HomeMy WebLinkAbout20252285.tiffMEMORANDUM
TO: Diana Aungst, Planning Services
FROM: Mike McRoberts, P.E., Development Review
DATE: May 23, 2025
SUBJECT: 1MJUSR25-08-1647 Addition of Two Gas Turbines
The proposal has been reviewed by Development Review on behalf of the Weld County Department of
Public Works and the Department of Planning and Zoning. Staff comments made during this phase of the
application process may not be all-inclusive, as other issues may arise during the remaining application
process.
COMMENTS
GENERAL PROJECT INFORMATION/LOCATION
Project description: A Major Amendment to Use By Special Review USR-1647 for a 1041 Major Facility of
a Public Utility (Fort Saint Vrain Generating Facility and natural gas pipelines) to add two (2) natural gas
fired combustion turbines (CT) and associated facilities in the 1-3 (Heavy Industrial) and A (Agricultural)
Zone Districts.
The subject parcel is north of and adjacent to County Road 34 (Circle 34) and is east of and adjacent to
County Road 19 1/2.
Parcel number 120910000006.
Access is from County Road 19 1/2.
ACCESS
Development Review has reviewed the application materials related to access. The applicant is proposing
to use two existing accesses onto County Road 19 1/2 for this amendment. The northern project access
(the main entrance to the site) is a non -permitted access located approximately 4,205 feet north of County
Road 34. The southern project access is a permitted access (AP22-00409) located approximately 3,610
feet north of County Road 34.
The Weld County Property Portal shows the subject parcel has several unpermitted accesses and three (3)
temporary permitted accesses (TAP22-0023, TAP23001, and TAP23-0002) on County Road 19'/2. All three
temporary accesses have expired. The applicant shall contact the Development Review Access Group to
resolve the unpermitted and expired temporary accesses.
Per Section 8-14-30, an Access Permit is required for access to Weld County maintained roadways.
Minimum access and intersection spacing requirements are shown in Weld County Code, Section 8-14-30,
Table 1. Please refer to Chapter 8 of the Weld County Code for more information regarding access.
ROADS AND RIGHTS -OF -WAY
County Road 19 1/2 is a paved road and is designated on the Weld County Functional Classification Map
(Code Ordinance 2017-01) as a collector road, which requires 80 feet of right-of-way. Pursuant to the
definition of setback in the Weld County Code, Section 23-1- 90, the required setback is measured from
the future right-of-way line. Be aware that physical roadways may not be centered in the right-of-way. This
road is maintained by Weld County.
County Road 34 is a paved road and is designated on the Weld County Functional Classification Map (Code
Ordinance 2017-01) as a collector road, which requires 80 feet of right-of-way. Pursuant to the definition of
setback in the Weld County Code, Section 23-1-90, the required setback is measured from the future right-
of-way line. Be aware that physical roadways may not be centered in the right-of-way. This road is
maintained by Weld County.
Per Chapter 8, Article 13, Section 8-13-30.B, a Weld County Right -of -Way Use Permit is required for any
project that will be occupying, constructing, or excavating facilities within, and or encroaching upon, any
County rights -of -way or easement. Right -of -Way Use Permit instructions and application can be found at:
https://www.weld.gov/Government/Departments/Public-Works/Permits/Right-of-Way-Permits.
Weld County will not replace overlapping easements located within existing right-of-way or pay to relocate
existing utilities within the County right-of-way.
TRAFFIC
Latest average daily traffic (ADT) on County Road 19 1/2 counted 912 vehicles per day with 20% trucks. The
85th percentile speed is 63 miles per hour.
It is anticipated that approximately 10 semitrucks and four (4) concrete trucks will be utilized during peak
construction activities each day. On average, one construction equipment delivery per day is expected.
One (1) lattice boom crane and four (4) forklifts will be delivered to the temporary construction area adjacent
to the project site for use during construction.
Once the new turbines are operational, traffic at the Fort St. Vrain Generating Facility is not expected to
increase from its current level.
TRACKING CONTROL
Tracking control is required to prevent tracking from the site onto public roadways. For access to paved
roads, tracking control devices can be back-to-back double cattle guards with 100 feet of asphalt or 300
feet of asphalt. Recycled concrete is not allowed in County right-of-way. A variance request for alternatives
to the tracking control requirement can be submitted to Development Review for review and consideration.
ROAD MAINTENANCE AGREEMENT FOR CONSTRUCTION
Development Review is requesting a Road Maintenance Agreement for Construction including, but not
limited to, dust control and damage repair to specified haul routes.
Improvements/Road Maintenance Agreement: An example agreement is available at:
https://www.weld.gov/Government/Departments/Planning-and-Zoning/I mprovements-Agreements
DRAINAGE REQUIREMENTS
This area is within an Urbanizing Drainage Area. Urbanizing Drainage Areas typically require detention of
stormwater runoff from the 1 -hour, 100 -year storm event falling on the developed site and release of the
detained water at the historic runoff rate of the 1 -hour, 5 -year storm event falling on the undeveloped site
having a 2% impervious value.
The applicant has submitted a preliminary drainage report. A final drainage report and detention pond
design completed by a Colorado Licensed Professional Engineer (P.E.) is required prior to recording the
amended USR map. The drainage report must include a Certificate of Compliance stamped and signed by
the P.E. A Certificate of Compliance form and Drainage Review Checklist form can be found at:
https://www.weld.gov/Government/Departments/Planning-and-Zoning/Development-Review/Drainage-
Review
Historic Flows:
The applicants will be required to maintain the historic drainage flows and run-off amounts that exist on the
property.
GRADING PERMIT
A Weld County Grading Permit will be required if disturbing more than one (1) acre of land. Grading Permit
applications are accepted after the planning process is complete (map recorded). An Early Release
Request Form may be entertained only after the applicant, Public Works and Planning Department have
reviewed the referral and surrounding property owner comments. The Early Release Request may or may
not be granted depending on referral comments and surrounding property owner concerns. Contact
Development Review for more information.
COLORADO CONSTRUCTION STORMWATER DISCHARGE PERMIT
A Colorado Stormwater Discharge Permit is required when disturbing more than one (1) acre of land.
Contact: Colorado Department of Public Health and Environment, Water Quality Control Division, 303-692-
3575.
CONDITIONS OF APPROVAL
A. A Road Maintenance Agreement for Construction is required at this location. Road maintenance
includes, but is not limited to, dust control and damage repair to specified haul routes. (Development
Review)
B. A Final Drainage Report and Certification of Compliance stamped and signed by a Professional
Engineer registered in the State of Colorado is required. (Development Review)
C. The amended USR map shall delineate the following:
1. County Road 191/2 is a paved road and is designated on the Weld County Functional Classification
Map as a collector road which requires 80 feet of right-of-way at full buildout. The applicant shall
delineate and label on the amended USR map the future and existing right-of-way (along with the
documents creating the existing right-of-way) and the physical location of the road. All setbacks
shall be measured from the edge of right-of-way. This road is maintained by Weld County.
(Development Review)
2. County Road 34 is a paved road and is designated on the Weld County Functional Classification
Map as a collector road which requires 80 feet of right-of-way at full buildout. The applicant shall
delineate and label on the amended USR map the future and existing right-of-way (along with the
documents creating the existing right-of-way) and the physical location of the road. All setbacks
shall be measured from the edge of right-of-way. This road is maintained by Weld County.
(Development Review)
3. Show and label the approved access locations, approved access width and the appropriate turning
radii (65'). (Development Review)
4. Show and label the approved tracking control. (Development Review)
5. Show and label the entrance gate if applicable. An access approach that is gated shall be designed
so that the longest vehicle (including trailers) using the access can completely clear the traveled
way when the gate is closed. In no event, shall the distance from the gate to the edge of the traveled
surface be less than 35 feet. (Development Review)
6. Show and label the accepted drainage features. Stormwater ponds should be labeled as
"Stormwater Detention, No -Build or Storage Area" and shall include the calculated water quality
and detention volumes. (Development Review)
7. Show and label the drainage flow arrows. (Development Review)
8. Show and label the parking and traffic circulation flow arrows showing how the traffic moves around
the property. (Development Review)
Prior to Construction:
A. The approved tracking control shall be constructed prior to on -site construction. (Development Review)
B. Overweight and/or oversized special transport permits from the Department of Public Works shall be
acquired for all applicable trucks. (Development Review)
C. If more than one (1) acre is to be disturbed, a Weld County Grading Permit will be required.
(Development Review)
DEVELOPMENT STANDARDS (NOTES ON THE USR MAP)
1. The property owner or operator shall be responsible for controlling noxious weeds on the site, pursuant
to Chapter 15, Article I and II, of the Weld County Code. (Development Review)
2. The access to the site shall be maintained to mitigate any impacts to the public road, including damages
and/or off -site tracking. (Development Review)
3. There shall be no parking or staging of vehicles on public roads. On -site parking shall be utilized.
(Development Review)
4. Any work that may occupy and or encroach upon any County rights -of -way or easement shall acquire
an approved Right -of -Way Use Permit prior to commencement. (Development Review)
5. The Property Owner shall comply with all requirements provided in the executed Road Maintenance
Agreement for Construction. (Development Review)
6. The Road Maintenance Agreement for this site may be reviewed on an annual basis, including a site
visit and possible updates. (Development Review)
7. The historical flow patterns and runoff amounts will be maintained on the site in such a manner that it
will reasonably preserve the natural character of the area and prevent property damage of the type
generally attributed to runoff rate and velocity increases, diversions, concentration and/or unplanned
ponding of stormwater runoff. (Development Review)
8. Weld County is not responsible for the maintenance of onsite drainage related features. (Development
Review)
COUNTY
WELD COUNTY DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
1555 North 17th Avenue, Greeley, CO 80631 www.weldhealth.org
Memorandum
To: Diana Aungst, Planning Services
From: Lauren Light, Environmental Health Services
Date: May 12, 2025
Re: 1 MJUSR25-08-1647 Applicant: Public Service
Company of Colorado
Environmental Health Services has reviewed this proposal for a Major
Amendment to Use By Special Review Permit No. USR-1647 for a 1041 Major
Facility of a Public Utility (Fort Saint Vrain Generating Facility and natural gas
pipelines) to add two (2) natural gas fired combustion turbines (CT) and
associated facilities in the 1-3 (Heavy Industrial) and A (Agricultural) Zone
Districts
According to the application: "Domestic wastewater is treated through a pre-
package system that includes a preaeration unit before flowing to a lagoon with
two aeration cells and then through a polishing pond. The outflow from the
polishing pond can be chlorinated if needed. Effluent from the system is
comingled with treated industrial process wastewater and discharged to either
Saint Vrain Creek or South Platte River under the Fort St. Vrain facility Colorado
Discharge Permit System (CDPS) Individual Industrial Major Permit (CO -
0001121)."
A vault is used for the chemistry lab restrooms (SP -0800019) and an on -site
wastewater treatment system (G19880162) is used at the visitor center. An on -
site wastewater treatment system (SP -9600408) is utilized for the office building.
This system was designed for up to 40 people
Portable toilets will be utilized during construction and will be removed from the
subject parcel once construction of CT Units 7 and 8 is completed. Potable water
is provided by Central Weld County Water District.
An updated air emissions permit from CDPHE may be required. Secondary
containment shall be constructed around tanks to provide containment for the
largest single tank and sufficient freeboard to contain precipitation. Secondary
Health Administration
Vital Records
Tele: 970-304-6410
Fax: 970-304-6412
Public Health &
Clinical Services
Tele:970-304-6420
Fax: 970-304-6416
Environmental Health
Services
Tele:970-304-6415
Fax: 970-304-6411
Communication,
Education & Planning
Tele:970-304-6470
Fax: 970-304-6452
Emergency Preparedness
& Response
Tele:970-304-6470
Fax: 970-304-6452
Public Health
containment shall be sufficiently impervious to contain any spilled or released
material.
A Noise Study was submitted by Power Engineers, Inc. The noise study does
not appear to include the addition of the compressors. However, the application
states: "The operational noise from CT Units 7 and 8 will not substantially add to
the noise produced from the existing facility. The noise level from the Project will
comply with the maximum permissible noise level of 80 A -weighted decibels
(dB(A)) between 7:00 a.m. — 9:00 p.m. and 75dB(A) between 9:00 p.m. — 7:00
a.m. for industrial areas or construction activities as required by Section 14-9-40
of the Weld County, Colorado Charter and County Code (Weld County 2024)."
The facility is required to adhere to the industrial zone district as stipulated in
25-12-103 C.R.S.
We recommend that the following requirements be incorporated into the permit as
development standards:
1. All liquid and solid wastes (as defined in the Solid Wastes Disposal
Sites and Facilities Act, 30-20-100.5, C.R.S.) shall be stored and
removed for final disposal in a manner that protects against surface and
groundwater contamination.
2. No permanent disposal of wastes shall be permitted at this site. This is
not meant to include those wastes specifically excluded from the
definition of a solid waste in the Solid Wastes Disposal Sites and
Facilities Act, 30-20-100.5, C.R.S.
3. Waste materials shall be handled, stored, and disposed in a manner
that controls fugitive dust, fugitive particulate emissions, blowing debris,
and other potential nuisance conditions. The applicant shall operate in
accordance with Chapter 14, Article 1 of the Weld County Code.
4. Fugitive dust should attempt to be confined on the property. Uses on
the property should comply with the Colorado Air Quality Commission's
air quality regulations.
5. The applicant shall submit an Air Pollution Emission Notice (A.P.E.N.)
and Emissions Permit Application and obtain a permit from the Air
Pollution Control Division, Colorado Department of Public Health and
Environment, as applicable.
6. Portable toilets and bottled water are acceptable during construction.
Records of maintenance and proper disposal for portable toilets shall
be retained on a quarterly basis and available for review by the Weld
County Department of Public Health and Environment. Portable toilets
shall be serviced by a cleaner licensed in Weld County, shall contain
hand sanitizers and be screened from the public right of way and
neighboring properties.
7. Any on -site wastewater treatment system located on the property must
comply with all provisions of the Weld County Code, pertaining to on -
site wastewater treatment systems.
8. Adequate drinking, handwashing and toilet facilities shall be provided
for employees and patrons of the facility, at all times. A permanent,
adequate water supply shall be provided for drinking and sanitary
purposes, as applicable.
9. All chemicals on -site must be handled in a safe manner in accordance
with product labeling. All chemicals must be stored secure, on an
impervious surface, and in accordance with manufacturer's
recommendations.
10. Secondary containment shall be constructed around tanks to provide
containment for the largest single tank and sufficient freeboard to
contain precipitation. Secondary containment shall be sufficiently
impervious to contain any spilled or released material. Secondary
containment devices shall be inspected at regular intervals and
maintained in good condition. All secondary containment will comply
with the Energy and Carbon Management Commission (ECMC)
Commission Rules.
11. The facility shall comply with all provisions of the State Underground
and Above Ground Storage Tank Regulations.
12. The facility shall be constructed and operated to ensure that
contamination of soil and groundwater does not occur.
13. The applicant shall obtain a Colorado Discharge Permit System or
CDPS permit from the Colorado Department of Public Health and
Environment (CDPHE), Water Quality Control Division, as applicable.
14. This facility shall adhere to the maximum permissible noise levels
allowed in the Industrial Zone as delineated in 25-12-103 C.R.S.
15. The facility shall notify the County of any revocation and/or suspension
of any State issued permit.
16. The applicant shall notify the County upon receipt of any compliance
advisory or other notice of non-compliance of a State issues permit, and
of the outcome or disposition of any such compliance advisory or other
notice of non-compliance.
17. The operation shall comply with all applicable rules and regulations of
State and Federal agencies and the Weld County Code.
PROJECT:
MEMORANDUM
TO: Diana Aungst DATE: June 19, 2025
FROM: Diana Aungst, CFM
SUBJECT: 1 MUSR25-08-1647, PSCo 1041
A Major Amendment to Use By Special Review USR-1647 fora 1041 Major Facility of a Public Utility (Fort
Saint Vrain Generating Facility and natural gas pipelines) to add two (2) natural gas fired combustion
turbines (CT) and associated facilities in the 1-3 (Heavy Industrial) and A (Agricultural) Zone Districts
PARCEL: 120910000006
DELINEATE ON THE PLAT:
1. Show the floodplain and floodway (if applicable) boundaries on the map. Label the floodplain
boundaries with the FEMA Flood Zone and FEMA Map Panel Number or appropriate study.
(Department of Planning Services - Floodplain)
PRIOR TO CONSTRUCTION:
1. The applicant shall submit and receive approval for a Floodplain Development Permit. (Department of
Planning Services - Floodplain)
DEVELOPMENT STANDARDS:
1. A Flood Hazard Development Permit is required for all construction or development occurring in the
floodplain or floodway as delineated on Federal Emergency Management Agency (FEMA) FIRM
Community Panel Map # 08123C -1885F and 1905F dated November 30, 2023 (St Vrain River
Floodplain). Any development shall comply with all applicable Weld County requirements, Colorado
Water Conservation Board requirements as described in Rules and Regulations for Regulatory
Floodplains in Colorado, and FEMA regulations and requirements as described in 44 CFR parts 59, 60,
and 65. The FEMA definition of development is any man-made change to improved or unimproved
real estate, including by not limited to buildings or other structures, mining, dredging, filling, grading,
paving, excavation, drilling operations, or storage of equipment and materials. (Department of Planning
Services - Floodplain)
2. FEMA's floodplain boundaries may be updated at any time by FEMA. Prior to the start of any
development activities, the owner should contact Weld County to determine if the floodplain boundaries
have been modified. (Department of Planning Services - Floodplain)
Weld County Referral
Y
April 28, 2025
Submit by Email
Tap 240
The Weld County Department of Planning Services has received the following item for review:
Applicant: Public Service Company of Colorado Case Number: 1 MJUSR25-08-1647
Please Reply By: May 26, 2025 Planner: Diana Aungst
Project: A Major Amendment to Use By Special Review Permit No. USR-1647 for a 1041 Major
Facility of a Public Utility (Fort Saint Vrain Generating Facility and natural gas pipelines) to add
two (2) natural gas fired combustion turbines (CT) and associated facilities in the 1-3 (Heavy
Industrial) and A (Agricultural) Zone Districts.
Parcel Number: 120910000006-R0282587 Legal: ALL OF SECTION 10, T3N, R67W of the 6th P.M.,
Weld County, Colorado.
Location: North of and adjacent to CR 34; East of and adjacent to CR 19.5
The application is submitted to you for review and recommendation. Any comments or
recommendation you consider relevant to this request would be appreciated. Please reply by the
above listed date so that we may give full consideration to your recommendation. Any response
not received before or on this date may be deemed to be a positive response to the Department of
Planning Services. If you have any further questions regarding the application, please call the
Planner associated with the request. Please note that new information may be added to
applications under review during the review process. If you desire to examine or obtain this
additional information, please call the Department of Planning Services.
r
F-
Signature Date 5/22/25
We have reviewed the request and find that it does / does not comply with our
Comprehensive Plan because:
We have reviewed the request and find no conflicts with our interests.
See attached -letter. note below
Digitally signed by Kathy Naibauer
Date: 2025.05.22 09:41:07 -06'00'
Agency Central Weld County Water District
The District is in the process of negotiating a water transfer agreement with Public Service
to secure the raw water necessary for the proposed increased water demand at the property
served by tap 240. The District requests that the planning department require that the
agreement be executed prior to approval of the application.
Weld County Planning Dept. PO Box 758, Greeley, CO 80632 Tel:(970)-400-6100 Fax:(970)-304-6498
CDPHE
COLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Diana Aungst
Weld County
1402 North 17th Ave Greeley, CO 80631
VIA EMAIL
RE: Referral Agency Email
Dear Diana Aungst,
The Colorado Department of Public Health and Environment's Air Pollution Control Division
(APCD or Division) received a request for an air quality administrative review concerning the
proposed Fort Vrain turbine project as described in your correspondence dated April 28, 2025.
The Division has reviewed the project letter and respectfully offers the following comments.
Please note that the following Air Quality Control Commission (AQCC) regulations may not be
inclusive of the regulations the proposed project will be subject to. It is the responsibility of
the involved parties to determine what regulations they are subject to and follow them
accordingly.
APEN and Regulation No. 3
We note that projects similar to this proposal have included the use of engines and/or
generators. In Colorado, most businesses that are or will be emitting air pollutants above
certain levels are required to report those emissions to the Division by completing an Air
Pollutant Emissions Notice (APEN). This is a two in one form for reporting air emissions and to
obtain an air permit, if a permit will be required. While only businesses that exceed the AQCC
reporting thresholds are required to report their emissions, all businesses - regardless of
emission amount - must always comply with the Colorado AQCC regulations, found here
https://cdphe.colorado.gov/aqcc-regulations. APEN and permit reporting thresholds are
provided at
https: / /cdphe.colorado.gov/apens-and-air-permits/apen-and-permit-threshold-table.
A permit may not be required if it meets the following criteria:1
• Is a stationary internal combustion engine that is an emergency power generator
that operates no more than 250 hrs/year; or
• Is a stationary internal combustion engine with uncontrolled actual emissions less
than 5 tons per year for each individual criteria pollutant emitted; or
• Is a stationary internal combustion engine with manufacturer's site -rated horsepower
of less than 50
For additional information on exemptions and permitting requirements, please visit
https: / /cdphe.colorado.gov/apens-and-air-permits/common-apen-or-air-permit-exemptions.
Land Development
1 APEN or Permit Exemptions, CDPHE,
https: / /cdphe.colorado.gov/apens-and-air-permits/common-apen-or-air-permit-exemptions
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
We also note that projects similar to this proposal often involve land development. Under
Colorado air quality regulations, land development refers to all land clearing activities,
including but not limited to land preparation such as excavating or grading, for residential,
commercial or industrial development. Land development activities release fugitive dust, a
pollutant regulation by the Division. Small land development activities are not subject to the
same reporting and permitting requirements as large land activities. Specifically, land
development activities that are less than 25 contiguous acres and less than 6 months in
duration do not need to report air emissions to the Division. It is important to note that even
if a permit is not required, fugitive dust control measures including the Land Development
APEN Form APCD-223 must be followed at the site. Fugitive dust control techniques commonly
included in the plan are included in the table below.
Control Options for Unpaved Roadways
Watering
Paving
Graveling
Use of chemical stabilizer
Controlling vehicle speed
Control Options for Mud and Dirt Carry -Out Onto Paved Surfaces
Gravel entry ways
Covering the load
Washing vehicle wheels
Not overfilling trucks
Control Options for Disturbed Areas
Watering
Revegetation
Compaction
Wind Breaks
Application of a chemical stabilizer
Controlling vehicle speed
Furrowing the soil
Minimizing the areas of disturbance
Synthetic or Natural Cover for Slopes
Please refer to the website https://cdphe.colorado.gov/apens-and-air-permits for
information on land use APENs and permit forms. Click on "Land Development" to access the
land development specific APEN form. Please contact KC Houlden, Construction Permits Unit
Supervisor, at 303-692-4092, kenneth.houlden@state.co.us if you have any specific questions
about APENs and permit forms.
Federal General Conformity
The federal General Conformity rule applies to federally funded projects in federal
nonattainment and air quality maintenance areas, such as the Denver Metro/North Front
Range severe ozone nonattainment area.2 Within these areas, the general conformity rule
applies to any "Federal action" not specifically exempted by the Clean Air Act or
Environmental Protection Agency (EPA) regulations, i.e., any non-exempt activity by a federal
governmental department, agency or instrumentality, or any activity that such an entity
supports in any way, provides financial assistance for, or licenses, permits, or approves.
The federal general conformity rule and associated EPA guidance provides for a federal
department or instrumentality to determine if the estimated emissions resulting from a
proposed action in a nonattainment or maintenance area are below EPA's de minimis levels
(https://www.epa.gov/general-conformity/de-minimis-emission-levels) for the applicable
National Ambient Air Quality Standard (NAAQS).3 Note that Weld County is located in the
Denver Metro/North Front Range 2015 serious and 2008 severe ozone nonattainment areas.
The General Conformity de minimis levels for the 2015 Denver Metro/North Front Range
2 U.S. EPA, Green Book, Colorado, https://www3.epa.gov/airquality/greenbook/anayo_co.html
3 U.S. EPA, De Minimis Tables, https://www.epa.gov/general-conformity/de-minimis-tables
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
serious ozone nonattainment area are 50 tons per year of the ozone precursors VOCs or NOx
and 25 tons per year for the 2008 Denver Metro/North Front Range severe nonattainment
area. If a federal department or instrumentality determines that its action will result in
emissions that are below the de minimis levels, the action is exempt and detailed air quality
analysis is not required. Information about the general conformity rule, including training and
frequently asked questions, is available at https://www.epa.gov/general-conformity.
If you have any other questions or need additional information, please use the contact info
listed above, or e-mail or call me directly. Thank you for contacting the Air Pollution Control
Division about your project.
Sincerely,
Brendan Cicione
Air Quality and Transportation Planner
General SIP Unit
Air Pollution Control Division
Colorado Department of Public Health and Environment
303-691-4104 // brendan.cicione@state.co.us
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
COLORADO
Parks and Wildlife
Department of Natural. Resources
Fort Collins Service Center
317 W Prospect Rd
Fort Collins, CO 80526
P 970.472.4300
April 30, 2025
Weld County Planning Department
Attn: Diana Aungst
1402 North 17th Ave
Greeley, CO 80631
daungst@weld.gov
RE: 1041 Wildlife Impact Review for 1MJUSR25-08-1647 - Fort St. Vrain Generating Station
Combustion Turbine Units 7 And 8
Dear Diana,
Thank you for the opportunity for Colorado Parks and Wildlife (CPW) to comment on the
proposed Fort St. Vrain Generating Station Combustion Turbine Units 7 and 8 addition to the
Substation, located on the southwest corner of section 10, township 3N, range 67W. It is our
understanding that this is a request for review and comment on Fort St. Vrain Generating
Station Project application to Weld County for a 1041 permit to construct and operate the
proposed new combustion Turbines with regard to protected and sensitive species that may
potentially be present in the area of the Project. It is our understanding that the power
generation station will install two (2) natural gas -fired combustion turbines (CT) and
associated facilities on 2.8 acres of land east of the existing power plant.
The mission of CPW is to perpetuate the wildlife resources of the state, to provide a quality
state parks system, and to provide enjoyable and sustainable outdoor recreation opportunities
that educate and inspire current and future generations to serve as active stewards of
Colorado's natural resources. CPW has a statutory responsibility to manage all wildlife species
in Colorado, and to promote a variety of recreational opportunities throughout Colorado. One
way we achieve this goal is by responding to referral comment requests, as is the case for this
project. CPW appreciates the continued early consultation on this project, and has the
following recommendations:
THE IMPORTANCE OF HIGH PRIORITY HABITATS
Developers and permitting agencies can help avoid, minimize, and mitigate impacts to
wildlife from their projects by working with CPW. High -priority habitats (HPH) are defined as
Jeff Davis, Director, Colorado Parks and Wildlife
Parks and Wildlife Commission: Dallas May, Chair • Richard Reading, Vice -Chair • Karen Bailey, Secretary • Jessica Beaulieu
Marie Haskett • Tai Jacober • Jack Murphy • Gabriel Otero • Murphy Robinson • James Jay Tutchton • Eden Vardy
1MJUSR25-08-1647— CPW Comments (4/30/2025) Page 2 of 3
sensitive habitats where CPW has recent maps regarding sensitive wildlife use, plus
scientifically backed best management practice (BMP) recommendations. HPHs are a subset of
CPW's species activity maps that we collect and update for a variety of species and their
particular habitats; we provide these maps to the public and regulatory agencies for the
environmental assessment and land use commenting of proposed development on a given
parcel, and general scientific research.
Mule Deer Severe Winter Range HPH
Mule Deer Severe Winter Range is defined as the portion of a species' range where 90% of
individuals are found during the harshest two winters out of ten, when snowpack is highest,
and temperatures are lowest.
The entire proposed Project area is mapped as Mule Deer Severe Winter Range. For the
identified portions of the proposed Project area that traverse Mule Deer Severe Winter Range,
CPW typically recommends the following timing limitation be implemented for the
construction phase:
• No permitted or authorized human activities from December 1St to April 30, but with
this being an existing disturbance, we have no concerns with the timing limitation for
this project in particular.
Mule Deer Winter Concentration HPH
Mule Deer Severe Winter Range is defined as the part of the winter range where densities are
at least 200% greater than the surrounding winter range density during the same period used
to define winter range in the average five winters out of ten.
The entire proposed Project area is mapped as Mule Deer Severe Winter Range. For the
identified portions of the proposed Project area that traverse Mule Deer Winter
Concentration, CPW typically recommends the following timing limitation be implemented for
the construction phase:
• No permitted or authorized human activities from December 1St to April 30, but with
this being an existing disturbance, we have no concerns with the timing limitation for
this project in particular.
Ground Nesting Birds
Ground nesting birds may be present around the project site because of the available habitat.
CPW recommends avoiding work during the migratory bird breeding season (April 1- August
30). If this cannot be achieved, CPW recommends starting construction outside of the
migratory bird breeding season to reduce the likelihood of ground -nesting birds from nesting
in the project area.
1MJUSR25-08-1647— CPW Comments (4/30/2025) Page 3 of 3
Fencing
CPW is concerned for the safety of Mute deer, and White-tailed deer in the area for the
proposed project. CPW recommends that any installed fencing should be eight feet in height,
have round -capped posts (e.g., so wildlife isn't impaled), smooth top wire to the fence (e.g.,
no top barbed wire) (or if two top strands are needed, ensure they are at least six inches
apart). The bottom wire can be barbed but should be four inches or less from the ground.
Please see CPW's "Fencing with Wildlife in Mind" brochure for more information.
If the timing or scope of this project changes and/or if you have any questions, please contact
the local District Wildlife Manager, Mike Grooms at 970-692-4028 or
michael.grooms@state.co.us.
Sincerely,
Brandon Mutter
Area 4 Acting Area Wildlife Manager
Cc: Mike Grooms, Greeley S. District Wildlife Manager- michael.grooms@state.co.us
Lexi Ramous, NE Land Use Coordinator- lexi.hamous-miller@state.co.us
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