time or some other health problems of a severe  15 nature.  16 So it's about this that we're particularly  17 concerned at the Rocky Mountain Peace and Justice Center.  18 We think it's a mistake to subject people to this kind of  19 exposure if it's not absolutely necessary. So the  20 question that I put -- I've raised this question before,  21 I'll raise it again: Why take the risk of exposing  22 people to plutonium on the Rocky Flats environment,  23 people including children and other vulnerable members of  24 the population? Why take the risk if it is not  25 absolutely necessary?  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 24  1 I could point you to a fact sheet we have  2 over here on the table (indicated) if you'd like to pick  3 it up to get a little get more information on that.  4 Thank you very much.  5 MS. ERIKSON: Thanks, LeRoy. David  6 Waddington and Laura MacGillivray.  7 BY MR. DAVID WADDINGTON:  8 Good evening, ladies and gentlemen. I am  9 David Waddington. First of all, I support your  10 recommendation for Alternative B, as in baker.  11 I noted in Section 2.0 -- 10, page 70, a  12 desire to have a Cold War Museum and a combined visitor  13 center. I note that only Alternative D, as in dog,  14 supports this. I would certainly recommend that this be  15 added to B, because I think it's a well-worth thing. I  16 think it's a shame to have those buildings and not be  17 able to use them.  18 I understand there is a possible water  19 problem, and I would recommend working with Arvada for  20 planning to develop on 72 that they might be able to get  21 water up to that location.  22 Section 2.10, page 67 talking about  23 transportation. I think you need to consider having  24 underpasses to go under 93 and Indiana.  25 Mowing and fire. I definitely support it,  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
 25 

 1 but I would ask that you time it so that birds and  2 ground-living animals are past the young stage, birds are  3 able to fly, before you do.  4 Mineral rights. I understand that sand  5 and dust from mining is damaging various lands in the  6 wildlife refuge. I would recommend immediate action, any  7 way possible to stop this from occurring and preserve the  8 grasslands that we have.  9 You have planned for one restroom in  10 Alternative B. I think with 16 miles of trails, people  11 getting all around, you should plan for a restroom -- at  12 least of a port-a-potty type, to use a generic term -- at  13 each parking lot. And if you have entrances on the east  14 side for trails coming in, I would recommend one at each  15 of those. Thank you.  16 Fences. I definitely support your  17 barbed-wire fence. But I would consider that when  18 highways have much more increased traffic, in particular,  19 you provide underpasses for wildlife, that maybe you can  20 get the highway construction to put in some better fences  21 if necessary. I thank you for your time.  22 MS. ERIKSON: Thank you, David. Laura  23 MacGillivray and Gary Brosz.  24 BY MS. LAURA MACGILLIVRAY:  25 Hi. My name is Laura MacGillivray, and  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 26  1 I'm a student at the University of Colorado at Boulder.  2 And I know you don't want me to talk about this topic,  3 but it is an integral part of my concerns about the Rocky  4 Flats National Wildlife Refuge.  5 I'm only asking for your open ears and  6 respect, even if you decide to disregard what I have to  7 say to you. I know you don't want to talk about it, but  8 I feel that possible contamination of the soon-to-be  9 wildlife refuge needs to be addressed.  10 I believe that Alternative A is the best  11 choice at this point. The cleanup of the area is  12 currently under the supervision of the Department of  13 Energy and the EPA. Therefore, the cleanup of the area  14 is not your responsibility at this point. However, the  15 Rocky Flats area outside of the Department of Energy's  16 retained area will soon become your responsibility.  17 The EPA is expected to have the area  18 cleaned up and free from contamination before turning the  19 area over to you. My concern is that the area will be  20 handed over to the Fish & Wildlife Service and has not  21 been thoroughly tested for contamination from radioactive  22 materials emitted from the Rocky Flats plant.  23 There have been thousands of tests for  24 contamination within what would be the Department of  25 Energy's retained area; however, contamination testing on  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 the refuge lands has been limited.  2 My request is that Alternative A is chosen  3 until sufficient testing of the refuge area has been  4 completed to ensure the safety of the citizens and  5 workers that would be stationed on the refuge area.  6 Thank you.  7 MS. ERIKSON: Thank you, Laura. Gary  8 Brosz and Rick Warner.  9 BY MR. GARY BROSZ:  10 Hi. My name is Gary Brosz. I'm a city  11 council member with Broomfield City and County. I'm also  12 a member of RFCLOG, the Rocky Flats Coalition of Local  13 Governments. And for those who don't know, that's an  14 organization of area municipal governments that spend a  15 great deal of time overseeing DOE and Kaiser-Hill during  16 the cleanup operations and the planning for postclosure  17 activities, which we call legacy management.  18 I'm an engineer by trade. I'm a very  19 data-based person, and I've seen issues many times in my  20 career where there's the emotional side of the issue and  21 there's the real, honest data side of the issue. And  22 cutting through the emotion and finding the data is an  23 important step in resolving any issue, especially an  24 issue of a technical nature.  25 Furthermore, I consider myself to be a  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 28  1 reasonably hardcore environmentalist. I am a  2 card-carrying member of the Sierra Club, Greenpeace, the  3 Union of Concerned Scientists.  4 I have absolutely no interest in seeing  5 Rocky Flats being left in a state that is unsafe after  6 the DOE departs. It is the goal of RFCLOG to make sure  7 that that doesn't happen. And I am -- I have very high  8 confidence that will be the case.  9 There's been a great deal of concern  10 through this public input process about potential  11 contamination in the refuge area. I can assure you that  12 a great deal of sampling, actually, has already occurred  13 in the refuge area. We have maps that can show that, if  14 anyone is interested in seeing those.  15 Also, the planned sampling currently  16 underway is very extensive throughout the entire refuge  17 area. As a consequence, that site, when it closes, will  18 be certified safe; it will be verifiably safe. And it  19 will be safe to levels that are typical any place else  20 you might go on a hike or enjoy the open space in  21 Colorado.  22 Given that, I have worked with my city  23 council to keep them up-to-date. And our city council  24 over the years -- ex-Council Member Stovall here has been  25 working on this issue for about 20 years. We have a  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 great deal of information, and we have very high  2 confidence that there is no public risk to open up the  3 refuge. Consequently, we are very much in support of  4 Option B.  5 MS. ERIKSON: Thank you, Gary. If you  6 wrote your comments down, you're welcome to leave them on  7 the table so the stenographer and Fish & Wildlife Service  8 have them. So Rick Warner and then Randy Olson.  9 BY MR. RICK WARNER:  10 Thank you. Thank you for having this  11 meeting. I appreciate hearing all the members of the  12 public here. I think it's wonderful. I also understand  13 that this happened because it's an Act of Congress and  14 the Fish & Wildlife Service has been put in this  15 position.  16 I have about seven or eight years of  17 experience with Fish & Wildlife. I was actually involved  18 in a Superfund site at the Rocky Mountain Arsenal. I was  19 a member of about three boards there and different  20 groups.  21 There are problems. Their job is not to  22 clean up sites; their job is not public health. Their  23 job is taking care of the wildlife refuge.  24 Those sometimes come at odds. Oftentimes,  25 they stand in the way of cleanup activities. They can  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 30  1 sometimes stand in the way of biological studies, and  2 things of that nature. That aside, Rocky Flats is a very  3 dangerous site; it has been a dangerous site; it will  4 continue to be a dangerous site. In no way are the plans  5 that are occurring right now going to clean it up.  6 I can think back to days when there was a  7 lot of promotion -- public relations promotion out at the  8 Arsenal, when we knew that there was serious, dangerous  9 activities occurring out there, and there would be  10 pictures of young mothers and their young children  11 digging out there, planting trees. We knew that this was  12 not a safe site to be, because we were seriously involved  13 in the details daily on that site out there.  14 The Sierra Club, at that time, wrote to  15 all the schools in the area to stop sending their kids  16 there. I can tell you from tabling at universities, how  17 many times I was told, Yes, we spent a good many school  18 years -- two or three -- going and traveling to the Rocky  19 Mountain Arsenal and nobody ever told us it was a  20 Superfund site, nobody ever told us it was a toxic site.  21 And I can tell you the Fish & Wildlife  22 Service has told us many, many times that they would do  23 this on every tour. I heard many times -- in fact, I was  24 on tours where it was not mentioned.  25 So I can tell you that there are things at  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 odds here. For this reason, I would prefer Plan A: No  2 public -- in fact, no public involvement out there. In  3 fact, to some extent I have some reservations about some  4 of the habitat restoration.  5 If you had a -- if your family members get  6 sick, seriously sick at a time and at a point in their  7 lives that you wouldn't expect it, and you look back over  8 their lives and you wonder, What could I have done  9 differently to stop this? As I have recently had to do  10 this in my life.  11 You don't want irresponsible actions which  12 many people have claimed over the years. This has  13 plutonium, and it's all over that site. It is better to  14 be on the side of caution, rather than on haste. Thank  15 you.  16 MS. ERIKSON: Thank you, Rick. Randy  17 Olson and Lori Cox.  18 BY MR. RANDY OLSON:  19 Hi. I'm Randy Olson. I live in Arvada  20 and I'm the system state coordinator for Wheel and  21 Sportsman, which is a member of the National Wild Turkey  22 Federation. We are 300 strong in Colorado's Wheel and  23 Sportsman, and we're 6,000 members of the National Wild  24 Turkey Federation.  25 We partner with the Fish & Wildlife  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 32  1 Service on many areas nationally, and our national  2 organization of the National Wild Turkey Federation is  3 500,000 strong. And the Wheel and Sportsman is over  4 10,000 members.  5 We -- I stand here tonight in support of  6 Plan B on behalf of the state of Colorado National Wild  7 Turkey Federation and the Colorado Wheel and Sportsman.  8 We feel it's an ideal opportunity for the State to have a  9 place where disabled hunters and youth can have the  10 opportunity at some point, once the site is clean, to go  11 and participate in an activity that they can't normally  12 do.  13 We work along with the Fish & Wildlife  14 Service and the other refuges around the United States,  15 which do allow hunting and fishing opportunities. And it  16 goes on to this day and has been. And we are very proud  17 of the association that we have with the Fish & Wildlife  18 Service.  19 We thank you for that opportunity. And  20 we'd like to stay with Plan B and hope that you will open  21 up, once the site is safe and it's deemed responsible to  22 open that up, and we have the opportunity to come out and  23 work with the youth and even maybe expand the program to  24 work with the disabled and the youth out on that  25 property.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 So we support the plan and stand behind  2 you 100 percent.  3 MS. ERIKSON: Thanks, Randy. Lori Cox and  4 Hank Stovall.  5 BY MS. LORI COX:  6 Thank you. My name is Lori Cox and I  7 serve with Council Member Rhodes on the City and County  8 of Broomfield City Council. I also serve with him on the  9 Rocky Flats Coalition of Local Governments.  10 But I speak to you this evening, not so  11 much in those official capacities, as a 30-year resident  12 of Broomfield. I've lived here for a very long time and  13 have seen Rocky Flats go through a number of changes.  14 Actually, Alternative B accomplishes what  15 I had envisioned quite some time ago for the site.  16 What's perhaps most attractive to me is the combination  17 of uses. What we're doing is taking a very large piece  18 of ground and allowing a huge range of uses for that  19 ground. And as far as I'm concerned, that's the best of  20 both those worlds: Biking and hiking, equestrian. I  21 think those are all fabulous options.  22 We very much appreciate the work that  23 you've done on each alternative, but the City and County  24 of Broomfield, the city council members, were concurrent  25 in their belief that perhaps Alternative B would the best  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 34  1 multi-use option.  2 We would encourage you to sort of sift  3 through all of the political statements and the emotional  4 debate and take to heart the fact that we believe that  5 for the citizens of Broomfield, which is who we're  6 responsible for, would prefer Alternative B. And thank  7 you.  8 MS. ERIKSON: Thank you, Lori. Hank  9 Stovall and Bob Nelson.  10 BY MR. HANK STOVALL:  11 Welcome, everyone, to Broomfield. What  12 are you laughing about back there? I am a 33-year  13 resident of Broomfield. I originally got interested in  14 Rocky Flats when there was a beryllium spill in our  15 reservoir back in 1973.  16 When I was deciding what comments to make  17 here tonight, I thought about vision, balance, safety,  18 and an amenity that could serve the entire community.  19 This will be a large, 4 to 5,000 acre -- that would be an  20 acre of wildlife preserve that will be available to the  21 public, assuming that Option B passes.  22 In terms of the history of the site, as  23 some of you may know, it was originally proposed as open  24 space. If it had been open space, the cleanup level  25 would have been much lower. When it was designated as a  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 wildlife preserve and the affected person would be a  2 wildlife worker, the cleanup level was required to be  3 much tighter.  4 There's been some discussion about cleanup  5 levels and about risk and so forth. I would submit to  6 you that the majority of the buffer area that's proposed  7 for Fish & Wildlife is no more contaminated than your  8 backyard, which is at or about background, from worldwide  9 testing of nuclear weapons.  10 Local governments have worked together  11 with the congressional delegation, Senator Allard,  12 Congressman Udall, as well as Beauprez, Tancrado, and  13 DeGette. And at the time when that proposed -- a  14 wildlife reserve was proposed and the legislation was in  15 Congress, the community was in a 100 percent consensus as  16 far as I heard.  17 At the local government level --  18 particularly in the communities of Broomfield,  19 Westminster, and others -- have technical staff that  20 follow every day of the week what goes on at Rocky Flats.  21 We work collaboratively with the Governor's office, with  22 the Department of Health and the EPA and with DOE. And  23 on occasion, some consultation with the subcontractor.  24 In summary, I support Option B. It  25 provides access for the public to the site. It is a  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 36  1 balanced plan. It proposes a moderate annual cost, and  2 it also proposes a moderate number of local -- of FTEs.  3 With that said, our preference is Option  4 B. I'd like to thank Fish & Wildlife for your  5 collaboration and your outstanding process for getting  6 the public involved. This is a great crowd and a lot of  7 good input. Thank you.  8 MS. ERIKSON: Thank you, Hank. Bob Nelson  9 and Shirley Garcia.  10 BY MR. BOB NELSON:  11 Good evening. I'm Bob Nelson. I'm mayor  12 pro tem for the City of Golden, and I'm here to say I  13 think we all support Option B very much -- or Alternative  14 B, because I think the site belongs to the people, the  15 people of Colorado. And it's a beautiful place, kind of  16 barren sometimes and windy sometimes, but it has species  17 of animals and grasses and shrubs that aren't found any  18 other places readily; and it would be a beautiful place  19 just to be able to go out and walk.  20 I have visited other wildlife areas in  21 several states: California, Hawaii, Washington State,  22 Colorado, Missouri, and they're all beautiful. They're  23 all just really nice places to go walking.  24 Mr. Moore states that if you get a  25 plutonium particle inside your body, you're probably  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 going to get in trouble. This is true. But if there is  2 plutonium out there -- and there probably is some  3 plutonium still on the site -- to the best of my  4 knowledge, plutonium doesn't jump up and attack you. If  5 it's laying on the ground, it's going to be there. It's  6 a heavy element, so it's not going to be -- you know, apt  7 to be moving around a lot.  8 I am board member, as is LeRoy Moore, of a  9 group of people called the Rocky Flats Cold War Museum.  10 We are trying to establish a cold war museum at the site,  11 and we hope we will be able to work in conjunction with  12 the Wildlife Service to get this done. It will probably  13 be in buildings 60 and 61, which are the west-most  14 buildings that are not on the closure site.  15 I worked at Rocky Flats for three years  16 four years ago, and I was part of the beryllium testing  17 process, because I was exposed to beryllium. So far  18 nothing has happened, not had a problem with it. And I'm  19 not worried about it. If I do die -- I'm going to do  20 that anyhow, there's no question about that.  21 So I strongly support Alternative B and  22 think it would be just a great thing for the people of  23 Colorado. Thank you.  24 MS. ERIKSON: Thanks, Bob. Shirley Garcia  25 and Kevin Standbridge.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 38  1 BY MS. SHIRLEY GARCIA:  2 Good evening. My name is Shirley Garcia,  3 and I'm a staff member for the City and County of  4 Broomfield. I am also a resident of Westminster; I've  5 lived there for 26 years. I'm also an ex-worker of Rocky  6 Flats. I worked there from 1982 to 1997. So I can bring  7 balance, I feel, to both sides of the story tonight.  8 I'm not here to speak, basically, for  9 Broomfield at this point in time. I'm basically giving  10 you my personal opinions, plus my technical opinion,  11 because that's what I do full time. I review data on a  12 daily basis dealing with characterization out at the site  13 and closure and legacy management issues.  14 I'd like to thank the Service especially  15 tonight for working with us, especially working with the  16 City and County of Broomfield and dealing with our issues  17 and addressing our concerns. I'd like to thank you for  18 working with us towards a vision for all of the  19 communities, that we would have as a community that has  20 one vision in common for our ecological benefits, and  21 also to work with us for our vision for the City and  22 County of Broomfield, working with trails and  23 connections.  24 Our goal for the CCP is the same as yours,  25 and that's to provide an approach for conservation and  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 biological diversity at Rocky Flats. We also want to  2 have an appropriate safe use of activities at Rocky  3 Flats. In dealing with data, I can assure you that  4 there's more than sufficient data currently that I've  5 seen, and future data that they're working on that will  6 ensure your safety.  7 And, again, you have an opportunity to  8 make that decision if you want to go out to Rocky Flats  9 or not.  10 So I therefore support Alternative B with  11 some minor modifications. You will be receiving a letter  12 from the City and County of Broomfield, so you will be  13 expecting that. You know what my letters are like,  14 anyway.  15 Let me be the first to volunteer to work  16 with you -- with the Service to foster recreational,  17 educational, interpretive opportunities for the  18 communities. As far as I'm concerned, education is very  19 important to continue legacy management out there. It  20 serves as a stewardship tool to actually maintain the  21 institutional memory of what's out there as far as  22 residual contamination.  23 We also ask DOE and the RFCA parties to  24 work with us to identify the mechanism to control access  25 to DOE-controlled land, because that's a major concern of  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 40  1 mine. It's hard for us to identify activities if we're  2 not sure what the controls are and who will be actually  3 overseeing controls to ensure that public access is not  4 allowed to the industrial area.  5 But once again, I'd like to thank the  6 Service for their support and willingness to discuss and  7 address our concerns. And we ask that you continue to  8 keep us involved with the development of your stepdown  9 documents and final trail development along the northern  10 side of the Great Western Reservoir. Thank you.  11 MS. ERIKSON: Thanks, Shirley. Kevin  12 Standbridge and Lauren Lawson.  13 BY MR. KEVIN STANDBRIDGE:  14 My name is Kevin Standbridge. I'm the  15 assistant city and county manager with Broomfield, and  16 I'd like to speak as a custodian and actually owner of  17 adjacent properties to the east. The City and County of  18 Broomfield is in the midst of a planning process for an  19 open space and trails master plan. We have, after  20 careful analysis, decided that it is appropriate to put a  21 trail across the Great Western Open Space immediately  22 east of this site. That trail is intended to tie in to a  23 future trail across the Rocky Flats preserve.  24 With that, we wholeheartedly support  25 Alternative B, and just through our own actions have  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 fully demonstrated that we think it's a safe and  2 worthwhile decision. Thank you.  3 MS. ERIKSON: Thank you, Kevin. Lauren  4 Lawson and Andrew Bennett.  5 BY MS. LAUREN LAWSON:  6 Hi. My name is Lauren Lawson. I'm  7 currently a junior at the University of Colorado,  8 majoring in biology and geography. So I come to you in  9 response, actually, to build upon one of the questions  10 that was already posed: If it is a refuge, why are we  11 letting it be used for humans, because of the fact that  12 habitat fragmentation does affect the landscape and it  13 does cause disturbances in the form of trails?  14 There have been numerous studies that I've  15 read done in the last couple of years about the effect of  16 corridors on habitat fragmentation and how species do not  17 favor crossing corridors, and then that limits their  18 ability to reproduce and live healthy lives. So I do  19 support Option A for that respect. That's all.  20 MS. ERIKSON: Thanks, Lauren. Andrew  21 Bennett and Tricia Class.  22 BY MR. ANDREW BENNETT:  23 Hi. My name is Andrew Bennett, and I'm  24 from Boulder, Colorado. First of all, I'd like to thank  25 the Fish & Wildlife Service for allowing this process to  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 42  1 go on. This is a really great process. I've been to  2 some meetings where you just fill out the little card and  3 turn it in, and that's not so personal. And I really  4 thank the Fish & Wildlife Service for working this out,  5 and I think it's a more personal and publicly involving  6 process.  7 First of all, I believe that the cold war  8 museum is definitely a good idea. I feel like it's a  9 beautiful part of this transition of our nation into a  10 nonnuclear nation and more of a peaceful nation.  11 I also feel that -- that it is commendable  12 that the National Wildlife Refuge is being formed in the  13 first place as a refuge for animals and biodiversity, and  14 it's also a way to keep some of the encroaching  15 communities and trails away from the industrial area,  16 which is definitely not clean yet.  17 Moving on from that, I feel that the grass  18 burning on the refuge area is an area of some concern. I  19 feel that there is possibility and potentially some  20 contamination still in the buffer zone area. And I feel  21 that the grass burning can pose a risk to public health  22 and safety in the area surrounding the site due to the  23 large amount of smoke that's put out by grass burning,  24 and also the fact that plants definitely can take up  25 plutonium and radionuclides from the soil into their  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 tissues and distribute them to their aerial tissues.  2 I have a report and a study by the  3 Environmental Protection Agency -- and I will hand it off  4 to you guys -- that details how plutonium is taken up by  5 plants. It's not a field study; it was done in a  6 laboratory, but it was done with several different kinds  7 of soil that -- I think one of them is comparable to the  8 soil that is on the site.  9 I also feel that the Fish & Wildlife  10 Service should be completely sure that their burning is  11 under control at all times, because if that burning is  12 allowed to encroach upon the industrial area, there could  13 be a massive amount of contamination that is potentially  14 released.  15 Moving on from that, I feel like the Fish  16 & Wildlife Service and the Department of Energy should  17 really work out a very workable plan to keep people,  18 animals, and their dogs -- people and their dogs,  19 animals, from the industrial area. If this means a fence  20 with some signs, I think we need to do it, because people  21 don't know what's going on in the industrial area. If  22 they are from out-of-state and they're not familiar with  23 the area, I feel like we really need to make sure that  24 that happens.  25 So I ask Fish & Wildlife Service exactly  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 44  1 what's going to be done, because I have read in the EIS  2 that a seamless boundary is what is needed and what is  3 desired. Thank you.  4 MS. ERIKSON: Thank you, Andrew. Tricia  5 and then Kristin Pritz.  6 BY MS. TRICIA CLASS:  7 Hi. My name is Tricia Class. I'm a  8 senior at the University of Colorado, and I am very much  9 in favor of Option A. If not A, then C.  10 I would like to go for A because I have  11 been doing a lot of research and everything on the  12 situation, and I feel that we all know that there is  13 contamination in the buffer zone. The limit on  14 contamination is up to 50 picocuries per 3 feet of  15 soil --  16 UNIDENTIFIED SPEAKER: Per gram.  17 MS. CLASS: Yes. So anywhere from the top  18 level to 3 feet of soil, you can have 50 picocuries of  19 contamination within that site.  20 There have been studies done with pocket  21 gophers, and there's also prairie dogs who live on the  22 site that burrow deeper than 3 feet. Underneath 3 feet  23 to 7 feet, they're allowing 7 nanocuries, which is a  24 thousand times more than the 50 picocuries. So if you  25 have this thousand times more contamination from 3 to  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 7 feet and you have these animals burrowing deeper than  2 this, they actually bring up their soil from their  3 burrows.  4 Pocket gophers -- there's been a study  5 done by Hankinson that shows that there was -- the pocket  6 gophers displaced over 20 metric tonnes of soil per acre  7 per year. And so this means that a lot of the  8 contamination below the 3 to 7 feet -- that prairie dogs  9 that burrow deeper than 7 feet can bring up this  10 contamination.  11 And I just want to ask the Fish &  12 Wildlife, I understand that it's out of your scope for  13 the contamination, but I want to know who is liable for  14 any contamination that might happen after it's been  15 passed over to the Fish & Wildlife.  16 There's other studies been done with  17 winds, and the USGS has done studies about landslides.  18 Landslides have been known to displace soil and bring up  19 the deeper soils. And so I wanted to know just who's  20 going to be in charge of taking care of that and making  21 sure that it's safe for the humans to come on?  22 Because no matter how much contamination  23 is left, it's still going to be radioactive. Plutonium  24 has a half-life of 2,400 years. That means that  25 plutonium is there. Even though it might be a minuscule  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 46  1 amount, it's still going to be radioactive for 24,000  2 years. That is way beyond the scope of this project.  3 And I just want to know what's going to happen later on  4 with that.  5 So just to wrap up, basically, you know,  6 an ounce of prevention is worth of pound of cure. It's  7 something my father has been telling me for my entire  8 life. Just make sure that you know that this site is  9 completely safe for people. The site has not been  10 completely characterized, you don't know where all the  11 contamination is.  12 I just want to make sure that -- I mean,  13 I'm a runner. I will -- personally, I will never go out  14 on the site. Inhalation of plutonium is the most deadly  15 way of getting sick from this contamination, so I'd just  16 like people to know that.  17 MS. ERIKSON: Thanks, Tricia. Kristin  18 Pritz is the final one. Kristin?  19 BY MS. KRISTIN PRITZ:  20 Hello. I'm Kristin Pritz, director of  21 open space and trails for the City and County of  22 Broomfield. We've been working for quite a long time to  23 develop this plan with other communities and with the  24 U.S. Fish & Wildlife Service and their consultant team.  25 A lot of work has gone into figuring out  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 where appropriate locations are for trails and other  2 improvements on the site, where we need to really locate  3 these trails and so on, so that we're respecting the  4 wildlife on this site and the other ecological aspects of  5 the site.  6 So tonight's meeting, as I understand it,  7 is really to focus on the plans that are being presented  8 tonight and to discuss what plans for the wildlife refuge  9 most represents what we want.  10 And I think that Plan B, Alternative B,  11 really represents that emphasis on wildlife. That this  12 is a wildlife refuge, and that's extremely important to  13 the whole purpose of the site, and it allows for public  14 access in a manner that does not take away from that  15 important purpose. And for that reason I recommend  16 Alternative B. Thank you.  17 MS. ERIKSON: Thanks, Kristin. Okay,  18 Mike?  19 MR. HUGHES: Okay. Obviously, there's  20 time -- if anyone is now interested in having three  21 minutes to make a comment, we'd like to have you come to  22 the microphone. If you would say your name when you get  23 to the microphone, that would be great.  24 BY MS. MARCI BOURGERY:  25 My name is Marci Bourgery. I'm a resident  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 48  1 of Broomfield as well as a student at the University of  2 Colorado. I, too, am in favor of Alternative A.  3 I do not feel like we have been given the  4 honesty that we deserve, and I'm afraid that I cannot  5 trust the -- I cannot trust the fact that the area will  6 be safe. A wildlife refuge is just that, it's for  7 wildlife. It is not for humans to come and interfere  8 with what they need -- the wildlife needs to do out  9 there.  10 Again, Alternative A -- I see no harm in a  11 wildlife refuge, but I don't see where humans need to go  12 there. There's a lot of open space here in Colorado, and  13 that area has not been determined to be 100 percent safe.  14 And, again, I don't feel humans need to interfere with  15 the wildlife. Thank you.  16 MR. HUGHES: Anyone else?  17 BY MR. DOUG GRINBERGS:  18 Doug Grinbergs from Louisville. I guess  19 my feeling is that if I trusted the Department of Energy,  20 what they've done for the last several decades -- if I  21 trusted companies like DOW and EP&G and Kaiser, whatever  22 their name is, and any other corporate interests that  23 were involved in the maintenance of that facility -- if I  24 trusted all of those entities, I might think it would be  25 great for us to go out there and have an open space  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 experience, ride our bikes, go ride horses, et cetera.  2 I don't have great trust in all of these  3 people, in the legacy and the history. I think they have  4 done a lot of environmental damage, caused a lot of  5 destruction. They've hurt a lot of people, they've  6 injured people -- you know, they've hurt people, they've  7 caused health problems. And so, if I felt very safe and  8 secure about all of those people and what they've done in  9 many decades, I could support an open space experience.  10 I'm a hiker and a backpacker and a runner  11 and a bicyclist, but I don't trust the government. And  12 this is not directed towards the people in this room. I  13 don't trust the people in Washington that are taking  14 scientific data from our government scientists and  15 they're massaging it to suit their purposes.  16 I don't trust the decisions that are being  17 made. So even if people in this room feel comfortable  18 about what's happening here, I have to inject my  19 suspicions about the people in Washington, that they're  20 not as concerned about our health, our safety, our  21 well-being.  22 So I'm here to lobby for Alternative A, I  23 guess. Thank you.  24 MS. ERIKSON: Thank you.  25 BY MS. NORELL LEUNG:  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 50  1 Hi. My name is Norell Leung. I am a  2 student at CU Boulder. I would like to argue in support  3 of Alternative A. With the point of -- I heard about,  4 like, the Rocky Flats being a seamless refuge, meaning  5 that signs cautioning the general public will not be  6 used. And I wanted to refute that it just goes to show  7 that if you argue that it might create a scare, then that  8 shows that there is a reason for people to be  9 apprehensive about the use of this site. And so I  10 support Alternative A. Thank you.  11 MR. HUGHES: Ready for questions? One  12 more speaker? Okay.  13 BY MS. ELIZABETH ASNICER:  14 Hi. My name is Elizabeth Asnicer. And I  15 was looking back at the history of Rocky Flats, and I  16 remember that in 1989, the FBI raided it. And they  17 convened -- a special grand jury was convened to  18 investigate the environmental crimes.  19 And in this last March, Judge Richard  20 Matsch ruled that the grand jury was prohibited from  21 talking publicly about what they found. So we really  22 don't know what was found because there was a plea  23 bargain. And there was an $18 1/2 million fine levied  24 against, as I understand it, Rockwell -- it possibly was  25 Kaiser-Hill -- but there definitely was a plea bargain  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 there.  2 So the public never heard exactly what was  3 out there or where it was. And at the last meeting I  4 heard that there was going to be some kind of a grid, I  5 believe a certain number of little samples taken, and I  6 remember -- could you tell me what that grid was, again?  7 MR. HUGHES: I'll get the question.  8 MS. ASNICER: Yeah. Would you? Because I  9 think it was several acres. And then you have little  10 tiny places, and, you know, the wind blows out there. If  11 you've got a trail, the trail gets worn, the dust blows  12 and the prairie dogs come.  13 I've got nephews in Golden, and they --  14 they used to burn -- they incinerated stuff out there.  15 There was an incinerator. We protested that, I remember  16 that.  17 So I have great concerns, because people  18 want to make it a beautiful place. We want to forget  19 what happened out there; but the plutonium is there, and  20 we can't gauge just where. And if you go out and run out  21 there and breathe in plutonium -- well, who knows?  22 MR. HUGHES: Anyone else?  23 (No response.)  24 MR. HUGHES: Okay. Our approach to the  25 next few minutes is, I'm going to ask Dean Rundle to take  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 52  1 the microphone. He's going to say a few words before we  2 open it to questions and answers. I'd like to start with  3 the questions we have; and then, if there are more  4 questions, we can take those also.  5 MR. RUNDLE: Thank you, Mike. I guess I  6 have to use this (indicated), but that's okay.  7 First, I want to thank all of you for  8 coming out tonight to provide your thoughts and testimony  9 and input into this very important planning process here  10 we're going through. It's been very gratifying. This is  11 our fourth meeting and final public meeting. All of them  12 have been have very well attended, and we appreciate very  13 much the thoughtful input that we're getting from many  14 people.  15 I know that there are people here tonight  16 and people who are out in the community who are  17 frustrated about the scope of the planning process --  18 input to us that we should be talking more in the Draft  19 Plan and the Draft CCP about contamination and cleanup.  20 There's a very clear reason that that's  21 not appropriate and why we're not doing that, and that's  22 because the U.S. Fish & Wildlife Services is not a  23 decision-maker in the cleanup process. Rocky Flats'  24 cleanup is the responsibility of the Department of Energy  25 and with oversight by the other signatories of the Rocky  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 Flats' cleanup agreement with the Environmental  2 Protection Agency and the State of Colorado Department of  3 Public Health and Environment.  4 The Refuge Act, which establishes the  5 National Wildlife Refuge, makes very clear that cleanup  6 issues trump any refuge issues. And, I think as Mike --  7 and I'd like to emphasize what Mike Hughes said in the  8 beginning, is that we are preparing this Draft Plan and  9 proceeding with this process in the context of a site  10 that is certified by the State of Colorado and the EPA to  11 be safe for the intended future uses as a national  12 wildlife refuge.  13 We are in a different situation than we  14 typically find ourselves here, and that is because it's  15 very unusual for the Fish & Wildlife Service to be doing  16 a refuge comprehensive plan before we acquire the  17 property.  18 Typically, if we're going out to use what  19 might be called bird resource money or land/water money  20 to buy a private property for wildlife, we do a process  21 to see if there should be a refuge there. There's  22 contaminant surveys to see if there's any old dumps from  23 farms and ranches and things like that, and then we buy  24 the land, and then we get into this planning process.  25 In this case, Congress has required us to  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 54  1 complete this plan by December of 2004. We had three  2 years from the date that the law was signed. And because  3 of the way the Rocky Flats cleanup agreement is working,  4 that means that we're preparing this plan in an  5 environment where all the cleanup decisions have not yet  6 been finalized.  7 So, that said, we're planning in the  8 context that we will get to certification, that it will  9 be certified clean for the intended future uses of the  10 site. If -- and there is additional sampling that's  11 going on, and there's a question that we'll address about  12 sufficient soil sampling.  13 The Fish & Wildlife Service -- we have  14 tissue samples from 26 deer that were taken on the site  15 last year to test for chronic wasting disease. Those  16 tissue samples are going to be analyzed for radionuclide  17 contamination, and if we get data back that indicates  18 that the deer are contaminated, obviously, that may --  19 will have an impact on some of our proposals.  20 So cleanup trumps refuge. And you should  21 be glad that we're not in charge of cleanup, because  22 cleaning up sites like this is not the core business of  23 the Fish & Wildlife Service. The DOE and State and EPA  24 are much more competent and have a lot more expertise in  25 those areas.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 There are appropriate and other venues for  2 you to engage those decision-makers about cleanup. The  3 Rocky Flats Coalition of Local Governments was mentioned.  4 All of you -- I think most of you who spoke tonight are  5 residents of jurisdictions that are represented on that  6 board. I encourage you to talk to your local elected  7 officials. I can you assure that RFCLOG is very  8 effective and respected by the RFCA parties.  9 The Rocky Flats Citizens Advisory Board  10 meets the first Thursday of every month, and it would be  11 wonderful to see this many people attending those  12 meetings and learning about cleanup from DOE, EPA, and  13 the State. So there are other venues out there.  14 With that said, I'd to ask Joe Legare to  15 come up for a minute -- Joe? This isn't a DOE meeting,  16 this is a Fish & Wildlife meeting, but I know a lot of  17 you are concerned about what DOE's doing; and, Joe, if  18 you can make an announcement for them.  19 MR. LEGARE: Hi. I'm Joe Legare. I've  20 been the environmental manager for DOE of Rocky Flats for  21 the past eight years, very involved in the implementation  22 of the cleanup agreement and working with the regulators  23 and the community in the development of the cleanup  24 levels.  25 Some comments that come out -- written  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 56  1 comments, and then in this forum, and then last summer  2 when they had the initial meetings -- a lot of questions  3 about the cleanup versus the management of the refuge.  4 And Dean had mentioned some forums where we talk about  5 cleanup issues, and I would agree with Dean saying if you  6 can get out and attend those meetings.  7 At this point, however, many of those  8 meetings deal with detailed specific issues about  9 specific spots: A landfill or ground water or something.  10 And those are good, go to those.  11 But something else that occurred to us  12 that we thought would be useful to try and be responsive  13 to what's been heard in this forum and the other ones in  14 the other cities, was to have a session specifically to  15 talk about the interaction between the Fish & Wildlife  16 Service; the DOE; the contractor, Kaiser-Hill; and the  17 State Health Department; and the EPA.  18 That's going to be right across the street  19 at Broomfield City Hall on April 14th -- there will be  20 other announcements that come out from -- from six to  21 eight in the evening, and I encourage you to attend that.  22 The specific agenda and format and so on  23 to be worked out, but it's a great opportunity to talk  24 about: Was there dumping at the site? You bet there  25 was. There was quite a bit, and that's what we've been  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 working on for the past 11 years. How do you know what  2 you know? How much characterization have you done? What  3 is the site going to look like in the next couple of  4 years? When we have a certification from the EPA that  5 it's ready to transition to the refuge, in terms of:  6 What are you leaving behind the subsurface? Is the  7 surface really safe? Is this conservative, or is this  8 kind of the low-budget cleanup? And what kind of models  9 did you use? Those types of things.  10 Happy to talk about all of those things to  11 help, perhaps, increase understanding. And in some  12 cases, they'll just -- there will just be disagreement on  13 certain points, and that's okay. This meeting and ones  14 like it is evidence that you can disagree, but it's nice  15 to hear your opinions.  16 So that meeting will be April 14th, as I  17 mentioned. There are other public forums, as well, that  18 are available to talk about cleanup issues; and also  19 there's contact information. If you haven't been  20 involved in these forums and you do want to communicate  21 more with the site, we can get you that information as  22 well.  23 But I suspect if you just -- if you just  24 put in "Rocky Flats" on a search, you'll get all the --  25 you'll get the Peace Center website, our website, the  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 58  1 Coalition of Local Governments, and so on. And there  2 will be contact information in there for you. Thank you.  3 MR. RUNDLE: Thanks a lot, Joe. I  4 appreciate that, and I hope a lot of folks will come. I  5 think that will be a real helpful, good meeting for all  6 of us on April 14th.  7 Before Mike will start taking questions  8 from the audience, we recorded several that were made  9 during testimony, and I'll try and address those the best  10 I can.  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 First one: Why are no dogs in any of the  2 alternatives? We look at this -- it is a national  3 wildlife refuge. It's not a local community open space,  4 it's not a city park, it's not a national park. Wildlife  5 does come first.  6 We also -- as we talked with people in  7 local governments as we began this plan and the scope,  8 and we said, We want to complement the adjoining open  9 spaces, because one of the real qualities of Rocky Flats  10 is that although it's a relatively small site, there is  11 good connectivity to very large chunks of public land  12 through Boulder and Jeffco, Broomfield, Westminster open  13 space, all the way into the Roosevelt National Forest.  14 And all of those land units don't need to provide the  15 same thing.  16 So we looked around and -- is there access  17 for people who want to walk and walk with their dog? And  18 the answer is yes. Dogs are allowed on leash on most of  19 the Boulder open space trails. Westminster has a  20 free-run dog park just a mile east. So there's not a  21 lack of opportunity for that.  22 We looked -- leash laws are -- I think, in  23 my experience, in management of refuges all over the  24 country, is a difficult enforcement issue. Many people  25 have dogs that are well behaved and stay at heel all the  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 60  1 time. My personal experience on open space is that there  2 is a high rate of violation and a low -- compliance rate  3 on the leash law on most open spaces is maybe, I don't  4 know, 50 percent, 40 percent.  5 We have a federally listed native small  6 mammal, the Preble's meadow jumping mouse, on this site;  7 and we feel that we need to maximize protection for those  8 threatened species.  9 Dogs have a potential -- studies done on  10 Boulder open space -- to cause greater disturbance than  11 pedestrians alone or equestrians alone to some species of  12 wildlife, and it is true that some wildlife reacts more  13 to people than they do to dogs.  14 But, for all these reasons: Difficulty  15 with enforcement, the waste from dogs that some people  16 don't like on trails, the fact that dogs are allowed and  17 there's plenty of places to take your dog outside, we  18 feel that it's not an appropriate use on the National  19 Wildlife Refuge.  20 Why is the refuge -- the next issue, yeah.  21 There's a couple of questions about: What does refuge  22 mean? And it's true that if you looked in the Webster's  23 dictionary, you will find some of the words specific for  24 it: Sanctuary, things like that. However, national  25 wildlife refuges are not defined by Mr. Webster or Funk &  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 Wagnel. They are defined by the National Wildlife Refuge  2 System Improvement Act of 1997.  3 We are not a multiple-use land management  4 agency, such as perhaps the BLM, managing public domain;  5 or the U.S. Forest Service. They have organic laws in  6 Congress that say, all various uses are given equal  7 consideration. We are a primary-use land system;  8 wildlife does come first.  9 What Congress also said in that  10 statute -- they recognize that the American people pay  11 for these places. The taxpayer funds the operation and  12 maintenance of these sites. And that wildlife-dependent  13 recreation -- going way back into the second decade of  14 the refuge system in the 1920s, there have been  15 wildlife-dependent uses such as bird-watching, hunting  16 and fishing, that have become traditional uses. And  17 Congress wanted to preserve those in this system when  18 they're compatible with the wildlife purposes.  19 And the purposes are found in the statute:  20 The preservation and management of eco systems; the  21 protection of endangered species; biodiversity; and, in  22 the case of the Flats, compatible scientific research.  23 Our job is to look at the proposed uses and determine if  24 any of them will materially detract from achieving those  25 purposes.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 62  1 We believe that the uses proposed do not  2 materially detract. That's a professional judgment that  3 I make with your input. There are draft compatibility  4 determinations in the Draft Plan, and you are certainly  5 welcome to comment on those as well as the EIS and the  6 CCP.  7 It does not mean that no disturbance at  8 all can be allowed. There will be some disturbance, we  9 acknowledge that. The question that we have to answer  10 is: Is that disturbance biologically significant? Does  11 it interfere materially and significantly with important  12 ecological functions such as reproduction, migration,  13 foraging and things like that?  14 So that's the best answer I can give on  15 that.  16 Why take a risk to human health when the  17 risk is unnecessary? Kind of a cleanup question, but we  18 think that there's -- there's no recreational uses that  19 are without risk.  20 The cleanup area is designed to be  21 protective of a refuge worker, and it's a very safe and  22 effective cleanup that's being planned. NEPA -- or,  23 excuse me, the Superfund law requires cleanup to at least  24 a 10 to the minus 4, or a 1 in 10,000 risk of cancer  25 above background. The cleanup of Rocky Flats is an order  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 of magnitude better than that.  2 There have been statements about  3 widespread contamination that's dangerous across the  4 entire site. We have seen no credible scientific  5 evidence that, within the land planned to be transferred  6 to the National Wildlife Refuge, that there are dangerous  7 levels that would create an unacceptable risk. Everybody  8 has to judge -- as I've said before, everybody has to  9 judge that by themselves, what's acceptable for them.  10 But that's what the risk is out there now.  11 The final calculations aren't made -- but we're talking 1  12 in a 100,000 or 1 in 300,000 for a person like me who  13 would work there and be in contact with soil and  14 vegetation a thousand hours a year for 15 to 20 years;  15 much lower for a visitor who might walk on trails several  16 weekends a year for a few hours at a time.  17 The area that is proposed to be  18 transferred to the Fish & Wildlife Service -- the  19 characterization that's been done so far, there are --  20 levels of plutonium in surface soils are all 5 or less  21 picocuries per gram. This line (indicated) -- DOE has to  22 retain lands for management of the remedy. I'm told that  23 this line right here (indicated) is about 7 picocuries  24 per gram line. And that's in the surface soil. All  25 those heavier concentrations that were mentioned will be  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 64  1 found in the industrial area in the subsurface, with the  2 DOE.  3 Anyway, most of this that's known right  4 now is less than 1 picocurie per gram. There is  5 additional characterization going on. Although there  6 have been tens of thousands of samples taken, there are  7 some areas of the buffer zone that are not as well  8 characterized. And I think there was a question on that.  9 Mark, do you want to -- just so I don't get the numbers  10 wrong. What are we doing right now?  11 MR. SATTELBERG: What is being planned  12 right now is there's a grid system that's being overlaid  13 the entire site, 30 acres. Within those 30 acres, there  14 will be five subsamples that are composited into one  15 sample.  16 In addition to that, if there's areas of  17 concern, there is the ability to go back and do some  18 targeted sampling. If we find something out there that  19 maybe looks a little unusual, we do have that ability.  20 But, essentially, we're going to be adding to the system  21 about 115 additional soil samples in the buffer zone.  22 And that's added to probably a couple of thousand that's  23 already out there.  24 MR. RUNDLE: So I think that answered --  25 MS. ERIKSON: Are you going to separate  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 the refuge area from the --  2 MR. RUNDLE: Oh, yeah. We do use words in  3 the Draft that we would desire to have a seamless refuge.  4 And what we mean by that is a boundary between the  5 retained lands and the National Wildlife Refuge that, if  6 it's safe, and we think it will be, will not preclude the  7 movement of wildlife across the entire site, and will not  8 unnecessarily detract from the aesthetic values of the  9 site.  10 One of the qualities that Congress noted  11 in its findings were the visual viewshed values of Rocky  12 Flats. So we don't want to detract from that if it's  13 unnecessary.  14 We don't think -- that decision, again,  15 will be made as part of the final decision by the RFCA  16 parties in terms of institutional controls and long-term  17 stewardship. We'll provide input to them; I encourage  18 you to do the same thing.  19 I think that our input, at this point,  20 will be that we want that matter to be clearly and as  21 permanently marked as possible. As many people have  22 said, there will be subsurface contamination left. I'm  23 very confident that when the closure is done, all those  24 pathways will have -- you know, below 3 feet  25 contamination will be cut off. And it will not present a  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 66  1 risk to the users at the surface.  2 But we want to make sure that nobody  3 forgets where that line is and what was left there in the  4 long term. So we want it to be clearly marked, then  5 maybe some type of signs or obelisks, something that's  6 visible, both to our workers -- so that we don't have  7 somebody inherently stray into that. So that we know  8 that if there are prairie dog colonies that need to  9 expand in that direction, that they have the opportunity  10 to take some kind of management action to help protect  11 that retained area from the prairie dog invasion.  12 And people need to know that, if they do  13 decide to violate the laws and trespass where they are  14 not allowed to, that they have appropriate notice that  15 what they're doing is illegal.  16 So we do need to have that marked and  17 posted. We don't need -- there's nothing there, but we  18 don't think it's necessary to put up a barrier to  19 wildlife movement.  20 MS. ERIKSON: Liability?  21 MR. RUNDLE: Liability. One thing that  22 the communities -- I believe one reason that the  23 communities supported the Refuge Act was it requires  24 perpetual federal ownership of the site. So the U.S.  25 government is the responsible party here. The Department  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 of Energy is the responsible -- agency responsible for  2 the cleanup and the long-term maintenance and stewardship  3 of the residual contamination to ensure the long-term  4 protectiveness of the revenue.  5 If somebody comes out and goes on one of  6 our trails and trips and falls and breaks their leg, then  7 they can blame Fish & Wildlife Service for that, and  8 there is a tort process to go through. We have an  9 obligation not to create particularly hazardous  10 situations or create attractive nuisances with the  11 appropriate use of facilities.  12 There are hazards involved in wildlife  13 recreation, and, I think, some of the uses that people  14 propose; such as, equestrian use and bicycle riding. My  15 son's a mountain biker and a snow boarder, and I'm sure  16 those are more hazardous than walking into the buffer  17 zone of Rocky Flats. So the U.S. government will be  18 responsible for that.  19 MR. HUGHES: Okay. We have some time for  20 more questions if you have them. Again, we ask that you  21 not add to the three minutes you already got by making  22 your comments. If you ask a question, we'll give it to  23 Dean.  24 All the way back there?  25 QUESTION: In regards to when this plan is  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 68  1 completed, if Plan B should be the final plan, there's  2 been some comment that has been made that -- about the  3 hunting part of it. If that is not included in Plan B  4 and addressed at the time that this final incident comes  5 to fruition, would that issue be addressed -- or could it  6 be addressed without major -- a congressional act to  7 allow hunting on the refuge?  8 MR. RUNDLE: Okay.  9 QUESTION: Does that make sense?  10 MR. RUNDLE: I understand what you're  11 saying. Well, first, let me say that Alternative B is  12 the proposed course of action, the proposed alternative.  13 It has not been decided that that will be the final  14 decision. I honestly -- based on the volume and the  15 quality of the public input we have received, I would be  16 surprised if the final decision is any of those  17 alternatives exactly as presented.  18 That's the purpose for bringing the draft  19 out, and I'm confident there will be some changes. The  20 final decision belongs to the regional director of the  21 U.S. Fish & Wildlife Service. The planning team will  22 take all of your input, we will make changes that we  23 think are appropriate to make in response to what we've  24 heard, and we will recommend to the regional director a  25 recommended decision. He may ask for some changes in  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 what we recommend, but there will be a decision made.  2 Now, I believe your question is: If a  3 final decision does not include a public hunting program,  4 how hard will that be to overcome? It would not require  5 an Act of Congress. It would require the regional  6 director to amend the record of decision. And, although  7 that would be possible before the CCP expires, this is a  8 15-year plan, we are required to come back to the public  9 to review what's happened after 15 years. I think it  10 would, frankly, be unlikely that following such a large  11 process, if the decision was made not to do that, that a  12 simple request by a group of individuals to reopen the  13 ROD, I think is unlikely; it's not impossible.  14 MR. HUGHES: We've got a question in front  15 here.  16 QUESTION: Yes. I'm wondering about the  17 use of -- multiple use of trails and so forth. Many  18 people perceive that as being dirt bikes and snowmobiles  19 and ATVs -- which, I presume, this is actually  20 nonmotorized?  21 MR. RUNDLE: That is correct.  22 QUESTION: It isn't specified.  23 MR. RUNDLE: Okay. Well, perhaps we need  24 to make that clearer. I used the words "multi-use trail"  25 when we did the draft compatibility determination. And,  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 70  1 really, the internal issue might exist to allow anything  2 other than pedestrian. And the uses proposed here -- we  3 don't view the equestrian use and the bicycle access as  4 recreational bicycling or horseback riding. We're  5 viewing those as modes of transportation for people to  6 engage in wildlife-dependent things, like wildlife  7 observation, interpretation of photography.  8 Now, we're not going to arrest people and  9 write tickets if they ride their bike or jog through the  10 refuge. And we're not going to stop them and say, Did  11 you look at a bird, 'cause if you didn't look at a bird,  12 we're going to pinch you. That's not what this is about.  13 And we know that in an urban area, people  14 are going to -- if the decision is made to have access to  15 trails, that people are going to use those trails for  16 hiking, and they're not going to pay attention to the  17 wildlife.  18 But those are valid modes of  19 transportation for people to get from point A to point B,  20 to engage in photography, or to get from one interpretive  21 site to the other, to get to the place where we interpret  22 the history of the Rocky Flats plant or the Lindsay  23 Ranch. And so those are modes of transportation.  24 No off-road -- off-road motorized traffic  25 on national wildlife refuges is prohibited throughout the  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 system. I've written more tickets for people driving  2 cars and snowmobiles and stuff off-road than any other  3 thing in the hundreds of citations I've written in my  4 career.  5 So we enforce that pretty aggressively.  6 You won't see anything in here that's -- we've had  7 requests for model airplane flying. That's not  8 wildlife-dependent. It's not going to be compatible;  9 it's not in there.  10 MR. HUGHES: Question here?  11 QUESTION: I was wondering, is it the DOE  12 or the Fish & Wildlife Service that's doing the 30-acre  13 grade sampling?  14 MR. RUNDLE: Well, the DOE and its  15 contractors are doing that. And they're doing that as  16 part of the conference of risk assessment, and it is  17 regulated by the State and the EPA. We did request  18 additional sampling -- the EPA requested it, and DOE has  19 agreed to do that.  20 QUESTION: Is that five samples per grid?  21 MR. RUNDLE: Well, every 30 acres, we'll  22 grab five soil samples. We'll combine those for  23 analysis. So you've really got 500 samples, but we're  24 only going to be doing laboratory analysis on the  25 composites.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 72  1 But, if you're talking about wind-blown, I  2 mean, that's not going to be -- there's two ways for  3 stuff to get to -- one is a point source like a dump.  4 And you could miss that with this type of sampling.  5 That's why Mark said that we are going to look for other  6 anomalies. The State's already done its work there,  7 which is as far as in the way of tire tracks, fresh dirt.  8 They show up, and we'll review that again.  9 And if anybody -- I've heard a lot of  10 statements in the last couple of weeks about, I know  11 there was this happened or that happened. If anybody has  12 personal knowledge that there's something that's being  13 missed, I believe it's your obligation to come and tell  14 us. Come and point on a -- draw an excellent map, and  15 we'll go look.  16 But I think this -- I mean, I'm not a  17 physicist or a chemist sampling-design person; but the  18 folks that do do that, they've come up with a sampling  19 scheme, and our contaminants biologists concur and agree  20 that it is an appropriate way to do the sampling.  21 MR. HUGHES: Got a question all the way  22 back here.  23 QUESTION: I have two or three questions  24 and a comment.  25 MR. HUGHES: Can you please just give us  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 the questions. We gave everybody their three, so just  2 the questions, please.  3 QUESTION: Oh, just the questions. How --  4 will all the animals that will possibly be harvested  5 under the hunting provisions be tested?  6 MR. RUNDLE: You mean for radioactivity?  7 We haven't considered requiring that. We're going to  8 test the deer now. It would make sense that if they're  9 clean now, and the site's being cleaned up and the  10 sources are being removed, it would be unlikely that it  11 would change later. That's a question I might want to  12 pose to the State Health Department to see if they  13 recommend that we do that.  14 QUESTION: That was one issue. The other  15 question I had was: I was curious about how those  16 samples are going to be taken? The samples you're going  17 to be taking, I thought it was 300 samples, was it 100?  18 MR. SATTELBERG: There's about 120  19 samples -- there will be about 120 samples total, but if  20 you count the five subsamples, it's over, like, 570  21 subsamples.  22 QUESTION: What's the actual procedure?  23 Are you just taking -- are going down a certain path?  24 Are you taking the first couple of inches? Tell me how  25 you're doing that.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 74  1 MR. SATTELBERG: Basically, what  2 they're -- what the sampling plan calls for is less than  3 a square foot, no deeper than 6 feet -- 6 feet? --  4 6 inches, I'm sorry. They collect it. They collect the  5 same volume from each point, put it into a bowl, mix it  6 up, put it into the actual sampling jar to transmit to  7 the lab.  8 QUESTION: If some of those samples that  9 you retrieve violate the standards relative to the amount  10 of contamination that would be permissible, what -- how  11 would you deal with that issue? What would you do?  12 MR. SATTELBERG: Well, all the subsamples  13 are surveyed in; and so we'd go back to that grid, find  14 those five subsamples and probably sample each one  15 individually.  16 QUESTION: Okay. And then, having done  17 that, and then, say, you isolated the area in particular,  18 then what would you do?  19 MR. SATTELBERG: Go through the normal  20 process to see if there needs to be an action taken.  21 QUESTION: Would you remove the --  22 MR. RUNDLE: The surface soil cleanup is  23 50 picocuries. If they find a spot that's hotter than  24 that, the DOE's going to have to expand its cleanup and  25 they'll have a new -- a new site that they'll have to go  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 in and remediate.  2 QUESTION: So that's the standard you'd be  3 using then to evaluate --  4 MR. RUNDLE: In terms of the required  5 cleanup. But if we found -- you know, from what we know  6 right now, this is all 0 to 1 out here (indicated). If  7 we found 10 someplace, I think we'd start looking at  8 where that came from.  9 And that might affect -- we'd have to  10 consult with the health agencies if they didn't require  11 cleanup, but it was still higher than the 7 that we're  12 looking at now for the retained lands.  13 MR. HUGHES: Good. Question here. Go  14 ahead. And then one over here. Sir, go ahead.  15 QUESTION: I was just going to make a  16 statement that --  17 MR. HUGHES: Actually, we --  18 QUESTION: -- while the website is down,  19 people might be able to find a copy of some of the  20 information on Google or other websites.  21 MR. HUGHES: Please, question?  22 QUESTION: Given the DOE's and EPA's lack  23 of credibility in doing scientific things like this, has  24 anyone proposed, or has it been suggested, that an  25 independent -- truly independent scientific validation be  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 76  1 done of the processes and the methodologies for the  2 testing? Something that passes a scientific, not a  3 political, mandate?  4 MR. RUNDLE: I guess I wouldn't accept  5 that those agencies you mentioned are unreliable in terms  6 of their testing. But there -- and this is really a  7 question that we need to direct to the RFCA parties.  8 My understanding is there has been peer  9 review data -- or peer review analysis of various  10 decisions along the way. So it's not totally RFCA  11 parties in many cases. There have been other reviews.  12 The soil action -- I hope I get this right. Mark, help  13 me if I get it wrong -- the Citizens Advisory Board had a  14 significant grant. They hired an independent contractor  15 to view the original surface soil cleanup levels, and  16 that, I think, did have a significant bearing on changing  17 those levels from what was originally proposed in 1996.  18 You know -- I've -- I haven't been around  19 Rocky Flats for a long time. I've been at the Arsenal  20 four years, pretty close; and I don't see any indication  21 that the Colorado Health Department is in any way  22 inclined to cut slack to federal polluters.  23 And I put a lot of -- you know, CDPHE  24 tells me, Yeah, this is true. I mean -- and that's not  25 that I don't trust DOE and the EPA, but, I mean, you've  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 got other than federal agencies that have to sign off on  2 this.  3 QUESTION: Just the federal agencies,  4 though?  5 MR. RUNDLE: No, it's the State of  6 Colorado. The State of Colorado does not have a dog in  7 the hunt in terms of -- you know, they're not -- I don't  8 believe the State Health Department, Governor's office,  9 is going to let any fed walk away from an unhealthy site  10 for the citizens of Colorado. That's my personal  11 opinion.  12 MR. HUGHES: Good. Question up front?  13 QUESTION: Is the only place that a person  14 could bring a car and park -- would it be only the access  15 from Highway 93?  16 MR. RUNDLE: That is correct. In all  17 alternatives, the only vehicular access to the site would  18 be through the current west access gate, going north,  19 just at the corner of Section 16 and to the trailhead.  20 That orange line (indicated), that would be the only  21 vehicular access, except for parking lots along the  22 perimeter of the trailheads.  23 QUESTION: So then, would there still be  24 access for hikers, then, to come to the south side of the  25 refuge? Or would they be strictly -- after they park  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 78  1 their car, would they only be able to go on the north  2 side of the refuge?  3 MR. RUNDLE: Well, they could go south,  4 but they'd either have to make a long hike, or -- you  5 know. We were asked for loops and we were asked for  6 connectivity. So I think if you wanted to hike the south  7 side or the north side, you could park and do one of the  8 loops that's there. If you wanted to hike all the way  9 through, you'd probably have to leave a vehicle at both  10 ends.  11 MS. SHANNON: Are you asking whether you  12 can access from Arvada? Is that the question?  13 QUESTION: No. I was wondering, though,  14 how -- if you had to park, which is more on the north, I  15 don't see a connecting trail where people could then walk  16 from their cars and then hike on the south side.  17 MR. RUNDLE: Oh, I see what you're saying.  18 QUESTION: Is there a trail?  19 MR. HUGHES: There's a trail. It starts  20 right here (indicated).  21 MR. RUNDLE: Yeah. There is a proposal  22 out there for the front range trail to run from, like,  23 Pueblo up to Fort Collins, or at least the Springs to  24 Fort Collins. That's not sited there. That's a state  25 park lead. We think that's going to go someplace around  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 the 93 corridor, so we'd have a trail going out the west  2 gate area, not precisely sited right now, that would  3 connect up with that one.  4 MS. SHANNON: If it went along that  5 corridor, it may not.  6 MR. RUNDLE: It could go east too.  7 MS. SHANNON: There's been a suggestion  8 that it go east too, like, going that way (indicated).  9 MR. RUNDLE: As Laurie said, we did not  10 put a -- you know, the east side along Indiana is not the  11 most scenic or exciting part of the site. You don't get  12 that rolling topography. You're out of the tall grass.  13 No decision made yet. We think it's  14 likely there will be a transportation corridor  15 improvement, and how we're involved in that is in their  16 scoping, and what we're telling the corridor people is  17 that you need to provide a multi-modal route there if  18 you're going to have a highway or widen Indiana. You  19 need to make provisions there for bikes and equestrians  20 and pedestrians within that right-of-way as opposed to  21 giving the right-of-way up, and then taking more refuge  22 land for more trails.  23 MR. HUGHES: Question here.  24 QUESTION: When you're talking about your  25 wildlife first viewpoint, have you taken into  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 80  1 consideration that -- I mean, how have you looked at the  2 cancer latency period with animals that live on the site?  3 You're saying you have an endangered species on this  4 site. How is this endangered species being affected by  5 the contamination on the site? Have you done any studies  6 on that -- or how it might surface? I mean, these  7 animals don't live 20 to 30 years, which is the cancer  8 latency period.  9 MR. RUNDLE: Uh-huh.  10 QUESTION: So how might you, you know,  11 determine whether or not these animals are being killed  12 off just naturally by death? Or if, you know, the cancer  13 is actually having an effect on these already  14 endangered -- you know, their numbers are already  15 relatively small? How are you going to put an animal  16 that's already endangered on a site that could endanger  17 them more?  18 MR. RUNDLE: Well, they're already there.  19 And that's -- to me -- and we don't have a lot -- I don't  20 have any data on whether the Preble's meadow jumping  21 mouse, which is the threatened species out there -- we  22 don't have any sampling for those. We try not to use  23 lethal techniques to sample an endangered species.  24 But the bioassay is that these animals are  25 there -- there are actually sites within the DOE retained  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 lands in Walnut Creek and Woman Creek, that have  2 successful mouse populations. Now, I don't think that --  3 I don't know the particular biology of the species  4 extremely well, but you're talking about a  5 one-to-two-year life cycle max on a mouse. So you're  6 right. It would be unlikely that mortality would be  7 caused by cancer from plutonium.  8 We have looked -- there have been studies  9 of wildlife uptake and plants done by Colorado State  10 University in the '70s and '80s; we've looked at that.  11 We're going to look at the deer now. And, so far, we  12 have not -- of the data that's available -- had an  13 indication that radionuclide contamination is impacting  14 wildlife populations.  15 I'm not aware of any die-offs or  16 abnormalities in wildlife that are on the site. And  17 that's -- typically how we monitor on national wildlife  18 refuges is, we don't have the resources to do a lot of  19 analytical testing of soil and water and vegetation, but  20 we do get to things -- because that's one of the great  21 values of wildlife, is that they are such a great  22 indicator of the environmental health for people. If you  23 have rich and abundant wildlife -- I mean, those critters  24 out there -- I mean, they spend their whole life there,  25 not a thousand hours a year and not a couple of hours a  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 82  1 month.  2 If, you know, they're doing pretty well  3 and they're reproducing well and their populations are  4 stable within their normal fluctuations, I think that's a  5 very good indicator. In fact, for a lot of urban youth,  6 when we do education, they say, What good is wildlife? I  7 don't hunt and fish. And it's the wildlife that tells  8 you if that's a safe place for people.  9 QUESTION: Okay. So what happens when,  10 you know, maybe they're not dying off from the cancer,  11 but perhaps the contamination is creating gene mutations  12 and everything like that, throughout all their multiple  13 generations. A couple of years down the line, you might  14 see mutations and stuff like that. Who's going to be --  15 what's going to happen if that ends up --  16 MR. RUNDLE: We will continue to monitor  17 the populations and the habitat quality for the  18 endangered species. If you look in the wildlife  19 management -- parts of the CCP -- and so there will be  20 live capture. And if our biologists are finding animals  21 that are abnormal, you know, then -- that's when we start  22 asking questions and start asking for funding to look at  23 why that's happening.  24 Or if the habitat's good, you know, in  25 terms of stem density and species composition, and we get  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 a handle on the weeds and things, and we still see  2 population problems, you know, that's the kind of thing  3 where we'll go and seek funding to do more indepth  4 testing. But we kind of use that population monitoring  5 on refuges, because we are a management entity and not a  6 research entity. And that's where we go look, is when we  7 start seeing things.  8 QUESTION: At that point, would you keep  9 humans off the land?  10 MR. RUNDLE: You know, I don't know. I  11 think it would depend on what we're seeing and where --  12 and where it was. We're trying to keep people out of the  13 Preble's habitat pretty much. If you look at this trail  14 system, we're staying out of the more sensitive  15 riparian -- I mean, you mentioned in testimony the need  16 for -- to look at corridors and its effects on wildlife.  17 Alternative A, all the roads and the culverts that  18 fragment habitat could stay in. Alternative B, we're  19 pulling most of that fragmentation out and greatly  20 reducing the amount of trail fragmentation.  21 So most of the trails are not in the  22 Preble's areas.  23 But I think in Rocky Flats for a  24 considerable amount of time, we'll be pretty sensitive to  25 any changes we see and consulting with the RFCA parties.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 84  1 And I think that's -- I think these discussions that are  2 upcoming about long-term stewardship and what level of  3 monitoring will go on in the future and whether that  4 would include biomonitoring. Those are important  5 discussions and I would encourage you, if you have ideas  6 on how to incorporate biomonitoring into the long-term  7 monitoring, then we'd like to hear that; and DOE, I  8 think, would like to hear that as well.  9 MR. HUGHES: Okay. Good. Two more.  10 QUESTION: Dean, isn't it the case that  11 the sampling method that you referred to actually would  12 have the effect of diluting plutonium concentrations in  13 two ways? One is depth. If you're taking 6 inches  14 instead of the plutonium on the surface, like 3  15 centimeters or something like that. And the other way  16 that you dilute it is that you take five samples from 30  17 acres and then average them together. So if there's  18 really a higher level in there, it gets averaged away.  19 MR. RUNDLE: Clearly, there's dilution --  20 and Mark can jump in -- but I think what Mark said  21 earlier is that what we think is that there is -- what  22 the current science tells us is it's so low, that if  23 there's anything elevated, we're going to go back and  24 look, because there's probably one of the samples was a  25 hotter spot than the others. So if we see things that --  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 what's the krig -- what's the name of that map?  2 MS. SHANNON: Kriging.  3 MR. RUNDLE: Kriging map, you know, and we  4 see a -- you know, less than one, and we pull a composite  5 of that area that's a three, I figure you're going to see  6 a lot more sam -- I'm going to ask for a lot more  7 sampling in the area -- additional sampling from where  8 that was taken to find out what the maximums are.  9 I think that -- and, Mark, if I'm stepping  10 on it, let me know -- it's like, if you see those  11 elevated levels, you're going to look for more. And the  12 sampling gives us the opportunity to look at more dirt  13 this way than taking the smaller samples that are less  14 than we --  15 QUESTION: You don't really answer my  16 question --  17 MR. RUNDLE: I'm sorry. Mark, why don't  18 you try?  19 QUESTION: -- as far as it dilutes the  20 sample.  21 MR. SATTELBERG: Well, as far as the two  22 dilution factors. The first one going down to 6 inches,  23 they get as much as they can at the surface. It's Rocky  24 Flats, so there's a lot of rocks in there. And the  25 rocks, you can't analyze for it. So they have to take  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 86  1 the rocks off until they get the sample.  2 Secondly, if we were looking for a hot  3 spot, yes, we would probably be diluting the sample; but  4 we're not expecting to see the hot spots in the buffer  5 zone. We're looking for the aerial dispersion, and so we  6 think it's going to be pretty homogeneous as far as the  7 concentrations across the buffer zone.  8 And so we don't think we're going to be  9 diluting. We're actually just, basically, averaging what  10 we're seeing over that 30 acres.  11 QUESTION: I want to ask a second  12 question. It has to do with your statement that the  13 concentrations of plutonium in the buffer zone are  14 between 0 and 1 picocurie. The only map I've seen is 5  15 picocuries or less, and that's over the whole buffer  16 zone. There's a lot of difference between 5 picocuries  17 and 1 or 0.  18 MR. RUNDLE: I agree that there's a lot of  19 difference. And I think I said two things. I think once  20 I said that all the area that's proposed outside the  21 refuge transfer, that the highest levels we know of in  22 that are 5. And that's over on this side (indicated).  23 But in the northern and western buffer  24 zones, that map that I've seen shows 1 or less. So,  25 yeah, 5 out here (indicated) --  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 QUESTION: Could you get me that map? I  2 haven't seen it.  3 MR. RUNDLE: Yeah, we can get it for you.  4 MR. HUGHES: Okay. Good. One more  5 question up here, and we're out of time.  6 QUESTION: I'll phrase it as a question, I  7 think.  8 MR. HUGHES: Okay.  9 QUESTION: I think it's great that the  10 Fish & Wildlife Service recognizes the opportunity to  11 restore the area to a presettlement fire regime with the  12 noxious weed burning and prescribed burning. I also  13 noticed in the DEIS that equestrian uses will be used in  14 certain places in some of the alternatives. I'm  15 wondering if the Fish & Wildlife Service has considered  16 the introduction of noxious weed seeds from horse manure  17 in there?  18 MR. RUNDLE: Right.  19 QUESTION: And also on trails where  20 there's a higher chance that noxious weeds would plant  21 and take up residence there.  22 MR. RUNDLE: It's a real good question.  23 And what immediately comes up internally within the  24 Agency -- horses, weeds. I think a lot of studies have  25 been done that -- you know, I'm not sure that it's not a  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 88  1 red herring, because weeds can also come in vibrant soles  2 and bicycles tires and the wind. And if you look at the  3 draft compatibility determination that's in the plan for  4 allowing horse and bicycle use, you will see one of the  5 stipulations there is that we have a volunteer  6 cooperative agreement with an equestrian group that will  7 police manure up off the trails on a weekly basis.  8 So if we don't get one of the equestrian  9 groups that requested access to step up and say, Yeah,  10 we'll come in and take the manure and weed source out,  11 then we're not going to have equestrian use. We've made  12 that a stipulation in order for that use to be  13 compatible.  14 I can tell you, though, that there are  15 significant inva -- there's great natural biodiversity on  16 the site and the botanical community sod has never been  17 broken. It wasn't farmland.  18 The mining activities are almost an  19 unlimited source of weed infestation. And the  20 surrounding -- I mean, we're not alone in this. The open  21 spaces that are managed by local governments also have  22 difficulties. So the weed war is going to be really  23 important to us.  24 I don't think that with the amount of  25 disturbance caused by the -- this industrial mining over  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 here (indicated), which really creates that root hold for  2 these noxious weeds to get a foothold and spread, that  3 the recreational uses are a significant weed source.  4 We are going to really cut down on the  5 width of the -- we're going to put our trails where  6 there's gravel roads now, 90 percent of it. We'll be  7 narrowing those corridors where weeds are common now. As  8 road grading goes on that was needed for the DOE security  9 maintenance, you know, we'll reduce those disturbances.  10 So they won't be zero, but I don't think that horses or  11 hikers are going to be the primary source of weeds at  12 Rocky Flats.  13 MR. HUGHES: Okay. Do you want to hear  14 something from Joe?  15 MR. RUNDLE: Sure.  16 UNIDENTIFIED SPEAKER: He doesn't really,  17 but . . . .  18 MR. LEGARE: I just want to make sure that  19 something -- it wasn't misconstrued, and I'll get to my  20 question.  21 And it was: You were talking about an  22 additional 500 samples or so in the buffer zone in the  23 methodology, but isn't it true that that's in addition to  24 about 130,000 samples in 10,000 locations of surface  25 water, ground water, surface soil, and subsurface soil  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 90  1 that we've already taken, that have been qualified?  2 The actual total number of samples is much  3 greater than 130,000, but those are the ones where we've  4 had qualification at the EPA, and the State has seen as  5 well. And that's really the basis to date for what we  6 know about the site.  7 In addition, you were talking about these  8 other spots on these 30-acre grids, where there's no  9 suspected contamination, but where we've negotiated and  10 agreed that it was reasonable to take a look there  11 anyway.  12 MR. RUNDLE: Yes.  13 MR. HUGHES: Having stretched the ground  14 rules to the absurd, go see Joe on the 14th of April.  15 Any last questions that have to be answered, or shall we  16 say good night?  17 QUESTION: One question. Could you repeat  18 the location and the time of the meeting on April 14th.  19 MR. LEGARE: City Hall.  20 QUESTION: Oh, I'm sorry.  21 MR. LEGARE: Oh, is it up there?  22 MR. HUGHES: Broomfield City Hall, six to  23 eight, April 14th. Okay. Done?  24 MR. RUNDLE: Thank you. Thank you very  25 much.  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 
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 1 MR. HUGHES: Thank you for your comments.  2 . . . WHEREUPON, the public hearing was  3 concluded at 8:40 p.m.  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352 

 92  1 CERTIFICATE OF DEPOSITION OFFICER  2 STATE OF COLORADO )  ) Ss.  3 COUNTY OF DENVER )  4  I, CHERYL M. ROBINSON, a court reporter  5 and Notary Public within and for the State of Colorado,  commissioned to administer oaths, do hereby certify that  6 previous to the commencement of the examination, the  witness was duly sworn by me to testify the truth in  7 relation to the matters in controversy between the said  parties; that the said deposition was taken in stenotype  8 by me at the time and place aforesaid and was thereafter  reduced to typewritten form by me; and that the foregoing  9 is a true and correct transcript of my stenotype notes  thereof.  10  That I am not an attorney nor counsel nor  11 in any way connected with any attorney or counsel for any  of the parties to said action nor otherwise interested in  12 the outcome of this action.  13 My commission expires February 25, 2007.  14 IN WITNESS WHEREOF I have affixed my  signature and seal this 30th day of March, 2004.  15  16  17 _____________________________  CHERYL M. ROBINSON  18 BOVERIE JACKSON BUSBY & LA  FERA  19 1735 East 16th Avenue  Denver, Colorado 80218  20 303-329-8618  21  22  23  24  25  BOVERIE JACKSON BUSBY & LA FERA  303-329-8618 719-442-0352