The Western Resilience Center, formerly known as the Yampa Valley Sustainability Council, has submitted formal comments to Routt County planners on Discovery Land Company’s proposed Stagecoach Mountain Ranch development.

In a 21-page comment letter dated Sept. 14, the Steamboat Springs-based environmental organization strongly opposed a proposed 7-megawatt natural-gas generation facility described in an April project load-forecast letter, arguing it conflicts with the development’s own climate commitments and could add more than 10,000 metric tons of carbon dioxide annually to Routt County’s inventory, depending on how often it operates.

The letter from the local nonprofit comes just over a month after the Routt County Planning Department submitted its second corrections letter to Discovery Land Company on its proposal, identifying more than 120 questions, conflicts and missing materials to be resolved before the county completes its review of the project’s 10 pending land-use applications.

Discovery Land Company is now required to respond to all points of contention noted in the corrections letter, after which the county will likely undertake a third round of review. Public hearings likely are still months away.

In their letter, Western Resilience representatives praised many elements of the proposed 6,100-acre private ski and residential development’s sustainability planning, acknowledging that the project’s developer requested a series of meetings with the nonprofit in 2025 to discuss the center’s recommendations.

They added, however, that many commitments described in the application — from electrified heating and water conservation to transit service and habitat protection — remain preliminary rather than enforceable.

The letter’s central question, the group wrote, is whether the developer’s stated sustainability measures “will become a binding and enforceable component of the development’s final design and operation.”

“Because Western Resilience Center is a nonpartisan, science-based organization, our comments focus solely on certain technical aspects of the development, including energy, transportation, landscape and ecosystem stewardship, water resources, and waste,” wrote the organization’s representatives.

The Western Resilience Center’s most pointed comments concern the project’s energy plans.

The Stagecoach Mountain Ranch Energy Master Plan describes a strategy centered on reducing energy demand, using efficient building systems and electrified geoexchange heating and cooling, adding solar generation and purchasing green power to cover remaining operational emissions.

But an April load-forecast letter proposed 7 megawatts of natural-gas generation for peak demand and firm capacity, along with 36 megawatt-hours of battery storage.

Western Resilience representatives said batteries could support resilience and grid management but argued the gas-generation proposal would be a significant departure from the project’s stated strategy.

The group estimated that a 7-megawatt gas turbine could produce more than 10,000 metric tons of carbon dioxide annually, depending on how often it operates. In an example using a 50% operating level, the center calculated annual emissions at about 15,330 metric tons.

The organization said the county and developer should evaluate other options for firm power, such as enhanced geothermal systems or renewable-diesel generation.

It also agreed with county planners that questions about a possible new electrical substation and transmission line should be addressed during the current review, rather than later.

Western Resilience praised the developer’s proposals to use native and climate-adapted landscaping, prohibit nonfunctional turf and require high-efficiency irrigation systems, but traced the issue back to the letter’s primary question.

“Will these commitments become a binding and enforceable component of the development’s final design and operation?” wrote the organization’s representatives. “How will the county ensure these commitments are honored?”

The group also backed stronger safeguards for Stagecoach Reservoir and the Yampa River.

Western Resilience representatives wrote that the developer’s commitment to keep nitrogen and phosphorus loading in the reservoir at 2025 levels is a positive step, but said the county should verify that stormwater and water-quality plans adequately protect the reservoir.

The group supported a Upper Yampa Water Conservancy District recommendation for a legally binding agreement that would allow the county and water district to compel mitigation if the development contributes to water-quality degradation or harms existing water rights.

Transportation was another focus of the comments. The group said that although not required by the Routt County Unified Development Code, Discovery Land Company should formulate and seek approval of a comprehensive transportation demand management and mobility plan before final approval.

Western Resilience recommended “strategic investment in electrified, winter-resilient transportation systems,” as well as high-quality transit infrastructure, including “fully enclosed shelters and other passenger amenities that make transit a convenient and attractive option throughout the year.”

The letter says the project anticipates about 475 full-time-equivalent employees at full buildout and would provide 132 residences designated for employees. Western Resilience said that housing would serve only a portion of the workforce, leaving many workers to secure housing elsewhere in the Yampa Valley and commute to the development.

As a result, the group recommended that Stagecoach Mountain Ranch explore partnerships with Steamboat Springs Transit and the Yampa Valley Regional Transportation Authority and, at minimum, operate dedicated employee shuttles during initial development.

It also suggested a “mobility hub” and park-and-ride facility in or near Steamboat for employees, along with a “frequent circulator service” connecting employee housing, maintenance facilities, residential neighborhoods and recreational amenities.

The nonprofit also asked the county to carefully evaluate the impacts of ski-area work, including an estimated 432 acres of tree clearing for ski runs and lift or gondola infrastructure, as well as 269 acres of selective thinning for glading.

Western Resilience did not offer recommendations on wildlife impacts, saying it would defer to Colorado Parks and Wildlife and other qualified experts. But it said county officials should distinguish between forest treatments undertaken for wildfire resilience and work primarily intended to accommodate recreation infrastructure.

The group agreed with Routt County planners that the developer should submit a Waste & Materials Management Plan showing how waste-reduction goals would be achieved.

Western Resilience did not ask Routt County to deny the Stagecoach Mountain Ranch proposal. The organization’s comments instead urge county planners to ensure the project’s environmental commitments are specific and enforceable.

The complete Western Resilience comment letter is at TinyUrl.com/y7w8da5h.