Xcel Energy transmission line rebuild near Leadville nears Forest Service approval
Public Service Company of Colorado (Xcel Energy) 9254/9257 and 9255 Transmission Line Rebuild
U.S. Forest Service· Pike-San Isabel National Forest, Cimarron and Comanche National GrasslandsU.S. Forest Service project page ↗
Forest ServiceWe track this on the agency’s own system of record, where most on-the-ground decisions live.
This is not a comment period
The comment round on this one is over
What is open now is a pre-decisional objection period. Only individuals and entities that already submitted timely, specific written comments during an earlier public comment opportunity on this project may file an objection (36 CFR 218.5(a)). If you commented, this is your round. If you did not, no filing you send here will be accepted, and the honest thing for us to say is that this door is closed to you rather than to hand you a form.
An organization’s comments count for the organization only. Being a member of a group that commented does not make you eligible; you had to comment in your own name (36 CFR 218.5(c)).
Objections are due September 28, 2026. That date came off the agency’s own legal notice, which is the only source the regulation lets an objector rely on (36 CFR 218.6(c)).
The groups on this fight
4 groups work Colorado
By footprint, from the same match the STAND matchmaker runs; none is linked to this decision in our record yet. Give straight to them; nothing routes through us.
- Center for Biological Diversity
Works Colorado: led the coalition suit against the Uinta Basin Railway, whose oil trains would run the river corridors below the monument.
- Rocky Mountain Wild
Works Colorado: joined the formal challenge to the January 2026 replacement lease sale and previously sued BLM over the Roan Plateau leases.
- San Juan Citizens Alliance
Works Colorado: shaped the 2010 management plan, has fought oil and gas leasing decisions inside the monument for two decades, mobilized against the 2017 monument review, and states it continues to defend CANM..
- WildEarth Guardians
Works Colorado: named petitioner against the Uinta Basin Railway over habitat destruction in the basin.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The Forest Service is close to approving steel monopoles and wider rights-of-way on Pike-San Isabel National Forest land.
What’s at risk
Only people or organizations that submitted written comments during the earlier public participation window are eligible to object. For those who qualify, the concern is expanded right-of-way width and new administrative access routes cutting through Pike-San Isabel National Forest and Cimarron and Comanche National Grasslands near Leadville and Buena Vista.
If this goes through
Xcel Energy would receive amended special use permits authorizing steel pole structures, a wider right-of-way corridor, and new access roads on federal land, with those terms locked into long-term permit conditions.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
The agency’s case, tested
What the agency argues, and whether its own record backs it
- 6
- No support given
- 3
- Never analyzed
The Forest Service and BLM propose approving Xcel Energy's request to rebuild about 45 miles of 1950s to 1960s wood-pole 115 kilovolt lines with steel structures, widen parts of the BLM right-of-way to 150 feet, and add administrative access roads. They say the aging lines need modern materials, clearance and wildfire hardening to stay safe and reliable.
“The need for the Proposed Action is to bring the transmission lines up to modern standards for materials, meet clearance requirements, and implement wildfire mitigation plans.”
Xcel Energy’s Goals and Objectives
Each Ask below goes into your letter when you write it with PLAN on this page, matched to what you tell it about how this land reaches you.
Purpose and need
No support given
Widening the right-of-way to 150 feet is needed so double-circuit lines can be maintained without repeated outages.
The document says widening lets crews work on the roughly 3.3-mile double-circuit segment without outages, and more generally gives space for safe construction and maintenance. That reasoning fits the double-circuit segment. But the plan also widens single-circuit segments of 9254 and 9257 to 150 feet on BLM land, while the same circuits stay at 75 feet on Forest Service land and 9255 stays at 75 feet. No outage data or width standard explains the difference.
AskExplain why single-circuit segments need 150 feet on BLM land when the same circuits operate in 75 feet on Forest Service land, and provide the outage or clearance standard behind the width.
The agency’s words, the record +Hide the words
The agency says
“Adequate ROW space is needed on the double-circuits to performance maintenance activities so multiple outages are not always required.”
Xcel Energy’s Goals and Objectives
Elsewhere in the same document
“The single-circuit portions of the 9254 and 9257 would be rebuilt by expanding the existing 75-foot and 100-foot transmission line ROWs, respectively, to 150-foot transmission line ROWs on BLM lands and operating within the existing 75-foot transmission line ROWs on USFS lands.”
Xcel Energy’s Goals and Objectives
Alternatives
No support given
A wood-pole rebuild was rightly dropped because it wouldn't meet Xcel's wildfire mitigation plan or provide access.
The document says steel poles fire harden the line. But it never describes what the wildfire mitigation plan requires or compares wildfire risk from wood and steel. The access problem it cites could be fixed by adding access roads to a wood-pole rebuild, so that reason doesn't depend on pole material.
AskDescribe the wildfire mitigation plan's requirements and any risk comparison, and explain why a wood-pole rebuild with new administrative access couldn't meet the purpose and need.
The agency’s words, the record and the law +Hide the words
The agency says
“Rebuilding the transmission lines in place with wood poles would not meet Xcel’s wildfire mitigation plan requirements.”
Alternatives Considered but Not Analyzed in Detail
Elsewhere in the same document
“Using steel poles would fire harden the transmission line and contribute to a reduction in wildfire risk.”
Alternatives Considered but Not Analyzed in Detail
The law
“consistent with the provisions of this chapter, study, develop, and describe technically and economically feasible alternatives;” National Environmental Policy Act, 42 U.S.C. 4332(2)(F) ↗
Effects
No support given
Permanent wetland and stream impacts are tiny, limited to pole footings and totaling 0.22 acres.
The Water Resources and Clean Water Act sections back the 0.22 acre figure with wetland tables built from sub-meter GPS data. The 3.48 acres in the Riparian and Wetland Habitats section is a different measure: riparian habitat inside the widened right-of-way, which the document says won't get vegetation maintenance in meadow and shrub types. Still, the numbers don't line up. The document says 9255's permanent impact is 0.21 acres from 2-foot by 2-foot poles, which would take thousands of poles, while Tables 10 through 12 add to about 0.16 acres of permanent wetland impact for 9255. Table 10 also lists 0.120 miles of permanent stream impact for 9254/9257 on BLM land without explaining it.
AskReconcile the permanent wetland, stream and riparian figures in Tables 10 through 13, explain what causes 0.120 miles of permanent stream impact, and confirm the permit type still fits.
The agency’s words, the record +Hide the words
The agency says
“Permanent impacts from the Project (Transmission Lines 9254, 9257, 9255) total 0.22 acres (Tables 9, 10, and 11).”
Clean Water Act Compliance
Elsewhere in the same document
“Permanent impacts to riparian and wetland habitat includes 3.48 acres from the transmission line ROW expansion of 9254/9257 on BLM lands.”
Riparian and Wetland Habitats
“Permanent impacts for 9255 are limited to the 2-foot by 2-foot transmission line poles and total 0.21 acres (Tables 9, 10, and 11).”
Water Resources
Show 3 more claims +Show fewer
Effects
No support given
Effects on big game habitat will be minimal and temporary thanks to seasonal restrictions and reclamation.
The seasonal closures for elk, bighorn and mule deer production and winter concentration areas support lower construction disturbance. The section also says no known critical big game migration corridors would be affected and that the long-term footprint is small compared to overall habitat. But the same section says some vegetation loss would be long-term. The Land and Forest Health section calls widened right-of-way impacts permanent and patrol roads a long-term loss of soil productivity. No seasonal limit is listed for the migration corridors mapped in Table 20 (elk 3,160 acres, pronghorn 980 acres in the 9255 analysis area).
AskQuantify permanent habitat loss from widening and new roads within elk winter range and production areas, and explain why mapped migration corridors get no timing restrictions.
The agency’s words, the record and the law +Hide the words
The agency says
“Overall, impacts to vegetation and big game habitat are expected to be minimal, temporary, and mitigated effectively.”
Big Game, Elk, Mule Deer, Pronghorn, and Bighorn Sheep
Elsewhere in the same document
“Impacts to forest management are expected to be permanent and long-term within the sections of the expanded transmission line ROW.”
Land and Forest Health
“These roads represent a loss of soil productivity (future vegetation growth) in the long term.”
Land and Forest Health
The law
“Resource plans and permits, contracts, and other instruments for the use and occupancy of National Forest System lands shall be consistent with the land management plans.” National Forest Management Act, 16 U.S.C. 1604(i) ↗
Effects
No support given
The new structures fit the current visual presence of the lines and reduce visual impacts along the scenic byway.
Pole counts in Tables 3 and 4 do drop, and rust-colored monopoles are narrower. But the tables show heights rising from 50-60 feet to 70-90 feet, and on 9255 from 48-70 to 66-106 feet, which the scenery section never weighs. The Land and Forest Health section gives yet another range, and no distances back the claim that lines move farther from highways.
AskReconcile the structure heights, analyze how taller poles look from the Top of the Rockies byway and trails, and give distances for segments moved away from Highways 24 and 91.
The agency’s words, the record and the law +Hide the words
The agency says
“The rebuild structures are in keeping with the current visual presence of a transmission line across federal lands.”
Scenery/Visual Quality
Elsewhere in the same document
“Proposed structures would range in height between 60 to 80 feet tall.”
Land and Forest Health
The law
“Resource plans and permits, contracts, and other instruments for the use and occupancy of National Forest System lands shall be consistent with the land management plans.” National Forest Management Act, 16 U.S.C. 1604(i) ↗
Process
No support given
Tribal consultation was completed and found no areas of concern.
Table 7 says the April 2025 round of consultation didn't identify areas of concern. That fits the Tribal Consultation section's report that no responses have come back. But that section also says letters went out again in June 2026 and consultation is ongoing, so calling it completed overstates where things stand, and the lack of concerns rests on silence rather than tribal input.
AskCorrect Table 7, describe which tribes were contacted and any follow-up beyond letters, and hold the decision until consultation produces actual responses or documented good-faith outreach.
The agency’s words, the record +Hide the words
The agency says
“Tribal consultation completed (April 2025) did not identify areas of concern.”
Table 7
Elsewhere in the same document
“USFS mailed Tribal consultation letters to consulting parties in April 2025 and again in June 2026.”
Tribal Consultation
“At the time of this EA publication, no responses have been received.”
Tribal Consultation
What the document never analyzes
Not analyzed
Herbicide use for weed and vegetation control
The document relies on weed control under permit terms and says the lines cross wetlands and the municipal watersheds that supply Leadville, but never says whether herbicides would be used or where.
Searched all 80 pages for ‘herbicide’, ‘herbicides’, ‘pesticide’, ‘chemical treatment’. None appear.
AskDisclose whether herbicides would be used for weeds or right-of-way vegetation, which products, and what buffers would protect wetlands, streams and the Parkville Water District supply.
Not analyzed
Electric and magnetic fields near homes
The lines cross developed land that includes single family housing, and structures would be taller and partly relocated, yet the document doesn't discuss field levels near homes or trails.
Searched all 80 pages for ‘electromagnetic’, ‘magnetic field’. None appear.
AskDisclose expected electric and magnetic field levels at the right-of-way edge near homes and trails, before and after the rebuild.
Not analyzed
Condition records for the existing lines
The need rests on the lines nearing the end of their serviceable life and deteriorating, but the document offers no inspection, failure or outage data showing their current condition.
Searched all 80 pages for ‘outage history’, ‘failure rate’, ‘inspection results’, ‘pole failures’. None appear.
AskProvide inspection findings, pole failure counts and outage records for circuits 9254, 9255 and 9257 that support the stated need to rebuild.
Read from the agency’s own decision document ↗, all 80 pages. Every quote is checked word for word against it, a claim marked contradicted stands on a quote from the same document, and a second reading argued the agency’s side of every verdict before it was published. The verdicts are our reading; the quotes are the agency’s. A court can set aside agency action it finds “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” (5 U.S.C. 706(2)(A) ↗), which is why these gaps are worth putting in the record.
What to say
Make these points, in your own words
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- Tribal consultation is admittedly incomplete at the time of EA publication, yet the agency is moving toward a FONSI rather than waiting for responses. The EA states under Tribal Consultation that letters were sent in April 2025 and June 2026 and that 'no responses have been received' and 'Tribal consultation is ongoing.' The EA's brief treatment of Native American concerns in Table 7 says only that the April 2025 consultation 'did not identify areas of concern,' but that statement predates the June 2026 letters entirely. An EA cannot support a FONSI when the government-to-government consultation record is still open. The agency should suspend the decision, complete Tribal consultation, disclose any responses received, and incorporate the results into the analysis before signing any authorization.
- The botanical surveys were conducted in July 2024 only, covering a single field season and a single time of year, yet the EA identifies 27 sensitive plant species as 'may impact individuals or habitat' in Table 18 and acknowledges that 'it is possible individuals were obscured by overhanging vegetation or missed during the surveys.' Many of the listed species, including sedges, orchids, sundews, and cottongrasses, have peak detectability outside of July or require multiple-year surveys to confirm absence. The agency cannot responsibly conclude no viability loss without multi-season survey data. The agency should require at minimum one additional survey season timed to peak detectability for the most vulnerable species before issuing any authorization.
- The EA states that 3.48 acres of riparian and wetland habitat within the ROW expansion of 9254/9257 on BLM lands will be permanently impacted (Table 13), yet the Water Resources section simultaneously says the project 'qualifies for NWP-3 (Maintenance)' on the grounds that it involves 'replacement of existing transmission structures, with no changes in use.' Expanding the ROW from 100 feet to 150 feet and converting riparian acreage to permanent transmission corridor is not maintenance of an existing structure; it is new footprint. The agency has not resolved this internal contradiction. The agency should either justify the NWP-3 classification for the ROW expansion acreage or require an individual Section 404 permit with a full alternatives analysis for the permanent riparian impacts.
- The EA dismisses the 'Steel Monopole Structures within the Existing Transmission Line ROW' alternative in one paragraph by asserting it would create 'safety and reliability risk' without providing any quantitative or engineering basis for that claim. The double-circuit section involves only approximately 3.3 miles and 3,500 feet of relinquished ROW on BLM land. NEPA requires that alternatives be meaningfully evaluated, not dismissed with unsupported assertions. No study, engineering report, or operational data is cited. The agency should document and disclose the specific engineering or operational analysis that demonstrates why the existing 100-foot ROW cannot safely accommodate the double-circuit configuration, or formally analyze this alternative in detail.
Show all 11 points from the document
- Table 3 shows that pole height on the 9255 line would increase from 48-70 feet to 66-106 feet on USFS lands, and Table 4 shows the same height range on BLM lands. The upper bound of 106 feet is a 51 percent increase over the existing maximum. The Scenery/Visual Quality section describes the replacement as 'like for like' and states that weathered steel monopoles are 'less visually impactful.' That characterization is inconsistent with a potential 106-foot pole replacing a 70-foot pole. The photo simulations in Appendix C are referenced but their content is not disclosed in the EA text. The agency should disclose the specific pole heights at each structure location, explain how structures up to 106 feet are 'like for like,' and provide a viewshed analysis from the Top of the Rockies National Scenic Byway and Colorado Trail crossings.
- The EA identifies eight recorded raptor nests within 0.5 mile of the project area, including one osprey nest at only 20 feet from an access road and a bald eagle nest at 0.20 mile (Table 17). The Migratory Birds section relies entirely on pre-construction survey commitments and CPW buffer guidelines to manage impacts, but provides no analysis of whether the access road to structure 9255-90 DE can be relocated or redesigned to increase the 20-foot buffer to an osprey. The EA says that if an active raptor nest is found within 0.25 miles, coordination will occur, yet the osprey nest is already documented at 20 feet and is presumably active. The agency should analyze whether the access road to 9255-90 DE can be rerouted now, before construction begins, rather than deferring that decision to a pre-construction survey.
- The EA discloses that the project crosses the California Gulch Superfund Site at multiple pole locations on both the 9254/9257 and 9255 lines, and the Groundwater section acknowledges that 'the presence of groundwater contaminants may require the pretreatment of recovered fugitive water prior to discharge.' However, the EA provides no site-specific analysis of whether pole excavation at depths reaching groundwater at 15 to 20 feet below surface will intersect contaminated plumes, what volumes of contaminated water or soil might be generated, or what the disposal pathway is. The agency defers entirely to USEPA and CDPHE guidelines without disclosing what those guidelines require in this specific context. The agency should disclose the EPA-approved remedial action plan requirements for subsurface work at the Superfund site and analyze whether pole excavation is consistent with the site's…
- The EA adds approximately 13 miles of new permanent administrative access roads and acknowledges in the Water Resources section that 'the long term addition of approximately 13 miles of permitted roads for intermittent maintenance patrol use represents a long term increase in erosion potential.' Despite this admission, the cumulative effects analysis for water resources consists of a single sentence stating the project 'is not anticipated to have cumulative effects on aquatic resources.' No quantitative analysis of sediment loading, no comparison to existing road density in the watersheds, and no discussion of how these roads interact with the municipal watershed supplying Leadville's drinking water is provided. The agency should prepare a quantitative cumulative watershed effects analysis that addresses the 13 miles of new roads in the context of existing road density and the Parkville…
- The EA states in Table 8 that the acreage within the rebuild transmission line ROW shows 'No change from existing' for both the expanded 9254/9257 and the 9255 on USFS lands, yet the document simultaneously discloses that 17 acres of permanent impacts would occur within the existing ROW on USFS land and 10 acres of additional permanent impacts outside the existing ROW on USFS land. These figures are irreconcilable with 'no change from existing' in the vegetation impact table. If permanent ground disturbance of 27 acres is occurring on USFS land, the vegetation type acreages must change. This internal inconsistency means the EA's vegetation impact disclosure is unreliable. The agency should correct Table 8 to show actual post-project vegetation acreages within and adjacent to the rebuilt ROW on USFS lands, and reconcile those figures with the ground disturbance totals disclosed elsewhere…
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
Proposal to amend permits(FS) or issue ROW grants(BLM) to replace wood poles with steel poles, adjust ROW width, and identify access roads on electric transmission line where it crosses FS and BLM lands. The line capacity 115kV remains the same.
Did the agency answer?
9 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingThe EA identifies eight recorded raptor nests within 0.5 mile of the project area, including one osprey nest at only 20 feet from an access road and a bald eagle nest at 0.20 mile (Table 17).
The EA identifies eight recorded raptor nests within 0.5 mile of the project area, including one osprey nest at only 20 feet from an access road and a bald eagle nest at 0.20 mile (Table 17). The Migratory Birds section relies entirely on pre-construction survey commitments and CPW buffer guidelines to manage impacts, but provides no analysis of whether the access road to structure 9255-90 DE can be relocated or redesigned to increase the 20-foot buffer to an osprey. The EA says that if an active raptor nest is found within 0.25 miles, coordination will occur, yet the osprey nest is already documented at 20 feet and is presumably active. The agency should analyze whether the access road to 9255-90 DE can be rerouted now, before construction begins, rather than deferring that decision to a pre-construction survey.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingTribal consultation is admittedly incomplete at the time of EA publication, yet the agency is moving toward a FONSI rather than waiting for responses.
Tribal consultation is admittedly incomplete at the time of EA publication, yet the agency is moving toward a FONSI rather than waiting for responses. The EA states under Tribal Consultation that letters were sent in April 2025 and June 2026 and that 'no responses have been received' and 'Tribal consultation is ongoing.' The EA's brief treatment of Native American concerns in Table 7 says only that the April 2025 consultation 'did not identify areas of concern,' but that statement predates the June 2026 letters entirely. An EA cannot support a FONSI when the government-to-government consultation record is still open. The agency should suspend the decision, complete Tribal consultation, disclose any responses received, and incorporate the results into the analysis before signing any authorization.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe botanical surveys were conducted in July 2024 only, covering a single field season and a single time of year, yet the EA identifies 27 sensitive plant species as 'may impact individuals or habitat
The botanical surveys were conducted in July 2024 only, covering a single field season and a single time of year, yet the EA identifies 27 sensitive plant species as 'may impact individuals or habitat' in Table 18 and acknowledges that 'it is possible individuals were obscured by overhanging vegetation or missed during the surveys.' Many of the listed species, including sedges, orchids, sundews, and cottongrasses, have peak detectability outside of July or require multiple-year surveys to confirm absence. The agency cannot responsibly conclude no viability loss without multi-season survey data. The agency should require at minimum one additional survey season timed to peak detectability for the most vulnerable species before issuing any authorization.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states that 3.48 acres of riparian and wetland habitat within the ROW expansion of 9254/9257 on BLM lands will be permanently impacted (Table 13), yet the Water Resources section simultaneously
The EA states that 3.48 acres of riparian and wetland habitat within the ROW expansion of 9254/9257 on BLM lands will be permanently impacted (Table 13), yet the Water Resources section simultaneously says the project 'qualifies for NWP-3 (Maintenance)' on the grounds that it involves 'replacement of existing transmission structures, with no changes in use.' Expanding the ROW from 100 feet to 150 feet and converting riparian acreage to permanent transmission corridor is not maintenance of an existing structure; it is new footprint. The agency has not resolved this internal contradiction. The agency should either justify the NWP-3 classification for the ROW expansion acreage or require an individual Section 404 permit with a full alternatives analysis for the permanent riparian impacts.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA dismisses the 'Steel Monopole Structures within the Existing Transmission Line ROW' alternative in one paragraph by asserting it would create 'safety and reliability risk' without providing any
The EA dismisses the 'Steel Monopole Structures within the Existing Transmission Line ROW' alternative in one paragraph by asserting it would create 'safety and reliability risk' without providing any quantitative or engineering basis for that claim. The double-circuit section involves only approximately 3.3 miles and 3,500 feet of relinquished ROW on BLM land. NEPA requires that alternatives be meaningfully evaluated, not dismissed with unsupported assertions. No study, engineering report, or operational data is cited. The agency should document and disclose the specific engineering or operational analysis that demonstrates why the existing 100-foot ROW cannot safely accommodate the double-circuit configuration, or formally analyze this alternative in detail.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingTable 3 shows that pole height on the 9255 line would increase from 48-70 feet to 66-106 feet on USFS lands, and Table 4 shows the same height range on BLM lands.
Table 3 shows that pole height on the 9255 line would increase from 48-70 feet to 66-106 feet on USFS lands, and Table 4 shows the same height range on BLM lands. The upper bound of 106 feet is a 51 percent increase over the existing maximum. The Scenery/Visual Quality section describes the replacement as 'like for like' and states that weathered steel monopoles are 'less visually impactful.' That characterization is inconsistent with a potential 106-foot pole replacing a 70-foot pole. The photo simulations in Appendix C are referenced but their content is not disclosed in the EA text. The agency should disclose the specific pole heights at each structure location, explain how structures up to 106 feet are 'like for like,' and provide a viewshed analysis from the Top of the Rockies National Scenic Byway and Colorado Trail crossings.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA discloses that the project crosses the California Gulch Superfund Site at multiple pole locations on both the 9254/9257 and 9255 lines, and the Groundwater section acknowledges that 'the presen
The EA discloses that the project crosses the California Gulch Superfund Site at multiple pole locations on both the 9254/9257 and 9255 lines, and the Groundwater section acknowledges that 'the presence of groundwater contaminants may require the pretreatment of recovered fugitive water prior to discharge.' However, the EA provides no site-specific analysis of whether pole excavation at depths reaching groundwater at 15 to 20 feet below surface will intersect contaminated plumes, what volumes of contaminated water or soil might be generated, or what the disposal pathway is. The agency defers entirely to USEPA and CDPHE guidelines without disclosing what those guidelines require in this specific context. The agency should disclose the EPA-approved remedial action plan requirements for subsurface work at the Superfund site and analyze whether pole excavation is consistent with the site's ongoing remediation.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA adds approximately 13 miles of new permanent administrative access roads and acknowledges in the Water Resources section that 'the long term addition of approximately 13 miles of permitted road
The EA adds approximately 13 miles of new permanent administrative access roads and acknowledges in the Water Resources section that 'the long term addition of approximately 13 miles of permitted roads for intermittent maintenance patrol use represents a long term increase in erosion potential.' Despite this admission, the cumulative effects analysis for water resources consists of a single sentence stating the project 'is not anticipated to have cumulative effects on aquatic resources.' No quantitative analysis of sediment loading, no comparison to existing road density in the watersheds, and no discussion of how these roads interact with the municipal watershed supplying Leadville's drinking water is provided. The agency should prepare a quantitative cumulative watershed effects analysis that addresses the 13 miles of new roads in the context of existing road density and the Parkville Water District's source watersheds.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe EA states in Table 8 that the acreage within the rebuild transmission line ROW shows 'No change from existing' for both the expanded 9254/9257 and the 9255 on USFS lands, yet the document simultan
The EA states in Table 8 that the acreage within the rebuild transmission line ROW shows 'No change from existing' for both the expanded 9254/9257 and the 9255 on USFS lands, yet the document simultaneously discloses that 17 acres of permanent impacts would occur within the existing ROW on USFS land and 10 acres of additional permanent impacts outside the existing ROW on USFS land. These figures are irreconcilable with 'no change from existing' in the vegetation impact table. If permanent ground disturbance of 27 acres is occurring on USFS land, the vegetation type acreages must change. This internal inconsistency means the EA's vegetation impact disclosure is unreliable. The agency should correct Table 8 to show actual post-project vegetation acreages within and adjacent to the rebuilt ROW on USFS lands, and reconcile those figures with the ground disturbance totals disclosed elsewhere in the document.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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