BLM Tres Rios Field Office

Sample Letter BLM Tres Rios Field Office Attn: Gina Jones 2465 S. Townsend Ave., Montrose, CO 81401 [email protected]

Re: BLM Resource Management Plan Amendment and Environmental Assessment for the Tres Rios Field Office to evaluate and consider management prescriptions for Areas of Critical Environmental Concern (DOI-BLM-CO-S010- 2016-0018-EA)

Dear Ms. Jones,

Thank you for this opportunity to comment on the Resource Management Plan Amendment and Environmental Assessment to evaluate and consider whether to designate Areas of Critical Environmental Concern (ACECs) for nominated areas on public land in the Tres Rios Field Office. I encourage you to protect important habitat for Gunnison sage-grouse through this process. I feel that Gunnison sage-grouse are an important part of the web of life in southwest Colorado. Protecting Gunnison sage-grouse habitat will benefit wildlife, keep our public land healthy, and make southwest Colorado a better place for future generations.

This process is an important opportunity for BLM to take decisive action to protect the most important habitat for Gunnison sage-grouse in the Tres Rios Field Office. The Gunnison sage-grouse is currently designated as a threatened species under the Endangered Species Act. Private landowners, counties, local working groups, conservation organizations and others are all working together to address threats to Gunnison sage-grouse and reach a point where the species no longer needs the protection of the Endangered Species Act. This effort will not succeed unless the Tres Rios Field Office puts in place additional and more effective conservation measures for Gunnison sage-grouse.

Please designate the Dry Creek Basin and Northdale nominated Areas of Critical Environmental Concern to protect habitat essential for the survival of the Miguel Basin and Dove Creek Gunnison sage-grouse populations. In order to prevent the extinction of the Gunnison sage-grouse, it is essential to maintain and increase the number of birds and the area of occupied habitat outside of the Gunnison Basin. The six small populations outside of the Gunnison Basin (including the San Miguel Basin and Dove Creek populations) are important to protect as insurance against extinction in case of catastrophic unforeseen losses possible in the Gunnison Basin. These populations are also critical to maintaining the genetic diversity of the species. Much of the last remaining habitat for San Miguel Basin and Dove Creek populations is on public land managed by the Tres Rios BLM. This important habitat for these small, vulnerable populations is not adequately protected from oil and gas drilling, construction of roads and powerlines, and many other threats. These populations will be lost if the Tres Rios BLM does not protect the habitat they need to survive. Protecting these critical Gunnison sage-grouse habitats through ACEC designation will help to prevent extinction of Gunnison sage-grouse, and benefit many other species that depend on the same habitat, including rare and imperiled wildflowers, songbirds, elk, mule deer, pronghorn and bighorn sheep.

In addition, please improve safeguards for Gunnison sage-grouse in the Tres Rios Field Office. The current Tres Rios Resource Management Plan does adequately protect Gunnison sage-grouse. I urge Tres Rios BLM put the following critical safeguards in place:

1. Establish a goal of maintaining AND increasing the size of the San Miguel Basin and Dove Creek populations by conserving and restoring habitat on public lands. Recognize that all remaining occupied habitat is essential to the survival of these populations and prevent further direct and functional loss of occupied habitat. 2. Fully protect occupied habitat from large scale disturbances (e.g. transmission lines, oil and gas wells, graded roads, etc.) that will affect population abundance and distribution at any level. Close occupied habitat to oil and gas leasing, and don’t allow construction or upgrade of new transmission lines in occupied habitat. For existing oil and gas leases (and other valid existing rights), prohibit surface occupancy. If that is not possible, limit disturbance to 1 well pad per section and 1% of occupied habitat in each population area and prohibit surface occupancy within 2 miles of leks. 3. Ensure that disturbance allowed around occupied habitat (particularly within 4 miles of leks) does not negatively impact populations in occupied habitat. Do not allow construction of tall structures or surface occupancy within four miles of leks. For existing oil and gas leases (and other valid existing rights) within 4 miles of a lek, limit surface disturbance to one well pad per section, place development as far as possible from leks and occupied habitat, and prohibit surface disturbance within 2 miles of leks. 4. Increase the amount of protected habitat by aggressively pursuing available tools, including mineral withdrawal, fluid mineral lease retirements, mineral claim buyouts, voluntary grazing permit retirement (where beneficial), and coal unsuitability findings. 5. Reduce existing infrastructure in and adjacent to occupied habitat. Identify roads that conflict with conservation of Gunnison sage-grouse due to proximity to leks or nesting habitat or habitat fragmentation and evaluate these roads for closure. Bury existing transmission lines or re-route them outside of occupied habitat. 6. Retain all Gunnison sage-grouse habitat (including isolated parcels) in public ownership (including making isolated parcels ineligible for conveyance to the state land board) and take advantage of National Landscape Conservation system funding available to purchase land or pay for private land conservation easements to benefit Gunnison sage-grouse in areas adjacent to designated ACECs. 7. Provide for restoration and threat amelioration in unoccupied critical habitat. 8. Comprehensively ameliorate all threats to the San Miguel Basin and Dove Creek populations of Gunnison sage-grouse on public land (including wildfires, invasive weeds, cumulative impacts of small scale disturbances etc.).

Finally, I strongly urge Bureau of Land Management (BLM) to take this process seriously and genuinely consider all of the areas that have been nominated for designation as Areas of Critical Environmental Concern. ACEC designation is urgently needed to not only to protect essential habitat for the endangered Gunnison sage-grouse, but also rare and imperiled wildflowers, sensitive archaeological and cultural resources, and many other unique and fragile resources that are not protected in the existing Tres Rios Resource Management Plan. Congress directed BLM to give priority to ACEC designation for areas that meet the criteria. We ask that BLM take this direction seriously, and consider all of the nominated areas for ACEC designation through this process.

Thank you for your consideration of my comments. I am hopeful that Tres Rios BLM will do what it takes to help ensure that future generations have the opportunity to enjoy watching the Gunnison sage-grouse dance at sunrise.

Sincerely, Name Address