January 29, 2018

NEPCO

P.O. Box 714

Monument, CO 80132-0714

Kari Parsons

Development Services

2880 International Circle, Suite 110

Colorado Springs, CO 80910

Reference: Abert Ranch Preliminary Plan

NEPCO is providing the collective input from its membership that includesmore than8,000 homeowners, 41 HOAs and 18,000 registered voters within and around Monument. The purpose of NEPCO, a volunteer coalition of Homeowner Associations in northern El Paso County, is to promote a community environment in which a high quality of life can be sustained for constituent associations, their members and families in northern El Paso County. We collectively address growth and land use issues with El Paso CountyPlanners and the Town of Monument, as well as addressing HOA issues of common interest among the members. NEPCO achieves this by taking necessary steps to protect the property rights of the members, encouraging the beautification and planned development and maintenance of northern El Paso County.

Some of NEPCO’s comments will be a restatement of previous concerns as in most cases, the Developer did not address our remarks between the previous submission and this submission.

NEPCO’s general comments related to Abert Ranch Preliminary Plan

  1. The Preliminary Plan as presented conforms well with adjacent properties. NEPCO applauds the Developer for proposing Lot sizes that are dictated by the land versus an arbitrary number stipulating that all lots are of equal size.
  1. Although there are some loose ends such as connecting roads for this development, there is positive interaction between adjoining land owners and that provides a bit of assurance that the infrastructure will materialize. Additionally, there are back-up plans for the road system to address unforeseen circumstances.
  1. It is NEPCO’s belief that Dark Sky Compliant lighting should be required on all new construction in El Paso County, to include residential construction, tomitigate the effects of light pollution. We are blessed with clear, smog/haze free skies most days; in fact, we brag about our 300 plus days of sunshine each year. We should also cherish the night sky. It is NEPCO’s strong recommendation that the Covenants for the property will address and enforce Dark Sky Compliant lighting throughout the development, including homeowner lighting.
  1. The Colorado Wildfire Risk Assessment Summary Report.This is an interesting report which, by its own words, “provides a consistent, comparable set of scientific results to be used as a foundation for wildfire mitigation and prevention planning in Colorado.Results of the assessment can be used to help prioritize areas in the state where mitigation treatments, community interaction and education, or tactical analyses might be necessary to reduce risk from wildfires.”
  1. It does not appear that the report should be viewed as an expression of a true analysis of the wildfire risk and hazard for this development.The disclaimer made at the beginning of the report states: “Colorado State Forest Service makes no warranties or guarantees, either expressed or implied as to the completeness, accuracy, or correctness of the data portrayed in this product nor accepts any liability, arising from any incorrect, incomplete or misleading information contained therein. All information, data and databases are provided “As Is” with no warranty, expressed or implied, including but not limited to, fitness for a particular purpose.Users should also note that property boundaries included in any product do not represent an on-the-ground survey suitable for legal, engineering, or surveying purposes. They represent only the approximate relative locations.”
  1. If the report is viewed as anything more than a good explanation of what data is necessary for a good wildfire risk and hazard analysis, then NEPCO would point out a few areas of disagreement with the data purportedly gathered and used.
  2. For example, on pages 7 and 8, why is housing density for the 39 acres broken into a 1 house/20-40 acres (78%) for 13 acres and less than 1 house/4 acres (22%) for 4 acres? The Additional Exhibit indicated that the overall density for the development was 1 house/4 acres. This shows a truer and higher housing density.
  3. Breaking it up the way this report does turns the page 11 Wildland Urban Interface (WUI) into a density map reflecting the predevelopment status of the land even though, as proposed, there will be homes throughout the development which will dramatically change the conclusions of the report.
  1. On the other hand, the Fire Protection Report makes it clear that the developers have considered recent wildfire events such as the 2013 Black Forest Fire (ignored in many of the typical reports we see), and that the Black Forest fire came within 1.5 miles of this development.In addition, we note in the Fire Commitment Letter that the Tri-Lakes/Monument Fire Protection District can respond to this area in 8 minutes.The report is well written and deals well with wildfire mitigation efforts that are reasonable for developers, builders, and for homeowners.
  1. Soils and Geology Report.Again, we have drillings taken in January to show the depth of groundwater 15 ft., a time of year known as our low water point.Contractors should wait to make borings until mid-summer to give the developer and planning commission better data in this area! There is noted in the Letter of Intent that a stock pond exists on the property which is translated into standing water on top of the ground at least during some portions of the year. The two swales noted on the property in the Natural Features Report (page 4) were dry on the date of the inspection by ERO Resources Corporation as most ditches are in El Paso County on February 28 of any given year. It might be prudent to check these same locations in late spring as people live in their homes 12 months of the year, not just the dry months.
  1. Wastewater Report. All builders should be reminded that since percolation rates were not suitable for conventional wastewater treatment systems, individually designed on-site wastewater treatment systems are required.
  1. The Erosion and Stormwater Control document and theAbert Ranch Stormwater Management Plan are silent on the issue of noxious weed control during and after the construction. Although El Paso County Community Development requires a Noxious Weed Management plan with each development submittal, they are rarely provided. This land has historically been grazing land and as such, noxious weeds have probably not been a significant issue. Once the soil is disturbed the weeds will flourish without an effective mitigation plan.
  1. It is incumbent upon developers in El Paso County to care for and protect the land under their control.Noxious weeds pose a serious threat to our natural environment due to the damage they cause to natural landscapes and agricultural lands resulting in economic loss. The first step in weed prevention, the most cost-effective means, is to prevent the potential spread of weeds. Construction sights often create ideal conditions for invasive weeds to thrive as topsoil is removed and the soil is compacted using large vehicles.Using a site-specificNoxious Weed Management Plan (NWMP), developers can prevent and significantly reduce the spread of noxious weeds through prevention, early detection and eradication.
  2. El Paso County should require a NWMP for this and every development within the County to mitigate, to the greatest extent possible, the introduction and spread of noxious weeds.

After our review, the NEPCO supports this effort with the assumption that all existing El Paso County requirements will be met, including a Noxious Weed Management Plan, as the proposal moves forward.

NEPCO appreciates the opportunity to engage in this dialogue to preserve and enhance our community while supporting continued reasonablegrowth.

//SIGNED////SIGNED//

Thomas M. VierzbaLarry Oliver

Vice President, NEPCO President, NEPCO

Chairman,

NEPCO Transportation and Land Use Committee

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P.O. Box 714, Monument, CO 80132-0714