Yes, if the person genuinely controls hiring, scheduling, budgets and subcontractors rather than simply being the most senior technician. Fluctuating headcount does not disqualify the role; the primary nature of the duties is what is assessed.
Show control over the work rather than proximity to it
A snowmaking contractor's workforce swells for the installation and winter season and contracts sharply in summer, so a reviewer will see an organization chart that looks different depending on the month. Do not pick the busiest week and present it as permanent. Instead, describe the annual cycle and the director's authority across it: she sets the seasonal hiring plan, negotiates subcontractor rates for excavation and electrical work, approves purchases of pumps and valves, signs off on ski-area contracts and disciplines or releases staff.
Those are managerial functions whether the crew count is twelve or three. Where she also climbs into a pump house to diagnose a fault, say so and quantify it, because a manager who spends most of her hours doing technician work will not meet the standard. The same test applies to the proposed Colorado role: an executive title on a subsidiary with no staff is not enough, and the plan must show when the first hires arrive and what she will direct once they do.