Biological Assessment

For

Federally Listed Species

For

Silverton Guides Helicopter Ski Terrain Exchange

Prepared For:

Bureau of Land Management, Gunnison Field Office, Gunnison County, Colorado

Prepared By: Reviewed By:

Clayton Bowers Katherine Brodhead Rocky Mountain Ecology, LLC Bureau of Land Management 306 Rosalie Dr. 210 West Spencer Ave., Suite A Durango, CO 81301 Gunnison, CO 81230

Date: October 2016 Date: December 2016

Contents

INTRODUCTION ...... Error! Bookmark not defined. Purpose ...... Error! Bookmark not defined. CONSULTATION HISTORY ...... Error! Bookmark not defined. PROJECT INFORMATION ...... Error! Bookmark not defined. Location ...... 2 Background ...... 3 Proposed Federal Action ...... Error! Bookmark not defined. PROJECT DESIGN CRITERIA ...... Error! Bookmark not defined. Landing Zones ...... 4 No Fly Zones ...... 4 Typical Flight Corridors ...... 4 User Days ...... 5 Avalanche Mitigation and Stability Testing ...... 5 EXISTING VEGETATION...... Error! Bookmark not defined. SPECIES CONSIDERED ...... Error! Bookmark not defined. Discussion Of Effects To Federally-Listed Species ...... Error! Bookmark not defined. Downstream Listed Fishes ...... 7 Direct, Indirect and Cumulative Effects ...... 7 Determination ...... 7 Terrestrial Species ...... 7 Canada Lynx ...... 7 Status and Distribution of Lynx in the Analysis Area: ...... Error! Bookmark not defined. Anthropogenic Influences Specific to Canada Lynx ...... Error! Bookmark not defined. Affected Environment and Environmental Baseline ...... Error! Bookmark not defined. Risk Factors Affecting Lynx Productivity ...... 10 Risk Factors Affecting Lynx Mortality ...... 10 Risk Factors Affecting Lynx Movement and Dispersal ...... 10 Direct and Indirect Effects ...... Error! Bookmark not defined. Cumulative Effects ...... Error! Bookmark not defined. Determination ...... Error! Bookmark not defined. Canada Lynx Conservation Assessment and Strategy – Conservation Measures ...... Error! Bookmark not defined. North American Wolverine ...... 14 Status and Distribution of Wolverine in the Analysis Area: ...... Error! Bookmark not defined. DIRECT AND INDIRECT EFFECTS ...... 14 CUMULATIVE EFFECTS ...... 15 DETERMINATION ...... 15 Uncompahgre Fritillary Butterfly ...... 15 Direct, Indirect and Cumulative Effects: ...... 15 Determination ...... 16 LITERATURE CITED ...... 16 Figure 1. Vicinity Map...... 19 Figure 2. Location of Silverton Guides SRP removed and proposed allowable use areas ...... 20 Figure 3. Silverton-Lake City linkage area in the Silverton Guides SRP project area...... 21 Figure 4. Lynx habitat in the Silverton Guides SRP project area ...... 22

Silverton Guides Helicopter Ski Terrain Exchange BA

I. INTRODUCTION

The purpose of this BA is to evaluate the potential effects from the proposed Silverton Guides Helicopter Ski Terrain Exchange project on federally listed fish and wildlife species and candidates for federal listing, as designated by the U.S. Fish and Wildlife Service (USFWS). The species considered are those that are known to occur or have the potential to occur in San Juan County on Bureau of Land Management land managed by the Gunnison Field Office. A list of U.S. Fish and Wildlife Service (USFWS) threatened, endangered, candidate, and proposed wildlife species as well as conservation status, habitat associations, and potential to occur in the analysis area is presented in Table 2. The proposed amendment to Silverton Guides’ helicopter skiing (heli-skiing) Special Recreation Permit (SRP) would change allowable use area (AUAs); including removal, retention, and expansion of areas where heli-skiing is authorized. Overall, there would be a net increase of 10,686 acres authorized for operations. This BA will review proposed activities associated with the exchange in sufficient detail to identify the level of effect that may occur to federally listed species. In 2008, an Environmental Assessment (EA) (and accompanying BA) was completed that analyzed impacts of three alternatives in the project area (Telluride Helitrax Special Recreation Permit EA and Decision Record (CO-800-2006-037-EA)). As part of that analysis, it was determined that the Proposed Action may affect, but is not likely to adversely affect the Canada lynx. All other species analyzed had “no effect” determinations. The current Proposed Action includes the removal of five of the individual ski areas (ski pods) and addition of four ski pods to the Silverton Guides SRP.

II. PROPOSED ACTION

A. PROJECT DESCRIPTION The BLM is responding to an application by Silverton Guides to exchange terrain that is permitted for heli-skiing under an existing SRP with other terrain on BLM lands. Silverton Guides currently holds an SRP for heli-skiing operations across 14,388 acres within eight ski pods but the requested exchange would remove five pods (5,566 acres), open operations in four new pods (16,252 acres), and retain three pods (Table 1, Figure 2). The purpose of this project is to improve the economic viability of Silverton Guides as an important component of the San Juan County economy and to maintain the sustainability of this recreational offering on BLM lands. The terrain exchange would allow Silverton Guides to operate on less hazardous terrain, reduce the risk of avalanche hazard, and provide more varied ski terrain. The ski pods that would be removed have poor quality and dangerous snow conditions created by winds funneling through the Uncompahgre Gorge. The new ski pods would offer less challenging terrain with more acreage below timberline. The Proposed Action would include removal of the Grouse Gulch, Cinnamon, Houghton, Poughkeepsie and Ross Basin ski pods, which all occur in the northern extent of the project area (5,566 acres). The California/Treasure, Bonita/Emery/McCarty and Slagle/Tower ski pods would remain within the SRP, which generally occur in the central portion of the project area. Finally, the Proposed Action includes the addition of four ski pods in the southern and western extent of the project area; these include the Illinois/Hancock, Round, Southeast and Minnie/Maggie ski pods (16,252 acres). The Proposed Action would result in a net increase of 10,686 acres to the SRP (Figure 2, Table 1).

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Silverton Guides Helicopter Ski Terrain Exchange BA

Table 1: Summary of Terrain Exchange

Pod Acres Removed from SRP Grouse Gulch 617 Cinnamon 1,100 Houghton 2,488 Poughkeepsie 883 Ross Basin 478 Total 5,566 Added to SRP Illinois/Hancock 1,789 Southeast 10,628 Round 779 Minnie/Maggie 3,057 Total 16,252 Net Increase in SRP 10,686 Total SRP Area 25,074

The proposed terrain exchange would not result in the construction of any infrastructure or other ground disturbing activity.

B. PROJECT LOCATION AND PROJECT AREA DESCRIPTION The project area is located within about a 10-mile radius north and east of the town of Silverton in San Juan County, Colorado and is primarily on BLM lands managed by the Gunnison Field Office. Portions of the project area are contained on the Silverton, Ironton, Handies Peak and Howardsville U.S. Geological Survey 7.5 minute topographic maps. The legal location of the project area includes many sections in T 41, 42 and T 43 N, R 6 and 7 W (Figure 1). The analysis area is located in the Animas River watershed and thus any water depletion activities would affect the San Juan River basin. All of the current and proposed allowable use areas (i.e., the currently permitted and proposed ski areas) are in the Silverton Lynx Analysis Unit, which is on public lands managed entirely by the BLM, Gunnison Field Office. The dominant vegetation type consists of alpine, which is comprised of turf, fellfield, dwarf willow and wetland vegetation types. Approximately one-third of the area is composed of bare soil and rock, including rock scree, talus slopes and cliffs. The remaining vegetation types consist of spruce-fir and mountain grassland matrices. The allowable use areas (AUAs) for the Silverton Guides SRP contain about 25,074 acres of these various habitat and vegetation types.

C. PROJECT DESIGN CRITERIA The Proposed Action incorporates design criteria and/or mitigation measures that are intended to maintain and/or improve wildlife habitat conditions and key habitat components. Determinations of likely effects of the Proposed Action on wildlife species are based on the full application of all design

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Silverton Guides Helicopter Ski Terrain Exchange BA criteria and mitigation measures. Failure to fully implement all design criteria and mitigation measures may invalidate this analysis and its determinations of likely effects to fish and wildlife species.

1. LANDING ZONES Silverton Guides would use a helicopter to transport guests from the Silverton Ski Area (typically from the top of the chairlift) to the heli-skiing pods within their SRP throughout the winter, as conditions allow. Guests would be dropped off by the helicopter at Landing Zones at higher-elevation points within the SRP and would then ski down with their guide to meet the helicopter at another Landing Zone. Landing Zones would have the following characteristics:  No vegetation clearing, trimming or modification would occur.  Landing Zones would be utilized when vegetation is covered and protected by snow.  Landing Zones would not occur within cultural resource avoidance areas (see Figure 2).  No Landing Zones or skier drop-offs would occur in the Weminuche Contiguous Wilderness Study Area (WSA).  No structures, improvements or equipment storage would be required.  No fueling would occur on BLM lands within the SRP.  Temporary “wands” would be utilized at proposed Landing Zones for use by the helicopter pilot in determining wind direction and speed during landings and takeoffs. Wands may be placed at Landing Zones each winter season, but would be removed at the end of the season. Wands are made of natural sticks with biodegradable natural flagging material.  Flight and avalanche safety protocols require that the pilot and guides have multiple options for landings and ski runs on any given day based on changing wind and avalanche conditions. Landing Zones would avoid identified cultural and Wilderness areas.

2. NO FLY ZONES Three No Fly Zones (areas where heli-skiing helicopters would be prohibited from entering) have been incorporated into the Proposed Action (Figure 2). The first is an area of approximately 4,700 acres around the Town of Silverton, the second is approximately 90 acres in the southern portion of the Southeast pod along the boundary with the Weminuche Wilderness area, and the third is approximately 800 acres in the Southeast pod where it overlaps with a Wilderness Study Area. In addition to the No Fly Zones in the Southeast pod, pilots would be provided with defined geographic points and GPS to prevent landings in the Weminuche Wilderness area. The No Fly Zone along the Wilderness boundary would ensure that helicopters remain at least approximately 250 feet from the Wilderness area.

3. TYPICAL FLIGHT CORRIDORS Flight corridors to the proposed Southeast, Round, and Minnie/Maggie pods would typically head southeast from the existing Silverton Ski Area and pass approximately 4 miles to the east of the Town of Silverton. Once in the vicinity of County Road 2, the helicopters would turn to the south or north depending on the specific area being skied (see Figure 2). Typical flight altitudes would be more than 4,000 vertical feet higher than the Town of Silverton at 13,500 feet.

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Silverton Guides Helicopter Ski Terrain Exchange BA

4. USER DAYS The current SRP authorizes 600 heli-skiing user days. No changes to the operational dates or increases in total user days are proposed. Silverton Guides uses one helicopter that holds six people, including the pilot, guide, and four guests. Flights originate from the top of the chairlift at Silverton Mountain Ski Area. Throughout the ski season, 600 user days could translate into as many as 150 helicopter trips. With an optimal season of 120 days, this would amount to over one trip per day. Hours of helicopter operation would be limited to 0.5 hour after sunrise through 0.5 hour before sunset, or generally between 8:00 am and 5:00 pm daily. No night time heli-ski operations are proposed.

5. AVALANCHE MITIGATION AND STABILITY TESTING Avalanche mitigation and stability testing is proposed for the additional pods (Illinois/Hancock, Southeast, Round, and Minnie/Maggie). Existing avalanche control measures would be terminated in the pods proposed for removal from the SRP. Stability assessments involve a number of procedures including ski cutting and avalanche forecasting. Silverton Guides currently performs stability assessment throughout their existing SRP and Silverton Ski Area, including helicopter explosive deployment. The majority of the stability assessments conducted by Silverton Guides do not use any explosives, however, some helicopter explosive deployment is proposed. Prior to any explosive use, standard operating procedures include a thorough visual reconnaissance to assure the absence of individuals from the hazard areas (e.g. hikers, backcountry skiers or snowmobiles). No explosives would be utilized without an inspection of the avalanche path and run out zone for the presence of backcountry users and/or wildlife. Additionally, no explosives would be used in identified cultural resource avoidance areas (see Figure 2). All use of explosives within the proposed SRP would be governed by the requirements outlined in federal regulations (14 CFR and 49 CFR). These regulations pertain to the use of explosive materials for the purposes of avalanche mitigation and control. All operations involving the handling, dispensing, or expending of hazardous materials for the purpose of avalanche control would conducted be in accordance with these regulations. Each winter season, prior to the commencement of operations, all personnel who will be involved with the use of explosives would participate in a minimum of four hours of refresher training in the use of explosives. All personnel would also participate in helicopter safety training with the contracted helicopter service provider. A written report currently is, and would continue to be, provided to the BLM at the end of each season detailing the areas tested and the results.

D. BACKGROUND The BLM lands encompassed by this proposed SRP amendment are used by increasing numbers of winter recreationists each year, including snowmobilers, cross-country skiers, backcountry skiers and snowboarders, snowshoers, as well as heli-skiers. The area also provides important winter habitat for wildlife species including Canada lynx and white-tailed ptarmigan. As the overall level of dispersed recreation use has increased, conflicts have arisen among various human user groups, and wildlife habitat concerns have grown. Silverton Guides currently holds an SRP for heli-skiing operations across 14,388 acres within eight ski pods. New technology of wider skis that has been developed over the past ten years has allowed more intermediate skiers to ski high alpine basins and deeper powder snow, which is the product accessed by

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Silverton Guides Helicopter Ski Terrain Exchange BA heli-skiing. Recent improvements in ski technology have therefore broadened the client base for heli- skiing operations.

III. SPECIES EVALUATED

A list of U.S. Fish and Wildlife Service (USFWS) threatened, endangered, candidate, and proposed wildlife species that occur or have the potential to occur within the analysis area was obtained from the USFWS Information, Planning, and Conservation (IPaC) decision support system (USFWS 2016). Information for each species including their conservation status, habitat associations, and potential to occur in the analysis area is presented in Table 2. No critical habitat occurs in the project or analysis area. Table 2. Federally listed species with potential to occur in the project area (USFWS 2016). Habitat Present In Federal Species Affected by Project Effects Species Allowable Use Status Proposed Action? Determination Areas (AUA)? Fish Bonytail chub Endangered No – species does not No – no water No Effect (Gila elegans) occur downstream in depletions from the San Juan River basin Animas River basin Colorado Endangered No – but species No – no water No Effect pikeminnow occurs downstream depletions from the (Ptychocheilus in San Juan River Animas River basin lucius) basin Humpback chub Endangered No – species does not No – no water No Effect (Gila cypha) occur downstream in depletions from the San Juan River basin Animas River basin Razorback Endangered No – but species No – no water No Effect sucker occurs downstream depletions from the (Xyrauchen in San Juan River Animas River basin texanus) basin

Mammals Canada lynx Threatened Yes – mature spruce- Yes – disturbance May Affect, Not Likely (Lynx fir and willow - effects from human, to Adversely Affect canadensis) riparian areas; parts helicopter and snow of Silverton-Lake City stability testing linkage are also in activities AUA

North American Proposed Yes – deep persistent If wolverine were to Will not jeopardize wolverine Threatened snow cover in occur in project area the continued (Gulo gulo subalpine cirques there would be existence of the luscus) near talus slopes and disturbance effects from wolverine rock outcrops human, helicopter and present in AUAs snow stability testing activities. However, the wolverine is believed to have been extirpated from the Southern Rocky Mountains in Colorado by early 1900s.

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Silverton Guides Helicopter Ski Terrain Exchange BA

Habitat Present In Federal Species Affected by Project Effects Species Allowable Use Status Proposed Action? Determination Areas (AUA)? Invertebrates Uncompahgre Endangered Yes – field confirmed No – habitat protected No Effect fritillary snow willow patches by snow cover butterfly in AUAs (Boloria acrocnema) Birds Southwestern Endangered No - Associated with No- no suitable habitat No Effect Willow riparian shrub in the project area flycatcher dominated habitats in (Empidonax broad lowland traillii extimus) floodplains

IV. DOWNSTREAM LISTED FISHES

All of the drainages in the AUAs on lands managed by the Gunnison Field Office flow into the headwaters of the Animas River upstream of the town of Silverton. Water from the Animas River basin flows southward in to the San Juan River near Farmington, New Mexico. Activities that deplete water from the San Juan River basin, of which the Animas River is part, have been identified by the USFWS as having adverse cumulative effects to the Colorado pikeminnow and razorback sucker. The two remaining listed fishes, humpback chub and bonytail, do not occur in the San Juan River basin and thus are not affected by activities that deplete water from the San Juan River basin.

1. DIRECT, INDIRECT AND CUMULATIVE EFFECTS The project area contains no habitat for listed fishes and the Proposed Action does not include any activities that might cause downstream water depletions from the San Juan River basin. For these reasons, the Proposed Action will not cause any direct, indirect, or cumulative effects for any downstream listed fishes.

2. EFFECTS DETERMINATION The Proposed Action does not include any activities that could cause downstream water depletions from the San Juan River basin. For this reason, the Proposed Action would have “no effect” on the humpback chub, bonytail, Colorado pikeminnow, or razorback sucker.

V. TERRESTRIAL SPECIES

A. CANADA LYNX

1. MANAGEMENT FRAMEWORK The Canada lynx was listed as threatened in the contiguous United States as a distinct population segment (DPS) under the ESA in 2000. In the final rule, the USFWS concluded that the factor threatening the contiguous U.S. DPS of lynx is the inadequacy of existing regulatory mechanisms, specifically the lack of guidance for conservation of lynx in the National Forest Land and Resource Management Plans and the BLM Land Use Plans (65 FR 16052–16086). The Lynx Conservation Assessment and Strategy (LCAS) (Ruediger et al. 2000) was developed to provide an approach for conservation of lynx on federal lands

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Silverton Guides Helicopter Ski Terrain Exchange BA and to assist with Section 7 consultation. The LCAS was revised in August 2013 by the Interagency Lynx Biology Team, incorporating the best available science that had been published since the previous edition (Interagency Lynx Biology Team 2013). The revised LCAS synthesizes the best available science on lynx and recommends guidelines, objectives, and standards for all projects on public lands within designated lynx range. In 2006, the USFWS designated critical habitat for the lynx, which was revised in 2009 (74 FR 8616–8701). The LCAS recommended that Lynx Analysis Units (LAUs) be identified for all areas with lynx habitat in order to provide context for analysis of effects of projects on individual lynx and to monitor habitat changes. LAUs were developed for public lands in southwest Colorado, including the Bureau of Land Management (Schultz et al. 2006). The area used to analyze direct, indirect, and cumulative effects for the proposed activities is the Silverton LAU. LAUs are considered the appropriate scale at which to analyze effects of management actions on lynx habitat because LAUs are delineated at a scale that approximates the area used by a female reproductive lynx (Ruediger et al. 2000, Interagency Lynx Biology Team 2013).

2. EXISTING CONDITION Lynx are associated with relatively high-elevation, moist conifer forests that experience cold, snowy winters and provide a prey base of snowshoe hare. Subalpine fir potential vegetation types provide primary lynx habitat (Interagency Lynx Biology Team 2013). Lynx in the San Juan Mountains primarily use high elevation spruce-fir and aspen vegetation types as habitat (Theobald and Shenk 2011). Winter foraging habitat has vegetation structure suitable for snowshoe hares including dense understories of young trees and shrubs that protrude above the snow level and conifer boughs that touch the snow surface. Lynx den sites are typically located in mature spruce/fir stands or mixed forests of aspen and spruce. Forest structure seems to be more important than cover type. Areas with large woody debris such as blow-down pockets, and ample overhead cover are preferred by lynx for denning. Downed logs, root fans, boulders, and dense shrub understories may provide hare cover during summer, as well as lynx denning structure. In an effort to re-establish a viable population of lynx, Colorado Parks & Wildlife (CPW) began transplanting lynx in 1999 and 2000 into a core area of southwestern Colorado (Colorado Parks & Wildlife 2004). Live lynx were captured in Alaska and Canada, held briefly in a holding facility near Del Norte, CO then released in early spring. Releases occurred in the core area every year from 1999 to 2006 and natural reproduction has been documented on San Juan Public Lands. To date, all lynx dens found in the San Juan mountains have been in Engelmann spruce/subalpine fir forests in areas of extensive downfall, generally on north facing slopes and ranging from about 10,200 feet to about 11,800 feet elevation (Merrill and Shenk 2006). The Proposed Action occurs entirely within the Silverton LAU, which is about 67,000 acres in size and lies on public lands managed entirely by the BLM. This LAU encompasses a rugged, remote, and high- elevation portion of the San Juan Mountains just northwest of the Weminuche Wilderness. The Silverton LAU contains about 22,100 acres of non-federal lands and about 44,900 acres of BLM lands. Private in- holdings are usually long narrow parcels that run roughly perpendicular to the general land slope from ridgelines to valley bottoms, and are usually obtained through purchase of patented mine claims In addition there are smaller pieces of Forest Service and very minimal State of Colorado land.

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Silverton Guides Helicopter Ski Terrain Exchange BA

Table 3. Acres of lands mapped as Canada lynx habitat in the Silverton Lynx Analysis Unit based on the San Juan Public Lands lynx habitat model (Schultz et al. 2006). Currently Denning Additional Winter Other Lynx Non-Lynx Total area in Ownership Unsuitable Lynx Habitat Foraging Habitat Habitat Habitat LAU Habitat 9,834 1,809 9,203 0 46,165 67,011 All Owners 15% 3% 14% 0% 69% 101% BLM Lands 7,062 1,119 6,628 0 30,081 44,889 Only 16% 2% 15% 0% 67% 100%

Of the 14,808 acres of suitable lynx habitat on BLM lands in the Silverton LAU, 55% (8,181 acres) is mapped as lynx denning or winter foraging habitat. Forty-five percent of suitable lynx habitat on BLM lands is mapped as other lynx habitat. About 67% of BLM lands in the Silverton LAU are mapped as non- lynx habitat. Much of the non-lynx habitat is alpine tundra, scree and talus slopes, alpine cirques, and rugged alpine peaks. Suitable lynx habitat is well distributed across the Silverton LAU with most patches of lynx habitat connected or in relatively close proximity to neighboring habitat patches. The town of Silverton is the only significant human impediment to lynx movement within or through the LAU. The Proposed Action generally contains denning and winter habitat at the lower elevation portions of the AUAs, where proximity to and presence of spruce-fir stands are common. Spruce–fir habitat in the analysis area is similar to that being used by lynx in southwest Colorado. Forest stand interiors frequently contain some saplings and pole-size trees with branches that extend down to the snow surface and thus are available for snowshoe hare during winter. Larger, mature trees also with sweeping lower limbs also provide a food source for snowshoe hare. The relatively high canopy closure typical of many spruce/fir forests in the San Juan Mountains often results in a sparse understory that is of limited value as foraging habitat during non-snow seasons. Forest edge habitats, such as along avalanche chutes, creeks, and wind throw openings, contain denser understories because of the additional light that reaches the forest floor. These areas provide higher value summer and winter foraging habitat than the forest interior. Much of the spruce-fir habitat in the analysis area is on relatively steep and generally north facing slopes. Connectivity of lynx habitat is an important consideration for the southern Rockies. Thirty-eight linkage areas were identified in the southern Rockies and management direction for these areas is to maintain connectivity of habitat and facilitate lynx movements (Interagency Lynx Biology Team 2013). Three designated lynx linkage areas come together at or near the town of Silverton. These are the Silverton- Lake City, Molas/Coal Bank Pass, and Red Mountain-South Mineral linkage areas. The Silverton-Lake City linkage area bisects the analysis area and overlaps much of the eastern AUAs (Figure 3). All three linkage areas and much of the Silverton LAU are known to be used by lynx for movement around and through the area and as year-round home range (S. Wait pers. comm.). The Silverton area, near which the AUAs are located, has a moderate level of human activity year round. During winter, BLM and County roads receive moderate use by cross country skiers, snowshoers, snowmobilers and people walking dogs. Some ski trails are groomed by snowmobile and snowcat when snow conditions warrant. During summer, most BLM and County roads are busy with recreation-use, 4- wheel drive- and ATV-use, and dispersed camping. Because Telluride Helitrax and Silverton Guides have provided heli-skiing services on BLM lands around Silverton since 1995 under 1-year annual and 5-year SRPs, heli-skiing operations are part of the historic environmental baseline and affected environment for this landscape.

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Silverton Guides Helicopter Ski Terrain Exchange BA

It is not known whether lynx released by the CPW are using any of the Silverton LAU for denning or general movements but suitable habitat exists and this analysis assumes that suitable habitat may be occupied by individual animals at some time during the year.

RISK FACTORS AFFECTING LYNX PRODUCTIVITY Risk factors specific to lynx productivity in the Silverton LAU are associated with quantity and quality of denning and winter foraging habitat, and potential competition for prey resources resulting from limited snow compacted corridors that allow access for other carnivores. Design criteria that are part of the Proposed Action will not permit vegetation clearing, trimming, or modification at landing sites or within AUAs. For this reason, the Proposed Action will not cause alteration of habitat structure for lynx or their primary prey species. Human activities in lynx habitat in winter, such as skiing, may lead to patterns of snow compaction that allow competing predators, such as coyotes, to access deeper snow habitats where lynx formerly held a competitive advantage. The potential for snow compaction is low with heli-skiing because the “product” provided by the flight service is powder skiing in untracked snow. Clients are given the opportunity to make several runs in untracked powder, and then are moved to a new location with untracked snow. The deep snow on preferred slopes, wind drifting, and successive storms fill in tracks left by skiers and serve to prevent a given area from becoming compacted by skier activities. For these reasons, heli-skiing activity is not expected to increase snow compaction within the AUAs, beyond that which already exists due to natural causes (i.e. avalanches) or other human activities (i.e. snowmobiles).

RISK FACTORS AFFECTING LYNX MORTALITY The potential for increased risk of lynx mortality resulting from increased human activities associated with helicopter use and skier travel is unlikely. The Proposed Action is not likely to result in the lynx becoming less competitive with other species in deep snow environments across the AUAs.

RISK FACTORS AFFECTING LYNX MOVEMENT AND DISPERSAL Lynx conservation depends upon maintaining landscape connectivity such that all areas of suitable lynx habitat have the potential to support lynx residency and movements and lynx populations remain connected. Connectivity among forested habitats allows lynx to move long distances in search of food, cover, and mates. Linkage areas are important in providing landscape connectivity between areas containing larger blocks of lynx habitat. Much of the AUAs are within the Silverton-Lake City linkage. Because heli-skiing and snow stability testing activities will be conducted primarily outside of lynx habitat, these activities are unlikely to preclude lynx movement through the AUAs and thus the use of helicopters is not expected to alter existing lynx habitat movement or dispersal patterns, habitat connectivity, or the function of the two nearby linkage areas. Lynx movement through AUAs will be maintained with the opportunity for lynx to use the area at night and during inclement weather and snow stability conditions when helicopter and skier activities are restricted or curtailed. Skiing and snow stability testing is unlikely to affect lynx nocturnal movement patterns and these areas could be crossed by lynx at night. Human disturbance associated with winter recreation can reduce effectiveness of habitat to support lynx as disturbance can preclude lynx from using habitat in an optimal manner. It is difficult to assess the magnitude of displacement associated with winter recreation as few studies have examined how lynx react to human presence and the effects of disturbance to lynx associated with winter recreation depend on the type of activity and the context within which it occurs (Interagency Lynx Biology Team 2013). Behavioral response to disturbance could range from startle response to temporary

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Silverton Guides Helicopter Ski Terrain Exchange BA displacement to abandonment of habitat, depending on the frequency and duration of disturbance and tolerance threshold of individual lynx. Preliminary information from Colorado indicates that some winter recreation is compatible with lynx presence but that lynx may avoid concentrated recreation use (J. Squires pers. comm. cited in Interagency Lynx Biology Team 2013). However, there is also evidence of lynx using ski areas and other human inhabited locations (Olliff et al. 1999) and with repeated exposure to regular human activity, lynx may adapt behaviorally and/or physiologically (Bowles 1995) . For all the reasons discussed above, the Proposed Action has the potential to affect lynx movement and dispersal patterns, primarily through disturbance effects.

3. EFFECTS OF THIS PROJECT

DIRECT AND INDIRECT EFFECTS The proposed AUAs contain denning and winter habitat, generally at the lower elevations of the ski pods where spruce-fir communities occur. The proposed AUAs are within the Silverton BLM LAU. The proposed AUAs (25,074 acres) represents a 74% increase in area from that permitted under the company’s current 5-year permit (14,388 acres). There are 873 acres of mapped lynx habitat in the currently permitted AUAs. In the proposed AUAs, there are 3,337 acres of mapped lynx habitat, which is approximately 9% of the habitat in the LAU and 23% of the habitat in the LAU owned by the BLM. The Southeast, Minnie/Maggie,and Round ski pods all occur entirely within the Silverton-Lake City linkage area. Together, these pods comprise 13,684 acres across both BLM and private lands. The Silverton-Lake City linkage area totals 36,634 acres; therefore, these ski pods comprise approximately 37% of the Silverton-Lake City linkage area. No change to user days per year is proposed as part of the Proposed Action. Therefore, no additional impacts to lynx or lynx habitat will result as part of this parameter. Silverton Guides is currently permitted for 600 heli-skiing user days. The season typically lasts from December through April. Silverton Guides uses one helicopter that holds six people, including the pilot, guide, and four guests. Flights originate from the top of the chairlift at Silverton Mountain Ski Area. Throughout the ski season, 600 user days could translate into as many as 150 helicopter trips. With an optimal season of 120 days, this would amount to over one trip per day. User days are likely to be higher in April than other winter months due to more favorable snow and mountain weather conditions. Three primary sources of direct and indirect effects to lynx and lynx habitat are possible from the Proposed Action: (1) increased snow compaction, (2) disturbance caused by skiers, and (3) disturbance caused by the use of helicopters and explosives for snow stability testing. Physical alteration of lynx habitat is not expected from implementing the Proposed Action due to design criteria prohibiting clearing, trimming, or modification of vegetation at landing sites or within the AUAs. The amount of increase in snow compaction from project implementation is expected to be negligible because of the generally disconnected nature of landing zones and ski runs from other compacted routes. Because foot and ski access into the AUAs during winter is difficult, the AUAs are generally far from most sources of human-caused snow compaction and preferred over snow travel routes. The AUAs have been selected in part to minimize the potential for conflict between non-motorized backcountry users and helicopter services in the backcountry. For this reason, the Proposed Action is unlikely to expand the extent or connectivity of snow compacted corridors in the analysis area and thus is not expected to increase access to lynx habitat by potential lynx competitors. In addition, much of the analysis area is bisected by avalanche chutes and terrain in which naturally triggered slides are a common occurrence.

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Silverton Guides Helicopter Ski Terrain Exchange BA

Heli-skiing will increase the distribution of skiers throughout the AUAs, thereby increasing the potential for skier disturbance to lynx that may be using the area. The risk of disturbance to lynx from skier presence is expected to be low because most skier activities will occur in alpine bowls and basins, generally above the elevation of primary lynx habitat. Some disturbance is possible however, because skiers dropped at the top of alpine runs may be picked up at landing zones below timberline and thus skiing through lynx habitat below timberline. In so doing, most skiers prefer to follow natural forest openings and open timber, thereby reducing the potential for disturbance to lynx that might be using the area. Heli-skiing activities would not occur during denning season so there is no risk to disturbance of den sites. The denning period is the period that lynx are likely to be most sensitive to disturbance. Heli-skiing will take place from early December through late April and is likely to be most common during the month of April. The denning period is from May through July (Olson et al. 2011). The use of helicopters could cause both visual and aural disturbance to lynx, and could cause modification of lynx behavior. Helicopters are expected to spend only a few minutes at each landing zone dropping off or picking up skiers. Furthermore, it is expected that flight duration over forested habitats would be short given the typically short linear distances between skier drop-off and pickup landing zones. The degree of disturbance risk to lynx from helicopter landings is expected to be low at most drop-off landing zones due to their being widely distributed across the AUAs and their being located primarily on alpine ridgelines and benches and thus well removed from primary lynx habitat. The degree of disturbance risk is higher at pickup landing zones because of their closer proximity to and the location of some within primary lynx habitat. Helicopter activities at landing zones would be irregular and unpredictable. Disturbance to lynx using these habitats is likely to be variable but generally low to moderate. Helicopter operations at and around the re-fueling locations would create additional noise disturbance to lynx that may be present in adjacent forest. No re-fueling would occur on BLM lands; however, BLM lands may exist adjacent to these locations. No increase in skier days is proposed as part of the Proposed Action; therefore, no increase in re-fueling frequency would result. There would be no net change in disturbance levels at re-fueling stations from what currently exists. Snow stability testing carried out in basins that lie near timberline are another potential source of disturbance to lynx. This effect is likely to be most pronounced in areas favored for skiing operations where terrain requires regular snow stability testing. The shape of some alpine basins concentrates and amplifies noise impacts, increasing the potential for disturbance to animals above that which would have occurred in more-open terrain. In most cases, the sudden explosion produced by charge detonation is likely to be more disturbing to animals than the relatively more consistent and predictable noise of a helicopter passing overhead. Therefore, snow stability testing is presumed to cause more intense disturbance to lynx than other project related activities. Disturbance from snow stability testing is likely to be quite variable, as it will depend on local weather and snowpack conditions, and on company terrain preferences and booking schedules. For these reasons, the disturbance effects of snow stability testing on individual lynx are expected to unpredictable, uncommon and irregular, and scattered across the AUAs, reducing the likelihood that these activities will significantly affect individual lynx. The safety risk posed to individual animals from avalanches triggered by snow stability testing is expected to be very low. During the day, most lynx are likely to be active in dense spruce-fir timber or other high cover areas and thus generally well removed from high-risk avalanche areas. In addition, because most snow-stability testing is likely to occur in areas that are also at risk of recurring natural avalanches, snow stability testing is unlikely to substantially increase the exposure or risk of individual

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Silverton Guides Helicopter Ski Terrain Exchange BA animals above that which they already face while using the same terrain in the absence of heli-skiing operations. In general, the type and intensity of response of lynx to disturbance is difficult to predict (Interagency Lynx Biology Team 2013). It is expected that most lynx would react negatively to increased levels of human and helicopter activity and/or snow stability testing associated with approving the Proposed Action as compared to current average annual levels of heli-skiing activity. It is possible however, that some individual lynx could become habituated to increased levels of activity around areas of regular and repeated helicopter use. For all the reasons discussed above, the Proposed Action has the potential to affect lynx productivity, movement, and dispersal patterns, primarily through disturbance affects to lynx and lynx habitat. The degree of risk of disturbance to individual lynx however, is expected to be generally low in intensity (depending on the type of disturbance), irregular in nature, brief in duration, and dispersed across the 25,074 acres of AUAs. For these reasons disturbance effects to lynx are likely to be insignificant and discountable.

CUMULATIVE EFFECTS Future actions that are likely to occur on non-federal lands include limited seasonal residential development on small private land in-holdings scattered throughout the project area. The project area contains moderate amounts of non-federal land (about 33% of the Silverton LAU). San Juan county land-use codes limit residential building to below tree-line and access to most non-Federal lands outside the town of Silverton is limited to foot and snowmobile travel in the winter. For these reasons, there is only limited construction in the project area. Currently, there are eight open building permits for these types of seasonal residential cabins within the Minnehaha and Southeast pods (K. Buck, pers. comm.). There is also very limited non-residential construction in the project area. The San Juan County Historical Society has been and is continuing restoration efforts on the Old Historic Boarding House within the Southeast pod, which is work that requires helicopters to deliver supplies. Given the limits on construction in the project area, fragmentation of the linkage area is unlikely to be significant.

4. EFFECTS DETERMINATION Based on the above information, the Proposed Action may affect but is not likely to adversely affect the Canada lynx and lynx habitat in the project area. The Proposed Action has the potential to affect lynx productivity, movement, and dispersal patterns, primarily through disturbance affects to lynx and lynx habitat. However, the degree of risk of disturbance to individual lynx is expected to be generally low in intensity because it will be irregular in nature, brief in duration, and dispersed across the 25,074 acres of AUAs. Additionally, the amount of increase in snow compaction from project implementation is expected to be negligible. For these reasons, effects of disturbance on individual lynx would be insignificant and discountable. The proposed activities are described by the 2013 LCAS as activities that are not likely to have a substantial effect on lynx populations or habitat. Two tiers of anthropogenic influences were developed in the 2013 LCAS based on risk factors for Canada lynx in core areas. The first tier of factors includes those that have the potential to negatively affect lynx populations and habitat, while the second tier factors have potential to affect individual lynx but are not likely to have a substantial effect on lynx populations or habitat. The Proposed Action would be considered under recreation management, which are activities that are considered a second-tier factor. The project would be fully consistent with three of the four conservation measures in the LCAS pertaining to recreation (Interagency Lynx Biology Team 2013, p. 94). Lynx habitat connectivity will be maintained because there will be no changes to lynx habitat and any changes to habitat effectiveness as

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Silverton Guides Helicopter Ski Terrain Exchange BA a result of disturbance will be short-term and temporary. No facilities or concentrated recreational use areas will be developed as a result of this proposal. No designated over-the-snow routes or snowmobile play areas are being proposed. The fourth conservation measure in the LCAS specific to recreation, to direct activities away from linkage areas, is only partially met. The Proposed Action does not include any facility development but will result in a net increase of a recreational activity within an identified linkage area. However, given the lack of foraging habitat in linkage areas, transient lynx would move through the area quickly. Heli-ski activities on any given day will be brief and dispersed and if there were dispersing or transient lynx in the area at the same time as heli-skiers they could avoid activities because of the limited duration and because any tracks left by skiers will not change the ability of the lynx to cross the area. Overall, effects to the Silverton-Lake City linkage area as a result of the Proposed Action are insignificant and discountable.

B. NORTH AMERICAN WOLVERINE

1. MANAGEMENT FRAMEWORK On February 4, 2013, the US Fish and Wildlife Service (Service) published a proposed rule to list the distinct population segment (DPS) of the North American wolverine occurring in the contiguous United States, as a threatened species under the Endangered Species Act (78 FR 7863). The DPS evaluation in the proposed rule concerns the segment of the wolverine species occurring within the contiguous 48 states, including the northern and southern Rocky Mountains, Sierra Nevada Range, and North Cascades Range (78 FR 7863). The Service did not propose any critical habitat for the species. On August 13, 2014, The Service withdrew the proposed rule to list the species (79 FR 47522). On April 4, 2016, the United States District Court of the District of Montana vacated the Service’s withdrawal of the proposed rule (Case 9:14-cv-00246-DLC Document 108), reinstating the proposed status of the wolverine.

2. EXISTING CONDITION Wolverines inhabit alpine areas near tree-line basins and cirques and associated subalpine forests in areas that are otherwise remote from most other human winter activities (Inman et al. 2012). The persistence of snowpack into late spring is a strong determining factor in wolverine presence possibly because of the need for deep snow during the denning period (Copeland et al. 2010, Inman et al. 2013). The remote and inaccessible terrain targeted for heli-skiing is the same terrain favored by wolverines for denning, movement, and foraging; and the project area is thought by CPW to constitute some of the highest quality potential wolverine habitat remaining in the state of Colorado. There are numerous historical records of North American wolverines from the Colorado Rocky Mountains; however, the species is believed to have been extirpated from the Southern Rocky Mountains in Colorado, New Mexico, and Wyoming by the early 1900s (Aubrey et al. 2007 cited in 78 FR 7890).

3. EFFECTS OF THIS PROJECT

DIRECT AND INDIRECT EFFECTS If individual wolverines were present in the project area, project activities are likely to be focused on the areas providing core wolverine denning and foraging habitat. March and April is the time of year snow conditions are most favorable for heli-skiing. It is also the time of year when female wolverines dig and use natal dens and are thought to be most sensitive to disturbance (Copeland 1996). Although

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Silverton Guides Helicopter Ski Terrain Exchange BA helicopter use and backcountry skiing activities have been shown to pose a disturbance risk to individual wolverines (Krebs et al. 2007), the best scientific information available does not substantiate recreational activities as a threat to wolverine (FR 7878). There would be no change in service days as a result of the proposed action. Additionally, there is currently no wolverine population in the State of Colorado and, therefore, the recreational activities in the proposed action are not considered a threat to the wolverine.

CUMULATIVE EFFECTS Because Silverton Guides and Telluride Helitrax have provided heli-skiing services on BLM lands around Silverton since 1995 under 1-year annual and 5-year SRPs, heli-skiing operations are part of the historic environmental baseline and affected environment for this landscape. Helicopter-based snow stability testing and control activities are authorized at the Silverton Ski Area under the terms of a long-term permit issued by the BLM in 2005. Dispersed winter recreational activities include snowmobiling, heli- skiing, cat-skiing, backcountry skiing, cross-country skiing, and snowshoeing. Winter recreation is part of the environmental baseline but is likely increase as recreation opportunities are expanded and enhanced in and near Silverton (San Juan County Master Plan 2010). However, dispersed recreation activities with primary impacts to wolverine through direct disturbance are not considered to be a threat to the wolverine (78 FR 7878).

4. EFFECTS DETERMINATION The proposed action is not likely to jeopardize the continued existence of North American wolverine, as there is currently no wolverine population in the State of Colorado. The available scientific and commercial information does not indicate that other potential stressors such as land management, recreation, infrastructure development, and transportation corridors pose a threat to the DPS (78 FR 7863). Section 7 (a) (4) of the ESA requires conferencing with FWS when a proposed action is likely to jeopardize the continued existence of a proposed species or destroy or adversely modify proposed critical habitat. Because the proposed action is not likely to jeopardize the continued existence of North American wolverine, conferencing is not required.

C. UNCOMPAHGRE FRITILLARY BUTTERFLY

1. EXISTING CONDITION The Uncompahgre fritillary butterfly is a species endemic to the San Juan Mountains of southwestern Colorado and is listed as an endangered species. It is known from only 7 colonies with fewer than 20 populations (NatureServe 2015). Preferred habitat for the butterfly is moist alpine slopes above 12,000 feet with extensive snow willow (Salix nivalis) patches which serve as the larval food plant. Adult butterflies fly about late July into August. Flight is possible only in warm sunny weather. The species is biennial in terms of life history, but flies in both odd and even years. Some snow willow habitat has been field verified in the AUAs; many acres of terrain that may host snow willow plants exists within the AUAs.

2. DIRECT, INDIRECT AND CUMULATIVE EFFECTS: The Proposed Action would not affect butterfly host plants (snow willow) because no habitat modification is permitted at helicopter landing sites and landings are permitted only when vegetation is fully covered and protected by snow. It is expected that skiers leaving a landing zone would quickly ski through and out of terrain that hosts snow willows. In addition, when slopes suitable for snow willow have sufficient snow cover to make them attractive for use by skiers, the plants are likely to be covered

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Silverton Guides Helicopter Ski Terrain Exchange BA by snow that is deep enough to protect the plants from potential physical damage by passing skiers. For these reasons, it is unlikely that project activities would affect snow willow plants and thus effects to the butterfly or its habitat are unlikely. Therefore the Proposed Action would not affect butterfly habitat or snow willow plants and thus would not cause direct, indirect or cumulative effects to the butterfly.

3. EFFECTS DETERMINATION The Proposed Action would not include any activities that might alter habitat structure, function or use by Uncompahgre fritillary butterfly. For this reason the Proposed Action would have “no effect” on Uncompahgre fritillary butterfly.

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Silverton Guides Helicopter Ski Terrain Exchange BA

VI. LITERATURE CITED Bowles, A. E. 1995. Responses to wildlife to noise. Pages 109-156 In R.L. Knight and K.J. Gutzwiller, eds. Wildlife and Recreationists: Coexistence through management and research. Island Press, Washington DC. Buck, K. 2016. Personal Communication. Notes from phone conversation with Kim Buck on December 1, 2016. San Juan County Assessor, Silverton, CO. Case 9:14-cv-00246-DLC Document 108. Defenders of Wildlife v. Jewell. 85 pp. Available online at: http://wildlife.state.co.us /species_cons/lynx.asp. Colorado Parks & Wildlife. 2016. Colorado Listing of Endangered, Threatened and Wildlife Species of Special Concern, available online at: http://cpw.state.co.us/learn/Pages/SOC- ThreatenedEndangeredList.aspx. Accessed 9/27/2016. Copeland, J. P. 1996. Biology of the wolverine in central Idaho. M. S. Thesis, Univ. Idaho, Moscow, ID. 138 pp. Copeland, J. P., K. S. McKelvey, K. B. Aubry, A. Landa, J. Persson, R. M. Inman, J. Krebs, E. Lofroth, H. Golden, J. R. Squires, A. Magoun, M. K. Schwartz, J. Wilmot, C. L. Copeland, R. E Yates, I. Kojola, and R. May. 2010. The bioclimatic envelope of the wolverine (Gulo gulo): do climatic constraints limit its geographic distribution? Canadian Journal of Zoology 88: 233-246. 65 Federal Register 16052–16086. Endangered and Threatened Wildlife and Plants; Determination of Threatened Status for the Contiguous U.S. Distinct Population Degment of the Canada Lynx and Related Rule. Final Rule. Federal Register/Vol. 65, No. 58, March 24, 2000. Pages 16052–16086. 74 Federal Register 8616–8701. Endangered and Threatened Wildlife and Plants; Revised Designation of Critical Habitat for the Contiguous United States Distinct Population Segment of the Canada Lynx. Federal Register/Vol. 74, No. 36, February 25, 2009. Pages 8616–8701. 78 Federal Register 7863. Endangered and Threatened Wildlife and Plants: Threatened Status for the Distinct Population Segment of the North American Wolverine Occurring in the Contiguous United States. Federal Register/Vol. 78, No. 23, February 4, 2013. Pages 7864- 7890. 78 Federal Register 7878. Endangered and Threatened Wildlife and Plants: Threatened Status for the Distinct Population Segment of the North American Wolverine Occurring in the Contiguous United States. Federal Register/Vol. 78, No. 23, February 4, 2013. Pages 7864- 7890. 78 Federal Register 7890. Endangered and Threatened Wildlife and Plants: Establishment of a Nonessential Experimental Population of the North American Wolverine in Colorado, Wyoming, and New Mexico. Federal Register/Vol. 78, No. 23, February 4, 2013. Pages 7890- 7905. 79 Federal Register 47522. Endangered and Threatened Wildlife and Plants: Threatened Status for the Distinct Population Segment of the North American Wolverine Occurring in the Contiguous United States; Establishment of a Nonessential Experimental Population of the North American Wolverine in Colorado, Wyoming, and New Mexico. Federal Register/Vol. 79, No. 156, August 13, 2014. Pages 47522-47545.

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Inman, R. M., M. L. Packila, K. H. Inman, A. J. McCue, G. C. White, J. Persson, B. C. Aber, M. L. Orme, K. L. Alt, S. L. Cain, J. A. Fredrick, B. J. Oakleaf, and S. S. Sartorius. 2012. Spatial ecology of wolverines at the southern periphery of distribution. Journal of Wildlife Management 76(4): 778-792. Inman, R. M., B. L. Brock, K. H. Inman, S. S. Sartorius, B. C. Aber, B. Giddings, S. L. Cain, M. L. Orme, J. A. Fredrick, B. J. Oakleaf, K. L. Alt, E. Odell, and G. Chapron. 2013. Developing priorities for metapopulation conservation at the landscape scale: Wolverines in the Western United States. Biological Conservation 166:276–286. Interagency Lynx Biology Team. 2013. Canada lynx conservation assessment and strategy. 3rd edition. USDA Forest Service, USDI Fish and Wildlife Service, USDI Bureau of Land Management, and USDI National Park Service. Forest Service Publication R1-13-19, Missoula, MT. 128 pp. Krebs, J., E.C. Lofroth and I. Parfitt. 2007. Multiscale habitat use by wolverines in British Columbia, Canada. Journal of Wildlife Management 71:2180–2192. Merrill, G., and T. Shenk. 2006. Colorado lynx den site habitat progress report 2006. U.S. Forest Service and Colorado Parks & Wildlife cooperative effort, September 30, 2006. Unpublished report on file at the Columbine Ranger District office in Bayfield, CO. 8 pp. NatureServe. 2015. NatureServe explorer: an online encyclopedia of life [web application], ver. 7.1. NatureServe, Arlington, VA. Available online at: http://www.natureserve.org/explorer. Accessed 9/19/2016. Olliff, T., K. Legg, and B. Kaeding, editors. 1999. Effects of winter recreation on wildlife of the Greater Yellowstone Area: a literature review and assessment. Report to the Greater Yellowstone Coordinating Committee. Greater Yellowstone Winter Wildlife Working Group, Yellowstone National Park, Wyoming. Olson, L. E., J. R. Squires, N. J. DeCesare, and J. A. Kolbe. 2011. Den use and activity patterns in female Canada lynx (Lynx canadensis) in the northern Rocky Mountains. Northwest Science 85:455–462. Ruediger, B., J. Claar, S. Gniadek, B. Holt, L. Lewis, S. Mighton, B. Naney, G. Patton, T. Rinaldi, J. Trick, A. Vandehey, F. Wahl, N. Warren, D. Wenger, and A. Williamson. 2000. Canada lynx conservation assessment and strategy. USDA Forest Service, USDI Fish and Wildlife Service, USDI Bureau of Land Management, and USDI National Park Service. Forest Service Publication #R1-00-53, Missoula, Montana. 142 pp. Schultz, C., A. Garcia, and J. Redders. 2006. Developing a lynx habitat conservation model; assumptions, criteria, and components. Unpublished report on file at the Columbine Public Lands Center, Bayfield, CO. 38 pp. Theobald, D. M., and T. M. Shenk. 2011. Areas of high habitat use from 1999-2010 for radio-collared Canada lynx reintroduced to Colorado. Colorado State University. US Fish and Wildlife Service. 2016. Information for Planning and Conservation (IPaC), Trust Resources Report. Available online at: https://ecos.fws.gov/ipac/. Accessed 11/02/2016. Wait, S. 2007. Personal Communication. Notes from phone conversation with Scott Wait on February 14, 2007. Regional Terrestrial Biologist, Colorado Parks & Wildlife, Southwest Regional Office, Durango, CO.

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VII. LIST OF FIGURES Figure 1. Vicinity Map.

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Figure 2. Location of Silverton Guides SRP removed and proposed allowable use areas.

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Figure 3. Silverton-Lake City linkage area in the Silverton Guides SRP project area

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Figure 4. Lynx habitat in the Silverton Guides SRP project area

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