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Improving the Roadless Inventory EXHIBIT 1 IMPROVING THE ROADLESS INVENTORY INTRODUCTION. For any rule describing management of roadless areas, it is important to know, with as much precision as is reasonably possible, just what is roadless, so that the Forest Service, interest groups, and the pubic will know to just what areas of Colorado any roadless rule applies. We recognize that an inventory of all of Colorado’s national forest roadless areas can never be perfect, but we believe much improvement in the current inventory is needed. In what follows, we describe deficiencies in the roadless inventory that was used for the Draft Colorado Rule, both Colorado Roadless Areas having boundaries that do not include all roadless acreage and areas that we believe are roadless that were excluded from the inventory altogether. Our boundaries, acreages, and areas are based on extensive field surveys conducted over the past several years by volunteers trained by the Southern Rockies Conservation Alliance (SRCA). Field data was analyzed using GIS software. Maps comparing the CRA and SRCA boundaries for many of the roadless areas in dispute will be submitted to the Rocky Mountain Regional Office The descriptions as a whole should not be considered comprehensive, let alone exhaustive. However, we have attempted to include all of the areas where the omissions of roadless acreage is most glaring, as well as some others of slightly lower significance, as our capacity and time permitted. One general concern is with roadless areas that are on two national forest administrative units. In some cases, the combined areas do not appear to have been considered in delineating CRAs. In doing so, the Forest Service may miss good opportunities to recognize connections for wildlife habitat across artificial boundaries and to manage to protect this habitat connectivity. We expect to have further input on roadless inventory during forest plan revisions and at other times. We are happy to work with the Forest Service in any way possible to ensure development and maintenance of the most accurate roadless inventory possible. Data Sources Acreages and boundary information is based on information from the USDA Forest Service and from the Southern Rockies Conservation Alliance (SRCA). Road and trail numbers are from the 2008 Motor Vehicle Use Maps (MVUM) that were available on the National Forest web site as of October 2008. Where MVUMs were not available, road information was taken from the most up to date National Forest visitors maps, and from GIS data provided by the Forest Service as of April 2008 for the GMUG, Routt, and San Juan National Forest and as of December 2006 for the Arapaho-Roosevelt, Rio Grande, and White River National Forests. Stream and lake information is from the National Forest visitors maps and USGS quads. Vegetation is from the Southwest Regional Gap Assessment Project. Species activities are from the Colorado Division of Wildlife’s (CDOW) National Diversity Information Source. Land ownership data is from the CoMap GIS data version 6 dated April, 2007. Threatened and endangered species information is from the Colorado National Heritage Program. Grand Mesa - Uncompahgre - Gunnison (GMUG) National Forest A. General Problems With the GMUG Roadless Inventory. The 2005 re-inventory of roadless characteristics on the GMUG National Forest decreased the total roadless acreage significantly. While significant acreage was added to the inventory, a much greater acreage was removed, resulting in a decrease of over 200,000 acres of roadless lands in the inventory. A partial explanation for this dramatic decrease in roadless acres may be the methodology employed by the forest. Instead of relying on the definition of roadless found in the 2001 Roadless Area Conservation Rule and other agency guidance, the GMUG inventory used an inventory more oriented towards determining the capability and availability of roadless lands for wilderness designation. The result of this approach was that many quality roadless areas or parts of them were removed from the inventory because current uses such as motorized recreation would present obstacles to wilderness designation. Certainly some areas of the GMUG now have Forest Service system roads that did not exist in either 1979 or 2001, and those areas should not remain in the inventory. However many areas removed from the inventory do not contain Forest Service system roads, and no roads are likely to be proposed for these areas. Because there is no reason for the removal of these acres, they should remain in the inventory and be managed accordingly. Specific examples of the incorrect removal of roadless acreage are described below in sections C and D. This list is representative of the flaws of the inventory, but should not be considered exhaustive. The US Forest Service should carefully re-consider all aspects of its 2005 inventory for roadless acres that were incorrectly removed from the GMUG inventory. B. Wilderness Inventory vs. Roadless Inventory The rulemaking process is an opportunity to correct the GMUG Roadless Inventory and meet the USFS mandate of maintaining an accurate inventory of roadless lands. In the 2005 re-inventory of roadless lands on the GMUG, the forest applied incorrect standards in determining which lands were eligible for inclusion in the roadless inventory. Rather than using the criteria for potential Wilderness Areas as defined in the 2001 Roadless Rule FEIS, the GMUG used wilderness capability and availability standards to evaluate roadless areas. The definition of inventoried roadless area is: Inventoried Roadless Areas are undeveloped areas typically exceeding 5,000 acres that met the minimum criteria for wilderness consideration under the Wilderness Act. These areas have been inventoried during the Forest Service’s Roadless Area Review and Evaluation (RARE II) process, subsequent assessments, or forest planning. These areas are identified in a set of inventoried roadless area maps, contained in Roadless Area Conservation, Final Environmental Impact Statement, Volume 2, dated November 2000, which are held at the National headquarters office of the Forest Service. Forest Service Roadless Area Conservation, FEIS, Volume 1, November 2000, at G-5. See also Preamble for 2001 Rule at 66 Fed Reg 3250, January 12, 2001. In many instances the 2005 GMUG Roadless Inventory identifies new road mileage, evidence of timber harvest or challenges for management as reasons for excluding portions of Roadless Areas found in the 2001 inventory. However, according to the USFS Handbook on Wilderness Inventory: Areas may qualify for the inventory of potential wilderness even though they include the following types of areas or features: 1. Airstrips and heliports. 2. Cultural treatments involving plantations or plantings where the use of mechanical equipment is not evident. 3. Electronic installations, such as cell towers, television, radio, and telephone repeaters, and the like, provided their impact is minimal. 4. Areas with evidence of historic mining (50+ years ago). Do not include areas of significant current mineral activity, including prospecting with mechanical or motorized earthmoving equipment. The inventory may include areas where the only evidence of prospecting is holes that have been drilled without access roads to the site. Inventoried lands that may have potential for wilderness recommendation also may include: a. Areas that otherwise meet inventory criteria if they are covered by mineral leases having a “no surface occupancy” stipulation. b. Areas covered by mineral leases that otherwise meet inventory criteria only if the lessee has not exercised development and occupancy rights. If and when these rights are exercised, remove the area, or portion affected, from the inventory unless it is possible to establish specific occupancy provisions that would maintain the area in a condition suitable for wilderness. ... 6. Federal ownership of less than 70 percent if it is realistic to manage the Federal lands as wilderness, independent of the private land. 7. Minor structural range improvements (FSM 2240.5), such as fences or water troughs. Exclude areas where nonstructural range improvements are readily visible and apparent. Areas with spray or burning projects are permissible if there is little or no evidence of the project. 8. Recreation improvements such as occupancy spots or minor hunting or outfitter camps. As a general rule, do not include developed sites. Areas with minor, easily removable recreation developments may be included. 9. Timber harvest areas where logging and prior road construction are not evident, except as provided in Section 71.12 for areas east of the 100th meridian. Examples include those areas containing early logging activities related to historic settlement of the vicinity, areas where stumps and skid trails or roads are substantially unrecognizable, or areas where clearcuts have regenerated to the degree that canopy closure is similar to surrounding uncut areas. 10. Ground-return telephone lines, electric lines, and powerlines if a right-of- way has not been cleared. 11. Watershed treatment areas if the use of mechanical equipment is not evident. The inventory may include areas where minor watershed treatment has been accomplished manually such as small hand-constructed gully plugs. FSH 1909.12, section 71.11. Based on the US Forest Service Handbook direction above and the definitions contained in the 2001 Roadless Rule, many areas on the GMUG that were excluded from the inventory due to the presence of non-system roads and/or some evidence of past timber harvest should have been included in the 2005 inventory. While these lands may not rank high in capability of or availability for wilderness designation, they do continue to meet the minimum criteria for wilderness consideration and should be included in the current roadless inventory. Many examples of this situation are described below, but in all, over 200,000 acres of roadless lands on the GMUG were incorrectly excluded from the 2005 GMUG Roadless Inventory. These omissions should be corrected prior to issuance of any final Colorado Rule. C. Descriptions of Individual Roadless Areas Inventoried With Inaccurate Boundaries.
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