Restore Moraine Park wetlands in Rocky Mountain National Park
Moraine Park Wetland Restoration - Floodplain Statement of Findings
National Park Service· Rocky Mountain National Park, Moraine ParkNPS Planning (PEPC) project page ↗
NPS PEPCWe track this on the agency’s own system of record, where most on-the-ground decisions live.
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.
This project would repair wetland and riparian habitat in a glacial valley critical for elk and native wildlife.
What’s at risk
Moraine Park's floodplain wetlands and riparian ecosystem are at stake, degraded over time and in need of active restoration to recover their natural function.
If we stay silent
The project would restore floodplain wetlands in Moraine Park, improving habitat for elk and other wildlife that depend on healthy riparian conditions.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
8 holes in the agency’s own analysis
What the public could have raised, from the agency’s own document
- I support this action and urge the agency to advance it.
- The H&H modeling driving this entire floodplain analysis is based on 30% project design, meaning 70% of the design details were unknown when the flood hazard and risk conclusions were drawn. Section 1 states the modeling 'was based on the 30% project design,' yet Section 4 (Summary) certifies that the project 'does not significantly increase risks.' A preliminary design at 30% completion cannot support a definitive risk conclusion. The agency should either rerun the H&H model at final design (100%) before approving the FSOF, or commit in writing to re-issuing this FSOF with updated modeling before any ground disturbance begins.
- The sole flood scenario modeled is 100% blockage of the Kaley Cottage Road Bridge. The document acknowledges that BDAs and PALS 'may experience partial damage, deformation, or mobilization during higher flow events' and that structures 'require periodic maintenance or replacement,' yet no partial-blockage scenario (e.g., 25%, 50%) is analyzed. Partial blockage could produce intermediate backwater effects on private properties different from the binary existing/full-blockage comparison presented. Section 3 frames this as testing 'worst case scenarios,' but a partial blockage that redirects flow laterally without full pressure relief could be worse for some receptors than full blockage. The agency should model at least one intermediate blockage scenario and disclose results for private properties and roads.
- Section 3.2 states that flow velocities on private properties 'are less than 1 cubic foot per second' in both existing and proposed conditions, but cubic feet per second is a unit of discharge, not velocity. Velocity is measured in feet per second. This unit error calls into question the accuracy of the quantitative flood risk analysis for private inholders, whose land is shown to experience up to 0.8 feet of additional inundation and 0.08 acres of additional flooded area. The agency should correct this error, confirm the actual velocity values and units for private property parcels, and restate the risk conclusions for those parcels based on accurate data.
- The Summary in Section 4 acknowledges that 'beneficial effects of the project that are predicted to ameliorate flood damage such as slowing movement of water across the landscape, increased residence time in the floodplain and increased soil infiltration are not quantified in these scenarios.' The agency uses these unquantified benefits as qualitative justification throughout the document for accepting increased flood risk to roads and private properties, yet they are never modeled or numerically validated. A floodplain statement of findings that relies on unquantified benefits to offset quantified harms does not satisfy the EO 11988 requirement for a detailed and comprehensive risk disclosure. The agency should quantify these beneficial hydraulic effects using the same H&H model before finalizing the risk-benefit conclusion.
Show all 10 points from the document
- The mitigation section (Section 4, Mitigation Measures) proposes only two measures for all identified risks: annual bridge abutment inspections for five years and scour countermeasures if scour is observed. No mitigation is proposed for the increased flood depth and velocity on Kaley Cottage Road (modeled increases of 1.1 to 2.3 ft depth and 5 to 7.3 ft/s velocity), no mitigation is proposed for the up to 0.8-foot increase in water surface elevation on private properties, and no debris management plan is offered despite the entire risk scenario being predicated on debris blockage. EO 11988 requires explanation of strategies to mitigate flood risk; two inspection items do not address three of the five identified risk categories. The agency should develop and disclose specific mitigation measures for road washout risk and private property inundation increases before approving this FSOF.
- The document states that peak park visitation 'coincides with the May through October thunderstorm-driven flood risk period,' yet Section 3.2 dismisses risk to human health and safety on Kaley Cottage Road and Bridge by noting that both are 'already inundated in the existing condition during the 0.2% annual-chance event.' This reasoning ignores the project-induced increase in inundation depth (up to 1.2 feet more) and velocity (up to 2.3 ft/s more) over the road during a period when thousands of visitors are present. The FSOF does not analyze whether the increased depth and velocity cross any established threshold for vehicle passability or pedestrian safety. The agency should evaluate the increased road inundation against recognized flood safety thresholds for vehicles and pedestrians and disclose that comparison explicitly.
- Section 2 (Justification for Use of the Floodplain) dismisses the 'natural channel design' alternative in a single sentence, characterizing it only as 'very disruptive and damaging to the sensitive habitats during and after construction' and 'much more expensive.' No cost figures, no habitat impact analysis, and no comparison of long-term flood risk between the two alternatives is provided. EO 11988 requires the agency to determine that no practicable alternative exists before acting in the floodplain; a one-sentence qualitative dismissal of the primary engineering alternative does not meet that standard. The agency should provide quantitative cost and impact data for the natural channel design alternative and explain why it is not practicable within the meaning of EO 11988.
- The document states that the ungulate exclosure fences are 'temporary, per the Elk and Vegetation Management Plan Record of Decision' and that 'fences are considered impermanent as they are planned for removal once the wetland restoration is complete and the vegetation is mature,' but no timeline for removal is given, no trigger criteria for 'vegetation maturity' are defined, and no analysis is provided of flood risk during the interim period when approximately 10,000 linear feet of new fencing is present. Section 1.3 acknowledges that 'during a flood, debris could accumulate upstream of fencing and lead to local changes in flood extent, or the fencing may get knocked down and become a flow obstruction,' yet this scenario is excluded from the modeled flood analysis in Section 3. The agency should model the fence-debris-accumulation scenario for the regulatory flood and disclose the…
- 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
Floodplain Statement of Findings
Did the agency answer?
8 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
- PendingSection 3.2 states that flow velocities on private properties 'are less than 1 cubic foot per second' in both existing and proposed conditions, but cubic feet per second is a unit of discharge, not ve
Section 3.2 states that flow velocities on private properties 'are less than 1 cubic foot per second' in both existing and proposed conditions, but cubic feet per second is a unit of discharge, not velocity. Velocity is measured in feet per second. This unit error calls into question the accuracy of the quantitative flood risk analysis for private inholders, whose land is shown to experience up to 0.8 feet of additional inundation and 0.08 acres of additional flooded area. The agency should correct this error, confirm the actual velocity values and units for private property parcels, and restate the risk conclusions for those parcels based on accurate data.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe H&H modeling driving this entire floodplain analysis is based on 30% project design, meaning 70% of the design details were unknown when the flood hazard and risk conclusions were drawn.
The H&H modeling driving this entire floodplain analysis is based on 30% project design, meaning 70% of the design details were unknown when the flood hazard and risk conclusions were drawn. Section 1 states the modeling 'was based on the 30% project design,' yet Section 4 (Summary) certifies that the project 'does not significantly increase risks.' A preliminary design at 30% completion cannot support a definitive risk conclusion. The agency should either rerun the H&H model at final design (100%) before approving the FSOF, or commit in writing to re-issuing this FSOF with updated modeling before any ground disturbance begins.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe sole flood scenario modeled is 100% blockage of the Kaley Cottage Road Bridge.
The sole flood scenario modeled is 100% blockage of the Kaley Cottage Road Bridge. The document acknowledges that BDAs and PALS 'may experience partial damage, deformation, or mobilization during higher flow events' and that structures 'require periodic maintenance or replacement,' yet no partial-blockage scenario (e.g., 25%, 50%) is analyzed. Partial blockage could produce intermediate backwater effects on private properties different from the binary existing/full-blockage comparison presented. Section 3 frames this as testing 'worst case scenarios,' but a partial blockage that redirects flow laterally without full pressure relief could be worse for some receptors than full blockage. The agency should model at least one intermediate blockage scenario and disclose results for private properties and roads.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Summary in Section 4 acknowledges that 'beneficial effects of the project that are predicted to ameliorate flood damage such as slowing movement of water across the landscape, increased residence
The Summary in Section 4 acknowledges that 'beneficial effects of the project that are predicted to ameliorate flood damage such as slowing movement of water across the landscape, increased residence time in the floodplain and increased soil infiltration are not quantified in these scenarios.' The agency uses these unquantified benefits as qualitative justification throughout the document for accepting increased flood risk to roads and private properties, yet they are never modeled or numerically validated. A floodplain statement of findings that relies on unquantified benefits to offset quantified harms does not satisfy the EO 11988 requirement for a detailed and comprehensive risk disclosure. The agency should quantify these beneficial hydraulic effects using the same H&H model before finalizing the risk-benefit conclusion.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe mitigation section (Section 4, Mitigation Measures) proposes only two measures for all identified risks: annual bridge abutment inspections for five years and scour countermeasures if scour is obs
The mitigation section (Section 4, Mitigation Measures) proposes only two measures for all identified risks: annual bridge abutment inspections for five years and scour countermeasures if scour is observed. No mitigation is proposed for the increased flood depth and velocity on Kaley Cottage Road (modeled increases of 1.1 to 2.3 ft depth and 5 to 7.3 ft/s velocity), no mitigation is proposed for the up to 0.8-foot increase in water surface elevation on private properties, and no debris management plan is offered despite the entire risk scenario being predicated on debris blockage. EO 11988 requires explanation of strategies to mitigate flood risk; two inspection items do not address three of the five identified risk categories. The agency should develop and disclose specific mitigation measures for road washout risk and private property inundation increases before approving this FSOF.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document states that peak park visitation 'coincides with the May through October thunderstorm-driven flood risk period,' yet Section 3.2 dismisses risk to human health and safety on Kaley Cottage
The document states that peak park visitation 'coincides with the May through October thunderstorm-driven flood risk period,' yet Section 3.2 dismisses risk to human health and safety on Kaley Cottage Road and Bridge by noting that both are 'already inundated in the existing condition during the 0.2% annual-chance event.' This reasoning ignores the project-induced increase in inundation depth (up to 1.2 feet more) and velocity (up to 2.3 ft/s more) over the road during a period when thousands of visitors are present. The FSOF does not analyze whether the increased depth and velocity cross any established threshold for vehicle passability or pedestrian safety. The agency should evaluate the increased road inundation against recognized flood safety thresholds for vehicles and pedestrians and disclose that comparison explicitly.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingSection 2 (Justification for Use of the Floodplain) dismisses the 'natural channel design' alternative in a single sentence, characterizing it only as 'very disruptive and damaging to the sensitive ha
Section 2 (Justification for Use of the Floodplain) dismisses the 'natural channel design' alternative in a single sentence, characterizing it only as 'very disruptive and damaging to the sensitive habitats during and after construction' and 'much more expensive.' No cost figures, no habitat impact analysis, and no comparison of long-term flood risk between the two alternatives is provided. EO 11988 requires the agency to determine that no practicable alternative exists before acting in the floodplain; a one-sentence qualitative dismissal of the primary engineering alternative does not meet that standard. The agency should provide quantitative cost and impact data for the natural channel design alternative and explain why it is not practicable within the meaning of EO 11988.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document states that the ungulate exclosure fences are 'temporary, per the Elk and Vegetation Management Plan Record of Decision' and that 'fences are considered impermanent as they are planned fo
The document states that the ungulate exclosure fences are 'temporary, per the Elk and Vegetation Management Plan Record of Decision' and that 'fences are considered impermanent as they are planned for removal once the wetland restoration is complete and the vegetation is mature,' but no timeline for removal is given, no trigger criteria for 'vegetation maturity' are defined, and no analysis is provided of flood risk during the interim period when approximately 10,000 linear feet of new fencing is present. Section 1.3 acknowledges that 'during a flood, debris could accumulate upstream of fencing and lead to local changes in flood extent, or the fencing may get knocked down and become a flow obstruction,' yet this scenario is excluded from the modeled flood analysis in Section 3. The agency should model the fence-debris-accumulation scenario for the regulatory flood and disclose the results, or explain why it was excluded.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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