Dear Mayor McKibbin and Eagle Town Trustees,

When Eagle taxpayers voted for the Eagle Whitewater Park, they did so under the premise that the town river park will “improve and conserve natural areas, open spaces and wildlife habitat; protect and improve water quality in the Eagle River.” This was in the first sentence of the ballot initiative and was pointed to often during the campaign. Recent newspaper articles and the town’s own Eagle Eddy newsletter are touting the wonderful improvements to fish habitat. In fact, the Eagle Eddy’s January edition stated “The river, riparian zone health and fisheries continue to be a priority for the project team and the Town of Eagle. This is and has been a key focus on the design, construction and completed park.”

Eagle River Watershed Council has not seen these stated priorities come to fruition. Instead, we have seen element after element that was designed to protect the river, riparian areas, and the fishery eliminated from the plan or significantly reduced. We believe, however, it is not too late to achieve the goals voted for by the community and expressed by the Town. I will outline here our three areas of concern (the lack of: riparian revegetation, stormwater mitigation and fish passage) as well as, solutions for each of these.

Throughout the planning process the Watershed Council participated as one of the many stakeholders. We repeatedly stressed the importance of the riparian area in maintaining water quality and conserving natural habitat. In every meeting we brought attention to this need, and the other stakeholders/community members present agreed that this was a priority. When the design plans came out, we were satisfied to see that the Town and project designers listened to this suggestion and riparian revegetation plans were included.

In reality, we have found that in an effort to meet the Army Corps of Engineers’ permit requirements, the Town spent $50,000 of the park funds (taxpayer dollars) to buy wetland credits in the Yampa River watershed near Steamboat Springs, the Town has stated that this has relieved the Town from their obligation to revegetate the project here in Eagle. These funds could have purchased diverse native plant species like currents, dogwood, native roses, cottonwoods and more for our park. The wetland credits purchased may improve water quality and habitat in the Yampa River, but they will do nothing for our local Eagle River.

When the Watershed Council asked about this discrepancy, the project team explained that although they are not obligated to do any riparian revegetation in the project area thanks to the purchase of wetland credits, they do think it is important- though they have no revegetation plan in place. The project team explained that last fall, while a contractor waited for materials to arrive on site, one employee installed willow stakes (unrooted saplings) around the project area. We appreciate this effort as we often use this method in conjunction with other revegetation procedures; however, putting in a few saplings in a completely denuded area is just one small aspect of what should be a comprehensive revegetation plan.

The project proponents have repeatedly stated that this section of the river was degraded due to the impacts of the Interstate 70 construction and river realignment. We have heard recent arguments that the riparian area was non-existent previously, and therefore the lack of the revegetation is not a degradation. However, this project was sold to taxpayers as improving a degraded stretch of river–as it currently stands, the community is not going to gain these benefits. Additionally, prior to the project start there were not large expanses of exposed soil where erosion and noxious weeds were of concern- there is now.

Upon seeing the large amount of exposed, denuded streambanks, Colorado Parks & Wildlife (CPW) has committed to pursue grants and provide assistance with revegetating this riparian area collaboratively with the Watershed Council. Without meaningful revegetation, risk of erosion increases along with potential impacts to water quality, and a high potential for significant noxious weed growth that could compel the use of pesticides on the river bank. It is discouraging and troublesome that tax funds were collected specifically to avoid these adverse outcomes, and now a state agency and local nonprofit must see the job through.

Our second concern involves stormwater management, which was to include a rain garden in the middle of the terraced upland park area. The rain garden could provide a beautiful landscape of native, low-water and low-maintenance flowers and plants that would receive snowmelt and rain runoff from adjacent parking lots and paths and filter the water through the soil before it ever reaches the river. Filtering runoff water can significantly reduce water quality impacts from stormwater contaminants. Due to apparent overspending on the whitewater features, this was eliminated from the plans. However, the project team explained to the Watershed Council that the areas intended to be paved will not be at this time, eliminating the impervious surfaces that would contribute to runoff. The unpaved areas would typically allow stormwater to filter naturally through the ground removing the present need for a rain garden. However, with concentrated use of the planned paths (as well as the unplanned, but likely, social trails) the soils will become compacted and therefore impervious even without paving. Therefore it is critical that the Town commit to and memorialize that upon adding pavement to the park, or the pathways/parking lot compacting, a rain garden must also be installed. We recognize that funds for the project are running short, but we strongly encourage that you, at a minimum, spend the funds now on the appropriate rock, infiltration bed and grading so that the future installation will function as rain gardens are intended and mitigate stormwater runoff from the parking lot and path. We also recommend that the Town source and use limestone crusher fines in the pathways, as these look nice and will harden over time while maintaining their pervious nature so that water will infiltrate rather than runoff.

Our third concern is for the fish and their ability to move through the whitewater park. For a healthy fishery to exist, fish of all species and sizes should be able to move up and down the river to find food, access reproductive habitat, avoid predators, and pursue optimal environmental conditions that vary seasonally. Originally, the park was intended and designed to have a roughened channel bed and “fish notches” through the lower two structures to enhance fish passage upstream through the unnaturally high velocity features that are necessary to make the whitewater park structures fun. If fish were able to move through the lower two structures, they could then access the fish passage channel to move around the upper two structures. These specific elements were developed in cooperation with CPW. However, upon inspection, CPW discovered that a roughened channel bed did not extend through the lower structures due to smooth concrete chutes constructed on the upstream end.

Furthermore, the fish notches were not installed within the structures as presented in the design, which incorporated small alternating rocks along the channel bed. Instead, large flat boulders (rather smooth themselves) were utilized. Thankfully, during the final site visit Town engineers agreed to add some roughness features through the concrete chutes as touted in the Town’s newsletter. However, the large, flat boulders were not easily replaceable, thus the high velocities through the whitewater park structures will remain unmitigated for fish passage across most of the channel. It is true that the velocities are slightly lower along the banks of the river through these structures and some fish may be able to navigate through the features in those areas, although this will certainly not allow for the majority of fish to be able to do so. Overall, it is quite clear that the fish notches were not constructed as presented in the park’s designs and we believe that the Army Corps of Engineers should not sign off on this project until the permitted mitigation for fish passage is added. The project team should be obligated to complete the park as intended and designed to improve and conserve fish habitat. Furthermore, if fish passage remains severely reduced and mostly unmitigated through the lower two structures, it makes the fish passage channel around the upper two structures almost pointless.

Finally, while the Watershed Council has been asked to consult on educational signage at the river park, without the critical riparian vegetation, stormwater mitigation and fish passage pieces, we feel that we cannot support and promote this project as a prime example of these elements, which were the points these signs were intended to highlight. Once these concerns are addressed we will be happy to work on signage.

We ask that Town Council work with their design team to ensure that the ecological
benefits be incorporated into this project as promised by:
• Insisting the fish notches be installed in the whitewater structures as designed,
• Providing support for the effort to vegetate the riparian areas, and
• Installing the foundation for the future install of a rain garden and completing the
install once runoff associated with the upland park amenities is identified.

The Town should live up to the goals presented to the Army Corps of Engineers, CPW, the Watershed Council, and your constituents, who voted in 2016 for the tax increase to support this fun recreational opportunity that would also “improve and conserve natural areas, open spaces and wildlife habitat; protect and improve water quality of the Eagle River” (as stated in Ordinance 14). This was billed as supporting our quality of life here in Eagle- it is upon you to make it so. The Watershed Council is here to support you in your efforts.

Holly Loff
Executive Director

Holly Loff is the Executive Director for the Eagle River Watershed Council. The Watershed Council advocates for the health and conservation of the Upper Colorado and Eagle River basins through research, education, and projects. Contact the Watershed Council at (970) 827-5406 or visit