Lor Pelegrino, Case Manager
Jefferson County Planning Department
100 Jefferson County Parkway, Suite 3550
Golden, Colorado 80419-3550

February 5, 1999

RE: Review of Asphalt Paving Rail Line Quarry Proposal (#98015173RZP1)

Dear Ms. Pelegrino,

Last fall, after receiving information about the Asphalt Paving Company quarry proposal, we contacted residents in our community to find out what concerns people had regarding the proposal. Citizens for Eldorado Canyon was formed by community members in order to represent our position that the Asphalt Paving Company quarry is incompatible with the existing recreational and residential uses in our area.

Our community was not officially notified by the applicant, even though some of us reside within a two-mile radius of the quarry site.

We are major stakeholders in any decision regarding the proposal. We request to be considered a referral party regarding the Asphalt Paving Company proposal.

Further, we invite any and all members of the Jefferson County Planning Commission and the Commissioners to visit Eldorado Springs and Eldorado Canyon State Park, on our behalf. Visits of South Draw tributary may also be arranged.

Please feel free contact me at the above telephone number if you are interested.

Thank you very much for the opportunity to present our review.
 

 Eric Johnson

Committee Members:
Margaret Blank, Neil Blank, Tom Meyer, Jo Ann Dufty, Tony Delany, Claire Delany,Hillary Griffith, Joseph Janicke,
Vija Handley, Bruce Handley, Kirk Petersen, Aileen Horrigan, Mark Hammond, Rick Johnson
 

Summary and Contents of Eldorado Springs Community Review

1. Eldorado Springs is a unique historical town in a unique setting. See Exhibit A for historical notes and photographs of Eldorado Springs and Eldorado Canyon. See Exhibit B for map showing setting of Eldorado Springs. The Asphalt Paving Company quarry would be incompatible with the residential and recreational uses in this historical area.

 
2. The history of Eldorado Springs is the story of its water. Eons ago a narrow canyon was carved by water that started at the continental divide, picked up volume and momentum as it flowed eastward through the mountains, and finally reached the plains at Eldorado Springs. Here the stream chiseled its way through sheer rock walls hundreds of feet high.

 
3. Currently over 400 people live along South Boulder Creek in and near Eldorado Canyon, from the Kneale subdivision to the west of the State Park, to the town of Eldorado Springs, to the valley that reaches east to Highway 93.

 
4. In early times, because of the protected terrain of this canyon and plentiful wildlife in surrounding areas, Eldorado Springs was winter camp for American Indians. In this century, Eldorado Springs has been a resort and recreational area for outdoor activities. Swimming, hiking, rock climbing, bicycling and horseback riding are still the main attractions for tourists and residents.

 
5. Eldorado Springs Artesian Water Company is a locally owned water bottling company that is the successor of the original Eldorado Springs Resort, that was part of the early recreational development of the town in the early twentieth century. The swimming pool is still used and is very popular with people in Boulder and neighboring communities. Water has always been very important to the people of Eldorado Springs.

 
6. Other than several home-based businesses in the town, the artesian water company in Eldorado Springs is the only commercial activity in the area. There are no heavy industry operations or developments in the canyon or along South Boulder Creek. Our way of life is more or less rural, considering the proximity of the community to Boulder, Golden and Denver.

1. Section 33-10-101 of the Colorado Revised Statutes mandates that "It is the policy of the State of Colorado that the natural, scenic, scientific, and outdoor recreation areas of the state are to be protected, preserved, enhanced, and managed for the use, benefit, and enjoyment of the people of this state and visitors of this state." The development of a quarry in the proposed location is entirely inconsistent with this important statutory mandate.

 
2. In 1978, the Colorado Legislature created Eldorado Canyon State Park in a move to protect the canyon from a proposed quarry, and another purchase 20 years later expanded its boundaries into Jefferson County by purchasing 283 acres of land adjacent to the proposed quarry site. This commitment shows that the Eldorado Springs area is of enormous value to the people of the entire state, yet the proposed quarry would irreparably alter the basic topography of the landscape forever.

 
3. Eldorado Canyon State Park is renowned nationally and internationally for the beauty of its steep rock walls, the clean, clear water of South Boulder Creek, its pure and transparent air, storied history, abundant wildlife, world-class rock climbing, and renowned panoramas. See Exhibit D for photograph of Redgarden Wall in Eldorado Canyon.

 
4. Colorado State Parks reports that as many as 250,000 visitors including 100,000 climbers use the park annually, which makes it one of Colorado's most visited parks. The park attracts many visitors including residents from Jefferson and neighboring counties, and serves as a regional and national tourist attraction because of the variety of unique outdoor recreational opportunities it offers. The quality of its water, air, natural habitat and lack of intrusive noise should be preserved for future generations.

 
5. Eldorado Canyon State Park is an internationally recognized rock climbing site comparable in many respects to such places as Yosemite National Park and Joshua Tree National Monument. See Exhibit E for national magazine coverage of quarry proposal alongside news from Yosemite National Park and Joshua Tree National Monument. The rock climbing cliffs are heavily used by climbers from Jefferson County, and other counties in the metropolitan Denver area. Eldorado Canyon is known for its "traditional" climbing routes. The use of permanent bolts is restricted in the park. Climbers must use removable protective devices that do not harm the rock. Moreover, access to certain areas of the park is seasonally restricted to protect nesting raptors. Many rock climbers who use the park are from out-of-state and even from other countries, and in many cases they make Eldorado Canyon their primary destination point--for the quality of the climbing experience and the climbing history. The development and operation of a quarry adjacent to Eldorado Canyon State Park is incompatible with the purpose of the park as a public place where people can relax and escape the turmoil of urban life.

 
6. Eldorado Canyon State Park is one of the most intensely visited parks in the entire state system. The State Park is adjacent to Jefferson County Open Space, City of Boulder and Boulder County Open Spaces and Mountain Parks that together constitute a very large expanse of recreation areas that are extensively used by residents of Jefferson County as well as residents of other counties. See Exhibit B for map showing Eldorado Canyon State Park and surrounding open spaces and parks. The well-being of communities is dependent upon the availability of high-quality recreational facilities. This quarry would damage the recreational resources of Jefferson County residents.

 
7. There is no vehicular passage through Eldorado Canyon to the continental divide. The State Park has one dead-end road going from the entrance on the east to the visitor center to the west. In the open spaces and parks surrounding the quarry site there are few roads, because land management has viewed extra roads as incompatible with historical and existing uses. Current park development plans intend to leave the existing road unpaved, in order to preserve the historical character of the canyon. Proposals for new trails in the State Parks are very carefully reviewed, in order to preserve the existing environmental values of the park land.

 
8. The land purchases of open space and parks in the area represent a public investment of millions of dollars of tax-funded money. The State Park has invested significant resources to acquire and protect a quality outdoor experience. Families coming to picnic, barbecue or wade in the water, hikers, climbers, birdwatchers and other outdoor enthusiasts, and people simply enjoying the peace and quiet of Eldorado Canyon would be heavily affected by visual and noise impacts, air-quality degradation, and other disturbances caused by quarry operations. The value of these outdoor activities would be irreparably damaged. Many thousands of yearly park visitors would be impacted by the noise and visual intrusion of a quarry.

 
9. The development and operation of a quarry at the Asphalt Paving Site is incompatible with the existing land uses in the area. Quarry impacts to the State Park and communities downstream, downwind, and downgradient cannot be adequately mitigated. We believe that the best solution would be for Colorado State Parks, in conjunction with Jefferson and Boulder Counties, to investigate the possibility of acquiring the subject property for public use.

1. The proposed quarry would be located directly in the South Draw tributary of South Boulder Creek that runs through Eldorado Springs and the State Park. The north-facing basin of South Draw tributary is a relatively undisturbed forest foothills valley with high wildlife habitat value, located west of State Park land. Other than a single traversing rail line, South Draw has remained undisturbed for decades. Common sense should dictate that you don't put a quarry upstream in the watershed of a highly-visited State Park that is well-known for the beauty of its panoramas, clean air and water, and tranquility. See Exhibit C for panoramic photograph of South Draw.

 
2. The mine would radically change the topography of the land surface forever, thereby disrupting patterns of flow and sediment discharge that have existed over many hundreds and thousands of years. The new landscape would thus potentially affect residents below the mine long after the mine closes.

 
3. Asphalt Paving Company needs to consider the possible impacts on the numerous shallow residential wells in the watershed, the Eldorado Springs Artesian Water Company, and the cities of Louisville and Lafayette water shares on South Boulder Creek downstream from the quarry site. Possible impacts of increased sedimentation and water contamination on these water sources need to be carefully studied before any rezoning decision can be made.

 
4. The proposal references several quarries in Jefferson County as evidence for their claim that quarries have no impact on open space and property values (Morrison Quarry, Heidelberg Quarry, Ralston Dike Quarry,) but none of these quarries are, in fact, located in watershed sources of the communities. The people of Eldorado Springs have no assurance that the quarry would not have long term impacts on their water supply and the integrity of the riparian zones in the waterway.

 
5. The 168-acre quarry and processing facility would be situated within the upper South Draw watershed directly in the existing surface-water drainage. The South Draw creek and tributaries would flow directly though the 168 acre quarry area before continuing through the adjacent newly acquired land of Eldorado Canyon State Park and finally emptying into South Boulder Creek. South Draw is regarded as one of the most intact riparian areas in the Front Range. Any change caused by the intensive quarry operations would cause severe impacts to the South Draw riparian system within the State Park and to riparian zones east of the canyon.

 
6. While the proposal includes mitigation measures touted to maintain natural historical flows and sedimentation rates, such as sediment ponds, water recycling, erosion control in channels (rip-rap), and a possible "wetlands waterway," we have only the applicant's assurances that these features would work.

 
7. Quarry impacts include significant increases in sediment (mass particulate) transfer to downstream riparian areas. Sedimentation increases are expected from the removal of topsoil, routine large-scale excavation and other earth-moving activities inherent to a quarry operation, in particular during flood events common to our area. By stripping the natural cover, the quarry could accentuate the effects of flooding. Moreover, with 75 acres of hillside exposed and the blasting and crushing of up to 1.5 million tons of rock per year, even under "normal" conditions of quarry operation, there is no assurance that the pond system would not fail. Unless the ponds are managed perfectly, too much sediment accumulation in the ponds could result in discharge of less than historical amounts of sediment discharge, leading to stream bed degradation by scouring. Sediment pond capacity would diminish significantly as the sediments fill in. One major flood event could irreparably damage downstream habitats and our community. The sedimentation ponds would, by design, act to interrupt the natural stream flow in South Draw. They can be expected to have a severe dampening effect, cutting off critical water flow to downstream riparian plants and animals especially during periods of low precipitation and drought. Disruption and alteration of natural flow rates and natural fluctuations in flow would significantly impact the biodiversity of the riparian system. Water flows must be maintained at their historical levels.

 
8. Introduction of contaminants affecting water quality: Fuel oil and other chemicals such as residues from explosives used for blasting, foams and other anti-dust compounds, phosphorous compounds and other chemicals used in reclamation, may eventually be introduced into the environment. Introduction of these materials into the watershed by spillage and accidental releases would irreparably damage the essentially pristine riparian South Draw ecosystem as well as South Boulder Creek.

 
9. Quarry operations plan to use 20,000 gallons of water per day for dust suppression (Supporting Documentation No. 1, B, p.11). Runoff and infiltration from such uses would contain chemical residues that would eventually pass downstream and affect local surface wells used by the people in South Boulder Creek and Eldorado Springs, unique for the quality of its water.

 
10. Excavation could possibly release natural heavy metals or radioactive compounds, an impact not adequately addressed by the applicant. Although the Asphalt Paving Company study refers to core samples taken in the 1980s that show normal radiation levels, there is no way to guarantee that quarry operations would not uncover unexpected mineral deposits with dangerous potential, given the existence of uranium and other metal deposits in the area. Moreover, the exposure of subsurface material to air and water could create harmful compounds that would eventually work their way into the waterway. There are risks that heavy metals and/or radioactive contaminants could be uncovered in the 60-year life of the quarry.

 
11. The 1980 core-drilling map shows the location of the site, Boulder, Golden, Wondervu, and Coal Creek, and the railroad track, but fails to show the State Park or Eldorado Springs (Supporting Documentation C, No. 1, p. 3). This omission is indicative of the lack of consideration given by the applicant to Eldorado Springs and the State Park in the proposal.

 
12. Maps used by the Asphalt Paving Company hydrologists fail to indicate the existence of Eldorado Canyon State Park, Eldorado Springs, or Kneale Subdivision (Supporting Documentation K, No. 2, figures 1, 6 and 10). Moreover, these maps erroneously show Highway 170 going through Eldorado Canyon.

 
13. Possible water-quality problems and damage to riparian zones in South Draw and South Boulder Creek areas downstream from the quarry have been inadequately addressed by the applicant. These impacts would be great and long-lasting to the environmental values of the State Park and the community values of Eldorado Springs, and further demonstrate the complete incompatibility of the proposed quarry.

1. At present, the Eldorado Springs Community and the State Park enjoy an abundant supply of clean, fresh air that generally flows from west to east through the canyon off the mountains. Often, when there is air pollution out on the plains, the air in Eldorado Canyon is clean and clear. If a quarry is developed along the southwestern rim of the canyon, upwind from the State Park and our community, there would be increased levels of emissions and visible particulate matter, as well as "smog" possibilities that are currently unknown. The air-quality problems caused by quarry development and operation could lead to an increased risk of respiratory and health problems for long-term Eldorado Springs residents and State Park employees. The potential for long-term air-quality impacts further demonstrates the incompatibility of a quarry in the South Draw.

 
2. Jefferson County is classified by the State of Colorado and the EPA as "non-attainment" for small particulate matter (PM10), which means that "concentrations of PM10 may exceed state and federal ambient air-quality standards" (Supporting Document No. 1, H, 2.0). County-wide air pollution originating primarily from urban sources (automobile exhaust and fugitive dust, industrial particulate emissions, etc.) is well known along the Front Range as the "brown cloud." On certain days even the fresh mountain air cannot push back the pollution that emanates from the urban corridor along the Front Range. The Asphalt Paving proposal quarry would be another source of pollution adding to the brown cloud and adversely affect a heretofore pristine area.

 
3. The Asphalt Paving Company refers to a "quantitative estimate" of PM10 dust based on methods and EPA "emission factors" stating that only 33 tons of PM10 would be emitted, which they compare to the yearly wind erosion from 130 acres of agricultural land, or to the dust raised along a five mile stretch of unpaved road with 32 passenger cars per day moving at 25 miles per hour (Supporting Document No. 1, H, 4.0). This seems like a lot of dust to add to our air, given how clean it is now. Moreover, because the report contains no explanation of how the estimate was made, all we have is the applicant's assurance that the quarry dust will not be significantly greater..

 
4. The Asphalt Paving Study does not consider the effects of temperature inversion in an environment where dust and emissions would drift down hill and into the canyon. We anticipate that certain meteorological conditions (temperature inversions, lack of wind) would contribute to smog-like conditions with the dust and emissions created by explosions, aggregate crushing and pouring, vehicular movement on quarry access roads, other motorized machinery (generators, air compressors), scooping and scraping of rocks, loading of railcars and other quarry operations drifting into the canyon.

 
5. This supporting document concludes by stating "the quarry will cause no discernable degradation of air-quality for Jefferson County residents" (Supporting Documentation No. 1, H, 6.0). Once again, the Asphalt Paving Company and their consultants ignore the possible impacts on the people of Eldorado Springs and the State Park.

 
6. The 1982 "Air Quality Impact Analysis" misleadingly states that "[T]he valley where the site is located contains no homes" (Supporting Documentation 1, H, "Air Quality Impact Analysis," Introduction). Although the 1982 study was conducted 17 years ago, there were then and still are homes in Eldorado Canyon and along South Boulder Creek, i.e. down valley.

 
7. The use of water as a dust suppressant would not be adequate to eliminate the dust produced in such an expansive disturbed area. The area is known for extended periods of hot, dry, and windy weather, and dust suppression by water is only temporary and local. Effective use of water for dust suppression would sometimes have to be 24 hours per day during windy times from October through May. When water evaporates, the dust particles would simply accumulate on the quarry floor or in the holding ponds, and may later be carried downwind or downstream. The increased particulate dust would impact the quality of the air for the people in Eldorado Springs.

 
8. The proposal cites no studies that demonstrate that air-quality downwind and down-valley from the quarry would not be impacted. We support comprehensive air-quality studies of possible impacts to canyon air by unbiased consultants to demonstrate that quarry development and operation would not cause health hazards, damage the visual qualities of our air, or damage the other natural resources in our area.

1. The proposed Asphalt Paving quarry is also incompatible and inconsistent with the land use of the surrounding area due to severe and long-term impacts from noise. Although Asphalt Paving has described some noise mitigation measures in the proposal, these efforts would not prevent severe annoyance and long-term impacts from increases in ambient noise levels to nearby residents, to visitors in Eldorado Canyon State Park and to users of neighboring open space areas.

 
2. Noise can be expected from all aspects of quarry operation: drilling, blasting, extraction, rock crushing, earth moving, loading and transfer operations, increased train traffic (affecting the full length of the rail corridor), and truck traffic.

 
3. Because the quarry site is located in the upper "bowl" near the head of the South Draw drainage, areas in Eldorado Canyon would be especially impacted through echo effects and possible noise amplification. The proposed site adjacent to the steep canyon walls can be expected to act as an amphitheater providing the residents west of the main State Park area a direct auditory "experience" of quarry activities. See Exhibit C for photograph of north-facing South Draw bowl. See Exhibit D for photographs of south-facing Eldorado Canyon walls. Elevated noise levels from operation of the quarry are predictable throughout the community of Eldorado Springs and the State Park.

 
4. Noise transfer would also be enhanced through "skip effects" occurring during temperature inversions, which allow noises to reach areas otherwise dampened by intervening topography. In its formal comments to Jefferson County, the Boulder County Land Use Department concluded that the impacts on ambient noise levels would be felt most severely by residents in Boulder County and visitors to the Park and open spaces.

 
5. Asphalt Paving admits to significant noise impacts and annoyance for the Crescent Park area, and they propose mitigation measures. While the Company promises use of "noise reduction kits" to be installed on equipment and placement of "sound shields" around heavy drilling machinery, these minimal measures cannot reasonably be expected to prevent a 60-year imposition of incompatible noise impacts in the area.

 
6. Park users' enjoyment in the State Park would be seriously detracted by the impacts of noise produced by quarry development and operations. Rock climbers would be particularly impacted by the echo effect along canyon walls, given that their sport requires extreme mental concentration. The intrusion of sudden bursts of noise would create dangerous disturbances for climbers.

 
7. Eldorado Canyon State Park has submitted comments to the Jefferson County Planning Commission emphasizing their concern for ANY NOISE affecting people's experience of the Park. It is difficult to quantify the possible degradation of the high quality experience offered by this State Park that a quarry would cause. Readers should imagine hiking the trails where the natural background sounds of birds, waterfalls, and wind whispering through the pines have been replaced by the ceaseless, annoying din of daily drilling, blasting, rock crushing, earth-moving machinery and rail cars.

 
8. Asphalt Paving Company needs to clarify what kind of activities constitute "maintenance and repair" that would be permitted 24 hours per day. Any noise levels in the early morning or during nighttime hours is an unacceptable intrusion on nearby residents' privacy.

 
9. No noise study has been performed by the applicant. A noise study paid for by Crescent Park and Plainview residents (results in the Public Record) showed noise levels 2-6 times higher than those predicted in the rezoning application submitted to Jefferson County by Asphalt Paving.

 
10. The Asphalt Paving Company offers no analysis of the acoustic effects of deep canyon walls. See Exhibit D for photograph of south-facing Redgarden Wall in Eldorado Canyon. The State Park would become an echo chamber for quarry operations. Quarry noise levels and canyon acoustic effects must be understood before an evaluation of noise impacts on Eldorado Springs and the State Park can be assessed.

1. We reject the conclusions of the Asphalt Paving Company that the potential visual impacts of the quarry are not significant (Supporting Documentation No. 3, V, p.8). Their justification that "[T]he quarry area is not part of a pristine visual landscape; existing visual impacts include three miles of rail line, a 20+ acre scar on Eldorado mountain from rail line maintenance, a communication tower on the summit of Eldorado Mountain, and numerous road cuts of Scar Top Mountain" demonstrates precisely the kind of incompatibility that their quarry would bring to our area. A quarry would be far more devastating to the panorama than anything they list. The "20+ acre scar on Eldorado Mountain" is the rail line that has been there for decades. See Exhibit C for panoramic photograph of South Draw tributary.

 
2. Panoramas north of the quarry site would be subjected to high visual intrusion from the scar of the quarry, especially for climbers looking south from the cliffs in the northwest corner of the State Park and hikers in Boulder Open Space and Mountain Parks west and north of the quarry site. This is very clearly shown in the viewshed maps presented by the Crescent Park Homeowners Association. These climbs in the western corner of State Park are highly appreciated because of the esthetic value of the panorama they provide. The visual impacts of the proposed quarry would affect thousands of climbers yearly for many years beyond the Asphalt Paving Company's operation.

 
3. Quarry lights at night would be visible for miles in all directions, and this is an undesirable impact that further illustrates the incompatibility of the described land uses being considered in the rezoning. Drivers along the Front Range, particularly in Boulder County, may also be able to see the lights. It is entirely inappropriate for the mountain backdrop in this area to be subjected to light pollution of this nature.

 
4. Suspended particles of quarry dust and emissions in the canyon would produce an hazy filter across the valley and further detract from the enjoyment of park visitors and Eldorado Springs residents. This is another consequence of degraded air quality that the quarry can be expected to cause.

 
5. We strongly agree with, and incorporate by reference, the comments and conclusion of the visual impact studies of the Crescent Park Homeowners Association. See Exhibit B for map showing quarry visibility areas. In conclusion, the visual impacts of the quarry on the State Park, Walker Ranch Open Space, and pre-existing residential properties would be dramatic.

1. Statements by Asphalt Paving Company and the Colorado Division of Wildlife point out the diversity of wildlife species found in the area. The site is adjacent to thousands of acres of public open space and parks as noted above. There are numerous environmentally sensitive areas in the South Draw quarry site and surrounding areas. The relative isolation and lack of roads in the area, the current zoning, and existing uses of the land all suggest that a quarry should be prohibited.

 
2. Asphalt Paving Company admits that the development of the quarry would result in direct habitat loss, displacement of resident wildlife, direct mortality of the smaller, less mobile wildlife species, and fragmentation of remaining (undeveloped) corridors. These quarry impacts on wildlife would be felt in land adjacent to and near the site, both in Jefferson County and across the county line--wildlife know no jurisdictional boundaries.

 
3. The 1998 Asphalt Paving Company proposal would have more validity if their wildlife study had been conducted in the spring or summer rather than in the winter (March 2), given the snow cover and the fact that it is not the usual winter range of many mammals and many bird species are still in migration. There might have been evidence of even more wildlife than was actually reported on the one winter day that the study was conducted.

 
4. Increased presence of black bears and mountain lions since the 1983 quarry proposal can be associated with increases in the amount of publicly-purchased open space and parks in the surrounding area in the last 16 years.

 
5. The Asphalt Paving Company does not mention elk as a species in the proposal site, yet the Wildlife Division emphasizes that elk are present in the area. Though elk are seldom seen in the foothills, they are known to wander into Eldorado Springs, and destruction of elk habitat would make them even more rare in the future.

 
6. The proposal contains very little reference to aquatic life in South Boulder Creek, yet trout are reported in the South Draw tributary. Trout fishing is a common recreational activity in the State Park and in Eldorado Springs. Any judgement on the compatibility of a quarry in South Draw should consider the potential impacts to aquatic life in South Draw and in South Boulder Creek, which could be enormous.

 
7. Disappearance of wildlife, including raptors and other birds, due to noise and dust disturbance and habitat destruction in South Draw would affect the State Park as well as the Eldorado Springs community. If a quarry is allowed to be developed, we can expect to see fewer falcons, eagles, accipiters and other raptors that are now observed regularly. Noise, air, and water disturbances can be expected to force these raptors to relocate to areas that are less disturbed.

 
8. Fragmentation of corridors for seasonal movement of large mammals would impact and even prevent movement of such species as black bear, elk, and deer to non-contiguous open spaces, and may affect wildlife diversity in areas such as Asel Property, Eldorado Mountain, Walker Ranch, Eldorado Canyon State Park, and Boulder Mountain Parks.

 
9. It is precisely because of the environmentally sensitive characteristics and the high wildlife habitat value that the adjacent Eldorado Canyon State Park lands and Eldorado Mountain and Walker Ranch Open Space lands were acquired in the area near the Asphalt Paving Company site.

 
10. Viewing wildlife is highly valued by State Park users and the people who come to Eldorado Springs. Quarry impact to wildlife would result in an erosion of wildlife viewing opportunities. This impact would affect hikers, bird and animal watchers, climbers, wildlife photographers and mountain bikers, many of whom reside in Jefferson County and use the State Park land and other public properties surrounding the quarry site. Wildlife viewing and recreational enjoyment in designated conservation easements adjacent to the quarry site would be a seriously compromised substitute. The proposal site should be left unchanged and undamaged, and it will thus have far greater value to Jefferson County in the future.

 
11. The Asphalt Paving Company's plans for phased reclamation fail to demonstrate the effectiveness of converting quarry steps into wildlife habitat during the operational life-span of the mine. Reclamation cannot restore the mined landscape to resemble the natural habitat and topography that existed prior to mining. Reclaimed quarry land is an unacceptable substitute for essentially undisturbed pre-existing wildlife habitat.

 
12. The Asphalt Paving Company's proposed mitigation measures cannot significantly alleviate fundamental impacts caused by the presence of a quarry in this site that is surrounded by thousands of acres of open spaces and parks. A quarry is inappropriate for this part of the Front Range. The mine applicant is still far from demonstrating the compatibility of its intended use with the historical and existing uses of the land.

1. The investment value of homes and property in Eldorado Springs would be impacted by quarry development, because the quarry would make it less desirable to live in our community.

 
2. The existing land uses in the area have been established by years of consistently-applied Jefferson County and Boulder County zoning regulations. When area homeowners bought their houses, they did so with the belief that zoning ordinances reflecting existing use would protect them from the undesirable impacts of industrial and commercial development, and the current zoning was viewed as part of the value of the homes in the community.

 
3. People who live near the State Park, including the people in Eldorado Springs, South Boulder Creek, and the Kneale subdivision have chosen to live there because of the environmental values of the park and the zoning of surrounding areas. Zoning laws in Boulder County near the State Park are strictly enforced in order to maintain the existing historical character of the area.

 
4. The Asphalt Paving Company's evidence that property values near quarries are unaffected is unconvincing and hastily gathered. An unbiased study would try to model the extent to which property values increase in the absence of a quarry, and not simply explain away growth effects as absence of negative impacts. A rigorous study would analyze market impacts on a "before-and-after" basis. Yet, Asphalt Mining Company’s approach does not even look at pre-mine data. It focuses solely on what has happened after the mine’s inception--without even a glance to pre-mine market values. The fact that houses have been built or that market value may have risen since the inception of the mine misses the point. The central issue should be the impact that the quarry would have at its inception. Population growth along the Front Range is unrelenting and the factors that influence people to purchase homes depend to a large degree on local housing markets.

 
5. In this case, Asphalt Paving Company purchased the subject property knowing that such property was zoned Agricultural-1 with no reasonable expectation that such zoning would be changed. In contrast, nearby residents purchased their properties in reliance on existing zoning designations with reasonable investment-backed expectations that such zoning would remain unchanged. Clearly the equities lie with the existing residential homeowners.