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HomeMy WebLinkAbout04.0 Court ProceedingsIN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO PATRICIA A. COAN, MAGISTRATE JUDGE Civil Action No. 00 -PC -1243 FILED Uf1a[dL� DISMOT COURT ONV[NCOLORADO AUG 3 0 2001 JAMES K. Nih CL ARKER INTERMOUNTAIN RESOURCES, L.L.C., a Colorado Limited Liability Company, INTERMOUNTAIN RANCHES, L.L.C., a Colorado Limited Liability Company, and NORMAN A. CARPENTER, Plaintiffs, v. KATHERINE M. HONEA; the BOARD OF COUNTY COMMISSIONERS OF GARFIELD COUNTY, COLORADO; and the UNITED STATES FOREST SERVICE, an agency of the United States of America, Defendants. JUDGMENT This matter came on for a bench trial commencing August 16, 2001, the Honorable United States District Magistrate Judge Patricia A. Coan presiding. PURSUANT to and in accordance with the Memorandum Opinion And Order entered by the Honorable United States Magistrate Judge Patricia A. Coan on August 30, 2001, it is ORDERED that judgment is entered in favor of Plaintiffs Intermountain Resources, L.L.C., a Colorado Limited Liability Company, Intermountain Ranches, L.L.C., a Colorado Limited Liability Company, and Norman A. Carpenter and against the Defendants Katherine M. Honea; the Board of County Commissioners of Garfield County, Colorado; and the United States Forest Service, an agency of the United 1 Judgment 00 -PC -1243 States of America on plaintiffs' first claim for relief, as amended by the evidence at trial, that the Easement Grant conveyed by Tom VonDette to the Colorado Division of Wildlife on April 14, 1976 was an express common law dedication of a public road which was accepted within a reasonable time by the United States Forest Service and the general public. It is FURTHER ORDERED that the easement premises described in Section A -of the Easement Grant converyed by Tom VonDette to the Colorado Division of Wildlife on April 14, 1976 is a public road, open to all lawful public uses by all members of the public, including the plaintiffs, subject to regulation by the United States Forest Service consistent with the public use. It is FURTHER ORDERED that a permanent injunction is entered against Defendant Katharine M. Honea prohibiting her, and her agents and employees, from any and all actions obstructing, restricting, hindering, or preventing the plaintiffs' use of the public road. It is FURTHER ORDERED that judgment is entered in favor of Defendants Katherine M. Honea; the Board of County Commissioners of Garfield County, Colorado; and the United States Forest Service, an agency of the United States of America and against the Plaintiffs Intermountain Resources, L.L.C., a Colorado Limited Liability Company, Intermountain Ranches, L.L.C., a Colorado Limited Liability Company, and Norman A. Carpenter on plaintiffs' second claim for relief that the easement premises is an R.S. 2477 Road. It is 2 Judgment 00 -PC -1243 FURTHER ORDERED that judgment is entered in favor of Plaintiffs Intermountain Resources, L.L.C., a Colorado Limited Liability Company, Intermountain Ranches, L.L.C., a Colorado Limited Liability Company, and Norman A. Carpenter and against the Defendant Katherine M. Honea on Defendant Honea's counterclaim for trespass and nuisance. It is FURTHER ORDERED that each party shall bear his, her or its own costs.-_ DATED at Denver, Colorado this 30th day of August, 2001. BY THE COURT: CL CA) C(} Patricia A. Coan United States Magistrate Judge EOD TED STATES DISTRICT COL DENVER. "OLORADO AG3O, 1 -AMES R. 1ANSPEA.Kt R. FOR THE COURT: JAMES R. MANSPEAKER, CLERK By Step ' P. Ehrlich, Chief Deputy Clerk IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CERTIFICATE OF MAILING Civil Action No. 00 -PC -1243 The undersigned certifies that a copy of the foregoing Judgment dated August 30, 2001 was served on August 30, 2001 by: (*) Delivery to; or by (**) Depositing in the United States Mail, postage prepaid, addressed to: James K. Beckwith, Esq. ** 7910 Ralston Road, Ste. 7 Arvada, CO 80002 Timothy E. Whitsitt, Esq. ** Whitsitt & Goss 320 Main St., Ste 200 Carbondale, CO 81623 JD Snodgrass, Esq. Williams, Turner & Holmes, PC 200 N 6th St. PO Box 338 Grand Junction, CO 81502-0338 Michael Hegarty, Esq. Assistant US Attorney DC Mail Box Don K. DeFord, Esq. 109 8`h St., Room 300 Glenwood Springs, CO 81601 U.S. Magistrate Judge Gudrun Rice United States District Court 402 Rood Ave., Room 323 Grand Junction, CO 81501 ,—,4e4f—v•-a-->---\ Secretary/Deputy Clerk FILED UPU1�C itATis 0,4111I01 COURT *Mott COLORADO IN THE UNITED STATES DISTRICT COURT AUG 3 0 2001 FOR THE DISTRICT OF COLORADO Civil Action No. 00 -PC -1243 JAMES tz. r.AKER :1, CLERK 11 INTERMOUNTAIN RESOURCES, L.L.C., a Colorado Limited Liability Company, INTERMOUNTAIN RANCHES, L.L.C., a Colorado Limited Liability Company, and NORMAN CARPENTER, Plaintiff(s), v. KATHERINE M. HONEA; the BOARD OF COUNTY COMMISSIONERS OF GARFIELD COUNTY, COLORADO; and the UNITED STATES FOREST SERVICE, an agency of the United States of America, Defendant(s). MEMORANDUM OPINION AND ORDER Patricia A. Coan, United States Magistrate Judge Plaintiffs seek a judicial declaration under Fed.R.Civ.P. 57 that a road running across defendant Katherine Honea's private property in Garfield County, Colorado, is a public road which may be used for all lawful public purposes. The matter was tried to the court on August 16, 2001 in special session in the Rifle, Colorado, Municipal Court. Jurisdiction exists under 28 U.S.C. §1331 because the resolution of pertinent issues requires interpretation of federal statutes, and under §2409a and §1346(f) because the United States holds title to the Easement Grant at issue. The parties have consented to determination of this case by a United States Magistrate Judge under 28 U.S.C. §636(c). The court, having considered the evidence presented at trial, the arguments of counsel, and the files and records in this case, makes the following findings of fact and conclusions of law. Fed.R.Civ.P. 52(a). I. FINDINGS OF FACT A. The Easement Grant 1. Plaintiff Norman Carpenter' is the owner of approximately 4500 acres of land and timber situated on private property in Secs. 25, 26, 28, 35, and 36; Township 7 South, Range 94 West of the 6'h P.M., in Garfield County, Colorado, known as "Tepee Park." (Exhibits 1, 2, 21 and 22) Tepee Park is surrounded by public lands owned by the United States and administered by the U.S. Department of Agriculture, U.S. Forest Service ("USFS" or "Forest Service") and the U.S. Department of Interior, Bureau of Land Management ("BLM"). (Exhibits 1 and 2) 2. On August 28, 2000, Carpenter and plaintiff Intermountain Resources entered into a Timber Sale Agreement which authorized plaintiff Intermountain Resources, L.L.C. ("Intermountain Resources") to harvest timber from the Tepee Park property.2 (Exhibit 23; Christopher Meyers testimony) 3. Beaver Creek Ranch is a 160 acre parcel of land originally patented to Mr. Frank Von Dette, and situated, as relevant here, in Section 24; Township 7 South, Range 94 West of the 6th P.M. in Garfield County, Colorado. (Exhibits 1, 3, 4 and 5) Beaver Creek Ranch is bordered on its east, west and south sides by the White River National Forest. (Exhibits 1 and 2) Generally, Beaver Creek Ranch lies north of Tepee Park, ' By Order dated September 19, 2000, Norman Carpenter was substituted as a plaintiff for two of the original plaintiffs, Leelynn, Inc. and Wiley Mountain, Inc., entities who jointly owned Tepee Park at the time this action was filed but who later conveyed the property to Carpenter. 2It is unclear whether plaintiff Intermountain Ranches, L.L.C. has any current interest in the Tepee Park property. 2 separated by public lands administered by USFS between the Ranch and Tepee Park. (Id.) 4. In the 1940's or 1950's, Frank VonDette conveyed Beaver Creek Ranch to his son, Tom VonDette ("VonDette"). (Tom VonDette testimony) VonDette sold Beaver Creek Ranch to Messrs. Carey and Bishop in 1982. (Id.) On June 25, 1998, Messrs. Carey and Bishop conveyed Beaver Creek Ranch to defendant Katharine M. Honea ("Honea"). (Exhibit 3) Defendant Honea is the current owner of Beaver Creek Ranch. 5. One vehicular access route to the USFS lands south of Beaver Creek Ranch, and to Tepee Park, traverses Beaver Creek Ranch from north to south. Garfield County Road 317 ("GCR 317"), which runs from the north, intersects with a gate at the northwest corner of Beaver Creek Ranch. From there the route continues south through Beaver Creek Ranch for approximately one-half mile to the Ranch's southern boundary. The route as it traverses Beaver Creek Ranch will be referred to herein as "VonDette Road" or "Road." The southern boundary of the Ranch is also the boundary of the White River National Forest. At that point, VonDette Road intersects with U.S. Forest Service Road 824 ("USFS Road 824") which runs south through the White River National Forest for about one mile, where it reaches the boundary of the Tepee Park lands. (Ex. 1, Eugene Byrne testimony) 6. In 1975, Eugene Byrne, a Wildlife Conservation Officer for the Colorado Division of Wildlife (CDOW) received complaints from hunters that VonDette was barring public travel over VonDette Road to access the White River National Forest south of Beaver Creek Ranch. (Byrne testimony) After Byrne consulted with USFS employees, 3 Byrne concluded that the VonDette Road was an historic public right of way over Beaver Creek Ranch for use by the general public. (Id.) Byrne informed VonDette of the CDOW's and USFS's position that VonDette Road was a public road and told VonDette that he could sell the CDOW a road easement or, the CDOW would seek a judicial declaration that the VonDette Road was a public road. (Byrne, VonDette testimony) VonDette agreed to negotiate a public access easement with the CDOW, subject to certain conditions. (Id.) 7. Between September 1975 and February 1976, VonDette negotiated the terms of the easement grant with Byrne and USFS officials. (Exhibits 29, 30, 33; Byrne testimony) It was agreed that: CDOW would purchase the easement from VonDette for $6,000; the USFS would build the road across Von Dette's land after CDOW transferred the right of way to the USFS; and, the VonDette Road would not be open to the general public until after the road was constructed by the USFS. (Exhibits 30, 33) Pending completion of the road construction, VonDette further agreed to open the road to public travel during the Fall 1976 hunting season. (Ex. 34) 8. On April 14, 1976, Tom VonDette executed and delivered an Easement Grant to CDOW, which was recorded with the Garfield County Clerk and Recorder's Office. (Exhibits 6a, 6b) The Easement Grant, drafted by the CDOW, describes the easement premises as a 30 -foot wide strip of land across the Beaver Creek Ranch property. (Id. at Section A; Byrne testimony) The easement premises basically follows the same alignment as a road built by VonDette in the 1950's, with a few minor adjustments. (Byrne testimony) The VonDette Easement Grant states, in pertinent part: 4 This EASEMENT GRANT is made between Tom VonDette hereinafter referred to as "the Grantor," and the State of Colorado for the use and benefit of the Department of Natural Resources, DIVISION OF WILDLIFE, hereinafter referred to as "the Grantee." B. The Grantor wishes to grant and the Grantee wishes to receive an easement for perpetual public road easement upon, over, under and across the easement premises... 1. GRANT OF EASEMENT. The Grantor hereby grants to the Grantee, his successors and assigns, a perpetual easement for a perpetual public road easement, upon, over, under, and across the easement premises. . . 2. WARRANTIES OF TITLE: Grantor warrants that he has good and indefeasible fee simple title to the easement premises... 3. RUNNING OF BENEFITS AND BURDENS. All provisions of this instrument, including the benefits and burdens, run with the land and are binding upon and enure to the heirs, assigns, successors, tenants and personal representatives of the parties hereto. . . 4. ATTORNEY'S FEES: Either party may enforce this instrument by appropriate action and should he prevail in such litigation, he shall recover as part of his costs a reasonable attorney's fee... 5. CONSTRUCTION: The rule of strict construction does not apply to this grant. This grant shall be given a reasonable construction so that the intention of the parties to confer a usable right of public enjoyment on the Grantee. 9. On May 2, 1977, CDOW assigned the Easement Grant to the Forest Service. (Exhibit 7) The Easement Grant to the Forest Service was recorded with the Garfield County Clerk and Recorder. (Id.) The terms of the Easement Grant from CDOW to the USFS are substantially the same as the VonDette Easement Grant, with the exception of the named grantor and grantee, deletion of the attorney fee provision, and the addition of a clause which states that the grantee shall construct and maintain a road upon the easement premises within two years from the date of the Easement Grant. (Exhibit 7, section B.2) The Easement Grant further requires the Forest Service to post signs 5 advising the public that the road is a public access road crossing private property. (Id.) 10. In July 1977, VonDette and CDOW and Forest Service officials met and agreed upon further details of the road construction and alignment, including the posting of signs to notify the public that the road was crossing private property and the installment of: a fence along the creek side of the road; a gate at the northern boundary of the Beaver Creek Ranch; and a cattleguard at the southern boundary of the Ranch.' (Exhibit 37; Byrne testimony) By October 5, 1977, the Forest Service had completed the construction of VonDette Road, along with installment of the fence, gate, cattleguard and signs. (Exhibits 8, 38, 39) The Forest Service also built a public parking area, including a truck loading ramp, south of Beaver Creek Ranch (the "Beaver Creek Parking Area"). (Exhibit 11; Byrne testimony) The signs posted along VonDette Road at the northern and southern boundaries of Beaver Creek Ranch clearly state that the Road is a "public right of way" crossing private property. (Exhibit 12; Byrne testimony) 11. In 1997, Tucker and Frase Partnership, then owners of Tepee Park, applied for Forest Service authorization to access USFS Road 824 for the purpose of hauling privately -owned timber from Tepee Park. (Exhibits 42, 56) Tucker and Frase were granted a Forest Service special use permit' which designates USFS Road 824 through USFS lands and VonDette Road through the Beaver Creek Ranch as the approved access 3The purpose of the gate and cattleguard was livestock control. (Byrne testimony) 4The court uses the term special use permit as a generic term to reference the permission granted to plaintiffs to use the VonDette Road for timber hauling purposes. 6 for transport of logging machinery, trucks and harvested timber to reach GCR 317.5 (Meyers, testimony; Exhibits 42, 56, 58) The special use permit requires the following: (1) realignment of USFS 824 south of Beaver Creek Ranch; (2) improvement of the VonDette Road across Beaver Creek Ranch; and, (3) obtaining an extraction permit from defendant Board of County Commissioners of Garfield County ("Garfield County BOCC"). (Meyers testimony; Ex. 9) At some point, plaintiff Intermountain Resources became a party to the special use permit and completed the required improvements to USFS Road 824 through USFS lands. (Exhibit 14; Meyers testimony) Plaintiff has not made the required improvements to the VonDette Road because defendant Honea objects to use of the Road for commercial logging purposes. (Meyers testimony) 12. In 1997, defendant Garfield County BOCC granted Tucker and Frase Partnership a special use permit to harvest timber on Tepee Park lands, which was later assumed by plaintiff Intermountain Resources. (Exhibit 10; Meyers testimony) The permit is subject to the conditions that Intermountain Resources must improve GCR 317 leading to the north gate of Beaver Creek Ranch and obtain a decree by a court of competent jurisdiction that the VonDette Road "is a legal right-of-way for the proposed Special Use permit." (Exhibit 10) 5The USFS has treated Tepee Park as an inholding pursuant to the provisions of 16 U.S.C. §3210 of the Alaska National Interest Land Conservation Act ("ANILCA"), and has determined that it is required by 16 U.S.C. §1323 to provide the owners of Tepee Park "reasonable access" to their private lands. (Exhibits 42, 58) To that end, the USFS has designated the plaintiffs access to Tepee Park for the purpose of harvesting timber as GCR 317 to VonDette Road to USFS Road 824 to Tepee Park. (Id.) The Forest Service refers to VonDette Road as Forest Development Road 824. (Cindy Hockelburg testimony) 7 13. Plaintiffs have completed the required improvements to GCR 317 and have commenced the instant action in compliance with the second condition imposed by the Garfield County BOCC. (Exhibit 14; Meyers testimony) B. Historical Use of the VonDette Road 14. VonDette's father, Frank VonDette, homesteaded the property now known as Beaver Creek Ranch in 1911. (VonDette testimony) 15. Homestead Entry Survey ("H.E.S.") No. 309, filed on November 14, 1918, depicts a dotted line along the general alignment of what is now VonDette Road through Beaver Creek Ranch. (Exhibits 4 and 8, at p. 9) 16. H.E.S. No. 309 shows that the "Battlement National Forest" was established by Proclamation of December 24, 1892 and encompassed all lands south of the northern boundary of the Beaver Creek Ranch, including all of Beaver Creek Ranch. (Id.) 17. Frank VonDette obtained an ownership patent for the Beaver Creek Ranch property in 1920. (VonDette testimony; Exhibit 5) 18. Tom VonDette was born in 1926 and lived on Beaver Creek Ranch until he sold the property in 1982. (VonDette testimony) When VonDette was a child, a horse trail known as the Caton Ranger trail, which was approximately three to six feet wide, crossed the Beaver Creek Ranch property from north to south along Beaver Creek. (Id.) According to VonDette, the Caton Ranger trail is the route depicted on H.E.S. No. 309, and was east of what is now VonDette Road. (Id.) The Caton Ranger trail was open to the public to access Forest Service lands by foot or horseback. (Id.) In the 1930's, the Caton 8 Ranger trail was traversed by horse-drawn wagons to access Forest Service lands to gather poles or logs for ranching operations. (Id.) 19. During the 1930's, VonDette's brother and father worked at the Barn sawmill which was originally located on the Ranch, and was later moved to a location approximately a half mile to a mile south of the Ranch. (VonDette testimony) At that time, trucks traveled over the Caton Ranger trail to haul timber to Grand Junction. (Id.) The trail had become wide enough to accommodate trucks and a bridge was built over Beaver Creek. (Id.) 20. In the 1950's, VonDette constructed a road through Beaver Creek Ranch to access the Forest Service lands south of the Ranch and Tepee Park. (VonDette testimony) VonDette operated a sawmill on the Beaver Creek Ranch property in the 1950's and 1960's and used roads he built to transport felled timber from the White River National Forest lands south of Tepee Park to Beaver Creek Ranch where it was milled by the VonDettes. (Id.) The lumber was then hauled by truck to lumber markets in Rifle and Grand Junction, Colorado. (Id.) 21. Approximately two-thirds of the road built by the Forest Service in 1977 ("VonDette Road") followed the alignment of an existing road through Beaver Creek Ranch, but a new section was constructed at the point where the existing road diverged east to the location of VonDette's sawmill. (VonDette testimony) 22. Beginning in the 1950's and prior to the Forest Service's construction of VonDette Road in 1977, VonDette objected to any vehicular traffic across Beaver Creek Ranch without his express permission and maintained a locked gate at the northern 9 boundary of the Ranch where GCR 317 terminates. (Id.) During that time, VonDette allowed ranchers with USFS grazing permits to access Forest Service lands by use of the Caton Ranger trail. (Id.) 23. When VonDette owned the Beaver Creek Ranch and up to 1990, VonDette controlled a portion of the Tepee Park lands Tying at the head of Beaver Creek with a lease from the owner, the Virginia -Colorado Company. (VonDette testimony) VonDette did not permit public hunting or other public use of the Tepee Park lands. (Id.) After selling Beaver Creek Ranch in 1982, VonDette accessed Tepee Park by driving over VonDette Road. (Id.) VonDette never requested permission from the subsequent Ranch owners because he considered the Road to be a public road. (Id.) 24. Following the Forest Service's completion of the VonDette Road in 1977, hunters, fishermen, wildlife viewers, skiers, and snowmobilers have used the road for vehicular access to Forest Service lands. (Byrne, VonDette testimony) The Road has been used by all types of vehicles and trucks, including trucks pulling horse trailers and a one - ton farm truck. (VonDette testimony) 25. Since 1977, the owners of Beaver Creek Ranch have kept the gate at the northern boundary of VonDette Road closed, but unlocked. (Katherine Honea, VonDette, Byrne testimony) Additionally, defendant Honea maintained a closed, but unlocked, gate across the southern boundary of the Ranch until the gate was destroyed sometime last year. (Honea testimony) 10 26. Closed, but unlocked, gates are frequently maintained on USFS roads for livestock control, but the presence of a dosed, unlocked gate does not restrict the public's right to use the road. (Hockelburg testimony) 27. On November 12, 1997, Messrs. Carey and Bishop, the previous owners of Beaver Creek Ranch, granted an easement over VonDette Road to Barrett Resources, a commercial operator on USFS lands, authorizing the company to access its oil and gas leasehold, to transport oil and gas drilling rigs, accessory equipment and related services across the VonDette Road, and to install underground transmission lines along the Road. (Meyers, Honea testimony; Exhibit 20) Barrett Resources paid $1350 consideration for the easement. (Id.) 28. Defendant Honea was aware of the Easement Grant to the USFS at the time she purchased the Beaver Creek Ranch in 1998. (Honea testimony) Honea purchased Beaver Creek Ranch with the intent to use the property as a quiet residence where she could ride her horses, for livestock pasturage, and for the commercial purposes of operating a hunting camp and group retreat center. (Honea testimony) Honea testified that plaintiffs' road improvement trucks, which travel over VonDette Road to USFS Road 824, generate a substantial amount of dust and noise as they cross Beaver Creek Ranch. 29. Honea objects to plaintiffs' use of VonDette Road based on her interpretation that the Easement Grant allows members of the public to drive across her property to access Forest Service lands for recreational purposes, but does not allow commercial vehicle operators with commercial interests in Tepee Park to access that property by way of VonDette Road. (Honea testimony) Honea advised plaintiff Intermountain Resources 11 that she would grant an easement over VonDette Road to access Tepee Park for timber harvesting purposes in exchange for $100,000 per year. (Honea, Meyers testimony) II. CONCLUSIONS OF LAW Plaintiffs' complaint for declaratory relief seeks a judicial declaration that: (1) the VonDette Easement Grant to CDOW and CDOW's subsequent assignment of that Easement Grant to the USFS constitutes a dedication of a public road over private lands for the use and benefit of the general public without restriction, and, therefore, the VonDette Road is a public highway as defined by COLO.REV.STAT. ("C.R.S.") §43-2-201; or (2) the VonDette Road is a historic public right of way under former Revised Statute 2477 (1886) and is therefore a public highway under C.R.S. §43-1-202. Plaintiffs also seek an injunction against defendant Honea to prohibit her from committing any act to obstruct, hinder, or impede the plaintiffs' use of VonDette Road. Defendant Honea has asserted a counterclaim against plaintiffs for trespass. Defendant Garfield County BOCC does not take a position on the proper interpretation of the VonDette Easement Grant, or on the issue of whether VonDette Road is a public road. Defendant Forest Service takes the position that the VonDette Easement Grant granted a public road to a sovereign entity.' A. Is VonDette Road an R.S. 2477 Road? Plaintiffs' second claim for relief asserts that the VonDette Road is a public highway pursuant to former Revised Statute ("R.S.") 2477 (1886), formerly codified at 43 U.S.C. 61n the July 16, 2001 Final Pretrial Order, the Forest Service asserts that the VonDette Easement Grant is a statutorily dedicated public right of way. 12 §932, which stated: "The right of way for the construction of highways over public lands, not reserved for public uses, is hereby granted."' Whether and when the grant is accepted by the public is determined under state law. Barker v. Board of Cnty. Comm'rs of La Plata County, 24 F.Supp.2d 1120, 1127 (D.Colo. 1998); Sierra Club v. Hodel, 675 F.Supp. 594, 604 (D.Utah 1987), rev. in part on other grounds, 848 F.2d 1068 (10th Cir.1988). In Leach v. Manhart, 77 P.2d 652 (1938), the Colorado Supreme Court held that R.S. 2477 was "an express dedication of a right of way for roads over unappropriated government lands, acceptance of which by the public results from 'use by those for whom it was necessary or convenient.- (Internal quotation omitted). To establish that VonDette Road is an R.S. 2477 public road, plaintiffs must demonstrate that VonDette Road existed while Beaver Creek Ranch was a public land. Barker, 24 F.Supp.2d at 1127; Humboldt County v. United States, 684 F.2d 1276, 1281 (9`h Cir. 1982). Public land is land which is subject to sale or other disposition under the laws, excluding land to which any claims or rights of others have attached. Board of County Comm'rs of Cheyenne Cnty. v. Ritchey, 888 P.2d 298, 300 (Colo. App. 1995)(citing Bardon v. Northern Pacific R.R. Co., 145 U.S. 535 (1892)); Humboldt County, 684 F.2d at 1281)(internal citation omitted). Public roads established under R.S. 2477 can include footpaths, in appropriate circumstances, see Simon v. Pettit, 687 P.2d 1299 (Colo. 1984), and roads formed by the passage of wagons. See Central Pacific Ry. v. Alameda County, 284 U.S. 463 (1932). 'The Federal Land Policy Management Act of 1976 ("FLPMA") repealed R.S. 2477, but preserved any rights of way that existed prior to the date of enactment. 43 U.S.C. §1769(a). 13 The evidence was that VonDette's father, Frank VonDette, homesteaded the Beaver Creek Ranch property in 1911 under the Homestead Act of 1862 which granted 160 acres of land to individuals who lived on and improved the property for five years. Act of May 20, 1862, ch. 75, 12 Stat. 392, 43 U.S.C. §§161-284 (repealed in 1976 by FLPMA). Homestead Entry Survey No. 309 in the Battlement National Forest was approved by the U.S. Surveyor General's Office on November 14, 1918 and was accepted on March 10, 1919. (Exhibit 4) Frank VonDette obtained a patent for Beaver Creek Ranch in 1920. (Exhibit 5) The 1918 Survey shows that a Forest Reserve, which included the land now known as Beaver Creek Ranch, was established by Proclamation of December 24, 1892. The Survey depicts a dotted line running south from the northern boundary of the Ranch through Beaver Creek Ranch. VonDette, who was born on the Ranch in 1926, testified that the dotted line represented a horse trail and footpath used by the public which the VonDette family referred to as the Caton Ranger trail. It appears from H.E.S. No. 309 that Beaver Creek Ranch was removed from the public lands by a Presidential Proclamation establishing the Battlement National Forest in 1892. If that is the case, plaintiffs must show that what is now VonDette Road existed as a public road prior to 1892 to establish an R.S. 2477 Road. There is no evidence, however, that a public road existed on the easement premises prior to 1892. Further, even if the Beaver Creek Ranch was not withdrawn from the public domain until it was patented in 1920, the only evidence of a pre-existing road is the dotted line depicted on H.E.S. No. 309, which VonDette states represents the Caton Ranger trail. VonDette testified that horse-drawn wagons used the trail in the 1930's to cross the Beaver Creek Ranch property 14 into Forest Service lands to obtain logs and poles for their ranching operations; however, there was no competent evidence as to public use of the Caton Ranger trail prior to the 1930's. Because VonDette was not born until 1926, he has no personal knowledge of the existence of a road prior to 1920. The court is unable to conclude from the evidence of record that the dotted line depicted on Homestead Entry Survey No. 309 represents a road that was used by the public prior to 1920. Because the evidence does not establish that VonDette Road came into existence before Beaver Creek Ranch was removed from the public lands, I find and conclude that plaintiffs have failed to demonstrate that VonDette Road is an R.S. 2477 public road. Accordingly, the VonDette Road is not a public highway under C.R.S. §43-1-202 which provides that all roads which were open to public traffic on May 4, 1921 are public highways.' B. Is VonDette Road a Dedicated Public Road? Plaintiffs' first claim for relief asserts that VonDette Road is a dedicated public highway pursuant to C.R.S. §43-2-201(1) which states: "The following are declared to be public highways ... (a) All roads over private lands dedicated to the public use by deed to that effect, filed with the county clerk and recorder of the county in which such roads are situate, when such dedication has been accepted by the board of county commissioners." sPlaintiffs' second claim for relief also alleges that Beaver Creek Road has been used continuously and without interruption by the general public for a period in excess of twenty years and has therefore become a public highway by dedication and public use pursuant to Colorado statutes. (Compl.,¶¶41-44) To the extent that plaintiffs claimed in their complaint that the VonDette Road is a dedicated road by prescriptive use under C.R.S. §43-2-201(1)(c), I find that the claim has been abandoned because it was not asserted in the parties' July 16, 2001 Final Pretrial Order or argued at trial. 15 The Easement Grant deed from VonDette to CDOW, and from CDOW to the Forest Service, expressly conveys a "perpetual public road easement" across the Beaver Creek Ranch. The evidence was that both Easement Grant deeds were filed with the Garfield County Clerk and Recorder. It is undisputed, however, that the purported dedication was not accepted by the Garfield County BOCC.9 Plaintiffs argue that a statutory dedication of a public road may be accepted by any public entity that is authorized to hold an interest in land. Plaintiffs maintain that the USFS accepted VonDette's dedication of a public road by making improvements to the road in 1977. Defendant Honea responds that a statutory dedication has not been demonstrated because the easement was not conveyed to, or accepted by, the Garfield County BOCC. Honea contends that the purported dedication of a public road to the CDOW is outside the purview of the Colorado statute. I agree with defendant Honea that the requirements of C.R.S. §43-2-201(1)(a) have not been satisfied. "A court's primary task in statutory construction is to ascertain and give effect to the legislative purpose underlying a statutory enactment." Woodsmall v. Regional Transp. Dist., 800 P.2d 63, 67 (Colo. 1990). If the language of the statute is clear and unambiguous, the court should presume that the legislature meant what it clearly stated. Id. The statute expressly states that the dedication must be accepted by the board of county commissioners of the county in which the road is situated. The most reasonable 9At the June 11, 2001 hearing on plaintiffs Motion for Partial Summary Judgment, the Assistant Garfield County Attorney represented to the court that the Garfield County BOCC had never accepted a dedication of the VonDette Road as a public road. 16 construction of §43-2-201(1)(a) is that the statutory subsection applies to dedications made to a county and accepted by the county's BOCC. If the legislature intended that any governmental entity could accept a dedication of a public highway, it would have stated as much. I find and conclude that a dedication accepted by a public entity other than a county is not within the scope of the Colorado statute. Accordingly, I conclude that the easement premises described in the VonDette Easement Grant was not dedicated to the public in accordance with C.R.S. §43-2-201(1)(a). Having determined that the evidence does not establish a dedication pursuant to Colorado statute, the next question is whether a common law dedication of a public road has been demonstrated. A "dedication" is "an appropriation of land by the owner of the fee to some public use and the adoption thereof by the public." Hand v. Rhoades, 245 P.2d 292 (1952); see, also, Powell on Real Property, §84.01[1] (1999). Dedication can be made pursuant to state statute or according to the common law. Fortner v. Eldorado Springs Resort Co., 230 P. 386, 388 (Colo. 1924). A common law dedication may be express or implied. Id. A common law dedication operates as an estoppel in pais and ordinarily gives the public an easement only with the underlying possessory interest left in the dedicator. Buell v. Redding Mills, Inc., 430 P.2d 471, 473 (Colo. 1967); see, also, Powell on Real Property, §84.01[8]. Under Colorado law, a common law dedication of property to the public requires an unambiguous, unequivocal intent by the owner to so dedicate and an unambiguous acceptance of the dedication by the governmental authority. City of Northglenn v. City of Thornton, 569 P.2d 319, 321 (Colo. 1977)(internal citations omitted). A public authority's 17 acceptance of a dedication may be evidenced by a legislative act, or by the public entity's possession, improvement or use of the land as a public road. Bd. of Cnty. Comm'rs v. Sherrill, 757 P.2d 1085, (Colo.App. 1987)(citing Town of Center v. Collier, 144 P. 1123, (Colo. 1914)). A dedication is to the public at Targe; thus, even when a dedication is affected through a conveyance to a specific grantee, the public is the real transferee of the use of the land. See 26 C.J.S. Dedications §10 (2001). The existence of a common law dedication is a question of fact. Powell on Real Property, §84.01[7][b]. I first address whether the evidence supports a finding that VonDette's intent in conveying the Easement Grant deed to CDOW was to dedicate a public road though Beaver Creek Ranch. The language of the VonDette Easement Grant states that VonDette conveyed to the CDOW a thirty-foot wide "perpetual public road easement upon, over, under and across the easement premises ... " In construing a deed, the court's primary purpose is to ascertain the intention of the parties. Notch Mountain Corp. v. Elliott, 898 P.2d 550, 557 (Colo. 1995). In Lazy Dog Ranch v. Telluray Ranch Corp., 965 P.2d 1229, 1235-36 (Colo. 1998)(Lazy Dog II), the Colorado Supreme Court eschewed a rigid -four corners- approach to deed interpretation. The court instructed that a trial court may conditionally admit extrinsic evidence to determine whether the language of a deed is ambiguous, but if it is ultimately determined that the document is unambiguous, the extrinsic evidence must be stricken, and the court must give effect to the language of the deed. 965 P.2d at 1235-36. At trial, the court conditionally admitted evidence of the circumstances surrounding the conveyance of the 18 Easement Grant to determine if the deed's terms creating a "perpetual public road easement" are ambiguous. Defendant Honea presented evidence that the CDOW's stated purpose in acquiring the Easement Grant was for hunter access to public lands south of Beaver Creek Ranch and that access to Tepee Park lands was not contemplated at that time. The parties presented evidence of additional terms in the agreement between VonDette and the CDOW which were not included in the language of the Easement Grant, such as the posting of signs and construction of fences. Further, there was evidence that the CDOW paid VonDette $6,000 consideration for the Easement Grant after advising VonDette of the CDOW's position that the road was a public road. The evidence also showed that VonDette treated VonDette Road as a public road after he sold the Beaver Creek Ranch in 1982. I find that the language of the Easement Grant accurately and unambiguously reflects the intention of VonDette to convey a public road easement to the CDOW. "The language used in creating a servitude ordinarily should be interpreted to accord with the meaning an ordinary purchaser would ascribe to it in the context of the parcels of land involved." Lazy Dog 11, 965 P.2d at 1237 (quoting Restatement (Third) of Property §4.1 cmt. c (2000)). The plain and ordinary meaning of the term "public" is "accessible to or shared by all members of the community." Webster's Ninth New Collegiate Dictionary at 952 (1983). Any construction which limits the use of the easement to hunters or other recreational users of Forest Service lands would contradict the expressed intention of the grantor. I therefore disregard the extrinsic evidence which was conditionally admitted at 19 trial to determine whether the terms of the Easement Grant are ambiguous. Lazy Dog Ranch II, 965 P.2d at 1237. I find that the Easement Grant constitutes an express manifestation of VonDette's intent to dedicate the easement premises to public use as a public road. I next address whether the offer of dedication by VonDette was accepted by the public. An offer to dedicate must be accepted within a reasonable time. Litvak v. Sunderland, 353 P.2d 381, 383 (Colo. 1960); Near v. Calkins, 946 P.2d 537, 539 (Colo.App. 1997). Plaintiffs assert that the dedication of VonDette Road was accepted by the Forest Service when it constructed the road in the location specified by VonDette, and by the public's continuous use of the road thereafter. Defendant Honea maintains that neither the CDOW nor the USFS are statutorily authorized to accept a dedication of a public road. In 1976, when VonDette conveyed the Easement Grant to CDOW, the CDOW was authorized to acquire interests in land, including fee title interests and easements, "by gift, transfer, devise, lease [or] purchase," "for wildlife purposes or for the preservation or conservation of wildlife." C.R.S. §33-1-105(1)(a)(I). The CDOW transferred the Easement Grant deed to the Forest Service in 1977. At that time, the Forest Service was authorized to acquire access roads within and near the national forests to provide for the development and management of Forest Service lands for multiple uses, including outdoor recreation, range, timber, watershed, and wildlife and fish purposes. See 16 U.S.C. §528, §532, §535; 36 C.F.R. §212.7. The Forest Service may acquire road easements or other interests in land by purchase, condemnation, donation oras part of a reciprocal agreement. 36 C.F.R. 20 §212.7; 43 U.S.C. §1715(a). Any interest in land acquired by the Forest Service is subject to all laws, rules and regulations applicable for Forest Service lands. 43 U.S.C. §1715(d). I find and conclude that because the CDOW and the Forest Service have statutory authority to hold interests in land, they may also accept a dedication of public land on behalf of the public. I further find that the Forest Service's actions in constructing the new road across the easement premises in 1977 constitute public acceptance of VonDette's dedication of the easement premises as a public road within a reasonable time. The public's acceptance of the dedication is further evidenced by the public's use and enjoyment of VonDette Road after construction was completed by the Forest Service. I also find that the CDOW did not take any action to accept the dedication on behalf of the public, but acted merely as title holder of the Easement Grant for a one-year period. I find and conclude that the VonDette Easement Grant is an express dedication of a public road under the common law.10 The Forest Service holds title to the public road easement in trust for the public. Because the Easement Grant dedicated the easement premises to the public, all lawful public uses of VonDette Road are permitted, subject to regulation by the Forest Service. I reject defendant Honea's arguments that the use of VonDette Road is limited to members of the public who seek to access USFS lands south 10The court notes that plaintiffs' complaint, and the parties' Final Pretrial Order, assert a claim of statutory dedication only. Under Fed.R.Civ.P. 15(b), if issues not raised by the pleadings are tried by express or implied consent of the parties, they shall be treated as if they had been raised in the pleadings. I find that the issue of whether the Easement Grant is an express common law dedication of a public -right - of way was tried by implied consent of the parties. Accordingly, I will treat the issue as having been raised in plaintiffs' first claim for relief. 21 of Beaver Creek Ranch for hunting and recreational purposes. Once a road is declared to be a public road, the road is "open to all members of the public for any uses consistent with the dimensions, type of surface and location of the roadway." Lovvorn v. Salisbury, 701 P.2d 142, 144 (Colo. App. 1985)(rejecting Board of County Comm'rs v. Ogburn, 554 P.2d 700 (Colo.App. 1976), wherein a different panel of the Court of Appeals held that if a road is declared to be a public road through prescriptive use, the extent of permissible public use must be limited to that established by the historical public use). Because VonDette Road is a dedicated public road, members of the public may use the Road to access Forest Service lands south of Beaver Creek Ranch or private property adjacent to, or within, Forest Service lands. Defendant Honea and her successors -in -interest, as owners of Beaver Creek Ranch, may use the dedicated road in any way consistent with the public use, but may not interfere with the public use. See 23 Am. Jur. Dedications §§65, 76 (1983). The Forest Service, as the governmental authority that accepted the dedication, may regulate and determine what public uses are appropriate for VonDette Road, consistent with the terms of the dedication, and is responsible for maintaining the road for the public use. See 26 C.J.S. at §74. The Forest Service has determined that plaintiffs' proposed use of VonDette Road for timber hauling is consistent with the public use and with the statutory purposes of an easement to which the Forest Service holds title. The Forest Service has required plaintiffs to make improvements to VonDette Road so that plaintiffs' use is consistent with the dimensions, type of surface and location of the Road. 22 Plaintiffs, as members of the public, are entitled to use VonDette Road to access the Tepee Park lands for timber harvesting purposes. C. Honea's Counterclaim for Trespass Defendant Honea asserts a counterclaim for trespass against plaintiffs for using VonDette Road to access Tepee Park to prepare for their logging operations. Honea asserts that plaintiffs' use of VonDette Road for commercial purposes has damaged Beaver Creek Ranch, rendering it unfit for her intended use of the property as livestock pasturage, a commercial hunting camp, and as her residence. I will deny the counterclaim for trespass based on my conclusion that VonDette Road is a dedicated public road available to the public for all lawful uses, as regulated by the Forest Service in the public interest. Defendant Honea did not present any evidence to establish that plaintiffs' vehicles have traveled outside the boundaries of VonDette Road. To the extent Honea's counterclaim also asserts that plaintiffs' use of VonDette Road is a private nuisance, Honea must prove that plaintiffs have unreasonably and substantially interfered with the use and enjoyment of her property. Public Service Co. of Colorado v. Van Wyk , 996 P.2d 193 (Colo. 2001). The evidence was that plaintiffs' road improvement trucks are loud and create a lot of dust, thereby interfering with Honea's enjoyment of her residence. Honea testified that plaintiffs' use of VonDette Road to access USFS Road 824 to make the road improvements required by the Forest Service has impacted her financially; however, Honea did not present persuasive evidence that the plaintiffs' use of the Road has substantially interfered with her use of the property as livestock pasturage, a retreat, or a commercial hunting camp. Further, other evidence 73 demonstrated that the VonDette Road is currently being used by Barrett Resources' oil and gas drilling trucks. The evidence did not show that the alleged diminishment of Honea's use and enjoyment of her residence is due to the plaintiffs' use of the road rather than Barrett Resources' use. To prove a public nuisance, Honea must show that plaintiffs' use of VonDette Road "injuriously affects the safety, health or morals of the public or works some substantial annoyance, inconvenience, or injury to the public." State, Dep't of Health v. The Mill, 887 P.2d 993, 1002 (Colo. 1994). No such evidence was presented. I therefore deny defendant Honea's trespass counterclaim to the extent she may have claimed that plaintiffs' use of VonDette Road must be abated as a private or public nuisance. III. PLAINTIFFS' REQUEST FOR ATTORNEY'S FEES Plaintiffs request that I award them their reasonable attorney's fees incurred in prosecuting this action, under Section 4 of the VonDette Easement Grant which states: "Either party may enforce this instrument by appropriate action and should he prevail in such litigation, he shall recover as part of his costs a reasonable attorney's fee." Plaintiffs argue that they are third party beneficiaries to the VonDette Easement Grant and are therefore entitled to enforce the attorney's fees provision. Contractual provisions providing for the award of attorney's fees are strictly construed in Colorado. See Parker v. Center for Creative Leadership, 15 F.3d 297, 299 (Colo.App. 2000)(declining to hold plaintiff liable for attorney fees under attorney fee provision in Service Agreement between organization and plaintiff's employer because the 24 provision expressly referred to the payment of such fees by a party to the Service Agreement). Because the express language of Section 4 of the Easement Grant does not provide for an award of attorney's fees to members of the public who seek to enforce the terms of the Easement Grant from VonDette to the CDOW, I find and conclude that plaintiffs are not entitled to their reasonable attorney's fees under the terms of the Easement Grant. Plaintiffs further claim that an award of attorney's fees is warranted against defendant Honea because her defense of this action was frivolous and groundless. Plaintiffs also request an award of attorney's fees against defendant Garfield County BOCC for its actions in aiding and abetting defendant Honea's frivolous and groundless defense by requiring the plaintiffs to obtain a judicial declaration that the VonDette Road is a public road when the Easement Grant expressly so provides. An award of attorney's fees is discretionary with the court. Hart & Trinen v. Surplus Electronics Corp., 712 P.2d 491, 492 (Colo.App. 1985). The court may award a plaintiff a reasonable attorney's fee against an attorney or party whose defense of a civil action lacks substantial justification as determined by the court. C.R.S. §13-17-102(2). A defense lacks substantial justification is if is substantially frivolous, substantially groundless, or substantially vexatious. C.R.S. §13-17-101; In re Gomez, 728 P.2d 747 (Colo.App. 1986); Shaw v. Baesemann, 773 P.2d 609 (Colo.App. 1998). "Substantially frivolous" means that the proponent's arguments in support of the defense were not rational based on the evidence or applicable law. Western United Realty, Inc. v. Isaacs, 679 P.2d 1063 (Colo. 1984). "Substantially groundless" means that the defense was 25 sufficient to survive a motion to dismiss, but was not supported by any credible evidence at trial. Id. A losing position is not necessarily a groundless one. Torres v. Portillos, 638 P.2d 274, 276. (Colo. 1981). I find and conclude that defendant Honea's arguments in defense of plaintiffs' claims that VonDette Road is an R.S. 2477 Road ora dedicated public road under C.R.S. §43-2-201(1)(a) were supported by the law and the evidence; thus, her defense of those claims was not frivolous or groundless. The crux of plaintiffs' request for attorneys' fees is defendant Honea's position that the VonDette Easement Grant conveyed a public road easement, but that the easement was restricted in use to hunters and recreational users of Forest Service lands. Plaintiffs maintain that Honea's position was not supported by any credible evidence at trial and was irrational under Colorado law. I disagree. In Bd. of Cnty. Comm'rs of Delta Cnty. v. Ogburn, 554 P.2d 700 (Colo.App. 1976), a panel of the Court of Appeals held that when a road becomes a public highway by prescriptive use, the extent of the public easement acquired is limited to the public's historical adverse use. Defendant Honea argued that if a dedicated public road established by prescriptive use could be subject to use restrictions, then the public easement at issue in this case could also be subject to use limitations. Although a different panel of the Court of Appeals rejected the Ogburn decision in Lovvorn v. Salisbury, Ogburn has not been over-ruled by the Colorado Supreme Court. Accordingly, I find that defendant Honea's position did have arguable basis in Colorado law and was therefore not frivolous. Further, there was evidence at trial that the public's historical use of VonDette Road since 1976 has been primarily, but not entirely, as access 26 to Forest Service lands for hunting and recreational purposes. Accordingly, I find that defendant Honea's position was not groundless. I thus find and conclude that plaintiffs' are not entitled to an award of attorney's fees under C.R.S. §13-17-102(2). I further find that plaintiffs are not entitled to an award of attorney's fees against the Garfield County BOCC under C.R.S. §13-17-102(2). The attorney's fee statute does not contemplate an award of attorney's fees unless a claim or defense lacks substantial justification. Garfield County has not taken any position in this case from the outset. Further, the propriety of the County's administrative actions in requiring plaintiffs to obtain a judicial declaration that VonDette Road is a public right of way as a condition to issuance of a timber extraction permit are not at issue in this case. There is no basis for assessing attorney's fees against defendant Garfield County BOCC. IV. ORDER Accordingly, it is ORDERED that: 1. Judgment shall enter in favor of Plaintiffs and against Defendants on Plaintiffs' first claim for relief, as amended by the evidence at trial, that the Easement Grant conveyed by Tom VonDette to the Colorado Division of Wildlife on April 14, 1976 was an express common law dedication of a public road which was accepted within a reasonable time by the United States Forest Service and the general public. 2. It is hereby DECLARED, ADJUDGED, and DECREED that the easement premises described in Section A of the Easement Grant conveyed by Tom VonDette to the Colorado Division of Wildlife on April 14, 1976 (attached as Appendix 1)," is a 'Appendix 1 consists of a certified true and correct copy of the April 14, 1976 Easement Grant from Tom VonDette to the Colorado Division of Wildlife, recorded in the Garfield County Clerk and Recorder's Office (Rec. #272156, Book #484, p. 291), and, a legible true and correct copy of that document, as stipulated to by the parties at trial. 77 public road, open to all lawful public uses by all members of the public, including the Plaintiffs, subject to regulation by the United States Forest Service consistent with the public use. 3. A permanent injunction SHALL ENTER against Defendant Katharine M. Honea prohibiting her, and her agents and employees, from any and all actions obstructing, restricting, hindering, or preventing the Plaintiffs' use of the public road. 4. Judgment shall enter in favor of Defendants and against Plaintiffs on Plaintiffs' second claim for relief that the easement premises is an R.S. 2477 Road. 5. Judgment shall enter in favor of Plaintiffs and against Defendant Honea on Defendant Honea's counterclaim for trespass and nuisance. 6. Plaintiffs' request for attorney's fees is DENIED. 7. Each party shall bear his, her, or its costs. 8. The Clerk of the Court SHALL ENTER final judgment in this matter consistent with this Order. Dated this day of August, 2001. BY THE COURT: GL Cakt1 PATRICIA A. COAN United States Magistrate Judge 28 Civil Action No. 00 -PC -1243 APPENDIX 1 1.• ;•7•‘ r.••••,\ : .:•. •• • • -,••,ot1,o Cite Cranto-, ;I..... • ••••: for th.• use on:1 1:•ol.r.•`.1.t oE thn Itc....c-;ur: • LITV:SIC::: 0,r v7I.LDIFF., ,t. 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' - ' . •:'''..,....-;,• "::::,>,:.::•: .iN-CW T:1Oi‘E, -in consideration of Ten a n'd :no/100 ;1'-•--7 . . receipt- .e.r.d -sufficiency oi w:ttch\i..re hereby aOkno.'ledged, the - Dollars ,(S10. 00) and 'other vs, It:F.1bl c consideration,' the P.,. --• , - .. , . . ...• . .. : • . _ , . • . . • - • , .• . • . - _ . • folloing gr'antS.; acrce:-.'.emts and cc.:enants. and 'reStrictions.„--reg7q1-:.--;f:.:;-T •• • , • . , . .. ..,•. truzzent-::-rinc rig s -,the e n.6 f t u rd e 2/- run .1,4 th • : • • - • - E. t_ t c.; SOt -' _nef pa rt ies,r,to 4, • •„.• •-;-• • • e , . • • 7-1r.n e.. f o :-.6-.711k,e;oth • , - • • ••• • ;:•= • •..: ,E,.trz7. , c../1 .,1,•• • , 1 ' c, • .1. ( • NI -1 rt.• I, 1 C) • • . ;j,,,": 4 • ' • •• • , • . • . . •r r \ r • -„L'-,79 • 2. • ' ..• • .,:-: • • • ". • • '; • • • • • 1-?'? • Cafitfate of Copy of Record STATE OF COLORADO County of Garfield I, Mildred Alsdorf, County Clerk and Recorder in and for said County, in the State aforesaid, do hereby certify that the foregoing is a full, true and correct COPY of EASEMENT GRANT REC#272196 RR14R4 PC,#291 04/14/1978 1-38P as the same appears upon the records of my office. Given under my hand and official seal this 23RD MAY Mildred Alsdorf , A.D. 2 Cb.4, 11:15 day of o'clock A M County Clerk and Recorder Deputy Gr' cZ 7 This E.yS]N} Nr C:R NT is m1c'•e b=twaen Tom Von Dette here- inafter referred to as "tae Grantor," and the State of Colorado P") for the use and benefit of the Department of Natural Resources, IVISIOI: OF WILDLIFE, hereinafter referred to as "the Grantee." The following recitals of fact are a material part of this instrument: A. The Grantor is the owner of land in the County of 'Garfield, State of Colorado described as follows and herein- after reie.rred to as "tho easement premises: Being a strip cf land 30 feet in width across U.E.S. #309 of unsurveyed section 24, Township 7 South, Rance 94 \'est of the 6th Principal Meridian in Gar- field County, Colorado_ Said easement being 15 feet on each side of the following described center line. Beginning at a point on the 1-5 line of II.E. S . 309, from which point Corner Number 5 of H.E.S. 309 hear= Test 171.20 feet; thence along the arc of a curve to the right.having a radius of 220.38 feet for 57.93 feet.; thence south 14°01'15" west 30.11 feel; the:,calong the arc of a cur,:.e to the .left Navin❑ a radius of 286.50 feet for 103.92 feet; thence south 6°46'05" east 205.18 feet; thence south 9°32'29" east 184.44 feet; thence south 7°42'53" east 323.05 feet; thence along the arc of ..curve to the right ?-laving a radius of 286.50 feet for 128.17 feat; thence south 17°55'11" west 60.48 feet; thence along; the arc of a curve to the left having a radius of 286_50 feet for 81.17 feet; thence south 1°40'50" west 82.84 feet; thence south 1°38'58" east 129.70 feet.; thence along the arc of.a curve to the right having a r:;dips of 296.50 feet for 67.67 fez::_ thence south 11'53'10" west 109.85 feet; thence along the arc of a curve to the left having a radius of 236.50 feet to' 271.33 feet; -iioe south 42'22'22" f=ast feet; the n e along tic arc of a curve to the right having a _-:.d_us cj2 230.::0 feet. for 129.39 feet; t?:eJ:ca south 33'54'06" east 13.02 feet; thence along the arc of a cul•:2 to.t e 12ft having a radius of 260.50 '_°Get. for 166.52 f2.eet; tnc:`ce 50"32.:',5" east 61.29 fent an.:11 en: lrq on a loin .on 2-3 line CLE i-i.E.9. 309. FAL 'whin pc,int tai.: Corner i . 2 cf E.E.S. 309 bears r±c•::t:1' 05°:7' `:Je^e 211.413 -et containing 1.6 __ DEFENDANT'S i EyIBIT I ••- q3 • IT. The Gr:nitor wishes to grant and the Grantee wishes to receive an easement for perpetual public road easement ipon, over, under, and across the easement premises. NOW TIiEREFORE, in consideration of Ten and no/100 ars'($10.00) and other valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the following grants, agreements and covenants and restrictions are • made: 1. GRANT OF EASEMENT: The Grantor hereby grants to the Grantee, his successors and assigns, a perpetual easement for a perpetual public road easement upon, the easement premises. 2. WARRANTIES OF TITLE: Grantor warrants that he has good and indefeasible fee simple title to the easement premises. . 3. RUNNING OF BENEFITS AND BURDENS: All provisions of instrument, including the benefits and burdens, run with over, under, and across this the land and are binding upon and enure to the heirs, assigns, uccessors, tenants and personal representatives of the parties hereto. 4. ATTORNEY'S FEES: Either party may enforce this instrument by appropriate action and should he prevail in such ]it3 Tnric,n. 1-1p, ch:yll remove_ as parr of his costs ,.. 1ph.71sonable attcrnev's fee. not apply to this grant. This grant shall be given a reasonable construction so that the intention of the parties to confer a usable right of public enjoyment on the Grantee is carried cut. S. CONSTRUCTION: The rule of strict construction does IN WITNESS WIHEREOF the Grantor and the Grantee have hereunto set their hands this_42:_day of , ].9 %l . GRANTOR ) Tom von De t ie STATE OF COLORADO ) County of ) s. The foregoing instrument was acl:nowledged before me this day of A.U. 19 Lir Tom \rondei:i:e. My corrniist.:ion cxhi.re n Feb. G, 1979. liLriess my 1 e:n:1 arc1 ,ffic3.a]. seal. -2- 1;;o:.7-ry Public IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CERTIFICATE OF MAILING Civil Action No. 00 -PC -1243 The undersigned certifies that a copy of the foregoing Memorandum Opinion and Order dato August30, 2001 was served on August 30, 2001 by: (*) Delivery to; or by (**) Depositing in the United States Mail, postage prepaid, addressed to: James K. Beckwith, Esq. ** 7910 Ralston Road, Ste. 7 Arvada, CO 80002 Timothy E. Whitsitt, Esq. ** Whitsitt & Goss 320 Main St., Ste 200 Carbondale, CO 81623 JD Snodgrass, Esq. Williams, Turner & Holmes, PC 200 N 6th St. PO Box 338 Grand Junction, CO 81502-0338 Michael Hegarty, Esq. Assistant US Attorney DC Mail Box Don K. DeFord, Esq. 109 8th St., Room 300 Glenwood Springs, CO 81601 U.S. Magistrate Judge Gudrun Rice United States District Court 402 Rood Ave., Room 323 Grand Junction, CO 81501 178 Secretary/DeputyJerk BE EXHIBIT FORE THE CITY COUNCIL OF THE CITY OF RIFLE, CuLORADO � OF: OCONCERNING THE APPLICATION FOR A WATERSHED Y KTRTIUCKER; SHARON IL. M D. FRASE; STACEY D. FRASE; DAVE P. FRASE, TUCKER; PAUL R. QUATRARO; AND KAY QUATRARO • FINDINGS OF FACT, CONCLUSIONS OF LAW AND APPROVAL OF WATERSHED DISTRICT PERMIT NO. 1-97 I. BACKGROUND 1. On May 28, 1996, as supplemented by a letter dated July 17, 1996, the Tucker and prase Partnership filed an application with the City of Rifle pursuant to Ordinance No. 22 (Series No. 1994). The application was filed on behalf of the 1797, Applicant by DCiv d EE. Levi, Professional Forester, 305 Railroad Avenue, Suite 7, P.0.. 95959. By letter dated May 6, 1997, the Applicants, Tim D. Frase and Stacey D. Frase, Dave Paul R. and Kay Quairaro, whose address is c/o P. Frase, Clay K.. Tucker, Sharon L. Tucker, California 96002 (phone number Tim Frase and Dave prase, 1805 Hilltop Drive, fo Redding, applicant Tucker and Frase 9116-223-2900) , were substituted as app pP Partnership. Accompanying the application was a document entitled Tepee Park Forest Colorado, prepared by David Levy Forestry Services dated Management Plan, Garfield, County, representatives have met March 1995. Following the receipt of the application, the Applicant's gout limitation Tim with the staff and consultants of the City of Rifle, Colorado, including Moore, City Engineer, and Paul Bussone and Scott Fifer, Consulting Professional Engineers, Colorado. A public meeting for informational Resource Engineering, Glenwood. Springs, also needs a Special Use Permit purposes was held October 2, 1996. Because the Applicanto road from the U.S. Forest Service to allow for the construction and om realignment id County to allow the through Forest Service land, as well as a Special Use Perms Applicant to conduct loggia activities on the property, action on the Watershed District permit was held in abeyance with the Applicant's consent pending further progress on the other permits. As a result of the need for other permits, the City and the Applicant have worked to coordinate their respective permitting clog ley with the U.S. Forest Service and Garfield County staff Special Use processes. To date, the U.S. Forest Service has not enurudecision on the from the Garfield County Permit request. The Applicant did obtain a favorable recommendation Planning and Zoning Commission. To date, the Board of County Commissioners has not yet acted on that recommendation, and the request for a Special Use Permit from the County is still pending as well. II. FINDINGS OF FACT 2. Aortion of the proposed activity is within the defined boundaries of the Cit er Watershed District as defined in Section 10.05.020 of the Rifle Municipal Coder( Ies ofthe "Rifle Code"), specifically the Beaver Creek drsinage above and within five (5) E:I9.1FLED.2MS May 9. 1997 tivity within the City's Beaver Creek municipal diversion structure. The proposed de acctiviry outside the District. District cannot be functionally or practicably separated 3. The application as supplementedby the Applicant is complete. The application the Tepee Park Forest consists of correspondence dated May 28, 1996, and July 17, 1996, Management Plan (Garfield County, Colorado) prepared by David Levy Forestry Services, Nevada City, California, dated March 1995. Also, a Tepee ParkForest sCity�Cal formal and agement Pan tan April 1996, prepared *by David Levy Forestry Services, accompanying Water Quality Plan for Tepee Park Forest Management Plan (undated) was submitted which supersedes the March 1995 Plan. The April revi1996 rest Management of the Plan, as supplemented by the Water Quality Plan, constitutes th Applicant to mitigate any adverse water quality impacts under the City's Watershed District Ordinance. 4. The Applicant has paid all fees required by the Ordinance. 5. A duly noticed Public Hearing was held on April 16, 1997. At the hearing, the Applicant presented the Tepee Park Management Plan in detail, together with the Water Quality CityTim by Moore, Plan as proposed by the Applicant. In addition, testimony was presented Engineer, and Scott Fifer, Consulting Hydrologi to the Cityof Rifle. The City Engineer testified that, pursuant to his review under Section 10.05.050(2)(e), the proposed activity posed a foreseeable and significant risk and injury to the City's water works, and pollution to the City's water supply, and recommended that the City Council issue the permit with the de his credentialsdiastions set forth in Scott Fifer's letter dated March 31, 1997. Mr.1995 expert hydrologist and presented into evidence letters datedFAugust 5, ifer presented 1996,exAugust testimony 199 , July 31, 1995, April 12, 1995, and March 21, Plan anMr. recommended conditions of approval, regarding modifications to the Water Quality together with his expert opinions as to why those tiooc� a�spa resulwere the proposed to mitigate impacts to the Beaver Creek Watershed thatmay activity and the need, under Ordinance 12, to require such conditions of approval. 6. Mr. Fifer also testified that, if the Applicanticomplies Fifer'swith lettertdated March e terms and conditions of the Management Plan the Water Quality Plan, an 31, 1997, (copy of which is attached hereto and incorporated by reference) the Applicant would be exercising Best Management Practices and that the potential for risk and injury to the City's Fifer further . d. water works and pollution to the City's water supply would be mitigatetype of logging testified and introduced exhibits regarding studies that demonstrate that, the crino flows on increase the quantity of water by in proposed by the Applicant would actually g ecrease in the rising side of the hydrograph and by slightly. increasing peak flows, without any ddere were • late irrigation season or winter flows. Finally Mr. Fifer indicated he and the Appli negotiating modifications to Paragraph 3(B) of his March 31, 997, letter. 7. Mr. David Levy, on behalf of the Applicant, presented testimony confirming Mr. Fifer's testimony and also asserting that the construction of the proposed logging roads would help in fighting forest and wild fires and help reduce fire rianger risks. E:\RIFLm.2.Ms May 9, 199'7 -2- 8. In addition to the testimony of the City staff and the City's consulting hydrologist, imon was also taken from members of the public. Testimony from the public was both in test Y favor and against the proposed activity and issuance °uesuonedatandhchallDenged the effectistrict t t. and Testimony against the activity was lay testimony only 4 of the proposed activity on water quality and water quantity. 9. By letter dated April 22, 1997, (a copy which is attached hereto and incorporated herein by reference) Mr. Fifer modified Condition No. 3(B) of his letter dated March 31, 1997, and represented that this modification was consistent with Best Management Practices and had been agreed to by the Applicant. • 10. The City Council finds that the Applicant's water quality mitigation plan, and as outlined in the Tepee Park Management Plan dated April 1996 and supplemented by the Water Quality Plan, and as supplemented and modified by the conditions of approval contained in Scott enient Practices for the Fifer's March 31 and April 22., 1997, letters constitute the Best &'lanag proposed activity. 11. City Council hereby finds and determines that theis ace of t e datedMarch permit r31equires the inclusion of conditions, as more fully set forth in Scott Fifer's 1 97, as modified by Mr. Fifer's letter dated April 22, 1997; and that such conditions are. necessary City's water works and pollution of the City's water supply, to prevent a risk of injury to the ursuant to Sections 10.05.050(4) and (5) of the Rifle and that such conditions are authorized p Code. III. CONCLUSIONS OF LAW AND ISSUANCE OF PERMIT 12. The foregoing Findings of Facts are incorporated herein by reference. 13. The City Council of the City of Rifle has jurisdiction over the proposed activityossible to differentiate pursuant to Section 10.05.020 of the Rifle �Code.eaterBsh�ed Dict and because the activity between the activities within and outside constitutes an integrated activity, this permit shall apply to all the activities of the Applicant within the Beaver Creek Watershed. 14. Based on the evidence presented at the Public Hearing and, in particular, the ulting testimony and exhibits of Tim Moore, City Engineer, and Scott Fifer, constituteconstitute City's aCW ns rsheg Hydrologist, the City Council hereby determines that outlined � the at this decision Tepee park Forest Colorado) prepared by David Levy district permit for the proposed logging activity as more fully Forestry Services Management Plan (Garfield County, � Water Quality (Nevada City, California) dated April 1996, together with the accompany gMr Fifer in his Management Plan, as modified by the conditions of approval recommended by letter dated March 31, 1997, as modified for condition 3(B) by Mt. Fifer's letter of April 22, 1997which conditions of approval contained in said letter are hereby approved and adopted by , the City Council as conditions of approval of this permit. 15. The bond required by condition 3(F) Mr. Fifer's March 31, 1997, letter shall be 1:\RIFLID.ZMS Mn 9. 1947 -3- e in the initial amount of 5100,000 which the City Council h r bey finds s ndvidetermines ete aiannuallysto ae adequate for the first year of the proposed activity. Thecondition 3(E) and increased or part of the annual meeting and operating plan required by decreased as appropriate. The form of the bond shall be first approved by the City Attorney prior to the commencement of any activity. 16. Any violation of the terms and conditions of the Management Plan, the Water Quality Plan, the conditions of Mr. Fifer's letter of March 31, 1997, as modified by Mr. Fifer's letter of April 22., 1997, or any other terms and conditions of this permit, which default is not cured or removed within ten (10) days after notice by the City shall be deemed a violation of this Permit entitling the City to take any pursue any and all remedies available, including without limitation calling on the surety bond to undertake remedial work; eal work and any enfoovided however rcement action t the Applicant shall be solely responsible for all the costs of such action by the City, including reasonable attorney fees and •costs. 17. The forest management practices of the Applicant and compliance with this permit consultant agreed upon by the Board of County • a will be monitored for compliance by Commissioners and the City of Rifle and the Applicant, and paid for by the Applicant. 18. Pursuant to Section 10.05.050(6), unless an extension is requested prior to the expiration date, if the proposed activity for which this permit is issued is not commenced within 12 months from the date of this permit, this permit shall expire and become void. 19. A copy of this Decision and Permit shall be sent by certified mail, return receipt requested, to the Applicant. 20. The City reserves all remedies contained in Sections 10.05.060, 10.05.070, and 10.05.090 as additional remedies for violations of the permit conditions. 21. This permit. shall expire on December 31, 2003, unless an extension is requested and approved by the City Council prior to the expiration date, following a review and public hearing of the Applicant's compliance with the permit conditions: provided,hhowever,,hnethe in bond required by Condition No. F in the Fifer March 31, 1997, letter o f 1l emainactivity to ensure that • agreed upon amount for a period of two years after the termination all revegetation and required mitigation continues. 22. This permit may not be assigned or conveyed by the Applicant without the prior written consent of the City. 23. This permit shall not be effective until agreed to and approved by the Applicant as evidenced by its signature below. - E:VUF1 ED.1M5 May 9. 1997 -4- Dated this ---- day of May, 1997. ATTEST: CITY OF RIFLE, COLORADO By ,T)./6\ -� Mayor City Clerk Accepted and agreed to this day of May, 1997. APPLICANTS: Tim. D. Frase Stacey D.l rase Sharon L. Tucker "? .e--.. Paul R. Quati`aro Dave P. Frase Kay Quatraro'� Cl‘r K. Tucker E:\RIFLED.2MS May 9. 1997 • -5- MI*1111R ES riU RCE • ■■ ■ili■■ �i10�■ E N G I N E E F; I N G I N C. Mr. Tim Moore City of Rifle PO Box 1908 Rifle CO 81650 March 31, 1997 RE: Tucker/Frase Application for a Watershed District Perrnit, City of Rifle Tepee Park Timber Management Plan Dear Tim: Resource Engineering, Inc. (RESOURCE) has completed a review of the Tucker/Frase Application for a Watershed District Permit to conduct logging operations within Beaver Creek Municipal Watershed. The review was completed pursuant to the guidelines and criteria established in the City of Rifle's Watershed Protection Ordinance (Ordinance No. 22, 1994). This letter provides a summary of our findings. The documents that we reviewed included; the City of Rifle's Watershed Ordinance (No. 22), the Tepee Park Forest Management Plan (David Levy Forestry Services, March, 1995 and April, 1996), and a report entitled Geologic and Geotechnical Engineering Feasibility Review prepared by Hepworth, Pawlak Geotechnical, Inc. (September 15, 1995). In additional, we have completed a site review with the applicant's foresters and have collected several water quality samples of Beaver Creek in proximity to the proposed logging operation. We have previously documented our preliminary review and recommendations in letters addressed to you dated March 21, 1995 and August 5, 1996. BACKGROUND INFORMATION In March, 1995 the City of Rifle requested RESOURCE to complete a review of the Applicant's original Tepee Park Timber Management Plan. Based upon that review, we concluded that the proposed logging operations •entailed extensive land disturbing activities that if not properly constructed, could adversely impact the City's municipal watershed. Accordingly, we recommended that the Tepee Park Timber Management Plan be evaluated under the City's municipal watershed ordinance and that a permit be issued or denied based upon the full analysis of potential impacts (see RESOURCE letter 3/21/95). Our letter also contained a request for additional information from the Applicant. In response to the concerns and recommendations outlined in the RESOURCE letter, the Applicant submitted an updated Timber Management Plan (April 1996). Our preliminary review of that plan was documented in a letter to you dated August 5, 1996. As outlined in that letter, we believe the Applicant made a good faith effort to incorporate our recommendations and request for additional information in the updated Timber Management Plan. We also noted, however, that the plan lacked specific detail and needed strengthening in certain areas. These deficiencies are identified in the following section entitled "Conditions of Approval." Consulting Engineers and Hydrologists 909 Colorado Avenue ■ Glenwood Springs, CO B1601 ■ (970) 945-6777 ■ Fax (970) 945-1137 Mr. Tim Moore City of Rifle Page 2 March 31, 1997 CONDITIONS OF APPROVAL Should the City Council elect to issue a Watershed District permit to allow logging activities within the Beaver Creek municipal watershed, we recommend that the following conditions of approval be incorporated in the permit. The conditions are necessary to help insure protection. of the City's municipal water supply as required under Ordinance No. 22. 1. The Applicant shall be in compliance with conditions contained in all Federal, State or County permits necessary to implement the Tmber Management Plan. 2. The Applicant shall implement the Best Management Practices and Water Quality Management Plan contained in the Tepee Park Timber Management Plan (April, 1996). 3. The following new conditions and/or modifications to the existing Timber Management Plan will be required as part of the Watershed District permit. A. Watercourse Protection Measures, see pages 66, 67 of Timber Management Plan The watershed protection zones outlined on pages 66 and 67 of the Timber Management Plan need to be expanded in order to adequately protect the riparian areas and water quality of Beaver Creek. The following modifications are recommended: 1. A 25 foot Watercourse Protection Zone, (WPZ) will be established adjacent all Class I and Class I1 streams. This means no timber harvest will occur within 25 feet of the stream as measured horizontally from the top of the bank. A diagram of the "top of bank" is shown on page 67 of the Timber Management Plan. Presently the Timber Management Ptarl contains a 25 foot WPZ for Class I streams only. 2. Equipment exclusion zones (EEZ) will be established as follows: Class I Stream - Class II Stream - Class III Stream - 100 feet 50 feet 25 feet RESOURCE ■u.m ■off■ E N mi N EE P I N m. I N Mr. Tim Moore City of Rifle Page 3 March 31, 1997 No equipment will be allowed within these zones except at designated road crossings or along existing roads located with the zone. The setback will be measured horizontally from the top of the bank of the watercourse. Presently, the Timber Management Plan contains a 50 foot EEZ for Class 1 and Class 11 streams only. B. Revegetation Plan, page 57 The revegetation plan (page 57) indicates that only road cuts and fills within 200 feet of a perennial watercourse (Class I stream) will be seeded and fertilized. This is inadequate and must be expanded to include all road cuts and fills. Furthermore, all other disturbed sites such as log landing areas, temporary haul roads and borrow areas will also be reclaimed and revegetated. Straw mulch should be applied to sites at a rate of 2 tons per acre and should be certified "weed free." All mulch should be either crimped into the soil by mechanical or hand methods or held in place by an organic mulch tackifies. to prevent it from blowing away. A plastic or paper fiber mulch netting cover over the mulch may be used as a substitute. The selected seed and fertilizer mixture shall be reviewed and approved by the U.S. Forest Service. Revegetation efforts will take place concurrently with road construction activities. Road cuts and fills will be.seeded and mulched within 15 days after final construction grading. Other areas, such as log loading areas, shall be reclaimed and revegetated within 15 days after equipment has been removed from the site. C. Road Construction All road construction activities will follow the geotechnical guidelines outlined in the September 15, 1995 geologic report prepared for the Applicant by Hepworth-Pawlak Geotechnical, Inc. Water Quality Plan, Appendix to Forest Management Plan As part of the Applicants water quality plan, stream monitoring will begin during the spring of 1997. Monitoring stations will be esta i shed ead d on Seaver Creek upstream and downstream of planned logging and D. RESOURCE E N G I N E E R I N G I N C Mr. Tim Moore City of Rifle Page 4 March 31, 1997 construction activities. The stations should coincide closely with those previously established by the City of Rifle. Baseline Monitoring. Beginning in May, 1997, paired samples of stream turbidity will be measured at each site twice a week. This data will be combined with past monitoring results by the City of Rifie to establish baseline water quality conditions. The objective of the monitoring is to collect a sufficient data base to allow statistical analysis of pre and post development water quality during various times of the year. A staff gage will be installed at each site to record water depth. During each site visit, stream discharge will be measured at each site and a corresponding water stage (depth) recorded. This will allow the Applicant to develop a stage/discharge relationship at each station. Once the relationship is established (8 measurements over a range of flow conditions), future investigators will be able to read the staff gage and accurately estimate streamflow. In addition to turbidity measurements, an expanded sampling program will be conducted once a month, May through September. The parameters to be monitored monthly are shown in the attached summary table entitled Beaver Creek Logging Operation, Water Quality Monitoring. The baseline data will be used to establish existing relationships between the upstream and downstream sites for, the selected water quality parameters. Because contributing watershed area and streamflows are similar at the two stations, Beaver Creek should exhibit a predictable relationship between sampled parameters. Attachment 1 displays the relationship between paired turbidity readings collected from a similar stream system associated with a different project. As is evident from inspection of Attachment 1, a strong relationship exists between the turbidity at the two sampling sites. As turbidity increases at one site there is a corresponding increase at the other site. A similar relationship is probable on Beaver Creek. As sufficient information is collected a regression equation expressing the relationship similar to that shown in Attachment 1 can be developed. Also, a 95 % confidence interval of the relationship can be described. This confidence interval provides an expected range of water quality values at the downstream site based upon what was observed upstream. At a 95% confidence interval, there is a 95% probability that the downstream sample will lie within the defined range. If the downstream value exceeds the expected range, it is highly probable that some process is changing the water quality relationship in Beaver Creek. Detection of a change outside of the 95% RESOURCE E N G I N E E P I N G i N C Mr. Tim Moore City of Rifle Page 5 March 31, 1997 confidence interval would initiate a response from the Applicant's water quality control officer designed to identify and mitigate any water quality problems. Monitoring During Construction and Logging Operations. Potential water quality problems will be greatest during road construction and timber harvest. During this period, soils will be exposed to potential erosion resulting from thunderstorm activity in the summer and snowmelt runoff during the spring. Accordingly, the field monitoring of turbidity shall be continued so that problems, if any, can be detected early and mitigation measures taken. During road construction and logging operations, bi-weekly readings 'of stream turbidity at the upstream and downstream sites shall be taken. In addition, during heavy thunderstorm activity, turbidity shall be measured at the sample stations both during and immediately following storm events. Turbidity was selected because it can quickly be determined in the field and is relatively inexpensive to measure. This will eliminate delays associated with sending samples to a laboratory. If problems are detected, mitigation can be initiated immediately. Further, turbidity was selected because it is closely related to total suspended solids, which is the most likely pollutant that could be produced during construction and logging activities. The Applicant will provide the City with a summary of its monitoring results on a monthly basis. A significant increase in turbidity between the upstream and downstream sampling stations indicates that 'pollution is probably occurring from activity within the upper basin. A significant increase will be determined by the regression equation described previously (Attachment 1). If the upstream/downstream relationship between turbidity falls outside the expected 95% confidence interval, a water quality mitigation plan shall be initiated. The first step in the plan is to immediately repeat the sampling at both sites to ensure the results were not due to sampling error. If the second sample reading is also outside the 95% confidence interval, the water quality officer shall immediately notify the City of Rifle and inspect the property to identify the source of sediment and implement a plan to mitigate its impact. Mitigation could include construction of additional sediment traps, filter fences and other structural or nonstructural controls discussed in the water quality plan. The City will, on occasion, monitor Beaver Creek turbidity at the established monitoring sites. The data will be compared to the Applicant's monitoring results to ensure consistency in field sampling and test equipment. RESOURCE ENGINEERING INC Mr. Tim Moore City of Rifle Page 6 March 31, 1997 E. Annual Meeting and Operating Plan By March 15th of each year, the Applicant will submit a proposed operating plan for the upcoming logging season. The plan must be reviewed and approved by the City prior to any road construction or timber harvest activities planned for the following year. The plan would contain as a minimum the following items. 1. A map of proposed road construction activities accompanied by a description of expected site conditions including soils, geology and land forms. Include discussion on proposed construction and revegetation techniques. 2. A map of the planned logging activity for the upcoming year. 3. Identification of any changes in key personnel including Project Forester or designated Water Quality Control Officer. 4. Updated inventory of erosion control materials maintained on site (Le. stream banks, filter fence, rock rip rap, etc.) 5. Provide a summary of the previous years revegetation efforts. Discuss whether or not changes are needed in seed mixture, application rates or general revegetation procedures. Identify areas that did not take and describe plans to initiate additional revegetation efforts. 6. Provide a summary of the previous years water quality monitoring results. On or about April 1st, the City and the Applicant shall meet to discuss the annual operating plan and to review the prior years compliance with the permit conditions. Once the City is satisfied that the App licants have met the required conditions, the annual operating plan shall be approved and additional work can commence within the Beaver Creek watershed. F. Surety Bond As provided in Section 10.05.050(5) of the City's Watershed Ordinance we recommend that the Applicant post a surety bond in an amount RESOURCE N GINE E RING I N C • March 31, 1997 Mr. Tim Moore City of Rifle Page 7 sufficient to insure compliance with the District permit. The purpose of the bond is to allow the City to step in and take corrective action should the Applicant default on the permit conditions. Specifically, the bond should be in an amount that would allow the City to reclaim and revegetate any areas left in a disturbed state and to offset the increased. treatment cost to the City in the event it is forced to use its Grand Mesa Treatment Plant. The amount of the bond shall be reviewed and adjusted annually as plans and conditions dictate. The initial bond for year 1 should be set at approximately $100,000. We hope that the information contained in this letter will be helpful to you and City Council in further review of the Tepee Park Timber Management Plan. Sincerely, RESOURCE ENGINEERING, INC. R. Scott Fifer Hydrologist RSF/mmm 341-1.2 tmwatershed.341 CC: Mr. Lee Leavenworth RESOURCE E N G I N E E P, N G i N C. tis■* mu r1 iii■na E .RE RESOURCE ..... ■��/■ E N G I N E S Fq i N G I N C. Mr. Tim Moore City of Rifle PO Box 1908 Rifle CO 81650 RE: Tepee Park Timber Management Plan, Revegetation Requirements Dear Tim: April 22, 1997 The purpose of this letter is to describe the revegetation requirements recommended for the Tepee Park Timber Management Plan. These requirements were discussed with the Applicant and their professional forester, David Levy on April 16, 1997. 1. All new road cut and fill slopes will be revegetated and fertilized. The seed mixture and application rate shall be approved by the U.S. Forest Service. Revegetation efforts will take place concurrently with road construction activities (within 15 days of final construction grading). 2. The seed will be broadcast applied at the prescribed rate and raked (drag/harrow/chain) into the soil. 3. Cut and fill slopes within 300. feet of a Class 1 stream and within 200 feet of the Class 11 stream will be mulched with clean, weed free, straw at a rate of 2 tons per acre. The mulch should be either crimped into the soil by mechanical or hand methods or held in place by ari organic mulch tackifer. 4. Other disturbed areas such as major skid trails, landing areas, etc. will also be revegetated when logging activities cease. These areas will be reclaimed (graded and water barred as necessary) and revegetated within 15 days after equipment has been removed from the site. Please give me a call if you have any questions concerning the recommended revegetation requirements. Sincerely, RESOURCE ENGINEERING, INC. R. S tt Fifer Hydrologist RSF/mmm 341-1.2 tmrevep.341 CC: + If: Lee Leavenworth Mr. David Levy LEAVENWORTH & ASSOCIATES, RC. Consulting Engineers and Hydrologists 909 Colorado Avenue Is Glenwood Springs, CO B1601 ■ (970) 945-6777 ■ Fax (970) 945-1137 BEFORE THE CITY COUNCIL OF THE CITY OF RIFLE, COLORADO EXHIBIT 8 CONCERNING RIFLE WATERSHED DISTRICT PERMIT NO. 1-97 HELD BY INTERMOUNTAIN RANCHES, LLC FINDINGS OF FACT, CONCLUSIONS OF LAW AND AMENDMENTS TO RIFLE WATERSHED DISTRICT PERMIT NO. 1-97 I. FINDINGS OF FACT 1. Rifle Watershed District Permit No. 1-97 (the "Permit"), issued by the Rifle City Council to Tim D. Frase, Stacey D. Frase, Dave P. Frase, Clay K. Tucker, Sharon L. Tucker, Paul R. Quatraro and Kay Quatraro (the "Original Applicants") became effective on May 22, 1997. 2. The Permit allowed for certain logging activity to be conducted within the Beaver Creek Watershed pursuant to various terms and conditions set forth therein and in attachments thereto. 3. The Original Applicants assigned their rights and obligations under the Permit to Intermountain Ranches, LLC on October 15, 1997, and said assignment was approved by the City of Rifle on the same date. 4. As of October 15, 1997 Intermountain Ranches, LLC, a Colorado limited liability company of which Mr. Chris Meyers is a member, owned the real property (the "Subject Property") on which the logging activity is to occur, as well as the timber harvest rights associated with the Subject Property. 5. On November 5, 1998 Intermountain Ranches, LLC executed a Timber Deed whereby it conveyed certain timber harvest rights for the Subject Property to Intermountain Resources, LLC, a Colorado limited liability company of which Mr. Meyers is a member. 6. On February 10, 1999 Intermountain Ranches, LLC conveyed the fee title ownership of the Subject Property to LeeLynn, Inc. and Wiley Mountain, Inc., two Oregon corporations whose principals are also members of a member of Intermountain Resources, LLC. 7. By a separate lease agreement to be reached between the Permit Holders, LeeLynn, Inc. and Wiley Mountain, Inc. shall agree to provide Intermountain Resources, LLC access to the Subject Property in order to harvest timber pursuant to the Timber Deed and F:11999\Resolutions\RIFLE-1-97-amendment.wpd -1- subject to the management and oversight of Intermountain Ranches, LLC. 8. No logs have been removed to date, but the parties expect such activity to begin in 1999. 9. The Permit should be amended to identify the additional parties involved in the management and operation of the logging activity contemplated by the Permit, subject to all of its original terms and conditions as well as the conditions and clarifications listed below, and to further provide that the Permit is still valid. II. CONCLUSIONS OF LAW AND AMENDMENTS TO THE PERMIT 10. The City incorporates the foregoing recitals as findings and determinations by the City Council, and conclusively makes all of the Findings of Fact, Determinations and Conclusions contained herein. 11. An undivided interest in the Permit shall be assigned by Intermountain Ranches, LLC to Intermountain Resources, LLC, LeeLynn, Inc. and Wiley Mountain, Inc. to properly reflect the identity of the four parties (collectively referred to herein as the "Permit Holder") involved in logging activity pursuant to and in reliance upon the Permit, and such assignment is hereby approved. 12. As soon as possible, but in no event later than July 1, 1999, the Permit Holder shall submit its proposed logging plan for 1999 to the City's Consulting Engineer, Resource Engineering Inc., with copies to the City Manager and City Attorney. The City Engineer shall use his best efforts to notify the Permit Holder of objections to the plan within 14 days of receipt, however, if the City Engineer fails to do so respond within 30 days of receipt, such plan shall be deemed approved. 13. The Permit requirement of twice -weekly baseline water quality monitoring, consisting of turbidity measurements at various flow levels on distinct points along Beaver Creek, shall be conducted for four to six weeks, as determined by the City's Consulting Engineer, prior to the commencement of any logging activity. Such water quality monitoring shall be at the Permit Holder's sole expense. 14. The monthly extended baseline water quality sampling program required by the" Permit shall commence as soon as practicable and shall continue until five samples have been taken. At least one sample must be taken prior to the commencement of any logging activity. Such water quality monitoring shall be at the Permit Holder's sole expense. 15. The ongoing water quality monitoring required by the Permit (bi-weekly and storm event turbidity testing) shall occur at the Permit Holder's expense, but may be subject to F:\19991Resolutions\RIFLE-1-97-amendment.wpd -2- cost-sharing with other active permit holders within the Beaver Creek Watershed. The burden to negotiate such cost-sharing rests solely upon the Permit Holder and the other active permit holders and, in the event a cost-sharing agreement cannot be reached, each permit holder is responsible to conduct whatever water quality monitoring is required under its permit. 16. The $100,000 performance bond required by the permit shall be posted in a form suitable to the City Attorney and provided to the City Manager prior to the commencement of any logging activity. 17. The reasonable costs incurred by the City of Rifle in amending the Permit as provided for herein and ensuring that the Permit Holder begins to comply and continues to comply with the terms and conditions set forth herein and in the Permit, including without limitation attorney fees and engineering fees not listed in paragraphs 13 and 14 above, shall be borne by the Permit Holder. 18. Subject to approval by the Board of County Commissioners of Garfield County, the Permit Holder shall hire Bill Gherardi of Woodland Management Consultants, Fort Collins, Colorado, or such other consultant as the parties may mutually agree upon, to act as the forest management practices compliance consultant required by the Permit as well as the erosion control/water quality supervisor required by the Permit. 19. Unless an extension is requested and granted, the Permit shall expire and become void if the log removal is not commenced by November 20, 1999. 20. Any notice to the City required by the Permit or this Amendment shall be provided to: Selby Myers, City Manager, 202 Railroad Avenue, Rifle, CO, 81650 Lee Leavenworth, Esq., City Attorney, 1011 Grand Ave, Glenwood Springs, CO, 81602 Paul Bussone, Consulting Engineer, 909 Colorado Ave., Glenwood Springs, CO, 81601. 21. Any notice to the Permit Holders required by the Permit or this Amendment shall be provided to: Chris Meyers, 11925 6530 Road, Montrose, CO, 81402 J.D. Snodgrass, Esq., 200 N. 6th Street, Grand Junction, CO, 81502-0338 Larry Gildea, Esq., 38437 Dexter Road, Dexter, OR, 97431. 22. This Amendment was discussed at a duly noticed public hearing of the Rifle City Council at the Rifle City Hall on June 16, 1999. 23. This Amendment shall not be effective until agreed to and approved by the Permit F:\19991Resolutions RIFLE-1-97-amendment.wpd -3- -I.oldt.r and '..he City i $ t-;Vidst ced by their re.snective below. 24. Fa.Csimi sigrv;rares cr on behalf of any r.3arty ti? this Amer: roam^.i shall be effective s.:- ..i purposes. 25. Except as expressly modified herein. the :c:rr:s ar;4 condi:ions of Rifle Watrsl'ccd Dist-ria Per:nit No. 1-97 shall remain in Tun fcorce and eff cr. C''_'w' )F .RIFT.E, COLORADO AGREED TO BY: WILEY MOUNTAIN, INC.. 3Y: Mr. Nn_-:nan2 ti.lvf ougal INTERMOUNTAIN RANCHES, LLC 1N E_MO"' AIN RESOURCES, LLC 1 VAIAgrsnh:dnpnk1R:.L• n»-.urea:mcu xr- . Mr. Chris Mev JUti. 1: 99 ;FR:: 09:46 Co/NUN:CA:IO Nz:44 PACE. 7 EIlII ..■■ I ■R E ■■.■■ ■UI E N G I N E E R I N G I N C. James Neu, Esq. Leavenworth & Tester PC PO Drawer 2030 Glenwood Springs CO 81602 RE: City, of Rifle Watershed Permit No. 1-97 Intermountain Resources, LLC Dear Jim: EXHIBIT c June 14, 2001 At your request we reviewed the proposed renewal of Rifle Watershed Permit No. 1-97 held by Intermountain Resources, LLC. We have no specific comments or changes other than those we conveyed during our meeting but we would like to offer the following general information. 1. The baseline and extended baseline water quality data collection, required by paragraphs 13 and 14 of the amended permit dated June 11, 1999, has been completed. 2. Additional water quality sampling is required to be on-going during all phases of the road construction, logging activity and reclamation and is the responsibility of the permit holder. 3. The proposed 1999/2000 logging plan was reviewed by RESOURCE and we recommended approval of the plan. Some of the work was completed but it is our understanding that no actual logging was done. We recommend that Intermountain Resources submit an updated 2000/2001 logging plan for our review and allow 30 days for the review process prior to any logging activity. 4. We suggest that Intermountain Resources be reminded of the requirements outlined in the March 31, 1997 Resource Engineering letter, which was a part of the amended permit and we recommend that it be a part of the new permit. We see no reason to change any of these requirements. 5. During our inspection of the 1999 road construction activity we found that some of the silt fencing had been improperly installed. We suggest that RESOURCE conduct at least two inspections of the logging activities per year to assure compliance with the watershed protection requirements. Consulting Engineers and Hydrologists 90J Colorado Avenue • Glenwood Springs, CO B1601 ■ (970) 945-6777 ■ Fax (970) 9_45-11 37 LS l l 5V6 0L6 ON I d33N I ON3 332:110S3d 1,10dd WdEZ = V l ez-V l -6 James Neu, Esq. June 14, 2001 Page 2 We will attend the Rifle City Council meeting on Wednesday, June 20, 2001 to answer any questions Council may have at that time_ Sincerely, RCE ENGINEERING, INC. Paul S. Bussone, P.E. Water Resources Engineer PSB/mmm 341-10.1 jn intermtn permit.341.wpd E 'd RESOURCE C N G N Cr N C i N C LEII SV6 OL6 ONIdSSNIONS 33df10S3b WOdd WdVZ V leZ-VI-S