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Defenders of Wildlife The Wilderness Society Western Environmental Law Center WildEarth Guardians

Rio Grande National Forest ATTN: Rio Grande Plan Revision 1803 W. Highway 160 Monte Vista, CO 81144

Via e-mail: [email protected]

December 29, 2017

Dear Rio Grande National Forest Planning Team,

Please accept the following comments on the Rio Grande National Forest Draft Plan and Environmental Impact Statement (DEIS) as a supplement to a comment letter our organizations (along with several other organizations) submitted on December 22, 2017. This letter covers additional topics including ecological integrity, species at risk, and the transportation system.

Thank you for your work on this forest plan and commitment to this remarkable national forest. We look forward to the next steps in the plan revision process.

With regards,

Lauren McCain Vera Smith Federal Lands Policy Analyst Director of Forest Planning and Policy Defenders of Wildlife The Wilderness Society 535 16th Street, Suite 310 1660 Wynkoop St., #850 Denver, CO 80202 Denver, CO 80202 720-943-0453 303-650-5942 [email protected] [email protected]

John R. Mellgren Greg Dyson Staff Attorney Wild Places Program Director Western Environmental Law Center WildEarth Guardians P.O. Box 10947 516 Alto Street Eugene, OR 97440 Santa Fe, NM 87501 541-359-0990 503-730-9242 [email protected] [email protected]

12/29/2017 Parks & Wildlife - Species Profiles

COLORADO PARKS & WILDLIFE

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CPW Species Profiles

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Species name: Search Clear

http://cpw.state.co.us/learn/Pages/SpeciesProfiles.aspx 1/8 12/29/2017 Colorado Parks & Wildlife - Species Profiles

Amphibian Bird Crustacean Fish Insect Mammal Mollusk

Plant Reptile

American Pika

Badger

Beaver

Big brown bat

Big free-tailed bat

Bighorn Sheep

Bison

Black Bear

Black-Footed Ferret

Black-tailed Prairie Dog

Bobcat

Botta's Pocket Gopher

Brazilian free-tailed bat

California myotis

Canyon bat

Chipmunks

Cottontail Rabbits http://cpw.state.co.us/learn/Pages/SpeciesProfiles.aspx 2/8 12/29/2017 Colorado Parks & Wildlife - Species Profiles

Coyote

Deer

Eastern Mole

Eastern pipistrelle, or tri-colored bat

Elk

European Wild Hog/Feral Hog/European-Feral Crossbreed and Javelina/Peccary

Foxes

Fringed myotis

Gray Wolf

Grizzly Bear

Ground Squirrels

Hares

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Hoary bat

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Kit Fox

Little brown myotis

Long-eared myotis http://cpw.state.co.us/learn/Pages/SpeciesProfiles.aspx 3/8 12/29/2017 Colorado Parks & Wildlife - Species Profiles

Long-legged myotis

Lynx

Marten

Mink

Moose

Mountain Goat

Mountain Lion

Muskrat

Nine-Banded Armadillo

Northern Grasshopper Mouse

Northern Pocket Gopher (macrotis subspecies)

Ord's Kangaroo Rat

Pallid bat

Pocket Gophers

Pocket Mice

Porcupine

Prairie Dogs

Pronghorn

Raccoon

http://cpw.state.co.us/learn/Pages/SpeciesProfiles.aspx 4/8 12/29/2017 Colorado Parks & Wildlife - Species Profiles

Red bat

Ringtail

River Otter

Shrews

Silver-haired bat

Skunk

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Townsend's Big-Eared Bat

Tree Squirrels

Virginia Opossum

Voles/Meadow Mice

Weasels

Western small-footed myotis

White-Footed Mice

Wolverine

Scientific Name: Gulo gulo Status: State Endangered Description:

http://cpw.state.co.us/learn/Pages/SpeciesProfiles.aspx 5/8 12/29/2017 Colorado Parks & Wildlife - Species Profiles have a reputation larger than life, but they are impressive weasels by any standard. Wolverine are three feet long, with a rather short tail, just one-quarter the total length. Otters are longer, but are the heaviest of weasels, tipping the scale at 20 to 30 pounds or more. They are stocky mammals, built like a small bear. Their fur is dark brown to black, and the sides have a characteristic yellowish brown to whitish stripe. Like other weasels, wolverine have anal musk-producing glands. Range: Wolverine are animals of high alpine environments in both and Eurasia. In North America, they occupy western mountains in and Canada; the southern portion of their current range extends into the contiguous United States, including , Idaho, and Wyoming. Habitat: Wolverine have a circumpolar distribution in the Northern Hemisphere and are found in tundra, taiga, boreal and alpine biomes. These relatively unproductive habitats are areas where daily low temperatures can fall below freezing most of the year, growing seasons are short and snow persists into the summer months. The wolverine occupies a unique niche by accessing scarce food resources available in these environments, despite the presence of deep snow-cover, and caching these resources in cold, rocky areas that inhibit competition from insects, bacteria and other scavengers.

In Colorado, nearly all historical and recent reports of wolverines are from higher elevation, alpine areas that occur in an island-like fashion. Until recently, the last confirmed wolverine sighting in Colorado was in 1919. Occasional reports of wolverine sightings were investigated, but wolverine were never officially documented. In spring 2009, researchers http://cpw.state.co.us/learn/Pages/SpeciesProfiles.aspx 6/8 12/29/2017 Colorado Parks & Wildlife - Species Profiles with the Greater Yellowstone Wolverine Program tracked a wolverine from Grand Teton National Park south into north central Colorado. This was the first wolverine confirmed in the state in 90 years. Diet: Wolverine eat small rodents, rabbits, porcupines, marmots and other small mammals. They may attack large game (for example, weakened deer or other large prey, especially when bogged in deep snow), but most ungulate remains in their diet are probably from carrion. Wolverine are legendary marauders of the North, renowned for their strength, cunning and viciousness. Pound for pound, they are probably no stronger than the next weasel. "Cunning" and "vicious" are terms best reserved for people. People can be cunning and vicious. Wolverine probably are just hungry and quite capable of satisfying it. Reproduction: Wolverine breed during the warmer months. Embryos implant in January. Two to four young are born in late March or early April. Growth of the blind, toothless newborns is rapid, and they will be half-grown when they disperse in autumn. Additional Information: Have you seen a Wolverine?

Think you've seen a wolverine in Colorado? View our Wolverine Identification Guide for more information to ensure you have positively identified a wolverine. If you have seen a wolverine, please help biologists by filling out the Wolverine Sighting Form. Wolverine Confirmed in Colorado

http://cpw.state.co.us/learn/Pages/SpeciesProfiles.aspx 7/8 12/29/2017 Colorado Parks & Wildlife - Species Profiles Researchers from the Greater Yellowstone Wolverine program say they have confirmed the first wolverine in Colorado in 90 years. A male wolverine, tracked via GPS-satellite collar, was confirmed in the north- central part of Colorado in early June 2009. While many wolverine sightings have been investigated by wildlife officers in the past decade, the last confirmed wolverine in Colorado was in 1919. Biologists believe it is possible that other wolverine are in the state but they have been unable to find definitive proof of other wolverine in Colorado. The newcomer wolverine, labeled M56, was captured near Grand Teton National Park in northwestern Wyoming in May 2009 as part of a study to understand these wide-ranging little-known animals. The wolverine traveled approximately 500 miles to reach Colorado. Colorado Parks and Wildlife is working with recovery program researchers to track the wolverine in order to monitor its movements and activities. On July 8, 2010, at its meeting in Gunnison, the Parks and Wildlife Commission granted CPW’s request to begin having conversations about restoring wolverines with CPW’s partners and stakeholders. CPW is having these discussions with a broad spectrum of user groups, government agencies and other interested people and organizations.

Woodrats

Yellow-Bellied Marmot

Yuma myotis

http://cpw.state.co.us/learn/Pages/SpeciesProfiles.aspx 8/8 David M. Nead Jame. C. Halfpenny Mountain Research Station University of Colorado Nederland, Colorado 8M66 and SleYa Biasell Colorado Division of Wildlife 6060 Broadway Denver, C"A>lorado 80216

The Status of Wolverines in Colorado

Abstract Wolverines ( Gulo gJ1!rJ), once d a:ssified as furbearers in Colou.do, are now ;i_fforded complete pm­ teetion. However. thC'ir srarus io the srare is in doubt. This paper reviews historical literature and presents 57 new wolverine reports. Two recent posidvc reports suggest that wolverines ma}' still exist in Colora.J o.

Wolverines ( Gnlo gnlo) are scarce in the south cencral Rocky Mountains and reach the southern limirs of their discriburion in Colorado (Deems and Pursley 1978• Hall 1981, Wilson 1982 ) . Their numbers appear secure in Montana (Newby and McDougal 1964) but in Wyoming they are rare (Hoak et al. 1982). Durrant (1952) suggested that wolverjnes may be cxcincc in Utah. Wo!verines were once dassified as furbearers in Colorado. Howe'\'er, in 1965 the season was closed and wolverines were afforded complete protection. The C..olorado Wildlife Commission classified the wolverine as an endan,gcred species in 1973. This paper reviews historical litcramrc and presents 57 new wolverine reports for the state of Colorado. These reporrs were gathered through a Colorado Division of Wildlife (DOW) project. Wilson ( 1982) suggested rhat wolverine numbers are increasing in Colorado. How­ ever, the.re never has been a population estimate on which co base such a suggestion and it is doubrful that wolverines were ever common in Colorado. Elliot Coues (1879) stated "ic is only of lace years that the presence of this remarkable animal so far south has been koown." Historical records were ofren based on sight obser-.·ations (Armstrong 1972, Cary 1911 , Field and Fclrner 1974, Spahn 1954, Warren 1942) . A total of 22 reports, representing at least 25 animaJs, were based on wolverine carcasses between 1871 and 1919. The last verified kill of a wolverine in Colorado occurred in 1919 (Grinnell 1926). Quick (1961 ) stated that the occurrence of wolverines in Colorado "in modern times is doubtful." The Colorado Division of Wildiife initiated a wolverine project in 1978 to summar­ ize the history of wolverines in Colorado and to accumulate information about current wolverine srarus. Historical information was sought by searches of museum material and

286 Nonhwesr Science, Vol. 8, No. 4, 1985 through a review of published literature. Unpublished recnrds were inspecred. Historical and cwrent information were also sought by sracewidc "information rcquesc" campaigns. These campaigns employed slide programs, newspaper articles, and distribution of over 3,000 "wanted" posters to disrrict wildlife managecs, taxidermists, trappers., outfitters> private individuals, and state and federal agencies. A report form was developed to srandardize the evaluation of wolverine sightings. This form was sent to all individuals reporting a wolverine encounter. Study areas were selected based on returned reports. Snowmachines and skis were used co search these areas for either wolverine or their signs. Baited hair snags, con­ sisting of hardware cloth cylinders with barbed wire interiors, were sec to obtain hair samples. Reference slides of hair were prepared from collections at the Denver Museum of Nacmal Hiscory and the University of Colorado Museum. Three keys proved particularly helpful in identifying hair samples rakcn from snags (Brown 1942, Mayet 1952, Moore et al. 1974). A cota[ of 265 reports of wolverine observacions were evaluated during the study. Reports were rated as fo ll ows: positive reports, 3; probable reports., 18 ~ possjble repo.rrs, 36; and non-wolverine repmrs, 208. The 57 reporcs classified as posirive. probable, and possible arc mapped in fii,'llrc I. A detailed listing of reports is available from the authors. Some of chesc observations deserve special mention: 1 Three wolverines have escaped from CheY.enne Mountain Z.oo in Colorado Springs (Fig. 1, no. 1 ). A female, which escaped in 1964, was killed by Terry Schmidt on West Las Vegas Street. A se<.:ond female, which escaped in 1966, was killed by Ray Coecher of Lirtleron, Colorado in rhe Rampart Range on February 18, 1966 but the escaped male was never found. These reports were counted as one positive report. 2) July 1977, Al Williams, Assisrant Prindpal of Delta Higb &hoot, Delea, Colorado found a wolverine skull on rhe East Fork of rhc Cimmaron drainage (Gunnison Coumy) ( Fig. 1, No. 2). This skull was probably less than ten years old. This report was coumed as posi cive. 3} June 1978. George T.anum of Denver rook three photographs of an animal crossing a snow field on Trinchera Peak (Fig. 1, no. 30). His description and the body shape in the phoro~raph suggesc a wolvedne. 4) June 1978, Mr. and Mrs. Robert Haas of Texas photographed one adulr and three youn~ animals wesc of Lake City (Fig. 1, oo 9). The animals were too distant for posicivc idemificadon. However, the drawings and descripcions made by the Haas's indicate wolverines. 5) Oc:cobcr 1978, Stouffer Productions. Aspen, Coiorado released two wolvetioes while filming a movie. The wolverines, which were imported from Canada, were re.­ leased f'.•ast of Castle Peak, Pitkin County (nor mapped). Three reports in the general vicinity since their release may rcfote to these animals. 6) March 1979, Robert Kay of Vernal, Utah shot a male wolverine allegedly three km wesr of rhe Colorado-Utah border on U.S. Highway 40 (Fig. 1, oo. 3). There is reason co doubt chat the animal came from Utah. Also, since wolverines may roam over 32 km per day, if chis an imal came from Utah he probaby had part of his range in Colorado. 7) March 1979, Don Roberts, Gary Guggenbergcr, and Ron Sr. Pierre of the Col­ O[ado Division of Wildlife watched an animal for three minutes ac 2'5 m near rhe Rifle

The Status of Wolverines in Colorado 287 Jligure I. Distribution of 57 wolvciine reports in Colorado. Counties are shown only if report• occurre

Colorado Fish Hatchery (Fig. 1, no. 5). Tuey identified the mammal as a wolverine and the sighting was in an area of ocher credible reportS.

288 Nead, Halfpenny, and Bissell 8) June 1979, Kurt Keskamaki watched an animal as ir approached a bear bait that he had set near Parshall, Colorado (Fig. 1, no. 7). He watched the animal at less than 10 m for four minutes. Description, behavior, and signs indicared a wolverine. Despite several credible reports the study did not verify the presence of viable populations of wolverine in Colorado. Verified wolvedne include one skull found, one wolverine killed allegedly 3 km west of Colorado-Utah border, and two wolverines killed near Colorado Springs. In addition, two wolverines were imported and released by private interests. Repetition in credibre reports suggests areas where wolverine are still likely ro be found in Colorado. These include rhe San Juan Mountains (north of Durang<> and southeast of Wolf Creek Pass) and the southwestern portion of the Flat Tops Wilderness (Garfield County). North and west of Rocky Mountain National Park is another possibility. We believe wolverines continue to exist in Colorado. However, irrefutable proof of viable populations is absent due co difficulty in detection and obtaining positive proof. Even if positlve proof of a wolverine were obtained, it would not prove the existence of a viable population. We wish to thank the numerous volunteers and DOW personnel who helped on this project, in pacticulat, Dr. David Armstrong (CU), and Gary Miller (DOW). This paper is a contribution to Colorado DOW Federal Aid Endangered Species Project SE-3-2.

Literature Cited Armstrong, D. M. 1972. Disttiburion of mammals in Colot;tdo. Monogr., Unjv. Kansas Mus. Nat. Hist. 3 :x-~-1-415. Brown, F. M. 1942. The microscopy of mammalian h;iirs for the anrhropl)logists. Amer. PhiJ. Soc. , Philadelphia. Proc. 85:250-274.

Cary1 M. 1911. A biological survey of Colorado. N. Amer. Fauna. 33:1-256. Coues. E. 1879. Notice of Mrs. Maxwell's exhibit of Color.ado Mammals. Pp. 217-225. In On the piains and among the peaks: or how Mrs. MaxweH made ht!lr namral hftstorry collection (Dartt-Thompson, M.A.). Ciaxr:on, Remsen, and Haffolfinger, Philadelphia. Deems, E. F., Jr., and 0. Pursley. 1978. North American Furbearets: Their Management, Research, and HMvt·sr Srnms in 1976. Int. Assoc. F'ish Wildl. Agencies. Univ. of Maryland, CoHegc

Park1 Maryland. Durrant, S. D. 1952. Mammals of Utah. Un-iv. of Kansas PubJ., Mus. N~t. Hist. 6:1-126. Field, R. J., and G. Feltner. 1974. Wolverine. C..oiorado Oucdoors 23:1-6. Grinnell, G. B. 1926. Some habits of the wolvl.""fine, J. Mamm. 7:30-34. Hall, E. R. 1981. Mammals of North America. John Wiley and Sons, New York. Hoak,]. H., J L. Weaver, and T. W. Clark. 1982. Wolverines in western Wyoming. Northw. Sci. 56:159-161. Mayer, W. V. 1952. The hair of mammals with keys ro the dorsal guard hairs of CaJi. fornia mammals. Amer. Midi. Nat. 18:480-512. Moore, T. D., L T. Spence, and C E. Dugooilc. 1974. ldemjfication of the dorsal guard hairs of some mammals of Wyoming. Wyoming Game and Fish Department Buil. 14:1-177. Newby, F. E., and J. J. McDougal. 1964. Range extension of rbe wolvC'rine i'.n Montana. J. Mamm. 36:485-487. Quick, H. F. 1964. In Rodcck, H. G. Natural History of the Bouldet Area. Unlv. Colorado Mus. Spahn, J. J. 1951. Wolverine. Colorado Cons. 3:1-3. Warren, E. R. 1942. The Mammals of Colorado. Univ. Oklahoma Press. Wilson, D. F.. 1982. Wolverine

Received, March 9, 1983 Accepted for p"blication, ]Jme 14. • 1983

The Status of Wolverines in Colorado 289