(UNIVERSITY AFFILIATION FOR IDENTIFICATION PURPOSES ONLY)
DEPARTMENT OF BIOLOGY
COLLEGE OF SCIENCES
SAN DIEGO STATE UNIVERSITY
SAN DIEGO CA 92182-4614
Topic: Proposed Christo installation, Arkansas River
Ms. Sally Wisely BLM Director for Colorado 2850 Youngfield Street Lakewood, CO 80215-7093
Dear Ms. Wisely:
I am writing this letter wearing two hats. I am a full-time resident of Chaffee
County living near Hwy 285 about 10 miles north of Salida. I also hold a research
appointment in San Diego State University's Department of Biology, as indicated
by the letterhead.
First my research credentials. Although I am not an expert on the particular geographical areas at risk, I am fully qualified to assess the general nature of the potential for adverse, unmitigable impacts to the environment.
I am a plant ecologist (BA history Northwestern University, MA botany San Diego State University and PhD plant ecology UC Davis) who specializes in native plants and vegetation. I am also a wetlands biologist and served for 4 years on the City of San Diego's Wetlands Advisory Board. I am actively doing research and publishing. My career encompasses both pure and applied research. I have served on two endangered species recovery teams, and I was the lead author of the recovery plan for southern California's vernal pools. I have written the definitive report on the impacts of OHV vehicles to desert landscapes and the potential for restoration of desert lands damaged by vehicles. I wrote the vernal pool management plan for a 22 thousand-acre military installation. In addition, I have written, implemented and monitored numerous restoration plans. Finally, I have spent over thirty years reviewing EIR's (California Environmental Quality Act) and EIS's (National Environmental Policy Act) as well as forest plans, habitat conservation plans and other public environmental documents.
The proposed Christo project on the Arkansas River requires a full EIS, per NEPA regulations. The proposed project has a potential for significant environmental impact and a public controversy over the potential risks, adverse impacts and benefits of the project is abundantly evident. As stated in NEPA, an EIS will be prepared for a proposed action that "significantly affects the quality of the human environment," or is "highly controversial with respect to the environmental effects," in other words when a substantial dispute exists as to the size, nature or effect of the federal action.
Following are items which need to be considered when evaluating the necessity of a DEIS and which clearly apply to this proposed project. Furthermore, "EIS's shall serve as a means of assessing the environmental impacts of proposed...actions, rather than justifying decisions already made (OPNAVINST 5090.1).
The geographical extent of the action is extensive. The extent of both the direct and indirect impacts must be considered. Due to the topography of the area and the limited access to the canyon itself--as well as adjacent communities and counties in the mountains to the west--the geographical extent of the project's direct and indirect impacts could be hundreds of square miles. The project's potential impact covers diverse habitats, including waters of the US, riparian habitat, rocky slopes, forested land, seeps, springs and ephemeral wetlands, and both grass and shrublands.
The proposed project will be carried out over time and involve sequential steps and phases which will compound the adverse environmental effects and increase the environment's and the community's exposure to various risks and hazards.
The long term growth inducement of the project is reasonably foreseeable. The growth would take place in areas where water supplies may be in question, infrastructure is limited, public transportation is unavailable, roads have limited capacity for increased traffic and the economy depends on outdoor recreational activities such as hunting, hiking, rafting, fishing and birding which are incompatible with urban-type development. Socio-economic impacts of inappropriate and excessive growth must be considered as well.
Risk potential must be considered. For example, "even though the environmental impact of an efficiently run fuel depot may not be significant, the effects of an oil spill on the local fishing industry or the local beaches in the case of a tourist-oriented economy, may well render construction of such a depot very significant (OPNAVINST 5090.1). Two past Christo projects indicate risk assessment was inadequate. The umbrella installation resulted in two fatalities. At the Tejon Pass north of Los Angeles, the umbrellas were tested for 65 mph winds, despite the well known fact that gusty winds in southern California can well exceed that. One blew over and killed a woman. In recent months, tractor-trailer trucks overturned in the Los Angeles area due to high winds with gusts exceeding 70 mph (USA Today, 1/25/2006). The Rifle Colorado project, despite an impressive list of consultants and contractors working on it, misjudged the winds and was removed 28 hours after full installation, despite over 2 years of preparation (http://www.christojeanneclaude.net/vc.html).
What historic, anthropological or culture sites within the entire geographic area have the potential for adverse impacts, both direct and indirect?
What plant and animal species, migratory and resident, may be adversely impacted?
I have many other concerns that I will address at a later time. I would appreciate your review of my points and the incorporation of this letter into the official record.
Ellen T. Bauder, Ph D
Salida, CO