Appendix a Letter Submitted by the Wilderness Society Et Al On

Appendix A

Letter submitted by The Wilderness Society et al on September 6, 2016

on the Preliminary Wilderness Evaluation (without appendices)

San Luis Valley Ecosystem Council * The Wilderness Society Defenders of Wildlife * Quiet Use Coalition * Rocky Mountain Wild * Colorado Mountain Club * Rocky Smith * Western Environmental Law Center

Ms. Erin Minks, Forest Planner Rio Grande National Forest 1803 W. Highway 160 Monte Vista, CO 81144

September 6, 2016

Via electronic mail followed by a hard copy in the US Post

Re: Preliminary Wilderness Evaluation

Dear Ms. Minks:

The undersigned organizations appreciate the opportunity to provide input in response to your request for comments on the preliminary wilderness evaluation as part of the Rio Grande National Forest Land Management Plan revision. We thank you for the attention and effort that you are devoting to the wilderness inventory and evaluation process, and commend you and your colleagues for thoughtfully navigating the process as detailed in FSH 1909.12, chapter 70. In particular, we are pleased that you are adhering closely to the evaluation criteria presented in section 72 of the handbook. We also liked your approach of ranking the inventoried polygons by the degree to which they have wilderness character, presenting the associated information in a spreadsheet, and displaying the areas by rank on a map. Presenting the information this way made it quite easy to understand and digest.

General comments on preliminary evaluation

I. Missing information

a. Rationale needed to explain rankings is missing for numerous polygons

While we recognize that the evaluation outputs are preliminary, we are concerned that the information in the spreadsheet is skeletal and in many places simply missing. For example, for numerous polygons the spreadsheet stated “No” in response to whether specific wilderness criteria exist without any additional information. In other cases, the spreadsheet stated “Some” without benefit of additional explanation. The paucity of information makes it extremely difficult to understand why some areas might have lower wilderness character and provide helpful feedback. Without additional information and a reasoned explanation, the downgrading of an area’s wilderness quality is arbitrary and capricious.

For example, for polygons #1b, 30a-c, 31, 32, 33, 34, 35, 36a, 36b, 39, 45b, 49, 50, 56, 58a-c, 62, 65, and 66 the spreadsheet lists “No” without additional information for the ‘naturalness’ criterion. Similarly,

1 the spreadsheet for polygon #15 lists “Some” without additional information for the ‘naturalness’ criterion.

For polygons #1b, 3h, 3i, 3g, 5, 7, 13, 18, 20b, 23, 27, 30a-c, 31, 32, 33, 34, 35, 36a, 36b, 37b, 39, 40, 44, 45a, 45b, 46, 49, 50, 54, 56, 58a-c, 60, 65, and 66 the spreadsheet says “No” without additional information for the ‘solitude or primitive and unconfined recreation’ criterion. Similarly, for polygons #51, 52, 63a, 63b, 63c, and 64 the spreadsheet says “Some” without additional information for the ‘solitude or primitive and unconfined recreation’ criterion.

In rating polygons for manageability, the spreadsheet often just says, “Would be difficult to manage for wilderness characteristics” and does not provide any information on why this is the case. This situation occurs in polygons #1b, 3h, 3i, 3g, 4, 6, 7, 8, 9, 10, 13, 15, 18, 20b, 22, 23, 27, 30a-c, 31, 32, 33, 34, 35, 36b, 39, 40, 41, 43a, 45a, 45b, 46, 49, 50, 51, 52, 53, 54, 55, 56, 58a-c, 59, 60, 63b, 63c64, 65, and 66. For polygon #5 the spreadsheet just says “No” for the ‘manageability’ criterion without providing additional information.

Recommendation: In the final evaluation documents, for polygons with less than high rating, provide a clear rationale supported by best available information for why a polygon does not meet a specific evaluative criterion.

b. Rationale for naturalness ranking for specific polygons is insufficient

For a number of polygons, the spreadsheet provides a pithy and insufficient explanation for why the area may have diminished naturalness. For example, for polygon #4 (Elkhorn Peak Colorado Roadless Area) which is 25,664 acres, the spreadsheet states the following for the ‘naturalness’ criterion: “Grazing, mining impacts naturalness – imprint of man is noticeable.” From the information provided, we cannot discern where within the 25,664 acres are physical signs of mining and grazing activities, if the physical signs are substantially unnoticeable to the area as a whole, or if the physical signs are confined to one portion of this large area or spread throughout. If the physical impacts are confined to one portion of the area, can the polygon be divided into multiple parts each greater than 5000 acres in size such that one or more polygons rank high?

As an initial matter, FSH 1909.12, chapter 70, section 72.1(1) directs the Forest Service to “Evaluate the degree to which the area generally appears to be affected primarily by the forces of nature, with the imprints of man’s work substantially unnoticeable (apparent naturalness). Consider such factors as…(c) The extent to which improvements included in the area (sec. 71.22 of this Handbook) represent a departure from apparent naturalness.” A key factor in evaluating naturalness is whether the area (as a whole) “looks natural” to a reasonable person.1

1 See “Q&As Relating to Wilderness Planning under Chapter 70 of 2015 Planning Rule Directives, Version 1.1” published by the Forest Service Washington Office, Page 1 (“At the evaluation stage, the Interdisciplinary Team should be guided by the definition of wilderness and the overall evaluation of the degree to which, as a whole, the evidence of man’s influence in the past has detracted from the apparent naturalness of the area such that it may preclude a recommendation for inclusion in the NWPS.”). Also see page 2 (“In making this evaluation, the Interdisciplinary Team must, at a minimum, consider the criteria in Section 72.1(1)…In carrying out the evaluation,

Polygons #32d-I, 4, 5, 7, 8, 9, 10, 11, 13, 18, 20b, 22, 23, 25a, 27, 40, 43a,44, 45a, 46, and 52 need more information about where and how impacts are substantially noticeable to the area as a whole, and why the area generally would not appear natural to an average person.2 In providing more information in the final evaluation, it may be helpful to provide photographs, google earth imagery, and/or maps to depict visual impacts.

Recommendation: For polygons with a ‘naturalness” rating less than high (or yes), clearly explain the rationale, describing where and why the imprints of man are not substantially unnoticeable to the area as a whole. Where naturalness is diminished due to improvements, consider changing polygon boundaries to excise acres with diminished naturalness and then re-evaluate this criterion for the modified boundary.

c. Rationale needed for why adjacent areas are too small to manage for preservation and use in an unimpaired condition.

For some polygons that are adjacent to existing wilderness, the spreadsheet under the ‘size’ criterion states that the area is “Adjacent to designated wilderness but too small to manage it for its preservation and use in an unimpaired condition.” The spreadsheet provides no further information as to why an adjacent parcel would not be manageable as wilderness. FSH 1909.12, chapter 70, section 72.1(3) directs the Forest Service to “Evaluate how an area less than 5,000 acres is of sufficient size to make its preservation and use in an unimpaired condition practicable” (emphasis added). Simply stating that an area is not of sufficient size without an explanation is not adequate. Polygons #1b, 3h, 3i, 3g, 30a-c, 31, 32, 33, 34, 35, 36a, 36b, 43a, 54, and 58a-c do not have adequate explanations. For example, mysteriously, unit 36a, the Ruby Lake Colorado Roadless Area (CRA) (6800 acres) is an upper tier roadless area adjacent to the Weminuche Wilderness but it is somehow “too small to manage [] for preservation and use in an unimpaired condition”. Clearly, there are errors in the evaluation.

Recommendation: Make sure to provide a rationale for why adjacent areas are not of sufficient size to make their preservation and use in an unimpaired condition practicable. If, after further consideration,

visibility to users will likely be a big part of the analysis. It is also important to keep in mind that the idea of substantially unnoticeable should be analyzed with an eye toward an average user. With enough specialized knowledge anyone could identify imprints of human influence on the landscape… The evaluation of substantially unnoticeable is not necessarily reducible to an objective set of criteria that can be applied uniformly, but is a subjective determination left to the Responsible Official’s discretion and broad judgment. The conclusion may change and even be different within different habitat types within an area. For example, in an area near or above the tree line, even a relatively small structure may be visible from long distances, and therefore may not be “substantially unnoticeable.” On the other hand, a much larger structure that is in a dense forest area, may not be considered substantially noticeable, as it is not visible except when a user is very near the structure itself.” 2 Ibid, Page 2. (“[I]t is critical that the Interdisciplinary Team and the Responsible Official: 1) clearly document and explain the rationale for the ultimate conclusion….; 2) explain why certain criteria weighed for or against a conclusion that something was substantially unnoticeable, and why areas were considered but not selected for inclusion in the analysis; 3) clearly respond to public comments that question the process and the criteria selected by the official, and explain the rationale for the process used; and 4) ensure that the administrative record contains the documentary evidence that explains the process and the ultimate evaluation.”)

3 you decide that they are manageable, you should amend the findings for this criterion in the final documentation.

d. Supplemental information should consider available information on ecosystem representation and species occurrences.

FSH 1909.12, chapter 70, section 72.1(4) directs the Forest Service to evaluate “the degree to which the area may contain ecological, geological, or other features of scientific, educational, scenic, or historical value.” In a letter submitted by The Wilderness Society et al on April 13, 2015, and a letter commenting on the Assessment Report Chapter 15 submitted by The Wilderness Society et al on February 9, 2016, we provided information on the degree to which wilderness inventory polygons contain ecosystems that are not well represented in currently designated Wilderness – both at the national forest and national scale. We suggested that the information be reflected in the wilderness evaluation as a supplemental value.3 As far as we can tell, the information was not incorporated into the evaluation spreadsheet. We request that you incorporate it, and to facilitate the effort, we are providing a chart in Appendix 2 that shows the under-represented ecosystems contained in each polygon.

In addition to information on ecosystem representation, the evaluation should also include information on rare species occurrences. Much of this information is available from the Colorado Natural Heritage Program and is included in Appendix 1 of this letter.

Recommendation: Incorporate rare species occurrence and ecosystem representation information into the evaluation of supplemental values for each polygon.

Comments on specific areas

1a – Blanca Peak

3 In the letter dated April 13, 2015, we provided an example from the Sierra, Sequoia, and Inyo evaluation documentation of how this could be done. See Appendix 4 of the letter.

outstanding opportunities for solitude or unconfined and primitive recreational opportunities within the area. Most of the area’s acreage is distant from and not affected by the motorized route. See photographs of the area in Appendix 4 for evidence of solitude.

2 - Hot Springs, Cotton Creek, Crestone & Pole Creek CRAs additions to Sangre de Cristo Wilderness

We concur that this area deserves a ranking of high. We describe in detail the area’s high quality wilderness values in Appendix 3 in the write-up entitled Cotton Creek–Crestone addition to Sangre de Cristo Wilderness. We also provide detailed information on supplemental values and manageability, all informed by best available science.

 Regarding supplemental values, in addition to the values listed in the spreadsheet, we particularly want to point out that the area also overlaps six Colorado Natural Heritage Program Potential Conservation Areas (PCA), and contains ecosystem types along its lower slopes that are poorly represented within the Rio Grande’s existing wilderness areas. Wilderness designation of this polygon would significantly increase ecological representation of ecosystem types most under-represented within the Rio Grande’s existing wilderness. The most substantial increases in ecological representation occur for Southern Rocky Mountain montane-Subalpine Grassland, Southern Rocky Mountain Ponderosa Pine Woodland, and Southern Rocky Mountain Pinyon--‐Juniper Woodland. See the detailed description of supplemental values in Appendix 3.  The preliminary evaluation states that the area has some solitude because of popular hiking trails. We think that this ranking should be “Yes” instead of “Some” for two reasons. First, the criterion is the presence of outstanding opportunities for solitude or primitive and unconfined type of recreation, not necessarily both.4 Even if the area does have reduced opportunities for solitude in a small portion, overall it still offers outstanding opportunities for a primitive and unconfined type of recreation and therefore should have a ranking of high. Secondly, the area can still possess outstanding opportunities for solitude even if a small portion (e.g., a popular hiking trail) does not offer solitude. In this case, we assert that the area has outstanding opportunities for solitude and recreation. See photographs of the area in Appendix 4 for evidence of solitude.

3a, 3b and 3c – Miller Creek CRA; 3d, 3e, 3f - Butterfly CRA

4 See FSH 1909.12, chapter 70, section 72.1(2) (“Evaluate the degree to which the area has outstanding opportunities for solitude or for a primitive and unconfined type of recreation. The word “or” means that an area only has to possess one or the other. The area does not have to possess outstanding opportunities for both elements, nor does it need to have outstanding opportunities on every acre.”)

PCA supports an excellent and large occurrence of an unusual association of Gambel's oak (Quercus gambelii) with needle--‐and--‐thread grass (Hesperostipa comata), the only documented occurrence in the world. In addition, the creeks that run through the savanna from the Sangre de Cristo mountains exhibit unusually high quality occurrences of riparian forest dominated by either aspen or oak. (Colorado Natural Heritage Program 2015) The lower portion of the Butterfly Creek addition is also within the Decker Creek PCA, which Colorado Natural Heritage Program (CNHP) also ranks as High Biodiversity Significance. This PCA was identified for its value as sagebrush habitat for the small and only population of Gunnison sage grouse in the San Luis Valley. (CNHP 2015). These polygons contain ecosystem types that are poorly represented within the Rio Grande’s existing wilderness areas. Wilderness designation of these polygons would increase ecological representation of the oak savanna ecosystem to over 20% on the forest.  The spreadsheet says that grazing impacts naturalness in 3d, 3e, and 3f, but provides no additional information about how grazing related improvements or activities diminish naturalness in this polygon. The mere presence of grazing does not mean that naturalness is diminished. After all, grazing and associated infrastructure is commonplace throughout many designated and recommended wilderness areas in western national forests.5 See photographs of the area in Appendix 4 for evidence of naturalness.

4 - Elkhorn Peak

 We disagree with the finding of low to moderate wilderness value for this polygon. In our field investigations, we found that this area had high wilderness value, as described in the write-up for the area in Appendix 3.  Regarding naturalness, the spreadsheet says the area as a whole does not have naturalness, stating “Grazing, mining activity impact naturalness – imprint of man is noticeable.” See the comments for units 3d, 3e, and 3f regarding grazing and naturalness. Regarding mining, historic mining artifacts and such that blend into the landscape and that are not substantially noticeable to the area as a whole should not diminish an area’s naturalness overall. In this polygon, mining impacts are limited to the periphery of the area along Copper Gulch and Chloride Gulch. These are not visible from the vast majority of the roadless area. However, if deemed to be a substantially noticeable impact, the boundary can be readily modified to remove the affected 1,000-2,000 acres. See photographs of the area in Appendix 4 for evidence of naturalness.  In terms of the criterion of outstanding opportunities for primitive unconfined recreation or solitude, the text states, “Some Solitude possible away from motorized roads; can hear highway 285.” FSH 1909.12, chapter 70, section 72.1 (2)(a) directs the agency to “Consider impacts that are pervasive and influence a visitor’s opportunity for solitude within the evaluated area. Factors to consider may include topography, presence of screening, distance from impacts, degree of permanent intrusions, and pervasive sights and sounds from outside the area”

5 Congressional grazing guidelines provide that: (1) “[t]he maintenance of supporting facilities, existing in the area prior to its classification as wilderness (including fences, line cabins, water wells and lines, stock tanks, etc.), is permissible in wilderness,” and (2) “[t]he placement or reconstruction of deteriorated facilities or improvements should not be required to be accomplished using ‘natural materials.’” Forest Service Manual 2323.22 - Exhibit 01.

(emphasis added). If the highway noise is pervasive then the downgrading of solitude seems appropriate, but if it only can be heard occasionally or only in a few parts of the area, the downgrading is not appropriate. In our experience, the highway noise cannot be heard in the area, and therefore should not diminish the ranking of this criterion.6 Moreover, as stated above, the criterion is the presence of outstanding opportunities for solitude or primitive and unconfined type of recreation, not necessarily both. Even if the area does have reduced opportunities for solitude but it still offers outstanding opportunities for a primitive and unconfined type of recreation, the area should still have a ranking of high.  Regarding supplemental values, we offer the following information that is provided in detail in Appendix 3. The proposed Elkhorn Peak wilderness contains the entirety of the 2,014-acre Kelly Creek Potential Conservation Area, a Colorado Natural Heritage Program ranked as High Biodiversity Significance. The Kelly Creek PCA includes a wetland complex with a robust montane riparian shrubland where the undergrowth is still dominated by native species, an increasingly rare occurrence. Beaver ponds expand the floodplain habitat and constitute an important component in maintaining this healthy ecosystem. Shrubland associations at lower elevations like this one in Kelly Creek are usually impacted by water diversions, livestock grazing, invasive plant species and agricultural conversion, which makes the PCA all the more unusual (CNHP 2015). In addition, Elkhorn Peak helps fill the largest gap in the wilderness system in the Southern Rockies and provides connectivity across the landscape between the northern San Juan Mountains and the Sangre de Cristo range. The area is immediately south of the important Poncha Pass lynx linkage area (Miller 2003; Aplet et al 2000; USDA Forest Service 2008b).  Lastly, Elkhorn Peak contains several ecosystems under-represented among existing wilderness areas on the Rio Grande National Forest. The lowest slopes consist of rolling grasslands and ponderosa pine woodland at the national forest boundary with adjacent BLM lands, while forests of lodgepole pine and Douglas fir blanket the higher slopes. By protecting this area, the Rio Grande NF can substantially increase the ecological representation within its wilderness areas of Southern Rocky Mountain Montane-Subalpine Grassland, Southern Rocky Mountain Ponderosa Pine Woodland, Rocky Mountain Lodgepole Pine Forest, and Rocky Mountain Aspen Forest and Woodland (The Wilderness Society 2016).

6 - Antero Meadows/Bear Creek

 This area received “Yes” for all the criteria yet was given an overall ranking of “moderate.” This downgrading seems arbitrary. We think this area deserves a ‘high’ ranking. We describe in

6 A passenger car traveling at 65 mph has a typical noise level of 76 dB at a distance of 25 feet. Noise levels diminish quickly with distance, and at a distance of one mile the passenger car noise level drops to less than 30 dB, or considerably quieter than a typical library. It is not physically possible for noise from Highway 285 traffic to be noticeable within the Elkhorn Peak roadless area, which at its closest point is 3 miles from the highway. See USDOT, Federal Highway Administration, Highway Traffic Noise: Analysis and Abatement Guidance, 2011. Available at https://www.fhwa.dot.gov/environment/noise/regulations_and_guidance/analysis_and_abatement_guidance/rev guidance.pdf. Also note that part of the La Garita Wilderness is located less than 250 feet from Highway 149, and part of the Sangre de Cristo Wilderness is less than 420 yards from Highway 150.

detail the area’s high quality wilderness values in Appendix 3. We also provide detailed information on supplemental values and manageability, all informed by best available science.  Regarding the presence of outstanding opportunities for solitude or primitive and unconfined recreation, the spreadsheet states “Popular area during hunting season – affects solitude.” We think this rationale is inappropriate – please see our comments under unit #2 related to this issue.  Regarding supplemental values, we agree that the area is a remarkable stronghold for Rio Grande Cutthroat Trout. In addition, the area is important for large landscape scale connectivity and ecosystem representation as described in Appendix 3. Antora Meadows contains several ecosystems under-represented among existing wilderness areas on the Rio Grande National Forest. The lowest slopes consist of rolling grasslands at the national forest boundary with adjacent BLM lands, while forests of lodgepole pine and Douglas fir blanket the higher slopes, above meadows and stream valleys banded by aspen groves. By protecting this area, the Rio Grande NF can increase the ecological representation within its wilderness areas of Rocky Mountain Lodgepole Pine Forest, Rocky Mountain Aspen Forest and Woodland, and Southern Rocky Mountain Montane-Subalpine Grassland. (The Wilderness Society 2016)  Regarding manageability, the spreadsheet states, “May be difficult to manage for wilderness characteristics.” The spreadsheet does not provide any further explanation. In contrast, we found that the manageability for the area is high as described in Appendix 3.

12- Taylor Canyon and Four Mile CRAs

 We concur that this area deserves a ranking of high. We describe in Appendix 3 in the write-up entitled Saguache Creek the area’s high quality wilderness values. We also provide detailed information on supplemental values and manageability, all informed by best available science.  Although you do rank the naturalness criterion as “Yes” you also comment that there are constructed range features in the west end. As we discuss above, the mere presence of grazing features should not in and of itself diminish the ranking for this criterion. See our discussion above for polygon #3a, 3b, and 3c.  Regarding the criterion for outstanding opportunities for solitude or unconfined and primitive recreational opportunities, the spreadsheet states, “Solitude in central and east portions, not west.” The spreadsheet provides no further detail about why solitude is diminished in the western portion. In addition, as we discuss above under polygon #2, this criterion is the presence of outstanding opportunities for solitude or primitive and unconfined type of recreation; not necessarily both.7 Even if the area does have reduced opportunities for solitude in a small portion, it still offers outstanding opportunities for a primitive and unconfined type of recreation and therefore should have a ranking of high. Secondly, the area can still possess outstanding opportunities for solitude even if a small portion (e.g., a popular hiking trail) does

7 See FSH 1909.12, chapter 70, section 72.1(2) (“Evaluate the degree to which the area has outstanding opportunities for solitude or for a primitive and unconfined type of recreation. The word “or” means that an area only has to possess one or the other. The area does not have to possess outstanding opportunities for both elements, nor does it need to have outstanding opportunities on every acre.”)

not offer solitude. In this case, we assert that the area has outstanding opportunities for solitude and recreation. See photographs of the area in Appendix 4 for evidence of solitude.  Regarding supplemental values, we offer the following information in addition to that provided in the spreadsheet. The proposed wilderness centered on Saguache Creek, lower Fourmile Creek, and Luders Creek includes significant portions of two Colorado Natural Heritage Program Potential Conservation Areas (PCAs) – Saguache Creek and Luders Creek. The seven miles of Saguache Creek’s mainstem comprises the lowest segment of the Saguache Creek PCA. Saguache Creek is ranked as High Biodiversity Significance owing to its montane willow carr associations within the creek’s floodplain and valley toe slopes. The lower half of the Luders Creek PCA within the proposed wilderness is also ranked as High Biodiversity Significance because of its montane riparian shrublands, which combined with aspen forests and shrubby cinquefoil shrublands on adjacent terraces creates a structurally and floristically diverse assemblage of riparian and moist toe slope plant communities. (CNHP 2015).

Saguache Creek through the proposed wilderness was previously determined eligible for Wild and Scenic River designation under the wild classification owing to its outstandingly remarkable scenic, historic, and cultural values. (Rio Grande Forest Plan, 1996). The proposed Saguache Creek wilderness helps fill the largest geographic gap in the wilderness system in the Southern Rockies. The area is part of the ecological connection between the large protected wilderness areas of the San Juans to the southwest and the equally important preserves of the Elk, Sawatch, and Sangre de Cristo ranges to the north and east. The proposed wilderness also provides ecological continuity from the grasslands along lower Saguache Creek extending up through to its headwaters amidst the alpine tundra of the nearby La Garita Wilderness. (Miller 2003; Aplet et al 2000.)

The proposed Saguache Creek wilderness includes the largest expanses of grassland and ponderosa pine forest available for addition to the National Wilderness Preservation System among all of the available candidate areas on the Rio Grande National Forest. These two ecosystem types are critically under-represented in existing wilderness both regionally within the Southern Rockies and at the national level. By protecting this area, the Rio Grande NF can increase the ecological representation within its wilderness areas of Southern Rocky Mountain Montane-Subalpine Grassland and Southern Rocky Mountain Ponderosa Pine Woodland from less than 5% of the overall ecosystem acreage on the forest. (The Wilderness Society 2016)

15 – Sawlog CRA

 We disagree with the finding of moderate wilderness value for this polygon. In our field investigations, we found that this area had high wilderness value, as described in the write-up for the area in Appendix 3.  The spreadsheet states that this area has “Some” naturalness and provides no additional information. This determination needs supporting rationale. In contrast, we found that the area has high naturalness as described in Appendix 3.  Regarding manageability, the spreadsheet states, “May be difficult to manage for wilderness characteristics.” The spreadsheet does not provide any further explanation. In contrast, we found that the manageability for the area is high as described in Appendix 3.

 Regarding supplemental values, we offer the following information that is provided in detail in Appendix 3. The proposed Sawlog wilderness includes a portion of the Carnero Creek Potential Conservation Area identified by the Colorado Natural Heritage Program. Carnero Creek is ranked as having High Biodiversity Significance owing to its bristlecone pine woodland, a montane grassland, and a Rio Grande cutthroat trout population, all of which are state rare. This population of Rio Grande cutthroat progresses in quality as one continues up the stream (CNHP 2015). The North Fork of Carnero Creek hosts a high genetic purity, core conservation population for Rio Grande cutthroat trout (Alves et al 2004). The proposed Sawlog wilderness addition greatly increases the ecological representation within Rio Grande National Forest wilderness areas of several of the most under-represented ecosystem types on the forest. Sawlog includes thousands of acres of Southern Rocky Mountain Montane-Subalpine Grassland, Southern Rocky Mountain Ponderosa Pine Woodland, and Southern Rocky Mountain Pinyon- Juniper Woodland – all ecosystem types currently with less than 5% representation of the overall ecosystem acreage on the forest (The Wilderness Society 2016).

20a – Lake Fork, Sheep Mtn, Deep Creek/Boot Mountain CRAs

 We concur that this area deserves a ranking of high (with an adjusted southern border). We describe in detail the area’s high quality wilderness values in Appendix 3 in the write-ups entitled Wannamaker Creek-Deep Creek addition to La Garita Wilderness and Lake Fork addition to La Garita Wilderness. We also provide detailed information on supplemental values and manageability, all informed by best available science.  Regarding supplemental values, the spreadsheet says that there are none. We disagree. As detailed in Appendix 3, the proposed wilderness addition includes a portion of the Saguache Creek Potential Conservation Area identified by the Colorado Natural Heritage Program. Saguache Creek is ranked as having High Biodiversity Significance owing to its montane and subalpine willow carr associations within the creek’s floodplain and valley toe slopes. The Middle Fork of Saguache Creek is noted specifically for a good stand of beaked sedge (Carex utriculata) wetland and numerous smaller wetlands in the upper watershed (CNHP 2015). The Middle Fork of Saguache Creek hosts a high purity, recreation population for Rio Grande Cutthroat Trout that extends all the way into the headwaters at Machin Lake. Similarly, Wanamaker hosts a conservation population of Rio Grande Cutthroat Trout (Alves et al 2004).

The proposed Lake Fork addition enhances the ecological effectiveness of the La Garita Wilderness by expanding the size of the protected area. Larger protected areas are more likely to provide conditions for species persistence over the long term than smaller areas, as are areas with more compact boundaries. The addition increases the wilderness acreage of La Garita while reducing the length of the wilderness boundary, thereby increasing the ratio of acreage to boundary (Miller 2003; Aplet et al 2000).

The proposed Lake Fork wilderness addition increases the ecological representation within Rio Grande National Forest wilderness areas of Southern Rocky Mountain Montane-Subalpine Grassland, an ecosystem type currently with less than 5% representation of the overall ecosystem acreage on the forest. The proposed Wannamaker Creek-Deep Creek wilderness addition increases by thousands of acres the ecological representation within Rio Grande

National Forest wilderness areas of Southern Rocky Mountain Montane-Subalpine Grassland, an ecosystem type currently with less than 5% representation of the overall ecosystem acreage on the forest (The Wilderness Society 2016).

25.a – Wason Park and Lower East Bellows CRAs

 We concur that this area deserves a ranking of high. We describe in detail the area’s high quality wilderness values in Appendix 3. We also provide detailed information on supplemental values and manageability, all informed by best available science.  The spreadsheet implies that solitude might be affected by the fact that a person could see Creede from the west side of the area. But, as discussed above, FSH 1909.12, chapter 70, section 72.1 (2)(a) directs the agency to “Consider impacts that are pervasive and influence a visitor’s opportunity for solitude within the evaluated area. Factors to consider may include topography, presence of screening, distance from impacts, degree of permanent intrusions, and pervasive sights and sounds from outside the area” (emphasis added). There are many designated areas (e.g., Eagles Nest Wilderness adjacent to Vail and I-70) from which urban areas are clearly visible. However, in this case Creede itself is located in a deep valley, so it is essentially invisible from the overwhelming majority of the roadless area. Rural subdivisions in the Rio Grande valley pose a distant visual backdrop from the lower edges of the area, but are indistinguishable once a visitor travels several miles into the unit. See photographs of the area in Appendix 4.  Regarding supplemental values, we offer the following information that is provided in detail in Appendix 3. Wason Park contains outstanding supplemental values for a variety of wildlife species. It is in close proximity to high use lynx areas, contains lynx habitat, and provides an important landscape connectivity link for lynx. Wason Park provides important winter range for elk, deer, and bighorn sheep. Wason Park encompasses a migration route for bighorn sheep for the Bellows Creek, San Luis Peak, and Bristol Head herds. Wason Park also is adjacent to priority habitat for moose in West Willow Creek.

The proposed Wason Park wilderness addition enhances the ecological effectiveness of the La Garita Wilderness by expanding the size of the protected area to include lower elevation lands. The Wason Park addition would boost the size of the La Garita Wilderness by 15%. Larger protected areas are more likely to provide conditions for species persistence over the long term than smaller areas (Miller 2003; Aplet et al 2000).

Wason Park contributes thousands of acres of one of the most under-represented ecosystem types among existing wilderness areas on the Rio Grande National Forest. By protecting this area, the Rio Grande NF can significantly increase the ecological representation within its wilderness areas of Southern Rocky Mountain Montane-Subalpine Grassland (The Wilderness Society 2016).

Wason Park includes a pair of scenic waterfalls above Phoenix Park that are popular focal points for photographers.

28 – Pole Mtn/Finger Mesa

We concur that this area deserves a ranking of high. We describe in detail the area’s high quality wilderness values in Appendix 3 in the write-up entitled Pole Creek Mountain – Sheep Mountain Recommended Wilderness. We also provide detailed information on supplemental values and manageability, all informed by best available science.

 Regarding supplemental values, we offer the following information that is provided in detail in Appendix 3. Pole Creek Mountain is important for several species of significant conservation concern. It is an area of high use by lynx and provides connections for lynx moving through the heart of the core population of the San Juan Mountains. The area contains one of the few known populations of the Uncompahgre fritillary butterfly, and also the only known global occurrences of the stonecrop gilia. Pole Creek Mountain provides high quality habitat for future wolverine populations.

Pole Creek Mountain includes portions of two Potential Conservation Areas identified by the Colorado Natural Heritage Program. Two globally vulnerable riparian plant communities, Booth's willow (Salix boothii)/mesic forbs shrubland and Wolf's willow (Salix wolfii)/mesic forbs shrubland, occur within a large subalpine willow carr along the upper reaches of the Pole Creek PCA and are ranked as High Biodiversity Significance. The Sheep Mountain portion includes the entirety of the Sheep Mountain in San Juans PCA, which is ranked as Very High Biodiversity Significance owing to the existence of one of only two known global occurrences of the critically imperiled stonecrop gilia (Aliciella sedifolia). The best known worldwide occurrence of stonecrop gilia is located in the Half Peak PCA along the northern edge of the proposed wilderness (CNHP 2015).

Pole Creek Mountain includes over 20 miles of streams managed for recreation populations of Rio Grande cutthroat trout. Pole Creek, Lost Trail Creek, and West Lost Trail Creek create a large area of connected habitat, along with adjacent streams in the headwaters of the Rio Grande below Stony Pass (Alves et al 2004)

The lower slopes of Pole Creek Mountain along the Rio Grande would increase the ecological representation within Rio Grande National Forest wilderness areas of Southern Rocky Mountain Montane-Subalpine Grassland, an ecosystem type currently with less than 5% representation of the overall ecosystem acreage on the forest (The Wilderness Society 2016).

38.a – Snowshoe Mountain CRA

interest. The mountain is a resurgent volcanic dome formed in the Creede caldera, and the Deep Creek graben is conspicuous at the mountain’s crest (Lipman 2006).

Snowshoe Mountain includes the entirety of the 417-acre Deep Creek Uplands West PCA, which is a Potential Conservation Area ranked as Very High Biodiversity Significance. This PCA includes one of the best known populations of Smith whitlow-grass, a Colorado endemic and globally imperiled species, as well as a population of globally imperiled black canyon gilia. Snowshoe Mountain includes a portion of the 3,346-acre Spar City Potential Conservation Area identified by the Colorado Natural Heritage Program. Spar City PCA is ranked as Moderate Biodiversity Significance owing to its large and excellent quality occurrence of a state rare bristlecone pine/Thurber fescue (Pinus aristata/Festuca thurberi) montane woodland, a plant association limited to the southern Rocky Mountain ecoregion (CNHP 2015).

Snowshoe Mountain enhances the ecological effectiveness of the Weminuche Wilderness by expanding the size of the protected area by over 30,000 acres. Larger protected areas are more likely to provide conditions for species persistence over the long term than smaller areas (Miller 2003; Aplet et al 2000).

Snowshoe Mountain contributes thousands of acres of one of the most under-represented ecosystem types among existing wilderness areas on the Rio Grande National Forest. By protecting this area, the Rio Grande NF can significantly increase the ecological representation within its wilderness areas of Southern Rocky Mountain Montane-Subalpine Grassland (The Wilderness Society 2016).

51 – Bennet Mountain/Blowout/Willow Creek/Lion Point/Greenie Mountain CRA

 We disagree with the overall ranking of moderate to high for the upper tier portion. Instead, we think the ranking should be high for the 14,000-acre core area, which we recommend for wilderness designation. See a detailed description of the core area’s high quality wilderness values in Appendix 3, which we characterize as the North Fork of Rock Creek. We also provide detailed information on supplemental values and manageability, all informed by best available science.  The preliminary evaluation states that the area has some solitude but does not provide a rationale for that ranking. In contrast, we think that this ranking should be “Yes” instead of “Some” based on our field examinations. See Appendix 3 for a rationale for our finding. Also see our comments related to this criterion under polygon 2 – the same arguments apply here. See photographs of the area in Appendix 4 for evidence of solitude.  Regarding supplemental values in the core area, we offer the following information that is provided in detail in Appendix 3. The North Fork Rock Creek provides good representation of several ecosystem types under-represented among existing wilderness areas on the Rio Grande National Forest. The area covers the ecological transition from the San Luis Valley to alpine slopes, and at is lowest margins includes grasslands and pinyon-juniper woodlands, as well as ponderosa pine and dry mixed-conifer forests. Recommending this area for wilderness designation will increase the ecological representation on the Rio Grande NF of Southern Rocky

Mountain Montane-Subalpine Grassland, Southern Rocky Mountain Ponderosa Pine Woodland, Rocky Mountain Pinyon-Juniper Woodland, and Southern Rocky Mountain Mesic Montane Mixed-Conifer Forest and Woodland, all of which are currently represented at less than 5% on the forest (The Wilderness Society 2016).

53 – Summit Peak/Elwood Pass CRA

 We concur that this area deserves a ranking of high.  For the manageability criterion, the spreadsheet says that the area may be difficult to manage for wilderness characteristics but does not say why or provide any additional information. We request that you explain why this is the case or remove the comment.

55 – Gold Creek/Cascade Creek CRA

 We concur that the portion of this area near the wilderness deserves a ranking of high. We describe in detail the area’s high quality wilderness values in Appendix 3 under the write-up entitled Adams Fork – Three Forks Addition to South San Juan Wilderness. We also provide detailed information on supplemental values and manageability, all informed by best available science.  For the manageability criterion, the spreadsheet says that the area may be difficult to manage for wilderness characteristics but does not say why or provide any additional information. We presume it is because the boundary of the polygon is convoluted. Manageability is easily possible with a modified boundary such as we have proposed for the portion of the area encompassing the Adams Fork. We therefore recommend that you modify the boundary accordingly and assign a “high” rank to the manageability criterion.

57- Tobacco Lakes CRA

 We concur that this area deserves a ranking of high. We describe in detail the area’s high quality wilderness values in Appendix 3 under the write-up entitled Adams Fork – Three Forks Addition to South San Juan Wilderness. We also provide detailed information on supplemental values and manageability, all informed by best available science.  Regarding supplemental values, the spreadsheet says that there are none. In contrast, we direct you to our description of supplemental values in Appendix 3.

63a – Chama Basin and Cumbres CRA (lower Elk Creek)

 Chama Basin and Cumbres are in reality two geographically distinct areas for which separate analysis might be a better approach. We concur that the Cumbres CRA deserves a ranking of high. (Note that the spreadsheet ranks the area as high but the map shows it ranked as moderate. This needs to be corrected.) We describe in detail the area’s high quality wilderness values in Appendix 3 under the write-up entitled Elk Creek addition to South San Juans Wilderness. We also provide detailed information on supplemental values and manageability, all informed by best available science.  Adding lower Elk Creek to the wilderness notably expands the range of ecosystems present within the existing wilderness because of the presence of uncommon stands of robust

ponderosa pine at its lower end. These classic stands of stately ponderosa pine intermixed with park-like grasslands create a welcome entrance to the wilderness. This is an ecosystem type noticeably absent within the existing wilderness on the Rio Grande National Forest.  The Chama Basin component also deserves a ranking of high. Chama Basin is one of the most breath-taking spectacular vistas on the Rio Grande NF with outstanding opportunities for solitude and primitive and unconfined types of recreation. The area has a well-developed trail system that takes visitors to scenic waterfalls and to vast tracts of colorful aspen in fall. The Rio Grande NF has already determined previously that more than 10 miles of the forks of the Rio Chama and Archuleta Creek have identified outstandingly remarkable scenic and recreational values, hence the wilderness evaluation should similarly rank recreation opportunities as outstanding. Supplemental values include the basin’s significance as a headwaters source area, and the presence of Rio Chama Potential Conservation Area identified by CNHP for its montane riparian forest.

Development of Alternatives for Inclusion in the Environmental Impact Statement (EIS)

Under NEPA, an EIS must rigorously explore and objectively evaluate all reasonable alternatives. This analysis of alternatives is the “heart” of the EIS. The Ninth Circuit Court of Appeals has directly addressed what constitutes an adequate range of alternatives in the context of wilderness recommendations. In California v. Block, the Court invalidated as unduly narrow a range of alternatives that would have designated a maximum of 33% of identified roadless acreage as recommended wilderness. (690 F.2d 753, 765 (9th Cir. 1982)). The Council on Environmental Quality has suggested that a reasonable range of alternatives “might include dedicated 0, 10, 30, 50, 70, 90, or 100 percent of [a] Forest to wilderness.”8

Recommendation: The Rio Grande should ensure a broad range of alternatives for recommended wilderness in the EIS with at least one alternative that recommends all or nearly all of the qualified areas, while other alternatives recommend wilderness and provide other designations for substantial portions of the inventoried areas.

Conclusion

We extend our appreciation to the Forest Service for the opportunity to provide these comments on the preliminary draft wilderness evaluation. We appreciate all of the hard work that the staff on the Rio Grande National Forest has put into the wilderness inventory and evaluation process, including providing opportunities for the public to provide feedback, ensuring transparency, providing timely information to the public, and responding to concerns. We look forward to continuing working with you

8 See Council of Environmental Quality, 1981. Forty Most Asked Questions Concerning CEQ's National Environmental Policy Act Regulations at 46 Fed. Reg. 18026 (March 23, 1981) as amended. (“For some proposals there may exist a very large or even an infinite number of possible reasonable alternatives. For example, a proposal to designate wilderness areas within a National Forest could be said to involve an infinite number of alternatives from 0 to 100 percent of the forest. When there are potentially a very large number of alternatives, only a reasonable number of examples, covering the full spectrum of alternatives, must be analyzed and compared in the EIS. An appropriate series of alternatives might include dedicating 0, 10, 30, 50, 70, 90, or 100 percent of the Forest to wilderness…”).

15 as the forest plan revision process moves forward. Thank you for considering these comments. If you have questions, please do not hesitate to contact the undersigned to discuss.

With regards,

Vera Smith, Director of Forest Planning and Policy The Wilderness Society 1660 Wynkoop St., #850 Denver, CO 80202 303 650-5942 [email protected]

Rocky Smith, Forest Management Analyst and Consultant 1030 Pearl St. #9 Denver, CO 80203 303 839-5900 [email protected]

Christine Canaly, Director San Luis Valley Ecosystem Council P.O. Box 223 Alamosa, CO 81101 (719) 589-1518 [email protected]

Tom Sobal, Director Quiet Use Coalition P.O Box 1452 Salida, CO 81201 (719) 539-4112 [email protected] Alison Gallensky, GIS and IT Director Rocky Mountain Wild 1536 Wynkoop St. Suite 900 Denver, CO 80202 303 454-3345 [email protected]

Julie Mach Conservation Director Colorado Mountain Club 710 10th St. Suite 200 Golden, CO 80401

(303)996-2764 [email protected]

Lauren McCain Forest Lands Policy Analyst Defenders of Wildlife 535 16th St. Suite #310 Denver, CO 80202 720-943-0453 [email protected]

John R. Mellgren, Staff Attorney Western Environmental Law Center 1216 Lincoln Street Eugene, OR 97401 (541) 359-0990 [email protected]

Appendices

Appendix 1 – Chart Showing Biodiversity Values by Potential Wilderness Area Polygon Appendix 2a – Ecosystem Representation Report Submitted by The Wilderness Society et al in 2015 Appendix 2b – Ecosystem Representation Data Submitted by The Wilderness Society et al in 2016 Appendix 3 – Descriptions of Citizen Recommended Wilderness Areas Developed by The Wilderness Society, Quiet Use Coalition, San Luis Valley Ecosystem Council, Rocky Mountain Wild, Rocky Smith, and Defenders of Wildlife. Appendix 4 – Photographic album of areas described in Appendix 3.

References

Alves, John, Doug Krieger, and Tom Nesler, 2004. Conservation Plan for the Rio Grande Cutthroat Trout in Colorado. Colorado Division of Wildlife (CDOW).

Aplet, Gregory, Janice Thomson, and Mark Wilbert, 2000. “Indicators of Wildness: Using Attributes of the Land to Assess the Context of Wilderness.” In McCool, Stephen F.; Cole, David N.; Borrie, William T.; O’Loughlin, Jennifer, comps. 2000. Wilderness science in a time of change conference—Volume 2: Wilderness within the context of larger systems; 1999 May 23–27; Missoula, MT. Proceedings RMRS-P- 15-VOL-2. Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. Attached.

Colorado Fourteeners Initiative, 2015. Hiker Use Estimates, 2015. Available at: http://www.14ers.org/stay-informed/2015-colorado-14ers-hiking-use-estimates/

Colorado Natural Heritage Program, 2015. Potential Conservation Area Reports 2015. Available at: http://www.cnhp.colostate.edu/download/gis/pca_reports.asp.

Lipman, Peter, 2006. Geologic Map of the Central San Juan Caldera Cluster, Southwestern Colorado. US Geological Survey. Available at: http://pubs.usgs.gov/imap/i2799/

Miller, Brian, 2003. Southern Rockies Wildlands Network Vision: A Science-Based Approach to Rewilding the Southern Rockies. Colorado Mountain Club Press. 248 pages.

Rare Earth Science, 2011. Letter to Chris Canaly, San Luis Valley Ecosystem Council. August 1, 2011. Attached.

San Luis Valley Ecosystem Council, 2002. Roadless area descriptions. Available from the San Luis Ecosystem Council.

The Wilderness Society, 2016. Ecosystem Representation Report. Attached as Appendix 2.

US Fish and Wildlife Service, 2012. Sangre de Cristo Conservation Area Land Protection Plan. Available at: https://www.fws.gov/mountain- prairie/planning/lpp/co/sdc/documents/sdc_lppfinal_contents_summary.pdf.

USDA Forest Service and UDDOI National Park Service, 2009. Baca Mountain Tract and Camino Chamisa Project Environmental Assessment, 2009. Available at: http://www.fs.usda.gov/main/riogrande/landmanagement/planning.

USDA Forest Service, 1996. Rio Grande National Forest Land and Resource Management Plan.

USDA Forest Service, 2008a. Profiles of Colorado Roadless Areas 2008. Available at: http://www.fs.usda.gov/wps/portal/fsinternet/!ut/p/c4/04_SB8K8xLLM9MSSzPy8xBz9CP0os3gjAwhwtD Dw9_AI8zPyhQoY6BdkOyoCAGixyPg!/?ss=119930&navtype=BROWSEBYSUBJECT&cid=stelprdb5292112 &navid=111000000000000&pnavid=null&position=Not Yet Determined.Html&ttype=detail&pname=Roadless- Colorado Roadless Rule.

USDA Forest Service, 2008b. Southern Rockies Lynx Management Direction Final Environmental Impact Statement, Appendix D.

USDA Forest Service, 2015. Rio Grande National Forest Assessment Chapter 12, Areas of Tribal Importance. Available at: http://www.fs.usda.gov/detailfull/riogrande/landmanagement/projects/?cid=fseprd479245&width=full

USDOI National Park Service, 2007. Great Sand Dunes NP General Management Plan and Wilderness Study. Available at: https://parkplanning.nps.gov/projectHome.cfm?projectID=11015.

Appendix B

Ecosystem Representation Analysis Methods and Results Ecosystem Representation in the Rio Grande National Forest

These comments address the role of ecosystem representation in the Rio Grande National Forest’s land management planning process ‐ particularly its evaluation of areas that may be suitable for inclusion in the National Wilderness Preservation System (NWPS). As explained below and illustrated by the accompanying maps and data, the Rio Grande hosts numerous ecosystem types that are poorly represented in the NWPS both regionally and nationally. Given the central importance of ecosystem diversity to conserving biological diversity and satisfying the requirements of the 2012 National Forest System Land Management Planning Rule, 36 C.F.R. part 219, the upcoming plan revision process presents a crucial opportunity for the Rio Grande to increase the diversity of ecosystems that are protected as part of the NWPS or through other special designations. Most immediately, the Forest Service should incorporate ecosystem representation into its assessment of the need and opportunity for additional designated areas.

I. Ecological Importance of Ecosystem Representation in Wilderness and Other Protected Areas

Wilderness and other protected conservation areas are the cornerstones of most regional, national, and international efforts to conserve biological diversity and ecological processes of natural ecosystems (Bertzky et al. 2012). Research has shown that protected areas reduce the loss, degradation, and fragmentation of natural habitats (Bruner et al. 2001; Naughton‐Treves et al. 2005) and slow the rate of extinction of threatened species that occur therein (Butchart et al. 2012). Conversely, federal public lands in the United States that are managed for a variety of uses including mining, logging, and motorized recreation – and not primarily for conservation purposes – do not have the same benefits. Recognizing the central importance of protected areas in conserving biological diversity, the International Convention on Biological Diversity recommends that at least 17% of the world’s terrestrial areas be conserved by 2020 (Woodley et al. 2012). To that end, the NWPS already serves as the world’s largest national system of highly protected conservation areas.1

Wilderness and other protected areas, however, can help achieve biodiversity targets only if they are located in the right places – that is, if they are ecologically representative of terrestrial ecosystems. This “representation” approach assumes that for protected areas to conserve genetic, species, and community diversity – as well as the composition, structure, function, and evolutionary potential of natural systems – they

1 The NWPS contains 21 million hectares in 690 units, covering nearly 1/5 of what the International Union for Conservation of Nature (IUCN) classifies as “category 1 areas,” or the most natural and highly protected areas worldwide. By contrast, the IUCN classifies general Forest Service matrix lands as “GAP Status 3” – “Area having permanent protection from conversion of natural land cover for the majority of area. Subject to extractive uses of either broad, low‐intensity type (eg. Logging) or localized intense type (eg. Mining).” – which is not considered a “protected” category for biodiversity purposes. 1

must encompass the full variety of ecosystems (Olson & Dinerstein 1998; Margules & Pressey 2000). In other words, protection of distinct ecological communities in turn protects the species that rely on them and the natural ecological processes that are characteristic of those ecosystems (Rodrigues et al. 2004; Bunce et al. 2013). According to the Convention on Biological Diversity, the percentage of terrestrial ecosystems protected by 2020 (with a target of 17%) is one indicator of how well ecosystems are represented throughout the global network of protected conservation areas (Woodley et al. 2012).

Despite its importance, our analysis of ecosystem representation in the NWPS (Dietz et al. 2015) – which is described in detail below – shows that the NWPS suffers from a significant under‐representation of many ecosystems. Over 20% (117) of the 553 types of unique ecosystems occurring on federal lands in the contiguous United States are not included in the NWPS. Even more concerning is that less than half of those 553 ecosystems are more than nominally represented: only 244 ecosystem types have at least 5% of their federal land area protected in the NWPS. And at a more reasonable 20% target for biodiversity conservation purposes, that number falls to only 113 ecosystems with at least 20% of their federal land area protected in the NWPS. 95% of that diversity was achieved by 1994, and wilderness designations over the past 15 years have added only 1 new ecosystem type above the 20% threshold. Moreover, there is not a clear correlation between how rare an ecosystem is on federal lands and how well it is represented in the NWPS. We found that there are many ecosystem types that are common on federal lands (covering over 100,000 hectares) but are poorly represented in the NWPS.

With the Wilderness Act over 50 years old (signed into law on September 3, 1964), it is important to begin to remedy this under‐representation of ecosystems in the NWPS. Human population growth, climate change, and pressure for development and extraction of natural resources make wilderness and other protected areas increasingly vital to conserve biological diversity. Given those pressures and stressors, we must establish a network of connected wilderness and other protected areas that represent the full expression of ecosystem diversity.

II. Regulatory Requirements to Evaluate Ecosystem Representation

Given the regional, national, and global importance of ecosystem representation in the NWPS and other protected areas, the 2012 National Forest System Land Management Planning Rule requires the Forest Service to evaluate and incorporate ecosystem representation into its forest assessment and planning processes. Indeed, protecting ecosystem diversity is a central purpose of forest planning under the rule:

Plans will guide management of [National Forest System] land so that they are ecologically sustainable and contribute to social and economic sustainability; consist of ecosystems and watersheds with ecological

integrity and diverse plant and animal communities; and have the capacity to provide people and communities with ecosystem services and multiple uses that provide a range of social, economic, and ecological benefits for the present and into the future.

36 C.F.R. § 219.1(c) (emphasis added).

To satisfy the 2012 Planning Rule’s ecosystem diversity mandate, forests are first required to identify and evaluate existing designated areas, including wilderness, and the potential need and opportunity for additional designated areas as part of the assessment phase. Id. § 219.6(b)(15). In doing so, the assessment “should identify and evaluate available information to answer questions such as: . . . Are there specific land types or ecosystems present in the plan area that are not currently represented or minimally represented?” Forest Service Handbook (FSH) 1909.12, ch. 10, § 14(1)(4)(c).

Next, during the plan development or revision phase, the Forest Service is required to “[i]dentify and evaluate lands that may be suitable for inclusion in the [NWPS] and determine whether to recommend any such lands for wilderness designation.” 36 C.F.R. § 219.7(c)(2)(v). In evaluating potential wilderness areas, the agency must, among other things, “[e]valuate the degree to which the area may contain ecological, geological, or other features of scientific, educational, scenic, or historical value.” FSH 1909.12, ch. 70, § 72.1(4); see also 16 U.S.C. § 1131(c)(4) (wilderness, as defined by the Wilderness Act of 1964, “may also contain ecological, geological, or other features of scientific, educational, scenic, or historical value”). “Such features or values may include[ r]are plant or animal communities or rare ecosystems,” with “rare” being “determined locally, regionally, nationally, or within the system of protected designations.” FSH 1909.12, ch. 70, § 72.1(4)(a).

In addition to identifying and evaluating areas to recommend for wilderness designation, the 2012 Planning Rule also requires the agency to “[i]dentify existing designated areas other than [wilderness] and determine whether to recommend any additional areas for designation.” 36 C.F.R. § 219.7(c)(2)(vii). Those special designations may include, for example, ecological areas, botanical areas, or Research Natural Areas (RNAs), which are designed to “[m]aintain a wide spectrum of high quality representative areas that represent the major forms of variability . . . that, in combination, form a national network of ecological areas for research, education, and maintenance of biological diversity . . . [and s]erve as a baseline area for measuring long‐ term ecological changes.” Forest Service Manual 4063.02; see also 36 C.F.R. § 219.19 (Forest Service may designate RNAs as part of planning process).

Complementing the requirement to consider ecosystem representation in determining suitability for wilderness and other special designations, the 2012 Planning Rule directs that plans generally provide for ecological sustainability and integrity and “the diversity of plant and animal communities and the persistence of native species.” 36 C.F.R.

§§ 219.8‐219.9. The Forest Service cannot satisfy those substantive mandates without adequately protecting ecosystem diversity in the plan area. For example, plans “must include plan components, including standards or guidelines, to maintain or restore the diversity of ecosystems and habitat types[, including r]are . . . plant and animal communities.” Id. § 219.9(a)(2). With conflicting management and resource demands and human‐caused stressors such as climate change that threaten ecosystem diversity and integrity, plans simply cannot restore or maintain the diversity of plant and animal communities absent a robust network of protected areas that adequately represent that diversity.

Collectively, these various procedural and substantive mandates commit the agency to a meaningful evaluation and consideration of under‐represented and rare ecosystems throughout the planning process, starting with the assessment of the need and opportunity for additional designated areas. In doing so, the agency is required to use “the best available scientific information.” Id. § 219.3. As described in the methodology section below, we believe our analysis of ecosystem representation represents the best available scientific information, and we encourage the Forest Service to incorporate it into its assessment, wilderness evaluation, and the broader planning process.

III. Methods and Analysis of Ecosystem Representation

To inform the Rio Grande National Forest’s assessment of the need and opportunity for additional designated areas, we conducted an analysis of ecosystem representation in wilderness at the national‐ and forest‐level scales to provide the best available scientific information.

According to the U.S. Geological Survey (USGS), the contiguous United States contains 565 terrestrial, non‐developed ecosystems. In this study, we analyzed representation of those ecosystems by comparing their areas in the NWPS with their areas on federal land at both the national and forest levels in order to calculate a percent representation:

Equation 1: (area of ecosystem in the NWPS/area of ecosystem on federal land)*1002

Equation 2: (area of ecosystem in the NWPS on the Rio Grande NF/area of ecosystem on the Rio Grande NF)*100

We conducted these calculations at the finest scale for which consistent, spatially‐ explicit vegetative land‐cover data is available: the 6th level of the National Vegetation

2 We used federal land, as opposed to all land, within the contiguous United States to better assess where ecosystems are under‐represented on lands potentially available for wilderness designation.

Classification System (NVCS 2008).3 That data is from the USGS Gap Analysis Program (GAP) national land‐cover data version 2 at 30‐meter resolution (USGS 2011).

We obtained spatial data of the NWPS from the University of Montana College of Forestry and Conservation’s Wilderness Institute at wilderness.net, which maintains the most up‐to‐date spatial data on wilderness areas. To map federal land area, we used the U.S. Protected Areas Database (PAD‐US) version 1.3 (USGS 2012), which includes geographic boundaries, land ownership, land management, management designation, parcel name, area, and protection category.4

We overlaid the NWPS and all federal lands with land‐cover data in a Geographic Information System (ArcGIS 10.2) to calculate and compare the total area of each ecosystem within the NWPS and federal land. We then calculated the percent of each ecosystem within the NWPS based on all area occurring on federal land (Equation 1, above).5 This was part of a national assessment that we conducted (Dietz et al. 2014 (in revision)).

We did the same calculations at the forest level. We extracted land‐cover data and clipped it to the forest boundary, and then calculated the percent of each ecosystem within the Rio Grande National Forest’s four existing wilderness areas based on all federal land area occurring on the Forest (Equation 2, above).

Next we classified representation for each scale into four classes (<5%, 5‐9.9%, 10‐ 19.9%, ≥20%) and mapped them across the entire national forest. We considered ecosystems with <19.9% of their total area in the NWPS as inadequately represented.

We then brought the Rio Grande National Forest’s Chapter 70 wilderness inventory areas into Arc and created a new shapefile that included only the wilderness inventory areas. This allowed us to focus our analysis on the areas that are potentially suitable for wilderness designation by tabulating the area of each ecosystem occurring within each wilderness inventory area (see attached matrix, Table 2 “Ecosystem Composition of Roadless Areas.xlsx”). Values within the matrix are the estimated acres of each ecosystem occurring within each wilderness inventory area unit.

3 The NVCS classifications are as follows: 1) Class; 2) Subclass; 3) Formation; 4) Division; 5) Macrogroup; 6) Group (a.k.a. ecological system, to which we refer in this study as “ecosystem”); 7) Alliance; and 8) Association.

4 The PAD‐US is a national inventory of terrestrial and marine protected areas that are managed to preserve biological diversity and other natural, recreation, and cultural uses.

5 For example, when we say “boreal aspen‐birch forest has 19% representation in NWPS,” we mean that 19% of all federal land encompassing that ecosystem type is protected as wilderness in the NWPS. 5

We used these data to calculate the proportion (%) of each wilderness inventory area that is composed of ecosystems inadequately represented in the NWPS by each of the 3 lower representation classes (<5%, 5‐9.9%, 10‐19.9%) and for both scales of representation (Table 1).

IV. Results

Our analysis shows that a significant number of Chapter 70 wilderness inventory areas on the Rio Grande National Forest contain high proportions of inadequately represented ecosystem types at both the forest‐level and national scales (Tables 1 & 2; Maps 2 & 3). Cumulatively, we found that underrepresented ecosystems cover nearly 50% of the wilderness inventory areas on both forest‐level and national scales. On the forest‐level, severely under‐represented ecosystem types (<5%) cover over 25% of the wilderness inventory areas. All the wilderness inventory units contain at least one underrepresented ecosystem, with some units showing over 90% areal coverage of these ecosystems.

In many instances, the addition of one wilderness inventory unit would elevate specific ecosystems into adequate representation on the forest level (Table 4). For example, the addition of unit 3.f would elevate the Rocky Mountain Subalpine‐Montane Mesic Meadow ecosystem into adequate representation. A total of 8 other ecosystems could be elevated into adequate representation with the addition of one wilderness inventory unit. If all of the final wilderness inventory units were added into wilderness, 14 underrepresented ecosystems would be adequately represented on the forest level.

More broadly, our analysis shows that inadequately represented ecosystem types cover over 40% of the Rio Grande National Forest at both the national and forest levels of representation. (Table 3, Tabs 2 & 3).

At the forest level, our analysis found that only 11 of the 31 ecosystem types found on the Rio Grande are adequately represented (Table 3, Tabs 1 & 2; Map 3). In total, under‐ represented ecosystem types span over 43% of the forest area and approximately 788,000 acres. Ecosystem types with less than 5% representation at the forest level comprise over 23% of the entire Rio Grande, while ecosystem types with less than 10% representation at that scale cover 27% of the forest.

The story is similar at the national scale, with a total of 21 inadequately represented ecosystem types covering over 41% and 742,000 acres of the Rio Grande (Table 3, Tab 3; Map 2). Further, only 6% of these under‐represented ecosystems are protected in wilderness nationally.

Notably, two of the most prevalent ecosystems on the Rio Grande are under‐ represented both at the forest and national levels (Table 3, Tabs 2 & 3). The Southern Rocky Mountain Montane‐Subalpine Grassland covers over 191,000 acres of the forest,

yet only 3.4% of the ecosystem is protected as wilderness. The Rocky Mountain Aspen Forest and Woodland spans 209,000 acres on the Rio Grande, only 28,000 of which are protected in the forest’s wilderness.

The attached maps and tables depict these results in detail, showing the following:

Map 1 “Rio Grande National Forest Wilderness Inventory Areas”: Depicts each unit (polygon) in the Chapter 70 wilderness inventory area inventory, outlined in black with cross‐hatching with the forest boundary shaded deep green.

Map 2 “Ecosystem Representation on the Federal Level“: Color depiction of the results of Equation 1 (above), showing the level of representation in the NWPS of each ecosystem type at the national scale. For example, areas shown in red depict ecosystems that are represented in the NWPS at less than 5% of all available federal land. [Chapter 70 roadless areas are outlined in black with cross‐hatching]

Map 3 “Ecosystem Representation on the Forest Level”: Color depiction of the results of Equation 2 (above), showing the level of representation in the NWPS of each ecosystem type at the forest level. [Chapter 70 wilderness inventory areas are outlined in black with cross‐hatching]

Table 1, Tabs 1 & 2 “Rio Grande National Forest Wilderness Inventory Area Representation Table”: Proportion (%) and acreage of each Chapter 70 wilderness inventory area composed of under‐represented ecosystem types on the Rio Grande National Forest based on forest‐level (Tab 1) or national‐level (Tab 2) representation. Representation of each ecosystem type was quantified based on all available area on federal land and the individual forest. All ecosystems with <20% representation in the NWPS at each scale were broken into 3 levels of representation (<5%, 5‐9.9%, and 10‐ 19.9%). This table allows one to prioritize potential wilderness inventory units by proportion of land area as well as acreage that is composed of underrepresented ecosystems, at three levels.

Table 2 “Ecosystem Composition of Wilderness Inventory Areas”: Values within the matrix are the estimated acres of each ecosystem type occurring within each Chapter 70 wilderness inventory area unit. This table depicts the specific ecosystem composition of each unit.

Table 3, Tabs 1‐3 “Rio Grande National Forest Ecosystems Representation”: These tables depict which ecosystems are under‐represented at the forest‐level and national scales. Tab 1 shows a complete list of ecosystem types found on the Rio Grande National Forest, and the proportion of each type in the NWPS at the forest‐level and national scales. Tabs 2 and 3 show representation breakdowns at the three levels (<5%, 5‐9.9%, and 10‐19.9%) at the forest‐level and national scales.

Table 4 “Chapter 70 Wilderness Inventory Unit Analysis of Ecosystem Composition”: This table shows the estimated acres of each ecosystem type occurring within each Chapter 70 wilderness inventory unit. This table also shows how many acres of additional protection are needed to elevate a specific ecosystem into adequate representation, and how many units would be needed (if applicable) to achieve adequate representation on the forest level.

V. Recommendations

Sufficient ecosystem representation in the NWPS and other protected areas is crucial to achieving ecological integrity of the diverse plant and animal communities found in the Rio Grande National Forest. As described above and depicted in the attached maps and tables, our analysis shows that under‐representation of ecosystems in the NWPS is a significant problem on the Rio Grande. Thus, the planning process presents the Forest Service with a critical opportunity to prioritize protection of ecosystem diversity and begin to remedy the under‐representation of numerous ecosystem types in the NWPS.

To that end, we urge the Rio Grande National Forest to use the representation information in the attached tables and maps and described above throughout the planning process. Most immediately, the information should be used to assess the need and opportunity for additional designated areas. Following the assessment, the information also should be used to evaluate areas that may be suitable for inclusion in the NWPS,6 and to determine which areas to carry forward for NEPA analysis and, ultimately, which areas to recommend for wilderness designation. In addition, the forest should use the information more broadly in its planning process and determinations whether to designate or recommend for designation other areas such as RNAs, ecological or botanical areas, etc. As described above, we believe that this information is the best available science on ecosystem representation, which the agency is legally required to use in its planning process.

If you have any questions about the analysis or data, or would like to have the data in another format, please contact Phil Hartger ([email protected]).

6 For example, Region 5 has made exceptional efforts to incorporate our analysis into the wilderness evaluation processes for the Inyo, Sequoia, and Sierra National Forests. The Region’s wilderness team prepared a data summary for each inventoried unit, ranked by percent composition of under‐represented ecosystems, to assess the relative opportunities in each unit to enhance ecosystem diversity. Those summaries are attached hereto. 8

Literature Cited

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Bruner, A.G., Gullison, R.E., Rice, R.E. & da Fonseca, G.A.B. (2001). Effectiveness of parks in protecting tropical biodiversity. Science, 291, 125‐128.

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Rio Grande National Forest, underrepresented Ecological Systems ("Ecosystems") at the Forest Scale

Chapter 70 wilderness inventory Unit Acreage Percent coverage (%) Total wild. inv. < 5% (Acres) 5 ‐ 9.9% (Acres) 10 ‐ 19.9% (Acres) < 20% (Acres) area acreage < 5% 5 ‐ 9.9% 10 ‐ 19.9% < 20% 9 7,475 868 320 8,662 10,214 73.2 8.5 3.1 84.8 11 1,386 652 1,896 3,933 6,360 21.8 10.2 29.8 61.8 3.i 528 15 1,167 1,710 2,111 25.0 0.7 55.3 81.0 20.b 15,706 1,718 5,997 23,421 35,101 44.7 4.9 17.1 66.7 53 0 0 81 81 3,773 0.0 0.0 2.2 2.2 36.b 20 0 2277.8 0.0 22.2 100.0 61 281 111 627 1,019 1,540 18.2 7.2 40.7 66.2 3.b 589 521 323 1,433 1,772 33.2 29.4 18.2 80.9 37.b 1,111 48 934 2,093 7,594 14.6 0.6 12.3 27.6 39 5,435 1,700 1,726 8,861 11,637 46.7 14.6 14.8 76.1 43.a 163 98 244 505 6,292 2.6 1.6 3.9 8.0 49 2 0 809 811 7,587 0.0 0.0 10.7 10.7 50 7,519 1,283 4,342 13,144 15,678 48.0 8.2 27.7 83.8 6 13,036 439 7,601 21,077 33,012 39.5 1.3 23.0 63.8 59 3,375 1,515 10,845 15,735 36,641 9.2 4.1 29.6 42.9 3.c 28 16 163 207 244 11.3 6.7 66.8 84.8 1.a 1,463 179 259 1,901 4,025 36.3 4.5 6.4 47.2 32 39 0 41 80 118 33.4 0.0 34.7 68.1 58.c 00 2 280.0 0.0 31.4 31.4 4 7,260 184 4,214 11,658 15,599 46.5 1.2 27.0 74.7 23 4,784 0 0 4,784 5,094 93.9 0.0 0.0 93.9 55 52 1 691 744 7,668 0.7 0.0 9.0 9.7 29 122 0 310 432 6,334 1.9 0.0 4.9 6.8 65 73 2 1,109 1,184 2,774 2.6 0.1 40.0 42.7 37.a 167 36 290 494 3,667 4.6 1.0 7.9 13.5 15 6,224 1,942 3,307 11,473 15,756 39.5 12.3 21.0 72.8 21 28 0 50 78 355 7.9 0.0 14.1 22.0 18 2,698 601 1,534 4,833 6,115 44.1 9.8 25.1 79.0 31 75 0 23 98 137 54.7 0.0 16.8 71.5 54 00 3 3140.0 0.0 18.5 18.5 57 67 5 255 327 5,368 1.3 0.1 4.8 6.1 33 198 0 160 358 955 20.7 0.0 16.8 37.5 51 23,263 5,523 19,702 48,489 77,590 30.0 7.1 25.4 62.5 44 2,802 1,829 2,581 7,212 11,896 23.6 15.4 21.7 60.6 42 0 0 10 10 441 0.0 0.0 2.2 2.2 24 3 0 15 18 116 2.5 0.0 12.7 15.2 30.b 00 0 050.0 0.0 4.2 4.2 45.b 135 290 1,076 1,501 13,760 1.0 2.1 7.8 10.9 38.a 5,519 1,110 7,708 14,338 36,560 15.1 3.0 21.1 39.2 22 9,196 313 191 9,700 10,306 89.2 3.0 1.9 94.1 63.c 70 7142331.4 1.0 28.6 61.0 13 6,140 998 1,404 8,541 10,625 57.8 9.4 13.2 80.4 38.b 12 41 384 437 6,441 0.2 0.6 6.0 6.8 52 319 359 3,768 4,447 18,527 1.7 1.9 20.3 24.0 63.a 599 382 9,758 10,739 33,903 1.8 1.1 28.8 31.7 34 1 0 0 1 262 0.5 0.0 0.0 0.5 58.b 00 0 020.0 0.0 20.0 20.0 62 101 38 3,023 3,162 5,541 1.8 0.7 54.6 57.1 63.b 92 3 14 108 203 45.1 1.5 6.7 53.3 3.d 52 16 3 71 79 65.9 20.6 3.4 89.9 12 18,806 3,161 2,136 24,103 30,298 62.1 10.4 7.0 79.6 25.a 6,235 612 4,502 11,349 28,461 21.9 2.1 15.8 39.9 25.b 75 0 465 540 1,432 5.2 0.0 32.4 37.7 27 4,483 0 4,442 8,925 29,633 15.1 0.0 15.0 30.1 10 6,985 886 902 8,773 12,029 58.1 7.4 7.5 72.9 58.a 00 3 3570.0 0.0 5.8 5.8 30.c 10 0 3 12 18 53.1 0.0 16.0 69.1 3.f 170 46 189 405 446 38.1 10.3 42.4 90.8 30.a 00 4 4190.0 0.0 21.8 21.8 3.a 329 213 77 619 746 44.1 28.5 10.3 83.0 20.a 14,549 746 11,558 26,853 72,324 20.1 1.0 16.0 37.1 3.g 60 4 127 191 234 25.6 1.8 54.6 82.0 64 6,527 270 12,267 19,063 25,898 25.2 1.0 47.4 73.6 5 1,381 33 1,311 2,725 4,288 32.2 0.8 30.6 63.5 3.e 1,046 459 305 1,811 2,456 42.6 18.7 12.4 73.7 35 363 26 119 508 1,802 20.1 1.5 6.6 28.2 1.b 18 0 0 18 18 100.0 0.0 0.0 100.0 66 401 194 713 1,308 1,493 26.8 13.0 47.8 87.6 8 3,983 359 428 4,771 5,663 70.3 6.3 7.6 84.2 43.b 0 0 62 62 642 0.0 0.0 9.6 9.6 7 3,249 120 1,036 4,406 5,651 57.5 2.1 18.3 78.0 26 12,376 1,062 11,858 25,296 69,649 17.8 1.5 17.0 36.3 56 519 138 2,771 3,428 11,893 4.4 1.2 23.3 28.8 2 13,563 4,077 4,995 22,635 31,731 42.7 12.8 15.7 71.3 40 3,712 1,644 1,493 6,849 11,125 33.4 14.8 13.4 61.6 3.h 347 29 294 670 910 38.1 3.2 32.3 73.6 36.a 157 73 828 1,058 5,986 2.6 1.2 13.8 17.7 28 4,231 0 8,806 13,037 63,909 6.6 0.0 13.8 20.4 60 5,105 295 49 5,449 5,459 93.5 5.4 0.9 99.8 45.a 1,978 1,084 1,703 4,766 7,721 25.6 14.0 22.1 61.7 41 14,795 1,783 9,681 26,259 45,353 32.6 3.9 21.3 57.9 46 486 224 615 1,325 9,526 5.1 2.3 6.5 13.9

Rio Grande National Forest, underrepresented Ecological Systems ("Ecosystems") at the Federal Scale

Chapter 70 Wilderness Inventory Unit Acreage Percent coverage (%) Total roadless < 5% (Acres) 5 ‐ 9.9% (Acres) 10 ‐ 19.9% (Acres) < 20% (Acres) acreage < 5% 5 ‐ 9.9% 10 ‐ 19.9% < 20% 9 786 2,388 5,317 1,723 10,214 7.7 23.4 52.1 16.9 11 0 57 2,975 3,328 6,360 0.0 0.9 46.8 52.3 3.i 0 129 1,589 393 2,111 0.0 6.1 75.3 18.6 20.b 3,192 1,916 16,586 13,408 35,101 9.1 5.5 47.3 38.2 53 0 71 1 3,702 3,773 0.0 1.9 0.0 98.1 36.b 00 2 020.0 0.0 100.0 0.0 61 7 209 989 335 1,540 0.4 13.6 64.3 21.7 3.b 350 112 808 502 1,772 19.7 6.3 45.6 28.3 37.b 1 263 1,887 5,444 7,594 0.0 3.5 24.8 71.7 39 677 2,226 4,855 3,879 11,637 5.8 19.1 41.7 33.3 43.a 0 22 483 5,786 6,292 0.0 0.3 7.7 92.0 49 0 216 506 6,865 7,587 0.0 2.8 6.7 90.5 50 1,492 1,513 10,335 2,339 15,678 9.5 9.6 65.9 14.9 6 95 1,426 18,068 13,423 33,012 0.3 4.3 54.7 40.7 59 684 1,295 12,779 21,883 36,641 1.9 3.5 34.9 59.7 3.c 14 4 164 61 244 5.9 1.8 67.3 24.9 1.a 644 501 641 2,239 4,025 16.0 12.4 15.9 55.6 32 0 0 42 75 118 0.0 0.0 36.0 64.0 58.c 00 2 580.0 0.0 31.4 68.6 4 469 1,423 9,332 4,375 15,599 3.0 9.1 59.8 28.0 23 2,487 224 2,075 307 5,094 48.8 4.4 40.7 6.0 55 0 107 462 7,099 7,668 0.0 1.4 6.0 92.6 29 0 25 319 5,990 6,334 0.0 0.4 5.0 94.6 65 2 30 548 2,193 2,774 0.1 1.1 19.7 79.1 37.a 0 68 455 3,144 3,667 0.0 1.8 12.4 85.7 15 32 1,211 9,805 4,708 15,756 0.2 7.7 62.2 29.9 21 0 0 44 312 355 0.0 0.0 12.3 87.7 18 5 684 3,743 1,683 6,115 0.1 11.2 61.2 27.5 31 0 0 98 39 137 0.0 0.0 71.5 28.5 54 00 312140.0 0.0 18.5 81.5 57 0 800 149 4,419 5,368 0.0 14.9 2.8 82.3 33 20 392 336 209 955 2.0 41.0 35.1 21.8 51 3,628 4,143 40,718 29,101 77,590 4.7 5.3 52.5 37.5 44 141 1,272 6,146 4,338 11,896 1.2 10.7 51.7 36.5 42 0 0 0 441 441 0.0 0.0 0.0 100.0 24 0 0 3 113 116 0.0 0.0 2.5 97.5 30.b 00 0 550.0 0.0 0.0 100.0 45.b 0 326 1,110 12,323 13,760 0.0 2.4 8.1 89.6 38.a 13 891 11,886 23,769 36,560 0.0 2.4 32.5 65.0 22 4,779 704 4,126 697 10,306 46.4 6.8 40.0 6.8 63.c 0 9 14 0 23 0.0 39.0 61.0 0.0 13 1,171 1,726 5,849 1,880 10,625 11.0 16.2 55.0 17.7 38.b 0 77 326 6,039 6,441 0.0 1.2 5.1 93.8 52 3 187 3,978 14,359 18,527 0.0 1.0 21.5 77.5 63.a 52 1,416 8,768 23,668 33,903 0.2 4.2 25.9 69.8 34 0 21 1 239 262 0.0 8.1 0.5 91.4 58.b 00 0 220.0 20.0 0.0 80.0 62 0 46 2,913 2,582 5,541 0.0 0.8 52.6 46.6 63.b 17 70 83 32 203 8.4 34.7 41.0 15.9 3.d 46 4 21 8 79 58.0 5.1 26.5 10.4 12 157 5,395 17,287 7,458 30,298 0.5 17.8 57.1 24.6 25.a 57 511 8,899 18,994 28,461 0.2 1.8 31.3 66.7 25.b 0 4 96 1,333 1,432 0.0 0.2 6.7 93.0 27 0 526 6,832 22,276 29,633 0.0 1.8 23.1 75.2 10 16 1,272 7,316 3,424 12,029 0.1 10.6 60.8 28.5 58.a 00 354570.0 0.0 5.8 94.2 30.c 0 0 12 6 18 0.0 0.0 69.1 30.9 3.f 34 85 308 19 446 7.6 19.2 69.1 4.2 30.a 00 416190.0 0.0 19.5 80.5 3.a 207 42 353 144 746 27.8 5.6 47.3 19.3 20.a 2,886 931 19,586 48,921 72,324 4.0 1.3 27.1 67.6 3.g 0 33 171 29 234 0.0 14.1 73.3 12.6 64 234 556 12,102 13,005 25,898 0.9 2.1 46.7 50.2 5 29 280 2,399 1,579 4,288 0.7 6.5 55.9 36.8 3.e 359 46 1,363 689 2,456 14.6 1.9 55.5 28.0 35 8 138 490 1,166 1,802 0.4 7.7 27.2 64.7 1.b 612 0 01835.0 65.0 0.0 0.0 66 4 67 1,126 296 1,493 0.3 4.5 75.4 19.9 8 347 1,167 3,077 1,073 5,663 6.1 20.6 54.3 19.0 43.b 0 29 0 613 642 0.0 4.6 0.0 95.4 7 163 527 3,651 1,309 5,651 2.9 9.3 64.6 23.2 26 39 1,102 19,952 48,555 69,649 0.1 1.6 28.6 69.7 56 4 366 2,965 8,558 11,893 0.0 3.1 24.9 72.0 2 6,146 3,449 12,387 9,746 31,731 19.4 10.9 39.0 30.7 40 547 1,490 4,523 4,566 11,125 4.9 13.4 40.7 41.0 3.h 3 226 492 189 910 0.3 24.8 54.1 20.8 36.a 0 43 925 5,018 5,986 0.0 0.7 15.5 83.8 28 7 583 11,116 52,202 63,909 0.0 0.9 17.4 81.7 60 1,195 3,257 1,006 0 5,459 21.9 59.7 18.4 0.0 45.a 47 737 4,404 2,533 7,721 0.6 9.5 57.0 32.8 41 1,536 3,146 21,558 19,114 45,353 3.4 6.9 47.5 42.1 46 5 168 1,063 8,290 9,526 0.1 1.8 11.2 87.0 Table 2 ‐ Ecosystem Composition of Wilderness Inventory Areas Values are the estimated acres of each ecosystem occuring within each USFS Chapter 70 wilderness inventory area Chapter 70 wilderness inventory Areas

Ecosystem 9 11 3.i 20.b 53 36.b 61 3.b 37.b 39

Inter‐Mountain Basins Aspen‐Mixed Conifer Forest and Woodland 72 28 50 154 0 0 180 25 188 6 Rocky Mountain Aspen Forest and Woodland 76 966 1,126 4,062 1 0 627 133 729 605 Rocky Mountain Lodgepole Pine Forest 1,068 495 379 41 0 0 0 42 0 30 Rocky Mountain Subalpine Dry‐Mesic Spruce‐Fir Forest and Woodland 397 1,790 265 4,751 579 0 42 251 1,623 1,588 Rocky Mountain Subalpine Mesic Spruce‐Fir Forest and Woodland 1,028 557 42 4,455 175 0 41 23 2,132 1,040 Rocky Mountain Subalpine‐Montane Limber‐Bristlecone Pine Woodland 205 876 28 1,102 1 0 0 131 1 790 Southern Rocky Mountain Dry‐Mesic Montane Mixed Conifer Forest and Woodland 868 652 15 1,718 0 0 111 521 48 1,700 Southern Rocky Mountain Mesic Montane Mixed Conifer Forest and Woodland 1,003 424 24 2,116 0 1 70 20 79 1,037 Southern Rocky Mountain Ponderosa Pine Woodland 2,167 26 0 1,700 0 0 23 85 0 2,202 Colorado Plateau Pinyon‐Juniper Woodland 0 0 0 3 0 0 0 0 0 0 Southern Rocky Mountain Pinyon‐Juniper Woodland 783 0 0 2,952 0 0 0 0 1 661 Rocky Mountain Lower Montane Riparian Woodland and Shrubland 0 0 0 4 0 0 0 0 0 3 Rocky Mountain Subalpine‐Montane Riparian Woodland 191 0 0 0 0 0 0 21 0 2 Southern Rocky Mountain Montane‐Subalpine Grassland 2,111 439 45 8,648 0 1 181 70 1,031 1,482 Rocky Mountain Gambel Oak‐Mixed Montane Shrubland 3 0 0 1 0 0 6 350 0 9 Rocky Mountain Lower Montane‐Foothill Shrubland 0 0 0 11 0 0 0 0 0 3 Rocky Mountain Subalpine‐Montane Mesic Meadow 39 53 13 783 9 0 0 58 130 325 Rocky Mountain Alpine‐Montane Wet Meadow 0 28 0 1,147 1,705 0 55 36 235 11 Rocky Mountain Subalpine‐Montane Riparian Shrubland 47 24 28 800 755 0 197 4 840 70 Inter‐Mountain Basins Big Sagebrush Shrubland 0 0 0 0 0 0 0 0 0 0 Inter‐Mountain Basins Montane Sagebrush Steppe 149 2 79 2 0 0 0 0 0 6 Inter‐Mountain Basins Semi‐Desert Grassland 0 0 0 8 0 0 0 0 0 0 Inter‐Mountain Basins Semi‐Desert Shrub Steppe 0 0 0 222 0 0 0 0 0 1 Rocky Mountain Alpine Fell‐Field 0 0 0 138 74 0 0 0 64 0 Rocky Mountain Alpine Turf 0 0 10 86 304 0 0 0 57 0 Rocky Mountain Cliff, Canyon and Massive Bedrock 8 0 0 122 0 0 0 0 222 54 Rocky Mountain Alpine Bedrock and Scree 0 0 5 23 100 0 0 0 139 0 Undifferentiated Barren Land 0 0 0 0 0 0 0 0 0 0 Cultivated Cropland 00 000 0 0 0 00 Introduced Upland Vegetation ‐ Annual Grassland 0 0 0 0 0 0 0 0 0 0 Introduced Upland Vegetation ‐ Perennial Grassland and Forbland 0 0 0 0 0 0 1 0 0 0 Recently Logged Areas 0 0 0 50 71 0 0 2 73 6 Open Water (Fresh) 00 040 0 6 0 26 Quarries, Mines, Gravel Pits and Oil Wells 0 0 0 0 0 0 0 0 0 0 Developed, High Intensity 0 0 0 0 0 0 0 0 0 0 43.a 49 50 6 59 3.c 1.a 32 58.c 4 23 55 29 65 37.a 15 21 18

2 6 280 67 481 2 32 0 0 257 0 0 0 8 62 238 0 42 223 504 4,234 6,007 9,234 137 59 3 2 3,458 0 409 197 474 252 2,629 16 1,082 22 2 3 9,623 2 0 107 0 0 3,671 0 0 0 0 4 17 1 39 2,767 2,052 559 4,603 10,539 11 328 3 4 837 0 2,558 1,218 466 1,331 1,877 218 765 2,628 1,229 1,633 3,185 6,727 0 134 2 1 1,541 0 3,109 1,507 566 1,352 2,001 42 413 0 4 51 686 206 0 190 0 0 503 0 8 0 0 5 532 0 398 98 0 1,283 439 1,515 16 179 0 0 184 0 1 0 2 36 1,942 0 601 57 0 2,154 491 986 8 20 0 0 400 0 0 0 0 52 1,418 0 657 0 0 1,209 858 662 2 463 0 0 911 0 0 0 0 0 934 0 629 0 0 0 0 000 0 0 0 360 0 0 0 0 0 0 0 0 1,466 81 671 0 596 0 0 466 655 0 0 0 0 29 0 5 0 0 0 0 900 0 0 0 0 0 0 0 0 0 0 0 0 0 0 8 003 0 0 3 0 0 0 0 0 0 0 0 83 0 2,661 1,501 1,042 3 274 39 0 1,615 2,075 52 122 71 112 3,799 27 1,364 0021101400000 0 000300 0 0 200 000 0 0 1 710 0 0 0 0 0 0 7 91 34 869 1,329 26 10 38 0 189 0 171 95 612 30 131 35 45 76 1,153 5 163 1,626 23 36 0 0 99 0 614 81 202 40 30 10 31 123 1,476 54 1,191 1,193 1 78 32 0 520 0 491 864 348 174 130 7 23 0 0 0 0 0 0 48 0 0 0 0 0 0 0 0 0 0 0 0 0 0 461 0 0 0 0 0 191 0 0 0 0 0 24 0 4 0 0 0 0 0 0 0 0 0 0 224 0 0 0 0 0 0 0 0 0 3 0 1 0 0 0 0 0 1,722 0 0 0 0 0 0 0 26 177 0 59 4 0 9 0 0 9 0 5 151 0 3 0 0 0 17 290 0 1,260 14 0 119 0 0 328 0 0 1,534 0 12 0 0 0 39 161 3 90 226 0 139 0 0 139 307 114 19 0 180 7 0 9 104 231 0 1,317 21 0 1,196 0 0 211 0 29 520 0 17 0 0 0 0 0 0 0 000 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3 000 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 000 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 200 0 0 0 0 0 0 2 0 0 0 0 14 210 23 40 76 0 0 0 0 64 0 102 18 22 4 15 0 9 6 0 0 0 76 0 5 0 0 0 0 4 6 0 2 0 0 0 0 0 0 0 200 0 0 0 2 0 0 0 0 0 0 0 0 0 0 0 000 0 0 2 1 0 0 0 0 0 0 0 31 54 57 33 51 44 42 24 30.b 45.b 38.a 22 63.c 13 38.b 52 63.a 34

0 0 0 1 857 466 0 0 0 50 570 26 9 313 43 7 792 21 23 3 77 160 18,632 2,448 0 0 0 698 5,553 29 7 1,277 275 3,324 7,968 0 0 000 9 28000118600241 2 0 0 10 2 1,416 6 7,728 2,355 339 75 0 4,483 9,277 85 0 802 2,833 4,496 9,393 48 1 2 1,598 15 12,097 1,573 75 16 0 2,600 10,938 333 0 883 1,181 3,466 5,095 164 0 0 1 0 667 68 0 0 0 18 1,706 159 0 101 12 72 4 0 0 0 5 0 5,523 1,829 0 0 0 290 1,110 313 0 998 41 359 382 0 0 0 0 0 5,655 1,192 0 0 0 60 1,616 1,004 7 1,637 0 103 232 0 0 0 0 0 3,067 792 0 0 0 12 274 641 0 1,337 3 23 129 0 0 000 7 000000600 0 0 1 0 0 0 0 0 3,333 139 0000104,521 0 1,146 0 2 21 0 0 000 12000000000 0 0 0 0 0 000 6 000000001 0 0 0 0 75 0 67 175 10,892 650 0 3 0 62 3,421 2,780 0 1,911 9 189 186 1 0 000 17000000000 0 0 0 0 0 000 2 0000006400 0 0 0 0 0 0 93 0 232 54 10 15 0 124 425 4 0 10 77 218 1,366 0 0 6 273 34 3,364 20 3 2 0 2,082 450 0 0 2 234 3,232 4,591 0 4 2 604 92 2,274 80 8 1 5 1,641 798 52 0 75 508 1,325 1,851 26 0 000 0 000000000 0 0 0 0 0 003 9 000001110580 0 0 0 0 000 0 000000000 0 0 0 0 0 000 2550000011780250 0 0 0 0 0660 587000022648000 2121141920 0 0800 974400036318000 286113740 23 0 127 61 278 155 0 1 0 176 104 64 0 7 214 746 377 2 0 01620 899285306096000 4835767240 0 000 0 000000000 0 0 0 0 0 000 0 100000000 0 0 0 0 0 000 0 000000000 0 0 0 0 0 00160 000000000 0 0 300 0 0 84 0 170 11 0 0 0 236 25 0 0 15 20 154 420 0 0 071638841300029113502 103 750 0 000 2 0000021000 0 1 0 0 0 003 0 000000000 0 0 0 0 58.b 62 63.b 3.d 12 25.a 25.b 27 10 58.a 30.c 3.f 30.a 3.a 20.a 3.g 64 5

0 19 62 0 29 42 0 0 25 0 0 26 0 19 177 13 213 53 0 2,773 14 2 812 2,488 21 2,359 680 3 3 185 4 40 7,647 127 5,690 1,142 0 2 0 0 226 32 0 0 3,915 0 0 65 0 75 85 27 5 896 0 1,245 0 0 2,838 4,162 445 6,581 2,838 42 3 0 0 86 14,343 17 2,374 213 1 563 0 0 2,942 3,022 141 3,525 188 8010613,176 4 1,296 894 0 0 0 0 1,066 742 2 0 126 0000311,257 0 23 27 0 38 3 16 3,161 612 0 0 886 0 0 46 0 213 746 4 270 33 0 35 37 0 2,237 513 0 0 272 009091,141 0 549 218 0 0 8 4 5,148 374 0 0 1,056 00102145901472 0 0 0 0 0000 0 000000000 0 0 0 0130540014000002,787 0 14 0 0 0 8 0 0000 0 00000200210 0 0 0 1 0000 0 00001100961 0 64 29 1 10,851 5,254 75 4,473 1,564 0 10 3 0 6 9,967 12 5,494 108 0 0 9 46 25 1 0 0 3 0 0 30 0 207 18 0 189 25 0 0 0 0 0000 0 000008001 0 244 0 0 228 1,212 439 1,769 66 004052,377 0 6,373 43 0 277 0 8 75 2,072 81 256 34 4070165,180 3 1,338 162 0 251 32 0 157 2,518 63 3,549 81 0 0 6 15 0 6,856 6 1,470 135 0 0 0 0 0000 0 000000000 0 0 0 0 187 6 0 10 162 0 0 58 0 0 15 20 4 126 0 0 0 0 0000 0 000000000 0 0 0 0 3200 0 0000020000 0 0 0 0 0 1,003 0 106 0 000001,308 0 0 4 0 0 0 0 0 1,976 10 5,341 26 000002,495 0 0 90 0 2 0 0137705136740120200077001213 0 0 0 0 14 1,582 17 409 53 000001,159 0 11 8 0 0 0 0 0000 0 000000000 0 0 0 0 0000 0 0040027023 0 0 0 0 0000 0 000000000 0 0 0 0 0000 0 000000080 0 5 0 0 306043142900001277018199 0 220 0 22902020 0000020120 0 0 0 0 0000 0 000005000 0 0 0 0 0000 0 000000000 3.e 35 1.b 66 8 43.b 7 26 56 2 40 3.h 36.a 28 60 45.a 41 46

9 32 0 21 71 0 64 245 113 906 13 52 27 121 9 434 711 132 253 118 0 581 173 0 904 7,072 2,338 3,394 1,182 292 705 6,908 49 1,652 8,868 361 254 0 0 0 1,147 0 1,855 28 3 314 73 132 6 2 3 12 673 8 398 500 0 118 278 271 425 10,625 3,038 3,384 3,173 117 1,986 10,212 0 898 8,141 4,899 118 592 0 16 502 235 634 7,703 3,040 2,438 937 44 2,270 8,002 0 1,475 8,976 2,638 27 0 0 16 247 0 126 717 21 1,213 285 0 46 0 0 0 121 3 459 26 0 194 359 0 120 1,062 138 4,077 1,644 29 73 0 295 1,084 1,783 224 59 30 0 63 327 0 208 1,026 292 1,471 653 22 83 5 295 1,276 4,453 424 27 10 12 36 910 0 419 519 26 2,474 1,469 0 10 3 3,243 263 2,349 3 000000000000000000 006434301632305,772 544 0 0 0 1,163 38 1,499 2 0000000002000000110 1000026010044140000030 327 316 0 288 1,045 0 563 10,764 194 3,087 957 17 57 4,200 363 380 5,777 46 3582000000439030350140 100000000930000000 25 1 0 117 8 39 2 3,814 271 375 19 1 76 1,529 0 47 663 223 25 0 0 15 1 14 3 3,479 840 217 15 0 79 643 0 16 219 117 30 72 0 3 33 56 113 6,370 683 318 62 26 306 6,674 0 86 869 214 0000000002200000000 1000101850401403301730140030 0000000001600004000 000000000298000028000 120000001,103 113 407 0 0 23 1,938 0045 1900000010,051 99 302 0 0 31 16,320 0030 6 2 0 11 4 0 7 1,625 306 83 74 0 12 811 0 11 106 174 280000003,068 147 1,009 0 0 189 6,072 0 0 12 18 000000000000000000 0600000004000001110 000000000300000000 000000010000040803 0000023425614113700369042928 096000606787810677036535 0000300150000000000 000000000000000000 Table 3 ‐ Rio Grande National Forest Ecosystems Representation Rio Grande NF Rio Grande NF Non‐ All Rio Grande % Rio Grande % Coverage, Rio Ecological Group ("Ecosystem") Wilderness (Acres) Wilderness (Acres) NF (Acres) Wilderness Grande Forest Area

Representation @ < 20% Rocky Mountain Subalpine‐Montane Limber‐Bristlecone Pine Woodland 4,044 17,524 21,569 18.8 1.2 Rocky Mountain Subalpine‐Montane Mesic Meadow 7,832 36,940 44,772 17.5 2.5 Rocky Mountain Aspen Forest and Woodland 28,744 180,349 209,094 13.7 11.6 Recently Logged Areas 2,809 21,751 24,560 11.4 1.4 Southern Rocky Mountain Dry‐Mesic Montane Mixed Conifer Forest and Woodland 3,615 63,607 67,222 5.4 3.7 Rocky Mountain Lodgepole Pine Forest 1,801 43,089 44,890 4.0 2.5 Southern Rocky Mountain Mesic Montane Mixed Conifer Forest and Woodland 2,069 56,698 58,767 3.5 3.3 Southern Rocky Mountain Montane‐Subalpine Grassland 6,478 184,796 191,274 3.4 10.6 Introduced Upland Vegetation ‐ Perennial Grassland and Forbland 2 126 128 1.6 0.0 Rocky Mountain Gambel Oak‐Mixed Montane Shrubland 22 1,812 1,833 1.2 0.1 Inter‐Mountain Basins Montane Sagebrush Steppe 39 3,590 3,629 1.1 0.2 Southern Rocky Mountain Ponderosa Pine Woodland 634 63,099 63,733 1.0 3.5 Rocky Mountain Lower Montane‐Foothill Shrubland 3 567 571 0.6 0.0 Southern Rocky Mountain Pinyon‐Juniper Woodland 244 46,843 47,087 0.5 2.6 Rocky Mountain Subalpine‐Montane Riparian Woodland 2 516 518 0.4 0.0 Colorado Plateau Pinyon‐Juniper Woodland 0 180 180 0.0 0.0 Rocky Mountain Lower Montane Riparian Woodland and Shrubland 0 412 412 0.0 0.0 Inter‐Mountain Basins Semi‐Desert Grassland 0 1,265 1,265 0.0 0.1 Inter‐Mountain Basins Semi‐Desert Shrub Steppe 0 6,470 6,470 0.0 0.4 Inter‐Mountain Basins Active and Stabilized Dune 0 1 1 0.0 0.0 Total 58,339 729,636 787,975 7.4 43.7

Representation @ < 10% Southern Rocky Mountain Dry‐Mesic Montane Mixed Conifer Forest and Woodland 3,615 63,607 67,222 5.4 3.7 Rocky Mountain Lodgepole Pine Forest 1,801 43,089 44,890 4.0 2.5 Southern Rocky Mountain Mesic Montane Mixed Conifer Forest and Woodland 2,069 56,698 58,767 3.5 3.3 Southern Rocky Mountain Montane‐Subalpine Grassland 6,478 184,796 191,274 3.4 10.6 Introduced Upland Vegetation ‐ Perennial Grassland and Forbland 2 126 128 1.6 0.0 Rocky Mountain Gambel Oak‐Mixed Montane Shrubland 22 1,812 1,833 1.2 0.1 Inter‐Mountain Basins Montane Sagebrush Steppe 39 3,590 3,629 1.1 0.2 Southern Rocky Mountain Ponderosa Pine Woodland 634 63,099 63,733 1.0 3.5 Rocky Mountain Lower Montane‐Foothill Shrubland 3 567 571 0.6 0.0 Southern Rocky Mountain Pinyon‐Juniper Woodland 244 46,843 47,087 0.5 2.6 Rocky Mountain Subalpine‐Montane Riparian Woodland 2 516 518 0.4 0.0 Colorado Plateau Pinyon‐Juniper Woodland 0 180 180 0.0 0.0 Rocky Mountain Lower Montane Riparian Woodland and Shrubland 0 412 412 0.0 0.0 Inter‐Mountain Basins Semi‐Desert Grassland 0 1,265 1,265 0.0 0.1 Inter‐Mountain Basins Semi‐Desert Shrub Steppe 0 6,470 6,470 0.0 0.4 Inter‐Mountain Basins Active and Stabilized Dune 0 1 1 0.0 0.0 Total 14,910 473,072 487,981 3.1 27.1

Representation @ < 5% Rocky Mountain Lodgepole Pine Forest 1,801 43,089 44,890 4.0 2.5 Southern Rocky Mountain Mesic Montane Mixed Conifer Forest and Woodland 2,069 56,698 58,767 3.5 3.3 Southern Rocky Mountain Montane‐Subalpine Grassland 6,478 184,796 191,274 3.4 10.6 Introduced Upland Vegetation ‐ Perennial Grassland and Forbland 2 126 128 1.6 0.0 Rocky Mountain Gambel Oak‐Mixed Montane Shrubland 22 1,812 1,833 1.2 0.1 Inter‐Mountain Basins Montane Sagebrush Steppe 39 3,590 3,629 1.1 0.2 Southern Rocky Mountain Ponderosa Pine Woodland 634 63,099 63,733 1.0 3.5 Rocky Mountain Lower Montane‐Foothill Shrubland 3 567 571 0.6 0.0 Southern Rocky Mountain Pinyon‐Juniper Woodland 244 46,843 47,087 0.5 2.6 Rocky Mountain Subalpine‐Montane Riparian Woodland 2 516 518 0.4 0.0 Colorado Plateau Pinyon‐Juniper Woodland 0 180 180 0.0 0.0 Rocky Mountain Lower Montane Riparian Woodland and Shrubland 0 412 412 0.0 0.0 Inter‐Mountain Basins Semi‐Desert Grassland 0 1,265 1,265 0.0 0.1 Inter‐Mountain Basins Semi‐Desert Shrub Steppe 0 6,470 6,470 0.0 0.4 Inter‐Mountain Basins Active and Stabilized Dune 0 1 1 0.0 0.0 Total 11,295 409,465 420,759 2.7 23.3 Table 4 ‐ Chapter 70 Wilderness Inventory Unit Analysis of Ecosystem Composition

Values are the estimated acres of each ecosystem occuring within each USFS Chapter 70 orange = if added, creates wilderness inventory area 20% representation Chapter 70 Roadless Areas Forest Acres needed for Number of Wilderness Ecosystem Ecosystem adequate Inventory Areas to Reach 3.g 53 30.c 3.a Representatio protection in Adequate Protection Introduced Upland Vegetation ‐ Perennial Grassland and Forbland < 5% 24 1 0 2 1 181 Colorado Plateau Pinyon‐Juniper Woodland < 5% 36 1 00 0 14 Rocky Mountain Lower Montane Riparian Woodland and Shrubland < 5% 82 1 10 21 11 96 Rocky Mountain Subalpine‐Montane Riparian Woodland < 5% 102 1 327 70 6 5,494 Rocky Mountain Lower Montane‐Foothill Shrubland < 5% 111 1 25 58 5 6,373 Inter‐Mountain Basins Semi‐Desert Grassland < 5% 253 1 00 0 0 Rocky Mountain Gambel Oak‐Mixed Montane Shrubland < 5% 345 NA 10 0 0 Inter‐Mountain Basins Montane Sagebrush Steppe < 5% 687 NA 00 0 0 Inter‐Mountain Basins Semi‐Desert Shrub Steppe < 5% 1,294 1 12 0 0 0 Rocky Mountain Lodgepole Pine Forest < 5% 7,177 1 398 251 86 2,374 Southern Rocky Mountain Pinyon‐Juniper Woodland < 5% 9,173 NA 00 0 21 Southern Rocky Mountain Mesic Montane Mixed Conifer Forest and Woodland < 5% 9,685 3 27 85 21 147 Southern Rocky Mountain Ponderosa Pine Woodland < 5% 12,112 NA 00 0 0 Southern Rocky Mountain Montane‐Subalpine Grassland < 5% 31,777 NA 358 350 207 189 Southern Rocky Mountain Dry‐Mesic Montane Mixed Conifer Forest and Woodland 5 ‐ 10% 9,829 2 59 20 9 549 Rocky Mountain Subalpine‐Montane Limber‐Bristlecone Pine Woodland 10 ‐ 20% 269 1 459 521 213 270 Rocky Mountain Subalpine‐Montane Mesic Meadow 10 ‐ 20% 1,122 1 25 36 16 1,338 Recently Logged Areas 10 ‐ 20% 2,103 26 00 0 12 Rocky Mountain Aspen Forest and Woodland 10 ‐ 20% 13,075 2 254 42 75 5 Inter‐Mountain Basins Aspen‐Mixed Conifer Forest and Woodland > 20% NA NA 253 133 40 5,690 Inter‐Mountain Basins Big Sagebrush Shrubland > 20% NA NA 10 0 0 4 Open Water (Fresh) > 20% NA NA 00 0 0 Rocky Mountain Alpine Bedrock and Scree > 20% NA NA 00 0 0 Rocky Mountain Alpine Fell‐Field > 20% NA NA 19 0 0 0 Rocky Mountain Alpine Turf > 20% NA NA 6 0 0 121 Rocky Mountain Alpine‐Montane Wet Meadow > 20% NA NA 30 4 0 1,470 Rocky Mountain Cliff, Canyon and Massive Bedrock > 20% NA NA 28 0 0 11 Rocky Mountain Subalpine Dry‐Mesic Spruce‐Fir Forest and Woodland > 20% NA NA 118 23 6 1,296 Rocky Mountain Subalpine Mesic Spruce‐Fir Forest and Woodland > 20% NA NA 27 131 31 23 Rocky Mountain Subalpine‐Montane Riparian Shrubland > 20% NA NA 00 0 0 58.b 7 10 20.a 62 3.f 54 50 28 43.a 61 34 20.b 3.h 43.b 40

0 13 0 99 30 277 170 0 29 40 6 0 0 0 141 369 0 5,772 0 0 130 2,787 3,333 0 1,499 81 661 0 0 1,163 0 0 14401006038200000 1 3,087 3 108 10,851 9,967 10,892 3 5,777 1,501 1,482 29 181 363 194 4,200 0 375 4 43 228 2,377 232 26 663 869 325 0 0 0 271 1,529 0 298 0 0 3 20 255 0 0 0 1 0 0 28 0 0 0 90 108 200030000 0 01600000000000400 0 407 0 4 0 1,308 587 0 4 59 0 0 0 0 113 1,938 0 3,384 0 213 2,838 14,343 7,728 11 8,141 4,603 1,588 0 42 0 3,038 10,212 0 20 0020 12011038000 0 4 2,474 1 2 5,148 459 3,067 2 2,349 858 2,202 8 23 3,243 26 3 0 00 000 700000000 0 46 39 30 25 25 18 17 14 14 11 9 9 6 5 4 3 0 1,471 9 218 2,237 1,141 5,655 8 4,453 491 1,037 37 70 295 292 5 16 4,077 46 33 3,161 746 5,523 16 1,783 439 1,700 3 111 295 138 0 8 217 7 162 75 5,180 3,364 23 219 163 11 0 55 0 840 643 0 8 0 0 2 2 41 0 53 0 6 0 6 0 87 77 0 314 65 896 226 85 9 0 673 9,623 30 0 0 3 3 2 2 3,394 185 1,142 812 7,647 18,632 137 8,868 6,007 605 14 627 49 2,338 6,908 0 33 58 126 187 15 9 0 3 461 6 0 0 0 0 14 0 00 005 200000000 0 0 00 000 000000000 0 0 302 0 90 0 2,495 974 0 3 1,260 0 0 0 0 99 16,320 0 83 0 3 137 770 278 0 106 90 54 0 0 0 306 811 0 318 6 135 157 6,856 2,274 1 869 1,191 70 32 197 0 683 6,674 0 1,009 0 8 14 1,159 899 0 12 1,317 0 0 0 0 147 6,072 0 2,438 1 894 2,942 13,176 12,097 0 8,976 3,185 1,040 0 41 0 3,040 8,002 0 1,213 0 27 1,066 1,257 667 0 121 686 790 0 0 0 21 0 02200000000000000 56 29 25.a 39 64 63.b 9 6 1.a 66 35 24 26 37.a 8 57 30.a 38.a 3.b

0 15 29 23 0 60 50 0 64 4 0 25 7 9 256 11 0 15 14 0 29 14 1,466 0 54 2,952 596 466 163 343 10 544 5 23 139 0 1,146 0 0 0 0 0 0 0 033 1 26014000010 17 3,799 1,564 2,661 316 5,254 8,648 274 1,615 563 1,045 3,421 957 1,364 10,764 650 12 1,911 83 1 131 66 34 1 1,212 783 10 189 2 8 425 19 45 3,814 54 0 10 7 0 0 0 3 0 2 22200 0 0100000250 0 0 0 200 0 1101 0 003000000 0 0 0 0 0 0 800 0 000000000 0 0 0 0 0 1,003 138 9 9 0 0 48 0 0 1,103 0 0 0 26 117 1,877 2,838 559 500 4,162 4,751 328 837 425 278 9,277 3,173 765 10,625 2,355 17 802 2,767 0 0 0 0 0 0 400 0 000000000 0 934 1,056 1,209 10 374 1,700 463 911 419 910 274 1,469 629 519 792 0 1,337 0 0 0 0 0 0 0 300 0 000000000 3 3 3 2 2 1 100 0 000000000 22 1,418 272 2,154 30 513 2,116 20 400 208 327 1,616 653 657 1,026 1,192 0 1,637 57 29 1,942 886 1,283 26 612 1,718 179 184 120 359 1,110 1,644 601 1,062 1,829 4 998 98 0 30 34 5 0 2,072 1,147 36 99 3 1 450 15 31 3,479 20 3 2 76 0 0 0 0 96 29 4 5 0 0 0 11 1 0 67 3 0 2 6 132 17 3,915 3 0 32 41 107 3,671 1,855 1,147 186 73 39 28 28 27 24 22 292 2,629 680 4,234 118 2,488 4,062 59 3,458 904 173 5,553 1,182 1,082 7,072 2,448 127 1,277 223 173 24 162 0 0 6 2 0 191 40 185 11 0 4 14 0 20 58 0 0 0 0 0 0 0 000 0 3200150000 0 0 0 0 0 0 000 0 000000000 0 0 26 0 0 1,976 86 119 328 0 0 18 0 0 10,051 4 0 0 17 0 7 12 3 2 705 122 139 139 7 4 104 74 9 1,625 155 0 7 39 26 130 81 54 72 2,518 800 78 520 113 33 798 62 23 6,370 80 6 75 123 0 0 53 0 0 1,582 23 1,196 211 0 0 6 0 0 3,068 28 0 0 104 44 2,001 188 1,633 592 3,022 4,455 134 1,541 634 502 10,938 937 413 7,703 1,573 4 883 2,628 0 532 126 51 0 742 1,102 190 503 126 247 1,706 285 398 717 68 0 101 0 0 0 0 0 0 0 0480 0 000000000 36.a 60 2 55 63.c 49 63.a 37.b 42 65 22 32

4 28 0 4 154 76 5 210 236 0 20 0 38 2 0 0 2 671 0 0 0 0 0 655 0000 0 0 00 0 000 380 46 57 112 189 1,042 64 0 62 27 9 2,075 47 223 76 30 218 1,329 244 91 124 35 77 0 0 0 0 0 0 1 0 0 0 0 0 1,722 0000 0 0 00 0 0071 0 0 0 0 0 0 0 0 0 0 0 224 0 5 23 3 114 4 0 177 226 0 212 0 898 4,899 1,986 1,331 4,496 10,539 1,245 2,052 4,483 218 2,833 0 0000 0 9 00 0 000 263 3 10 0 23 662 0 0 12 0 3 0 0000 0 0 00 0 0036 0000 0 0 00 0 000 1,276 424 83 52 103 986 35 0 60 0 0 0 1,084 224 73 36 359 1,515 38 0 290 0 41 0 16 117 79 40 3,232 1,626 277 1,153 2,082 10 234 0 36 5 6 2 3 76 22 0 29 0 10 0 12 8 6 4 2 2 2 2 1 1 1 0 1,652 361 705 252 3,324 9,234 2,773 504 698 16 275 0 0000 0 0 00 0 000 0000 1 2 00 0 002 0000 0 0 00 0 000 0 0 31 12 113 14 0 290 363 0 286 0 11 174 12 180 746 226 2 161 176 0 214 307 86 214 306 174 1,325 1,193 251 1,476 1,641 7 508 0 0 18 189 17 576 21 0 231 609 0 483 0 1,475 2,638 2,270 1,352 3,466 6,727 563 1,229 2,600 42 1,181 0 0 3 46 5 72 206 0 4 18 0 12 0 0000 0 0 00 0 000 30.b 13 36.b 3.e 45.b 3.i 5 12 58.c 18 4 11 23 3.d 33 1.b 51 38.b 25.b 15 31

0 420 73 0 0 0 0 314 102 84 18 71 22 4 0 23 0 0 0 0 0 4,521 21 1 4 0 0 6 0 0000000000000 0 00000000000000000000 2,780 186 1,031 288 0 1 0 4,473 52 67 122 0 71 75 0031075175 4 1,366 130 117 0 0 0 1,769 171 93 95 9 612 439 10 39 15 0 0 0 0 17800000000000000000000 6400000000000000000000 0 00000000000000000000 019264000010656615174000000000 85 9,393 1,623 118 0 0 0 6,581 2,558 1,416 1,218 579 466 445 339 271 75 48 42 10 6 0 00000000000000000000 641129036001200000000000000 6 10000000000000000000 0 00000000000000000000 1,004 232 79 63 7 1 0 0 0000000000000 3133824819400001500200000000 0 4,591 235 15 0 0 0 256 614 273 81 1,705 202 81 3 14 2 0 4 0 34 35752000020247166000060000388 0 00000000000000000000 29 7,968 729 581 7 0 0 2,359 409 77 197 1 474 21 0000323160 1 0010000100000000000003 1000000000000000000000 0 00000000000000000000 0 74 57 0 0 0 0 5,341 0 80 1,534 304 0 10 0000000 64377222110007401141271900136001202361 52 1,851 840 3 0 0 0 3,549 491 604 864 755 348 63 8 56 1 26 0 4 92 07241390000409291625201000175030000 333 5,095 2,132 16 0 0 0 3,525 3,109 1,598 1,507 175 566 141 75 235 16 164 8 1 15 159411600008101020000000 0 00000000000000000000 3.c 59 27 21 52 58.a 44 45.a 41 46

0000000000 0000000000 0000000000 039100000000 03800000000 0000000000 0000000000 0000000000 0000000000 4332000000 0000000000 0000000000 0000000000 0000000000 0000000000 0000000000 0006000000 0000000000 0000000000 2333040000 0000000000 0000000000 0000000000 0000000000 0020000000 032020155000 0000000000 1202100000 0000000000 0000000000 MAP 1: USFS CHPT. 70 WILDERNESS INVENTORY AREAS RIO GRANDE NATIONAL FOREST

3.i 3.h 3.f 3.e 3.c 5 3.d 6 3.b 10 4 3.a 7 8 9

11 12 21 13

15 2 18 20.a 27 25.a 24 25.b 20.b 26 22 28 35 31 32 38.a 23 30.a 36.b 39 40 29 33 34 36.a 37.a 41 37.b 42 44 38.b 43.b 45.a 50 1.a 43.a 49 46 51 45.b 52 53 56 55

57 58.a 59 60 61 62

63.b

63.a Colorado 64 65 66 66 New Mexico

UT CO

¯ OK Rio Grande National Forest USFS Final Wilderness Inventory AZ NM TX 0 10 20 30 40 Miles Designated Wilderness MAP 2: ECOSYSTEM REPRESENTATION ON THE FEDERAL LEVEL, RIO GRANDE NATIONAL FOREST

Colorado New Mexico

Rio Grande National Forest USFS Final Wilderness Inventory UT CO Federal Representation in NWPS < 5% ¯ OK 5 - 10% 10 - 20% AZ NM TX 0 10 20 30 40 Miles > 20% MAP 3: ECOSYSTEM REPRESENTATION ON THE FOREST LEVEL, RIO GRANDE NATIONAL FOREST

Colorado New Mexico

Rio Grande National Forest USFS Final Wilderness Inventory UT CO Rio Grande NF, Representation in NWPS < 5% ¯ OK 5 - 10% 10 - 20% AZ NM TX 0 10 20 30 40 Miles > 20%

Appendix C

Report by New Mexico Natural Heritage Program entitled Wildlife Doorways Supporting Wildlife Habitat Connectivity Across Borders in the Upper Rio Grande Watershed Wildlife Doorways

Supporting Wildlife Habitat Connectivity Across Borders in the Upper Rio Grande Watershed

March 2016

Wildlife Doorways

Supporting Wildlife Habitat Connectivity Across Borders in the Upper Rio Grande Watershed

Esteban Muldavin and Rayo McCollough Natural Heritage New Mexico Biology Department and Museum of Southwestern Biology University of New Mexico, Albuquerque, NM

March 2016

Introduction

Wildlife habitat connectivity is widely regarded as a key to species conservation by providing for daily and seasonal movements as well as long-range dispersal and genetic interchange (Beier and Noss 1998; Rudnick et al. 2012). Yet, managing for connectivity in a multi-jurisdictional landscape presents unique challenges to public and private interests seeking to ensure long-term sustainability of wildlife populations. Species do not recognize jurisdictional boundaries as they move through landscapes, and over large multi-jurisdictional areas, the ecological, economic, social, and political issues become more complex with commensurate potential for larger impacts on species. Accordingly, solutions to these complex problems in wildlife conservation lie beyond isolated owner-by-owner planning and require a broader approach (Spies et al. 2002). To address this, most agencies are now taking more of an “all-lands” approach that includes attending to the impact of their activities on surrounding landscapes and ownerships and incorporating this into their long-term management plans. For example, the USFS need for landscape-scale wildlife habitat connectivity is encapsulated in the 2012 Planning Rule that requires plans “to maintain or restore the ecological integrity of terrestrial and aquatic ecosystems and watersheds in the plan area, including plan components to maintain or restore their structure, function, composition, and connectivity” (§ 219.8(a)) [emphasis added].

How this all-lands approach can be operationally applied to wildlife connectivity is not well defined. There are many elements that are important in maintaining connectivity

such as habitat loss prevention and excessive fragmentation, but at the larger landscape scales, removing barriers and maintaining open corridors for wildlife movement is critical to the long-term well-being of wildlife species. Traditionally, wildlife habitat management has focused on core habitat areas that are often in the central management area of say a USFS national forest or a BLM land unit, not at the periphery where there may be corridors or linkages to other core habitats in adjoining jurisdictions, particularly for wide-ranging species (e.g., elk, deer, mountain lion, etc.). As a result, the management of ecological conditions at these key boundary areas, or “wildlife doorways,” that foster connectivity to the next administrative unit can receive a lower priority. This can inadvertently put the functionality of corridors and linkages at risk.1 Accordingly, our purpose here is to explore the nature and extent of these wildlife doorways at unit boundaries in the context of overall wildlife movement areas, and to propose a framework for using them to support focused, multi-jurisdictional management at landscape scales to maintain wildlife habitat connectivity.

To do this, we use the Upper Rio Grande watershed, a region of north-central New Mexico and adjoining south-central Colorado, as an example of a large landscape where there are complex wildlife movements coupled with several federal units that are currently engaged in land and resource management planning (Figure 1). This affords the opportunity to address the structure of wildlife doorways using wildlife movement data and how the doorways and data might be integrated into the ongoing planning processes of multiple ownerships. Using a GIS, we compiled available data on wildlife patterns, provisionally identified significant “wildlife movement focal areas,” and then delineated a set of provisional wildlife doorways where the movement areas crossed jurisdictional boundaries. We also have provided supplemental information on biodiversity elements and connectivity opportunities that may be useful to land managers in planning for the maintenance of ecological integrity and connectivity in the doorways and associated wildlife movement focal areas. The outcome is a provisional set of specific management areas that can be used strategically to enhance wildlife connectivity across jurisdictions at large landscape scales. This is a working model, one designed to support discussions with resource planners and biologists across jurisdictions on the efficacy and accuracy of specific focal areas and doorways and how to make operational use of them in the planning process.

Methods

1 Haber and Nelson (2015) state per the 2012 planning rule that “in particular, segments of the national forest boundary identified in [the wildlife linkages interface] remain critical interfaces that link wildlife habitat on both sides of the boundary.” 3

We primarily took a focal-species approach per Lambeck (1997) because focal species, which historically have been mostly game species rather than endangered species, have the most readily available data for locating prospective wildlife corridors and linkages. We supplemented the species data with generalized naturalness-based models of animal movements that are not species specific (Krosby et al. 2015; Reed et al. 2012). We compiled all available spatial data on the occurrence and movement of species in the target region of northern New Mexico and southern Colorado (Table 1; see Appendix A for details on each dataset). The resulting data was quite heterogeneous and included direct species occurrences (living observations and road kill), expert-driven and analytical models of individual species movements and corridors, and the generalized habitat-based connectivity models (Figure 2).

Figure 1. Overview of the distribution of eight Wildlife Movement Focal Areas and the associated 22 Wildlife Doorways with the project area.

Figure 2. Overview of data used to delineate eight Wildlife Movement Focal Areas and the associated 22 Wildlife Doorways within the project area. See Table 1 and Appendix A for details on the datasets.

Table 1. Data sets compiled for the New Mexico-Colorado Wildlife Doorways project. a) Wildlife movement data Source Bighorn Sheep Migration Patterns and Corridors Colorado Parks and Wildlife Elk Highway Crossings and Corridors Colorado Parks and Wildlife Mule Deer Movement, Highway Crossings, and Migration Colorado Parks and Wildlife Corridors Pronghorn Migration Corridors Colorado Parks and Wildlife All Species Movement Arrows Southern Rockies Ecosystem Project All Species Top Linkages Southern Rockies Ecosystem Project Mule Deer Migration Data Sawyer 2011, 2013 (BLM, Others) CHAT Wildlife Corridor (cougar) NM Crucial Habitat Assessment Tool Chama Peak Land Alliance Elk Migration Chama Peak Land Alliance Chama Peak Land Alliance Deer Migration Chama Peak Land Alliance NM Dept. of Game & Fish Big Game Movement NM Dept. Game and Fish Colorado Potential Conservation Areas Colorado Nat. Heritage Program NM Conservation Opportunity Areas NM Dept. Game & Fish WGA Pilot Project – Corridor Analysis NM-CO Border NM Dept. Game & Fish; Reed et al. 2012 Colorado DOT Region 5 Wildlife Collision Data Colorado DOT New Mexico DOT Wildlife Collision Data NM DOT Taos Field Office Big Game Migration Corridors BLM b) Connectivity opportunity data Natural Heritage Species Data Colorado Nat. Heritage Pgm./NHNM Boreal Toad Overall Range Colorado Parks and Wildlife Crucial Habitat Assessment Tool (CHAT) Scores NM Crucial Habitat Assessment Tool CHAT Species of Concern NM Crucial Habitat Assessment Tool CHAT Terrestrial Game Species NM Crucial Habitat Assessment Tool CHAT Sport Fish (Aquatic SERI) NM Crucial Habitat Assessment Tool CHAT Wetland/Riparian Areas NM Crucial Habitat Assessment Tool CHAT Ecosystems of Concern NM Crucial Habitat Assessment Tool CHAT Large Natural Areas (large intact land blocks) NM Crucial Habitat Assessment Tool CHAT Freshwater Integrity NM Crucial Habitat Assessment Tool Protected Areas (land use limitations) Protected Areas Database-USGS Relative Wildness in the United States Wilderness Society

Given the heterogeneity, we did not attempt to normalize the data for analysis, but rather we took a preponderance-of-evidence approach to delineating broadly defined wildlife movement focal areas. That is, boundaries were drawn with heads-up digitizing around zones of high concentrations of wildlife movement and, for our purposes here, crossed at least one jurisdictional boundary. Within each focal area, one or more wildlife doorways were delineated where the data suggested wildlife corridors crossed jurisdictional boundaries. Doorways could occur within corridors or at their junctures with core habitats and had restricted areas and dimensions. They are intended to be relatively narrowly defined both in width and depth to help focus resource allocation on keeping corridors themselves open across ownerships. The widths should approximate that of the corridors and depths should be sufficient to capture both the boundary and enough area behind the doorways to be meaningful for habitat management. Here, they are rectangular in shape as a first approximation, but this is not a requirement—the depth could, with sufficient information, be delineated along natural features (e.g., watershed boundaries, landforms, or habitat types) but not so large as to lose the connection to the doorway itself.

We assigned tiers to the focal areas based on whether they were directly relevant to ongoing resource planning initiatives. Tier 1 Wildlife Movement Focal Areas had at least two agencies that were actively engaged in planning (e.g., USFS and BLM); Tier 2 involved two forests engaged in planning (e.g., Carson N.F., Rio Grande N.F., or Santa Fe N.F), and Tier 3 involved one unit engaged in planning with doorways to other land ownerships not currently undergoing resource plan revision (both public and private neighbors).

The results are presented in a series of maps with associated spatial databases that can be used in workshop settings among resource managers to evaluate their accuracy and efficacy, and to provide a vehicle for gathering additional data and modifying areas and doorways. The goal is to provide the most current, comprehensive, accurate, and pertinent information as possible on wildlife movement and habitat connectivity at landscape scales that can be integrated into multi-agency resource management planning processes.

Results and Discussion

We identified nine provisional Wildlife Movement Focal Areas (WMFAs) with 21 potential Wildlife Doorways (WDs) within the target study area (Table 2). These were distributed among the three national forests (Rio Grande [RGNF], Carson [CNF], and

Santa Fe [SFNF]) the BLM Rio Grande del Norte National Monument [RGdN], and the National Park Service Valles Caldera National Preserve [VCNP]) all of which are currently undergoing land and resource management planning processes (see Figures 1). The ownerships within focal areas also include private, Native American, and other ownerships. Jurisdictional structure varied from relatively simple configuration of national forest to national forest (e.g., CNF and SFNF in the Southern Sangre de Cristo WMFA), to multiple national forests and other agencies across regional administrative units and state lines (e.g., CNF, RGNF, BLM, and private in the Northern Taos Plateau WMFA). Within each WMFA, one to three potential wildlife doorways were delineated at jurisdictional boundaries. These are only initial approximations based on the confluence of wildlife movement patterns across a given WMFA. By design, the wildlife doorways were rectangular with the widest dimension along the jurisdictional boundary and ranged in area from approximately 10 to 145 sq. miles, with an average near 50 sq. miles. While WMFAs could be fairly large, the wildlife doorways delineated within them accounted for only 0.5% of the area. This is in keeping with the concept that wildlife doorways should be narrowly defined to provide a focus for management but sufficient in size to capture meaningful aspects of wildlife movements and habitat at landscape scales.

A detailed example of the utility of the wildlife movement focal area/wildlife doorways configuration is provided by the Northern Taos Plateau WMFA (Figure 3; Table 3a). The preponderance of evidence suggests that this is a major wildlife movement zone with high elk, mule deer, and pronghorn movements reflected by highway collision data points and expert-driven direct observations (multicolored lines and bands), along with a mountain-lion corridor model (light green zone), and a convergence of wildlife movement flow lines from a generalized naturalness model (blue lines; Reed et al. 2012). The WMFA is also jurisdictionally complex. The northern reaches of the area start at the high elevations of the RGNF’s South San Juan Wilderness in Colorado and continue down to the CNF’s Cruces Basin Wilderness in New Mexico, crossing state lines (and USFS Regions 2 and 3, respectively). The area then extends southward and eastward across a high desert plateau managed in part by both the CNF and the BLM Rio Grande del Norte National Monument, out of the BLM land east to the Sangre de Cristo Mountains of the CNF (and others).

Table 2. Wildlife Movement Focal Areas (WMFA) and Wildlife Doorways identified for the Upper Rio Grande watershed study area. CNF = Carson National Forest; SFNF=Santa Fe National Forest; SJNF=San Juan National Forest; SINF=San Isabel National Forest; BLM+ Bureau of Land Management; BLM-RGdN=BLM Rio Grande del Norte National Monument; VCNP=Valles Caldera National Preserve; BAND=Bandelier National Monument, and Other = private, Native American, and State lands.

Focal Area Area Wildlife Movement Focal Doorway Wildlife (sq. ID Area ID Doorway Jurisdictions Tier miles) 1 Northern Taos Plateau 2 Cebolla Mesa CNF, BLM-RGdN 1 60 3 Cruces Basin CNF, RGNF 1 98 1 San Antonio Mtn CNF, BLM-RGdN 1 144 2 Northern Sangre de Cristo 22 Cucharas SINF, Other 3 36 7 Purgatory SINF, Other 3 46 14 Red River CNF, Other 3 82 8 Sierra Blanca RGNF, SINF, Other 2 32 3 Southern Sangre de Cristo 15 Angel Fire CNF, Other 3 71 20 Cow Creek SFNF, Other 3 55 21 Glorieta SFNF, Other 3 31 Southern Sangre 19 Divide CNF, SFNF 2 35 4 Southern Taos Plateau 11 Chimayo SFNF, BLM,Other 3 20 18 El Rito CNF, BLM, Other 3 23 12 Southern Taos 1 CNF, BLM 2 13 13 Southern Taos 2 CNF, BLM, Other 2 10 South San Juan Navajo 4 5 Lake Jicarilla NE CNF, Other 2 28 16 Jicarilla West CNF, BLM 2 15 6 Pagosa SJNF, BLM, Other 3 74 5 South San Juan RGNF, SJNF 2 144 6 Southern Jemez 17 Pajarito SFNF, VCNP, BAND 3 68 San Juan Piedra 10 7 San Juan Piedra 1 RGNF, SJNF 2 103 8 Northern San Luis 9 Sheep Mtn RGNF, SINF, BLM 2 43 9 Tusas Rio Chama 23 Rio Chama CNF, SFNF, BLM 2 53

At each of these jurisdictional junctures we delineated a wildlife doorway that can provide a pivot for interagency management. That is, at a given doorway mutually agreed upon, management options can be explored beginning at the boundary and then extended away in both directions in a consistent fashion to ensure that the focal movement area remains as functional as possible. The wildlife doorways provide a

starting point for agencies and other cooperators to collaboratively pinpoint wildlife connectivity needs and then build off of these doorways and across the larger wildlife movement area to identify effective management strategies to facilitate connectivity.

To support the collaborative planning and management activities suggested by wildlife doorways, connectivity opportunities can also be identified within a WMFA (Figure 4; Table 3b). These include land units with designated or proposed protections from habitat fragmentation such as wildlife refuges, wilderness areas (designated and agency recommended), Research Natural Areas (RNAs), etc., that can provide anchors for connectivity linkages across the landscape to doorways. There are also spatial models that identify large intact natural land blocks across the landscape irrespective of designation that help identify optimal linkages of landscape elements to maintain connectivity (e.g., CHAT Large Natural Areas; Wilderness Society Relative Wildness in the United States). In addition, more information on focal species, species of conservation concern and other sensitive species that might receive collateral benefits in the management of wildlife movement focal areas and doorways would help in setting priorities and optimizing resource allocations for maintaining wildlife connectivity across large landscapes.

Next steps

The results reported here for the Upper Rio Grande watershed are provisional, and a key next step is to work with resource planners and biologists on refining the focal areas and doorways themselves within the study area. A possible avenue to address this would be through small, data-driven meetings with practitioners from across jurisdictions to review the content, provide additional data on wildlife movement and habitat in their areas of interest, and discuss how to implement the concept in their respective planning processes. The outcomes would be integrated into the framework presented here in a way that best serves the planning process and to also provide a prototype for the implementation of the wildlife movement focal area/wildlife doorway concept elsewhere in multijurisdictional contexts.

Beyond this, there is a need for more data on wildlife habitat and movement to support adaptive management in the context of the wildlife movement focal area/doorways framework. Specifically, additional information on core habitat areas as well as wildlife movement would help to more precisely define the location and dimensions of the doorways and the focal areas. More field-based monitoring is needed to validate doorways and focal areas, identify bottlenecks, and directly support focused land management to ensure open doorways and un-fragmented corridors that sustain wildlife connectivity at a landscape scale.

Figure 3. Three wildlife doorways were delineated within the Northern Taos Plateau WMFA based on a preponderance of evidence from multiple of data sources. Labeled points are from NMDOT and CODOT crash data. See text and Table 3a for details. 13

Figure 4. Examples of wildlife connectivity opportunities within the Northern Taos Plateau Wildlife Movement Focal Area (WMFA). See text and Table 3b for details.

Table 3. Examples of the wildlife movement and connectivity information available within the three wildlife doorways (WD 1 & 2) in the Northern Taos Plateau WMFA.

Data Set Name Wildlife Doorway 1 Wildlife Doorway 2 Wildlife Doorway 3 Wildlife Movement Data WGA Pilot Project – Corridor analysis NM-CO border X X X New Mexico DOT Wildlife Collision Data Elk, deer, antelope Elk, deer Chama Peak Land Alliance Elk migration X CHAT Wildlife Corridor (cougar) X X NM Dept. of Game & Fish Big Game Movement Mule deer, elk, pronghorn Mule deer, elk All Species Movement Arrows (SREP) Pronghorn, elk, wolf Gunnison prairie dog, elk, wolf Elk Highway Crossings and Corridors (CPW) x Mule Deer Movement, Highway Crossings, and Migration x Corridors (CPW) Taos Field Office Big Game Migration Corridors x x x Wildlife Connectivity Opportunity Data Natural Heritage Species Data - Colorado Mammals, birds, plants, fish Natural Heritage Species Data - New Mexico Gunnison's prairie dog, Peregrine falcon, yellow- Boreal owl, Astragalus mountain plover, billed cuckoo, Rio Grande ripleyi Lorandersonia cutthroat trout masked CO Crucial Habitat Assessment Tool (CHAT) Scores (1,2) 2 CO Crucial Habitat Assessment Tool (SERI) Scores (1,2) 2 NM Crucial Habitat Assessment Tool (CHAT) Scores (1,2) 2 1 and 2 1 and 2 NM CHAT Species of Concern (1,2) 2 2 2 NM CHAT Terrestrial Game Species (1,2) Elk, mule deer, cougar, Elk, mule deer, cougar, Elk, mule deer, cougar, bear, pronghorn bear, bighorn sheep, bear, pronghorn pronghorn CHAT Large Natural Areas (large intact land blocks) 2 2 2 and 3 CHAT Natural Vegetation Communities of Concern 2 2 2 Protected Areas (land use limitations) x x Relative Wildness in the United States (high score) x x

Acknowledgements

This project was supported by a grant from San Luis Valley Ecosystem Council and the Wilderness Society with additional support from Natural Heritage New Mexico (NHNM), a division of the Museum of Southwestern Biology at the University of New Mexico. Mark Watson and Chuck Hayes of the New Mexico Fish and Game Department provided review and comments on the project. We would like thank Mark Horner, Mitch East, and Rebecca Keeshen of NHNM for their contributions to the project. Photos clock wise from upper right: Wheeler Peak courtesy of Allan Ellis; Taos Plateau courtesy of George Fisher; Mountain lion courtesy of the USFS; pronghorn antelopes courtesy of Geraint Smith.

References

Beier, P., and R.F. Noss. 1998. Do Habitat Corridors Provide Connectivity? Conservation Biology 12:1241-1252.

Haber. J. P. Nelson. 2105. Planning for Connectivity. A guide to connecting and conserving wildlife within and beyond America’s national forests. Defenders of Wildlife, Washington, D.C.

Krosby, M., I. Breckheimer . D. J. Pierce, P.H. Singleton, S.A. Hall, K.C. Halupka, W.L. Gaines, R.A. Long, B.H. McRae, B.L. Cosentino, and J.P. Schuett-Hames. 2015. Focal species and landscape ‘‘naturalness’’ corridor models offer complementary approaches for connectivity conservation planning. Landscape Ecology 30: 2121-2132 .

Lambeck, R.J. 1997. Focal Species: A Multi-Species Umbrella for Nature Conservation. Conservation Biology 11:849-856.

Reed, S.E., D.M. Theobald and D. Harrison‐Atlas. 2012. Developing key datasets to support prioritization of wildlife habitat protection in Colorado and New Mexico. Colorado State University, Fort Collins, CO.

Rudnick D.A., S. J. Ryan, P. Beier, S. A. Cushman, F. Dieffenbach, C. W. Epps, L.R. Gerber, J. Hartter, J.S. Jenness, J. Kintsch, A.M. Merenlender, R.M. Perkl, D.V. Preziosi, and S.C. Trombulak. 2012. The role of landscape connectivity in planning and implementing conservation and restoration priorities. Issues In Ecology 16.

Sawyer, H. 2011. Migration patterns, winter habitat selection, and mule deer response to winter drilling in the Rosa Unit. Western Ecosystems Technology, Inc.

Sawyer, H. 2013. Rosa Mule Deer Study 2013 Progress Report. Western EcoSystems Technology, Inc., Laramie, WY.

Spies T. A., G. H. Reeves, K. M. Burnett, W.C. McComb, K. N. Johnson, G. Grant, J.L. Ohmann, S.L. Garman, and P. Bettinger. 2002. Assessing the ecological consequences of forest policies

in a multi-ownership province in Oregon. In: Integrating Landscape Ecology into Natural Resource Management. Port Chester, GB: Cambridge University Press.

Appendix A. Project dataset summaries for Wildlife Doorways: Supporting Wildlife Habitat Connectivity Across Borders in the Upper Rio Grande Watershed

Below is a table listing the data sets with thumbnail maps that have been collected for this project. Data sets are grouped by their source. 1. Colorado Parks and Wildlife’s data library: http://cpw.state.co.us/learn/Pages/Species-Maps.aspx Bighorn Sheep Migration Patterns and Corridors (http://cpw.state.co.us/lear n/SpeciesKMZMaps/Bighorn Sheep.kmz)

Elk Highway Crossings and Corridors (http://cpw.state.co.us/lear n/SpeciesKMZMaps/Elk.km z)

Mule Deer Movement, Highway Crossings, and Migration Corridors (http://cpw.state.co.us/lear n/SpeciesKMZMaps/MuleD eer.kmz)

Pronghorn Migration Corridors (http://cpw.state.co.us/lear n/SpeciesKMZMaps/Prongh orn.kmz)

Boreal Toad Overall Range (http://cpw.state.co.us/lear n/SpeciesKMZMaps/BorealT oad.kmz)

2. Southern Rockies Ecosystem Project (SREP) Connectivity report - http://rockymountainwild.org/_site/wp-content/uploads/LCL-Phase-1-Report.pdf - Maps start on pdf page number 44. May be the same as CPW data? a. GIS data is online here: LCL-Phase 1 GIS Data Download. b. And overview of the process to identify these linkages is here: http://rockymountainwild.org/srep/linking-colorados-landscapes. All Species Movement Arrows - SREP utilized a two-track approach that integrated local and regional expertise, as well as computer modeling. The first track – or 'expert track' – consisted of a series of interagency workshops held across the state to identify both functioning and degraded wildlife linkages vital to wildlife populations. The workshop participants then evaluated the characteristics and existing condition of each identified linkage.

The second track – or 'computer modeling track' – considered the same questions within the framework of a geographic information system (GIS). Colorado State University research scientist Dr. Dave Theobald led this effort. Dr. Theobald combined layers of spatial data about landscape characteristics (e.g., topography, rivers and streams) with wildlife habitat preferences and movement patterns to model areas of the landscape that are important for wildlife movement. The highest priority linkages identified by each of these tracks were then combined with CDOT animal-vehicle collision data and

transportation planning data to select a subset of high-priority wildlife linkages for further assessment.

In total, 176 linkages were identified via the expert workshops, with additional linkages modeled for Canada lynx, gray wolf and pronghorn. The Executive Committee selected high-priority linkages for further analysis in Phase II based on the workshop-based prioritization for large carnivores and ungulates, the model-based prioritization, and additional considerations such as: presence of local partners; stretches of roadway with frequent animal-vehicle collisions; planned transportation projects projected by CDOT through 2030; and the distribution of linkages across the state and their complementary contributions to landscape connectivity. Twenty-three linkages were thereby selected in the top tier and were grouped into twelve high-priority linkage complexes based on similar species usage and geography. This collaborative effort provides transportation planners, community leaders and conservationists with a statewide vision for protecting and restoring habitat connectivity, which is vital for maintaining healthy populations of native species. The Executive Committee reviewed the nominees over a period of several weeks, and from these selected 28 focal speciesi and two ecological systems.

Expert Workshop Details

Each group was asked to sketch both the core habitat patches and their connecting linkages for a given focal species. The decision to ask the participants to define core habitat patches themselves relative to a given focal species was based on the premise that core habitat patches may be different for different focal species, and to avoid biasing their responses. Core habitat patches did not have to be comprised of land in conservation ownership or management, and workshop participants delineated them based on vegetation, ownership and/or other considerations.

Each workshop began with a detailed presentation outlining the process for identifying linkages to ensure a consistent process at each workshop location. The participants were instructed to roughly sketch linkage areas rather than simply draw linear arrows connecting core habitat patches. Given the time constraints of a daylong workshop, participants were asked to focus on the highest priority linkages for the focal species being considered by their group, rather than attempting to identify every possible linkage on the landscape.

All Species Movement Arrows

All Species Top Linkages

3. Crucial Habitat Assessment Tool Data (http://nmchat.org/) – One-mile hexagonal data. On Colorado side only CHAT score is exposed. On NM side can get all 9 layers. See http://nmchat.org/data-metadata.html for detailed metadata.

CHAT Rollup Scores.

c. Species of Concern Scores. (only available for NM)

Terrestrial Game Species (SERI – Species of Economic and Recreational Value) Scores. (only available for NM)

Sport Fish (Aquatic SERI) – based on “fishing waters” layer from NMDGF. Used because of highlighted perennial waters. (only available for NM)

Wildlife Corridor Scores – based on a corridor model for cougars developed by K. Menke (2008) for NMDGF. (only available for NM)

Wetland/Riparian Areas – aggregation of 4 data sets. (only available for NM)

Ecosystems of Concern –ecosystems were given conservation ranks like sensitive species. (only available for NM)

Large Natural Areas – shows amount of anthropogenic disturbance. (only available for NM)

Freshwater Integrity – from the National Fish Habitat Action Plan (NFHAP). Measure of watershed stress. (only available for NM)

4. Game Species Data (see also CHAT SERI species in 2c and 2d above)

Hall Sawyer Mule Deer migration data (http://www.chamapeak.org/pdf/Watts_F INAL%20REPORT-2014.pdf)

Chama Peak Land Alliance (http://chamapeak.org/) Elk migration data (Chama Peak Land Alliance. Elk Corridors. ESRI Shapefile. Bozeman, MT: Cameron Ellis, 2013. Adapted and buffered data reconstructed from data provided by the Jicarilla Apache Nation and Tom Watts, personal communication.)

Chama Peak Land Alliance (http://chamapeak.org/) Deer migration data (Chama Peak Land Alliance. Mule Deer Corridors. ESRI Shapefile. Bozeman, MT: Cameron Ellis, 2013. Adapted and buffered data reconstructed from data provided by the Southern Ute Tribe and Tom Watts, personal communication.)

NM Dept. of Game & Fish Big Game Big Game Movement Polygons – Bighorn Sheep

NM Dept. of Game & Fish Big Game Big Game Movement Polygons

5. Natural Heritage Data from Colorado (http://www.cnhp.colostate.edu/) and New Mexico (http://nhnm.unm.edu/)

Heritage Data – Occurrence data from NM and CO for all state and federally listed species plus sensitive species including USFS species of conservation concern.

Colorado Natural Heritage Program – Potential Conservation Areas

Conservation Opportunity Areas (from draft NMDGF State Wildlife Action Plan - developed by NHNM and NMDGF)

6. Wildlife Corridor Models

WGA Pilot Project – Corridor analysis along border (Reed et al. 2012)

7. Protected Areas Data

Land use limitations (e.g. Wilderness, Proposed Wilderness, Wilderness Study Areas, Conservation Easements, etc.)

8. Wildlife Collision Data Colorado DOT Region 5 Wildlife Collision Data

New Mexico DOT Wildlife Collision Data

i Focal species - “For this project we adopted the Forest Service’s operational definition: Focal species are surrogate measures used in the evaluation of ecological sustainability, including species and ecosystem diversity. The key characteristic of a focal species is that its status and trend provide insights to the integrity of the larger ecosystem to which it belongs…. focal species may be used as surrogates to represent ecological conditions that provide for viability of other species, rather than directly representing the population dynamics of those other species (Proposed Planning Rule, Section 219.36, August 2000).” 28

Appendix D

Methods for Identifying Areas on the Rio Grande National Forest that are Restorable and Operable for Mechanical Treatment

We used ArcGIS 10.2 to assess areas potentially suitable for mechanical restoration treatment on the Rio Grande National Forest. Using methods derived from North et al. (2015), we analyzed the Rio Grande landscape in order to highlight “operable” areas of the forest, or those potentially available to mechanical treatment. Starting with the Rio Grande National Forest boundary, we first excluded designated wilderness areas from the extent of operable land on the forest. We obtained spatial data of designated wilderness from the University of Montana College of Forestry and Conservation’s Wilderness Institute1, which maintains the most up-to-date spatial data on wilderness areas. We then removed Colorado Roadless Areas (IRAs) from potential treatment areas. Following the approach taken in North (2015), we removed areas with slopes greater than 35%. North used a 35% threshold because “mechanical equipment is generally prohibited on slopes >35% with unstable soils. We used a digital elevation model to create a percent slope raster for Rio Grande National Forest, subsequently removing areas with slopes greater than 35%. We excluded areas outside of a 1,000-foot road buffer from the operable areas of the forest. We used Maintenance Level 1-5 roads in our analysis. The roads layer was obtained from the Rio Grande National Forest.

We further filtered the operable areas generated above by vegetation type, selecting ponderosa pine and mixed-conifer forest types for which mechanical treatment is viable. We conducted these calculations at the 6th level of the National Vegetation Classification System (NVCS 2008).2 We used data from the USGS Gap Analysis Program (GAP) national land-cover data version 2 at 30-meter resolution (USGS 2011). The final product of this analysis represents areas of Rio Grande National Forest that are potentially appropriate for mechanical restoration from both vegetative and operational standpoint.

To create the Wildland Urban Interface (WUI), we started with Census 2010 block data. We modified the blocks by subtracting public land and identifying communities using a housing density threshold of one structure per forty acres (the minimum density of a wildland-urban interface community, according to the January 4, 2001 Federal Register Notice). We then buffered these communities by a half-mile and removed non-wildland cover types (water, barren, rock, agriculture, urban land) to create the WUI.

1 Wilderness.net 2 The NVCS classifications are as follows: 1) Class; 2) Subclass; 3) Formation; 4) Division; 5) Macrogroup; 6) Group (a.k.a. ecological system, to which we refer in this study as “ecosystem”); 7) Alliance; and 8) Association.

While we excluded upper tier roadless areas from the WUI, we did not apply road buffer and slope restrictions within the WUI.

Cited

Urban wildland interface communities within the vicinity of Federal lands that are at high risk from wildfireFederal Register 663:751-777, January 4,2001.

North, M., A. Brough, J. Long, B. Collins, P. Bowden, D. Yasuda, J. Miller, and N. Sugihara. 2015. Constraints on mechanized treatment significantly limit mechanical fuels reduction extent in the Sierra Nevada. Journal of Forestry. 113(1):40-48.

US Geological Survey, Gap Analysis Program (GAP). (2011). National Land Cover, version 2, August 2011. Accessed 15 January 2014: http://gapanlysis.usgs.gov Opportunities for Mechanical Forest Restoration and Fuels Reduction in the Community Fire Protection Zone Overlaid with TWS Recommended Wilderness Area, Rio Grande National Forest

Citizen Recommended Wilderness Community Fire Protection Zone (CFPZ, 135,893 acres) Vegetation suitable for restoration (52,481 acres) Other Vegetation (489,327 acres) Wilderness + CRA, upper tier + slopes > 35% + areas outside of road buffers* (1,394,905 acres)

0 10 20 30 40 Miles *Road buffer and slope restrictions not applied within the CFPZ ³

Appendix E Descriptions of Areas Recommended for Wilderness by The Wilderness Society

Antora Meadows recommended wilderness

Proposed Wilderness Designation Rio Grande National Forest Saguache Ranger District 27,700 acres

General Description

One of Colorado’s least‐known segments of the Continental Divide runs between the San Juan and Sawatch ranges along the northern rim of the San Luis Valley. The proposed Antora Meadows wilderness contains a large portion of an easy to overlook forested length of the divide and is a primary component of one of Colorado’s largest unprotected roadless areas in the Cochetopa Hills. The proposed wilderness would fill one of the largest remaining gaps in the wilderness system in the Southern Rockies, and complete the ecological connection between the large protected wilderness areas of the San Juans to the south and the equally important preserves of the Elk, Sawatch, and Sangre de Cristo ranges to the north and east. The area is generally a refuge for wildlife, including robust deer and elk herds. It is also home to a pure population of the imperiled Rio Grande cutthroat trout.

Antora Meadows lies in the Saguache Creek watershed north of Saguache. The area is bounded on the north by the Continental Divide National Scenic Trail, but the primary access point is the Middle Creek Trailhead on its south side. Fescue grasslands and open ponderosa pine forest are typical in the lowest portions of the area starting at an elevation of 8,800 feet. Large stands of aspen and lodgepole pine forest become more common as one travels deeper into the area towards the Continental Divide at 10,600 feet. The area tops out at 13,269‐foot Antora Peak. The area is adjacent to a 3,600‐acre wilderness‐quality portion of the Starvation Creek roadless area on the Pike‐San Isabel NF.

Naturalness

Antora Meadows is a compact shape comprised of several tributary watersheds. It has escaped prior intensive timber management typical of adjacent areas. The PSCO gas pipeline is excluded from the area and forms the western boundary. The boundary cherrystems areas of mineral exploration and development along with the patented mining claims and access road in the Antora Meadows vicinity. It also omits the 5 miles of the Continental Divide National Scenic Trail open to motorized use along the northern boundary of the unit. Within these boundaries, there is no evidence of significant human imprints.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation This large expanse of roadless landscape offers solitude that is hard to find in other mountainous regions of Colorado. Due to its dry environment and lack of large bodies of water, this is a relatively unvisited part of the state. Visitors can readily achieve solitude in any of the several tributary valleys leading to the Continental Divide. The area’s remoteness and lack of roads makes it an ideal refuge for deer and elk, a fact that provides outstanding opportunities for backcountry hunting. The area offers angling opportunities for a pure Rio Grande cutthroat trout population. The area’s 20 miles of non‐ motorized trails in many cases parallel lush riparian zones of willow, blue spruce and aspen that makes it an outstanding destination for horseback riding, hiking and wildlife viewing. The Middle Creek trailhead is popular with backcountry horse users, and the trails are signed as closed to mountain bikes. Size and Roadlessness

Antora Meadows contains 27,700 acres on the Rio Grande National Forest. It is contiguous with 3,600 acres of wilderness quality lands in the adjacent Starvation Creek roadless area on the Pike‐San Isabel NF. The area’s boundaries are the PSCO gas pipeline on the west and the edge of past timber harvests in the Slaughterhouse Creek watershed to the east, with the national forest boundary and Forest Road 880.2B on the south, and the Continental Divide/national forest boundary to the north.

Supplemental Values

While Antora Meadows provides habitat for recovering lynx and potential wolverine populations, perhaps its most important ecological role comes in the form of undisturbed watersheds for core conservation populations of Rio Grande cutthroat trout. The core conservation populations in East Middle Creek and Tuttle Creek are >99% pure, phenotypically true, and representative of the species’ historic genome. East Middle Creek is also a Colorado Natural Heritage Program Potential Conservation Area of moderate biodiversity significance because of the trout population. (Conservation Plan for Rio Grande Cutthroat Trout in Colorado, CDOW, 2004; CNHP PCA Report, 2015)

Antora Meadows helps fill the largest gap in the wilderness system in the Southern Rockies. The area is part of the ecological connection between the large protected wilderness areas of the San Juans to the south and the equally important preserves of the Elk, Sawatch, and Sangre de Cristo ranges to the north and east. (SREP Wildlands Network Vision 2003; Aplet et al Indicators of Wildness 2000.)

Antora Meadows provides one of the few areas in Colorado where all of the state’s major forest types coexist. Ecologists can find an abundance of conifer species here in uncommon proximity, including Douglas fir, white fir, subalpine fir, lodgepole pine, limber pine, ponderosa pine, Colorado blue spruce and Engelmann spruce. The area is located amidst the only portion of the Rio Grande NF where lodgepole pine naturally occurs.

Antora Meadows contains several ecosystems under‐represented among existing wilderness areas on the Rio Grande National Forest. The lowest slopes consist of rolling grasslands at the national forest boundary with adjacent BLM lands, while forests of lodgepole pine and Douglas fir blanket the higher slopes, above meadows and stream valleys banded by aspen groves. By protecting this area, the Rio Grande NF can increase the ecological representation within its wilderness areas of Rocky Mountain Lodgepole Pine Forest, Rocky Mountain Aspen Forest and Woodland, and Southern Rocky Mountain Montane‐Subalpine Grassland. (TWS ecosystem representation report, 2016)

Manageability

Antora Meadows is a compact unit that is comprised of the Middle Creek watershed and has readily identifiable boundaries on the ground. It is bounded on the north by the motorized Continental Divide National Scenic Trail and on the south by the forest boundary, and by Forest Road 880.2B. The western boundary is readily delineated by the PSCO gas pipeline corridor, and the eastern boundary approximately by Forest Development Road 861 in the Slaughterhouse Creek watershed. The area’s eastern boundary, north of Mosquito Lake, is contiguous with several thousand acres of wilderness‐quality lands on the Pike‐San Isabel NF.

Patented mining claims at Antora Meadows are cherry‐stemmed out of the unit boundary along with the access route via FDR 880.2B. These are on top of a ridge and out of sight of wilderness users. A short, dead‐end and unmaintained motorized trail (#764) extends two miles north of Antora Meadows (see photo). The 2015 Rio Grande NF TAP ranked this trail as low value and high risk owing to its fords across four headwaters tributaries of East Middle Creek, which are inhabited by Rio Grande cutthroat trout. There are no oil and gas leases within the boundaries.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values Rio Grande Cutthroat Trout Conservation Plan for the Rio Grande Cutthroat Trout in Colorado. Colorado Division of Wildlife; CNHP PCA Report 2015 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem representation TWS Ecosystem Representation 2016

Elkhorn Peak recommended wilderness

Proposed Wilderness Designation Rio Grande National Forest 15,800 acres Saguache Ranger District

General Description

The proposed Elkhorn Peak wilderness serves an important role in landscape connectivity between the Sangre de Cristo range and the Cochetopa Hills of the northern San Juan Mountains. Elkhorn Peak straddles the ridge between Villa Grove and Bonanza south of Poncha Pass. Sweeping vistas of the Sangre de Cristo range are obtained from the summits of Elkhorn and Hayden peaks, enhancing the outstanding sense of isolation in this remote corner of the northern San Luis Valley. Several non‐motorized trails provide ready access into the heart of the area, such as the trail that traverses Kelly Creek and Elkhorn Gulch.

Elkhorn Peak extends from grasslands and ponderosa pine characteristic of the uplands of the San Luis Valley to two peaks over 12,000 feet – Elkhorn and Hayden. The elevational gradient creates a continuum of ecosystems through large stands of aspen to lodgepole pine and extensive forests of Engelmann spruce and subalpine fir. Bristlecone pine and limber pine can be found on wind blown dry rocky ridges and slopes.

Naturalness

Elkhorn Peak is a roughly square area with boundaries defined by the forest boundary and surrounding roads. The boundary excludes past mining impacts and patented mining claims in the vicinity of Bonanza and in the Kerber Creek valley. The resulting area is natural with no substantially noticeable human impacts.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation Outstanding opportunities for solitude and ample vistas are commonplace when exploring Elkhorn Peak. The feeling of seclusion and remoteness is particularly enhanced in the area’s western portion, amidst the rugged Elkhorn and Hayden peaks. Visitors can barely ascertain highways and farms more than a half‐dozen miles distant in the San Luis Valley. The separation from the sights and sounds of civilization further heightens the sensation of solitude and isolation gained within the unit.

Elkhorn Peak includes approximately ten miles of non‐motorized trails. These are popular destinations for horseback riding and hiking, particularly from the Kelley Creek trailhead. Scenic vistas and direct access to the crest of the area combine to create outstanding opportunities for primitive and unconfined recreation. The area’s primary drainages contain beaver ponds and trout fisheries, and important deer and elk winter range sustains healthy big game herds that draw fall hunters. Size and Roadlessness

The proposed Elkhorn Peak wilderness is a free‐standing unit of 15,800 acres. The area’s topography and compact boundary configuration enhances the practicality of managing it for its preservation and use in an unimpaired condition.

Supplemental Values

The proposed Elkhorn Peak wilderness contains the entirety of the 2,014‐acre Kelly Creek Potential Conservation Area, a Colorado Natural Heritage Program ranked as High Biodiversity Significance. The Kelly Creek PCA includes a wetland complex with a robust montane riparian shrubland where the undergrowth is still dominated by native species, an increasingly rare occurrence. Beaver ponds expand the floodplain habitat and constitute an important component in maintaining this healthy ecosystem. Shrubland associations at lower elevations like this one in Kelly Creek are usually impacted by water diversions, livestock grazing, invasive plant species and agricultural conversion, which makes the PCA all the more unusual. (CNHP PCA Report, 2015)

Elkhorn Peak helps fill the largest gap in the wilderness system in the Southern Rockies and provides connectivity across the landscape between the northern San Juan Mountains and the Sangre de Cristo range. The area is immediately south of the important Poncha Pass lynx linkage area. (SREP Wildlands Network Vision 2003; Aplet et al Indicators of Wildness 2000.)

Elkhorn Peak contains several ecosystems under‐represented among existing wilderness areas on the Rio Grande National Forest. The lowest slopes consist of rolling grasslands and ponderosa pine woodland at the national forest boundary with adjacent BLM lands, while forests of lodgepole pine and Douglas fir blanket the higher slopes. By protecting this area, the Rio Grande NF can substantially increase the ecological representation within its wilderness areas of Southern Rocky Mountain Montane‐Subalpine Grassland, Southern Rocky Mountain Ponderosa Pine Woodland, Rocky Mountain Lodgepole Pine Forest, and Rocky Mountain Aspen Forest and Woodland. (TWS ecosystem representation report, 2016)

Manageability

Elkhorn Peak can be easily managed to preserve its wilderness character. The area is a compact shape with readily identifiable topographic boundaries. The forest boundary defines the eastern, western and southern boundaries and are largely buffered by adjacent BLM administered lands. The northern boundary generally consists of forest roads and patented mining claims. The area’s lower reaches may be within the WUI boundary for Kelly Creek and Bonanza, which can be easily offset with a boundary cushion. There are no non‐federal inholdings as all patented mining claims are excluded from the boundary. There are no oil and gas leases.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values High Biodiversity Significance CNHP PCA Report 2015 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem representation TWS Ecosystem Representation 2016

Lake Fork addition to La Garita Wilderness

Proposed Wilderness Designation Rio Grande National Forest 3,800 acres Saguache Ranger District

General Description

The Lake Fork addition to the La Garita Wilderness finalizes wilderness protection for the watershed upstream of the remote Middle Fork trailhead on the wilderness area’s eastern boundary. The addition is characterized by large aspen stands and mountain‐bunchgrass parks, and completes wilderness protection for three miles of the Continental Divide. The wilderness boundary at present follows the center of the Middle Fork of Saguache Creek; this addition creates a topographically sensible wilderness boundary on both sides of the valley that incorporates the entirety of the Middle Fork watershed to the wilderness trailhead.

The added lands provide excellent range for summering elk herds, and enhance habitat protection for documented use by lynx. Machin Lake sits at the headwaters of the Middle Fork and the Middle Fork trail provides direct access to this recreation destination in the La Garita Wilderness.

Naturalness

The proposed wilderness addition applies to the Upper Tier portion of the Lake Fork Colorado Roadless Area, or about 3,800 acres of the larger 10,700‐acre roadless area. The addition consists of the Middle Fork valley and adjacent forests and hillsides that are consistent in natural appearance with the adjacent wilderness lands. The aspen and grasslands result from wildfires 100 years prior. There are no vehicle routes or past management activities within the proposed wilderness addition.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation The Middle Fork Trailhead is a remote wilderness access point into the adjacent La Garita Wilderness. It is located at the end of six miles of four‐wheel‐drive road. The Middle Fork trail is the gateway to a network of wilderness trails higher in the watershed and terminates in the alpine basin of Machin Lake. Multiple looping wilderness trips extend from the Middle Fork trail, such as those incorporating the Halfmoon Pass and Machin Basin trails. The Middle Fork trail provides outstanding opportunities for backpacking, fishing, horsepacking, and hunting. The remoteness of the trailhead helps guarantee outstanding opportunities for solitude, which is particularly notable along the trail‐less portion of the Continental Divide and in the Lake Fork drainage in the addition’s northern end. Size and Roadlessness The proposed Lake Fork addition to the La Garita Wilderness is 3,800 acres out of the larger 10,700‐acre Colorado Roadless Area. The northern boundary of this pie‐shaped addition is the Lake Fork of Saguache Creek, where the Tarbell Ditch diverts water across the Continental Divide out of the Cochetopa Creek watershed into the Saguache Creek watershed. The remainder of the roadless area boundary is the existing wilderness boundary.

Supplemental Values

The proposed wilderness addition includes a portion of the Saguache Creek Potential Conservation Area identified by the Colorado Natural Heritage Program. Saguache Creek is ranked as High Biodiversity Significance owing to its montane and subalpine willow carr associations within the creek’s floodplain and valley toe slopes. The Middle Fork of Saguache Creek is noted specifically for a good stand of beaked sedge (Carex utriculata) wetland and numerous smaller wetlands in the upper watershed (CNHP PCA Report for Saguache Creek, 2015).

The Middle Fork of Saguache Creek hosts a high purity, recreation population for Rio Grande Cutthroat Trout that extends all the way into the headwaters at Machin Lake. (Conservation Plan for Rio Grande Cutthroat Trout in Colorado, CDOW, 2004)

The proposed Lake Fork wilderness addition increases the ecological representation within Rio Grande National Forest wilderness areas of Southern Rocky Mountain Montane‐ Subalpine Grassland, an ecosystem type currently with less than 5% representation of the overall ecosystem acreage on the forest. (TWS ecosystem representation report, 2016)

Manageability

The Lake Fork addition is readily manageable as wilderness, and increases the compactness of the adjacent La Garita Wilderness by its addition. The only trail within the area is the non‐motorized Middle Fork trail leading several miles to the existing wilderness boundary. The transbasin water diversion out of Cochetopa Creek into Saguache Creek is excluded from the proposed wilderness boundary and forms the northern boundary. There are no oil and gas leases or non‐federal inholdings.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values High Biodiversity Significance CNHP PCA Reports 2015 Rio Grande Cutthroat Trout Conservation Plan for the Rio Grande Cutthroat Trout in Colorado. Colorado Division of Wildlife; CNHP PCA Report 2015 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem Representation TWS Ecosystem Representation 2016

Wannamaker Creek‐Deep Creek addition to La Garita Wilderness

Proposed Wilderness Designation Rio Grande National Forest 10,900 acres Saguache Ranger District

General Description

The Wannamaker Creek‐Deep Creek addition to the La Garita Wilderness consists of two wild valleys draining north from the 12,000‐13,000 foot escarpment of the La Garita Mountains. These two intact roadless watersheds lie adjacent to the wilderness area’s eastern boundary, and support primitive recreation on more than 15 miles of backcountry trails. The trails are remote, and in some cases difficult to access, creating an experience of outstanding solitude.

At its lowermost elevations, the addition greatly enhances the ecosystems protected within the existing wilderness by incorporating thousands of acres of grasslands typical of those in expansive Saguache Park. The area provides high quality habitat for elk and deer, and angling opportunities for Rio Grande cutthroat trout. The addition encompasses almost five miles along the South Fork of Saguache Creek.

Naturalness

The proposed wilderness addition applies to the northern half of the Deep Creek‐Boot Mountain Colorado Roadless Area. The private inholding and historic mining activity at Sky City is cherrystemmed out of the wilderness boundary, and past timber harvest areas east of Deep Creek are similarly excluded. There are no vehicle routes or past management activities within the proposed wilderness addition, and the area reflects unmodified naturally‐occurring ecological conditions.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation Both Wannamaker Creek and Deep Creek watersheds are remote and lightly visited. The steep northern escarpment of the La Garita Mountains creates a natural topographic barrier at the highest elevations, separating the two drainages from motorized routes including the La Garita Stock Driveway to the south of the mountain crest. This topographic isolation maintains outstanding opportunities for solitude. The Sky City inholding blocks public access from the lower end of Wannamaker Creek, but other trails provide several access alternatives into the upper end of Wannamaker Creek. These include the Deep Creek trail from the east, the Coyote Trail coming over the divide from the La Garita Wilderness to the west, and the Wannamaker Creek trail itself from the top of the high escarpment. The alternate access requires more effort and imagination by backcountry users, meaning the Wannamaker Creek watershed retains outstanding solitude and challenging primitive recreation opportunities. Similarly, there is a lightly‐ used and unobtrusive trail along the length of Deep Creek that begins at its confluence with the South Fork of Saguache Creek. The trail systems provide access for those seeking remote backcountry hunting experiences in the fall, and Wannamaker Creek supports a hybridized Rio Grande cutthroat trout population for anglers. Size and Roadlessness The proposed Wannamaker Creek‐Deep Creek addition to the La Garita Wilderness is 10,900 acres out of the larger 27,600‐acre Colorado Roadless Area. The watershed divide atop the La Garita Mountains escarpment defines the southern boundary, while the northern boundary is the South Fork of Saguache Creek. The area adjoins the La Garita Wilderness to the west, and the Deep Creek watershed divide forms the eastern boundary.

Supplemental Values

The proposed Wannamaker Creek‐Deep Creek addition includes a portion of the Saguache Creek Potential Conservation Area identified by the Colorado Natural Heritage Program. The Saguache Creek PCA is ranked as High Biodiversity Significance owing to its montane and subalpine willow carr associations within the creek’s floodplain and valley toe slopes. According to CNHP, the upper watershed of Saguache Creek supports a broad diversity of aquatic and terrestrial habitats and maintains a largely undisturbed hydrological regime. The headwaters streams provide a valuable refuge for species that have been impacted by land use in the lower watershed, such as the Rio Grande cutthroat trout. (CNHP PCA Report for Saguache Creek, 2015).

Wannamaker Creek hosts a conservation population for Rio Grande Cutthroat Trout. (Conservation Plan for Rio Grande Cutthroat Trout in Colorado, CDOW, 2004)

The proposed Wannamaker Creek‐Deep Creek addition enhances the ecological effectiveness of the La Garita Wilderness by expanding the size of the protected area. Larger protected areas are more likely to provide conditions for species persistence over the long term than smaller areas. (SREP Wildlands Network Vision 2003; Aplet et al Indicators of Wildness 2000.)

The proposed Wannamaker Creek‐Deep Creek wilderness addition increases by thousands of acres the ecological representation within Rio Grande National Forest wilderness areas of Southern Rocky Mountain Montane‐Subalpine Grassland, an ecosystem type currently with less than 5% representation of the overall ecosystem acreage on the forest. (TWS ecosystem representation report, 2016)

Manageability

The Wannamaker Creek‐Deep Creek wilderness addition has a clearly defined topographic boundary denoted by watershed divides to the east and south, and by the South Fork of Saguache Creek to the north (the existing wilderness boundary is to the west). This boundary readily excludes incompatible uses such as motorized vehicles. This subset of the larger Deep Creek‐Boot Mountain Colorado Roadless Area eliminates the irregularities of shape and also excludes all motorized trails characteristic of the southern half of the roadless area. The Sky City private inholding and its mile‐long access road #787 are cherrystemmed out of the lower end of the six‐mile long Wannamaker Creek valley. There are no oil and gas leases in the area.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values High Biodiversity Significance CNHP PCA Reports 2015 Rio Grande Cutthroat Trout Conservation Plan for the Rio Grande Cutthroat Trout in Colorado. Colorado Division of Wildlife; CNHP PCA Report 2015 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem Representation TWS Ecosystem Representation 2016

Wason Park addition to La Garita Wilderness

Proposed Wilderness Designation Rio Grande National Forest 22,000 acres Divide Ranger District

General Description

Wason Park is a large roadless area adjacent to the La Garita Wilderness’ western boundary and just outside of Creede. Wason Park adds wilderness protection for up to 8 miles of the Continental Divide on the Rio Grande National Forest, significantly enhancing the presence of the La Garita Wilderness south of the divide. The La Garita Wilderness at present is situated predominately north of the Continental Divide on the neighboring Gunnison National Forest.

Wason Park’s addition to the wilderness would greatly expand ecological representation of the La Garita Wilderness by incorporating south‐facing slopes dominated by grasslands and ponderosa characteristic of the Rio Grande valley that transition continuously through aspen and spruce‐fir to the Continental Divide. The addition spans an elevation range from 8,700 feet in the valley to over 13,000 feet on the Continental Divide. Its western flank consists of the steeply incised valley of East Willow Creek. Several non‐motorized trails lead through the area to the adjacent wilderness boundary, including Farmers Trail from the valley floor, the Wason Trail from Creede, and the La Garita Stock Driveway from Phoenix Park.

Naturalness

Wason Park is a broad, unfragmented area of undisturbed habitat blanketing the western approaches to the La Garita Wilderness. While some mining remnants are visible adjacent to the lower Bachelor Loop Road at its lowest elevations near Creede, Wason Park is otherwise free of any substantial unnatural impacts.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation Wason Park is a large landscape with intact forests and drainages leading to a remote section of the Continental Divide. The Continental Divide National Scenic Trail is located north of the actual divide in this section, thus making the southern flanks of the Divide in Wason Park an area of outstanding isolation and solitude. Upper East Willow Creek is exceedingly remote and trail‐less, and invokes a sense of vastness and impenetrability that further enhances the impression of solitude.

Wason Park contains over a dozen miles of non‐motorized trails. These trails near Creede offer the closest wilderness access into the La Garita Wilderness from any surrounding communities. Several trails traverse the roadless area before reaching the existing wilderness boundary and provide excellent routes for hikers, backpackers, and horse users heading into the adjacent wilderness. These include the Farmers Creek Trail from the valley floor, the Wason Trail from Creede, and the La Garita Stock Driveway from Phoenix Park. The expansive, intact wildlife habitat provides outstanding opportunities for remote backcountry big‐game hunting experiences.

Size and Roadlessness

Wason Park contains 22,000 acres. It is bounded on the east and north by the existing La Garita Wilderness, and on the south by the forest boundary in the Rio Grande valley. The area’s western boundary is generally defined by roads and patented mining claims.

Supplemental Values

Wason Park contains outstanding supplemental values for a variety of wildlife species. It is in close proximity to high use lynx areas, contains lynx habitat, and provides an important landscape connectivity link for lynx. Wason Park provides important winter range for elk, deer, and bighorn sheep. Wason Park encompasses a migration route for bighorn sheep from the Bellows Creek herd to the San Luis Peak and Bristol Head herds. Wason Park also is adjacent to priority habitat for moose in West Willow Creek.

The proposed Wason Park wilderness addition enhances the ecological effectiveness of the La Garita Wilderness by expanding the size of the protected area. The Wason Park addition would boost the size of the La Garita Wilderness by 15%. Larger protected areas are more likely to provide conditions for species persistence over the long term than smaller areas. (SREP Wildlands Network Vision 2003; Aplet et al Indicators of Wildness 2000.)

Wason Park contributes thousands of acres of one of the most under‐represented ecosystem types among existing wilderness areas on the Rio Grande National Forest. By protecting this area, the Rio Grande NF can significantly increase the ecological representation within its wilderness areas of Southern Rocky Mountain Montane‐ Subalpine Grassland. (TWS ecosystem representation report, 2016)

Wason Park includes a pair of scenic waterfalls above Phoenix Park that are popular focal points for photographers.

Manageability

Wason Park is readily manageable as wilderness. It is characterized by a broad, three‐mile‐ wide belt of forests and streams banding the southern and western boundary of the existing La Garita Wilderness. Steep topography out of the East Willow Creek drainage precludes ready trespass by motorized vehicles. Adjacent patented mining claims are excluded from the boundary, and access to those private lands is via non‐wilderness lands from the west. The primary Creede mineral belt along the famous Amethyst silver vein is situated along West Willow Creek and lies significantly outside the proposed wilderness addition. All of the existing trails are designated non‐motorized. There are no oil and gas leases or non‐federal inholdings within the area.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem representation TWS Ecosystem Representation 2016

North Fork Rock Creek recommended wilderness

Proposed Wilderness Designation Rio Grande National Forest 16,500 acres Divide Ranger District

General Description

The proposed North Fork Rock Creek wilderness consists of the northeastern portion of the Bennet Mountain Colorado Roadless Area unit. It neatly encompasses the watershed of the North Fork of Rock Creek along with adjacent lands to the north. The area provides coverage of a lower elevation ecological transition in the foothills of the southern San Luis Valley south of Del Norte. In the fall, spectacular displays of colorful aspen foliage dominate the landscape.

Elevation ranges from a low of 8,880 feet at the national forest boundary along Rock Creek to 12,800‐feet atop Pintada Mountain. Fescue dominated grasslands are common in the lowest elevations, then transition into pinyon‐juniper habitats. Depending on slope aspect and elevation, mixed‐conifer habitats of ponderosa pine, Douglas fir can be enjoyed at low to mid elevations. The highest elevations include alpine terrain above timberline. Two non‐ motorized trails offer abundant opportunities for hiking, angling, hunting, and horseback riding.

Naturalness

North Fork Rock Creek is a subset of a much larger, and more convoluted, roadless area. This smaller component is free of human imprints and displays a substantial level of naturalness throughout the area.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation The North Fork of Rock Creek watershed provides an isolated setting shielded from the San Luis Valley. Visitors can readily experience outstanding opportunities for solitude. The area’s high points above timberline atop Windy Mountain and Pintada Mountain offer outstanding vistas and similarly impart a sense of isolation amidst a large, undeveloped landscape. The area is traversed by two non‐motorized trails, North Rock Trail #701 and Dry Creek Trail #700. These trails each offer a half‐dozen miles of exploration for hikers, anglers and equestrians. One trail parallels the creek and crosses back and forth multiple times, while the other trail navigates the high slopes above treeline and meanders down through a range of forest transitions. The area provides important winter range for deer and elk, which translates also into outstanding opportunities for backcountry hunting. Size and Roadlessness

The proposed North Fork Rock Creek wilderness unit is 16,500 acres in size.

Supplemental Values

North Fork Rock Creek provides good representation of several ecosystem types under‐ represented among existing wilderness areas on the Rio Grande National Forest. The area covers the ecological transition from the San Luis Valley to alpine slopes, and at is lowest margins includes grasslands and pinyon‐juniper woodlands, as well as ponderosa pine and dry mixed‐conifer forests. Recommending this area for wilderness designation will increase the ecological representation on the Rio Grande NF of Southern Rocky Mountain Montane‐Subalpine Grassland, Southern Rocky Mountain Ponderosa Pine Woodland, Rocky Mountain Pinyon‐Juniper Woodland, and Southern Rocky Mountain Mesic Montane Mixed‐ Conifer Forest and Woodland, all of which are currently represented at less than 5% on the forest. (TWS ecosystem representation report, 2016)

Manageability

North Fork Rock Creek can be readily managed to preserve its wilderness character. The boundary is clearly delineated on three sides by easily identifiable topographic features such as ridgelines and streams, and is bounded on the east by the national forest boundary with adjacent undeveloped rural landscapes and BLM administered lands. The western boundary excludes the Middle Frisco Creek trail, which is utilized by mountain bikes. The area includes no non‐federal inholdings and there are no oil and gas leases.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive Recreation 1909.12,chapter 70, section 72 USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values High Biodiversity Significance CNHP PCA Report 2015 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem representation TWS Ecosystem Representation 2016

Pole Creek Mountain – Sheep Mountain recommended wilderness

Proposed Wilderness Designation Rio Grande National Forest 24,800 acres Divide Ranger District

General Description

The Pole Creek Mountain roadless area is an important piece of the puzzle in protecting landscape connectivity across the San Juan Mountains. The area fills a critical gap between the Weminuche Wilderness to the south and La Garita, Uncompahgre, Handies Peak and Red Cloud Peak wildernesses and wilderness study areas to the north. The roadless area incorporates an uncommon triple watershed divide, the high point amidst the Rio Grande, Lake Fork of the Gunnison, and Animas Rivers. The vast, sweeping expanses of upper Pole Creek bring to mind the immensity of Alaskan wilderness. Three distinct landscapes define the area: vertical cliffs rise out of the Lake Fork valley on the north, with numerous waterfalls and grottoes; rolling tundra interspersed with rugged volcanic peaks characterizes the central portion; while the southern end contains several deep, glaciated valleys.

The proposed Pole Creek Mountain and Sheep Mountain wilderness units are along 12 miles of the Continental Divide, from Stony Pass to Cataract Lake. The Colorado Trail and the Continental Divide National Scenic Trail traverse the area, paralleling the divide, and draw numerous hikers and backpackers. Others find Pole Creek equally intriguing for its oddly eroded volcanic formations called beehives and hoodoos.

The proposed wilderness consists of two units. Pole Creek Mountain is the central core of the roadless area, and is defined by the motorized trails along Pole Creek and West Lost Trail Creek, which are excluded. The Sheep Mountain unit is west of Pole Creek, largely within San Juan County, and extends to the Continental Divide.

Naturalness

Pole Creek Mountain is a large, primarily alpine roadless area along the Continental Divide. The imprints of human activity are few and substantially unnoticeable. There are a few scattered remnants of historic mining activity at the headwaters of the Rio Grande near Sheep Mountain. The area is generally indistinguishable in natural character from the adjacent Weminuche Wilderness to the south.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation Pole Creek Mountain and Sheep Mountain form the core of Colorado’s largest alpine expanse of tundra. Visitors experience a sensation of vastness and isolation unparalleled amongst existing wilderness areas across the Southern Rockies. From many vantage points, all one can see is undulating tundra ridges retreating into the distance, interrupted here and there by soaring peaks.

The Continental Divide National Scenic Trail/Colorado Trail defines the northern boundary of the proposed wilderness and is a popular with hikers and backpackers. Most long‐ distance backpackers through this segment are completing the entirety of the Colorado Trail from Denver to Durango. The route of the trail from Stony Pass to Cataract Lake follows a generally moderate grade above tree‐line making it one of the most accessible high routes in Colorado. The trail system in Pole Creek Mountain is part of a larger interconnected trail system over the Continental Divide with the non‐mechanized trails in Cuba Gulch and Cataract Gulch on the Grand Mesa‐Uncompahgre‐Gunnison National Forest and nearby lands managed by BLM within the Handies Peak Wilderness Study Area.

Size and Roadlessness The Pole Creek Mountain roadless area is one of the largest freestanding areas on the Rio Grande National Forest. Even with separating the larger roadless area into two units along the motorized Pole Creek trail, the two separate Pole Creek Mountain and Sheep Mountain units are still 16,500 acres and 8,300 acres, respectively. The areas are bounded by the Stony Pass road to the south, the Continental Divide trail to the west and north, and West Lost Trail Creek/Lost Trail Creek to the east.

Supplemental Values

Pole Creek Mountain is important for several species of significant conservation concern. It is an area of high use by lynx and provides connections for lynx moving through the heart of the core population of the San Juan Mountains. The area contains one of the few known populations of the Uncompahgre fritillary butterfly, and also the only known global occurrences of the stonecrop gilia. Pole Creek Mountain provides high quality habitat for future wolverine populations.

Pole Creek Mountain includes over 20 miles of streams managed for recreation populations of Rio Grande cutthroat trout. Pole Creek, Lost Trail Creek, and West Lost Trail Creek create a large connected population along with adjacent streams in the headwaters of the Rio Grande below Stony Pass. (Conservation Plan for Rio Grande Cutthroat Trout in Colorado, CDOW, 2004)

The lower slopes of Pole Creek Mountain along the Rio Grande would increase the ecological representation within Rio Grande National Forest wilderness areas of Southern Rocky Mountain Montane‐Subalpine Grassland, an ecosystem type currently with less than 5% representation of the overall ecosystem acreage on the forest. (TWS ecosystem representation report, 2016)

Manageability

The proposed Pole Creek Mountain and Sheep Mountain wilderness units are readily manageable as wilderness. The areas have compact boundaries and are situated in perhaps the most remote location in the Rio Grande National Forest, at the very headwaters of the Rio Grande. One cluster of non‐federal inholdings in the form of patented mining claims is located in the Sheep Mountain unit near the Continental Divide but is presently under negotiation for federal acquisition. There are no oil and gas leases.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values High Biodiversity Significance CNHP PCA Reports 2015 Rio Grande Cutthroat Trout Conservation Plan for the Rio Grande Cutthroat Trout in Colorado. Colorado Division of Wildlife; CNHP PCA Report 2015 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem Representation TWS Ecosystem Representation 2016

Saguache Creek recommended wilderness

Proposed Wilderness Designation Rio Grande National Forest 27,100 Acres Saguache Ranger District

General Description

The proposed Saguache Creek wilderness offers the opportunity to add thousands of acres of high quality wilderness landscapes among grasslands and ponderosa pine woodlands that are poorly represented ecosystem types within the National Wilderness Preservation System. Saguache Creek is an unusual wild landscape – an undeveloped lower elevation stream corridor lacking road access. A Saguache Creek wilderness would fill both a geographic and ecological gap in the system of designated wilderness in the Southern Rocky Mountains. It is a large, intact wild landscape located in one of the largest remaining gaps in the wilderness system in the Southern Rockies.

The proposed Saguache Creek wilderness offers both popular and remote recreation opportunities. Saguache Creek itself is an identified wild and scenic river candidate whose seven‐mile canyon is frequented by fly‐fishing anglers, while the grasslands and ponderosa forests of lower Fourmile Creek and Luders Creek provide quiet sanctuaries for hikers, horse users, and wildlife watchers. The Colorado Natural Heritage Program ranks the area’s high‐quality riparian willow‐carr and shrublands ecosystems along Saguache Creek and Luders Creek as possessing high biodiversity significance.

Naturalness

The central feature of the proposed Saguache Creek wilderness is the undeveloped seven‐mile long canyon of Saguache Creek immediately below the confluence of its source forks. A several‐ mile long tributary of California Gulch enters from the south. The grasslands, forests, and riparian zones extending a half‐dozen miles north of Saguache Creek are dissected by the lower reaches of Fourmile Creek and Luders Creek. The deep valleys of Saguache Creek and its tributaries are topographically isolated from access roads above the canyon rims, and the western boundary excludes roads, past timber sales, and grazing developments in the Fourmile Creek and Luders Creek watersheds. The area within the defined boundary appears natural.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation Saguache Creek is a premier destination for angling with trout fishing a popular recreational activity in the proposed wilderness. Fly fishermen avidly cast the seven‐mile length of Saguache Creek for brown and rainbow trout using flies and lures only. Hikers and backpackers enjoy the stream corridor as well, relishing the rugged grandeur of the 1,500‐foot deep canyon. Hikers can find complete isolation trekking into the lower reaches of Fourmile Creek and Luders Creek amidst lush riparian zones surrounded by stately ponderosa pines along infrequently maintained trails. The area’s eastern boundary is effectively blocked by private land, so access is restricted to the west via Saguache Park. A network of rugged four‐wheel drive routes define the area’s western boundary, and these receive light use other than during hunting season. Even in the peak of the summer camping season, just a handful of visitors explore the remote road network and even fewer venture cross‐country into the surrounding roadless landscape. The area’s topography enhances the sensation of outstanding solitude owing to rocky fin‐ shaped ridges that separate small meadows and canyons in between. Size and Roadlessness The proposed Saguache Creek wilderness is 27,100 acres, which places it among the largest stand‐alone roadless areas on the forest. The boundary excludes all roads ML2 and above. Even some of these excluded ML2 roads are effectively just ATV trails at this point owing to significant erosion and deterioration such as FDR 736 to Duck Creek.

Supplemental Values

The proposed wilderness centered on Saguache Creek, lower Fourmile Creek, and Luders Creek includes significant portions of two Colorado Natural Heritage Program Potential Conservation Areas (PCAs) – Saguache Creek and Luders Creek. The seven miles of Saguache Creek’s mainstem comprises the lowest segment of the Saguache Creek PCA. Saguache Creek is ranked as High Biodiversity Significance owing to its montane willow carr associations within the creek’s floodplain and valley toe slopes. The lower half of the Luders Creek PCA within the proposed wilderness is also ranked as High Biodiversity Significance because of its montane riparian shrublands, which combined with aspen forests and shrubby cinquefoil shrublands on adjacent terraces creates a structurally and floristically diverse assemblage of riparian and moist toe slope plant communities. (CNHP PCA Reports for Luders Creek, Saguache Creek, 2015).

The proposed Saguache Creek wilderness helps fill the largest geographic gap in the wilderness system in the Southern Rockies. The area is part of the ecological connection between the large protected wilderness areas of the San Juans to the south and the equally important preserves of the Elk, Sawatch, and Sangre de Cristo ranges to the north and east. The proposed wilderness also provides ecological continuity from the grasslands along lower Saguache Creek extending up through to its headwaters amidst the alpine tundra of the nearby La Garita Wilderness. (SREP Wildlands Network Vision 2003; Aplet et al Indicators of Wildness 2000.)

The proposed Saguache Creek wilderness includes the largest expanses of grassland and ponderosa pine forest available for addition to the National Wilderness Preservation System among all of the available candidate areas on the Rio Grande National Forest. These two ecosystem types are critically under‐represented among existing wilderness both regionally within the Southern Rockies and at the national level. By protecting this area, the Rio Grande NF can increase the ecological representation within its wilderness areas of Southern Rocky Mountain Montane‐Subalpine Grassland and Southern Rocky Mountain Ponderosa Pine Woodland from less than 5% of the overall ecosystem acreage on the forest. (TWS ecosystem representation report, 2016)

Manageability

Saguache Creek along with its neighboring Fourmile Creek and Luders Creek is a relatively compact unit with one or two cherrystemmed routes penetrating its boundary. The area’s eastern boundary is largely inaccessible to public use owing to private lands controlling the valley bottom along Saguache Creek. The boundary along Saguache Creek section is the topographically distinct canyon rim. The western boundary in the Fourmile Creek and Luders Creek watersheds is defined along remote four‐wheel‐drive routes, primarily Forest Development Road 740. All trails in the proposed wilderness are designated non‐ motorized. There are no oil and gas leases or non‐federal inholdings.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive Recreation 1909.12,chapter 70, section 72 USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values High Biodiversity Significance CNHP PCA Reports 2015 Wild and Scenic River Eligibility Rio Grande Forest Plan, 1996 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem Representation TWS Ecosystem Representation 2016

Blanca Peak addition to Sangre de Cristo Wilderness

Proposed Wilderness Designation Rio Grande National Forest 4,200 acres Conejos Peak Ranger District

General Description

The Blanca Peak addition to the Sangre de Cristo Wilderness includes two prominent Colorado fourteeners – 14,345‐foot Blanca Peak and its neighboring 14,037‐foot Little Bear Peak. The proposed addition abuts a contiguous wilderness addition that is comprised of Lily Lake and the Huerfano River headwaters on the adjacent San Isabel National Forest. Most mountaineers probably assume these rugged peaks are already included within the wilderness, but a comprehensive boundary expansion that incorporates that portion of the Blanca massif on national forest lands would significantly enhance the integrity of existing wilderness.

Blanca Peak is revered by many indigenous cultures in the Southwest, and has been identified as a potential Special Interest Area in recognition of its tribal cultural significance. The addition’s landscape consists of sweeping glaciated valleys, soaring granitic peaks, and high alpine lakes. Elevations range from the pinyon‐juniper dominated lower slopes of the San Luis Valley through a seamless transition of ecotypes to the rock summits of the high peaks. The challenging jeep trail to Lake Como is excluded from the wilderness addition.

Naturalness

The proposed Blanca Peak wilderness addition is remote and protected from prior development by its ruggedness, sheer topography and the adjacent private ranch that precluded access from the south. The Lake Como jeep trail forms the northern boundary of the proposed wilderness addition and is excluded from the wilderness. A block of patented mining claims on Little Bear Peak’s west shoulder show scant evidence of surface disturbing activity and does not impair the appearance of naturalness across the larger area.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation

The Blanca Peak addition at its highest point rises almost 7,000 feet above the San Luis Valley. The area’s soaring elevation, precipitous alpine ridges, and secluded glacial valleys conspire to create outstanding opportunities for solitude. This is particularly the case for the trail‐less valley of Little Bear Lake.

Blanca Peak and Little Bear Peak draw mountaineers hoping to reach the summits and test their mountaineering abilities in highly challenging circumstances. Little Bear Peak ranks among the most technically difficult summits among Colorado’s 54 fourteeners, which enhances the outstanding character of this primitive recreational pursuit. An estimated 1,000‐3,000 climbers attempt Blanca Peak annually, while less than 1,000 pursue Little Bear’s summit (Colorado Fourteeners Initiative, 2015). A half‐dozen alpine lakes draw hikers, campers, and photographers keen on experiencing jaw‐dropping mountain scenery.

Size and Roadlessness The proposed Blanca Peak wilderness addition is 4,200 acres in size. The area is bounded on the north by the adjacent Sangre de Cristo Wilderness.

Supplemental Values

Blanca Peak has outstanding value to native peoples of the Southwest. The Navajo, Ute, and Jicarilla Apache consider the peak sacred, and it is also important within the cultural landscape of the Upper Rio Grande pueblos. The tribes have a strong interest in maintaining the area’s pristine nature. The Navajo Nation has proposed designation as a Traditional Cultural Property. (Rio Grande NF tribal assessment, 2015)

The proposed Blanca Peak addition enhances the ecological effectiveness of the Sangre de Cristo Wilderness by expanding the size of the protected area. It specifically interconnects to the Huerfano River headwaters and Lily Lake on Blanca Peak’s northern slope, creating overarching protection for the entirety of the Blanca Peak massif when considered in conjunction with the conserved lands on the adjacent Trinchera Ranch to the south. Larger protected areas are more likely to provide conditions for species persistence over the long term than smaller areas. (SREP Wildlands Network Vision 2003; Aplet et al Indicators of Wildness 2000.)

Ecosystem types along the lower slopes of the proposed addition are poorly represented within the Rio Grande’s existing wilderness areas. Wilderness designation of the Blanca Peak addition would increase ecological representation of Southern Rocky Mountain Montane‐Subalpine Grassland, Southern Rocky Mountain Ponderosa Pine Woodland, and Southern Rocky Mountain Pinyon‐Juniper Woodland, each of which occur in designated wilderness at less than 5% on the forest. (TWS ecosystem representation report, 2016)

Manageability

The Blanca Peak addition is comprised of remote and steep ridges and peaks of the Sangre de Cristos, and intervening glaciated valleys. The area is generally bounded on the north by the adjacent Sangre de Cristo Wilderness. The southerly and easterly boundary is the private Trinchera Ranch, which is managed compatibly under a conservation easement. Rural lands administered by BLM abut the area’s western boundary. The northeast slopes of Blanca Peak are contiguous with adjacent wilderness‐quality lands managed by the Pike‐ San Isabel National Forest at the headwaters of the Huerfano River. The rugged jeep trail to Lake Como is adjacent to the existing wilderness boundary and forms the northern boundary of the addition, and would be a cherry‐stem into the Sangre de Cristo Wilderness boundary once the addition is completed. There are no oil and gas leases in the area. There is a 51.65‐acre block of largely inaccessible patented mining claims on the precipitous western ridge of Little Bear Peak for which there is no vehicular access. Is it unlikely these will pose a conflict with wilderness as many similarly situated inholdings have been acquired in wilderness areas throughout Colorado and elsewhere, and historic access has been by foot and horse.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation SLVEC Roadless area description 2002 Colorado Fourteeners Initiative hiker use estimates, 2015 Supplemental Values Cultural significance Rio Grande NF Assessment 12, Areas of Tribal Importance, 2015 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem representation TWS Ecosystem Representation 2016 Manageability Sangre de Cristo Conservation Area USFWS Sangre de Cristo Conservation Area Land Protection Plan, 2012

Butterfly Creek–Miller Creek addition to Sangre de Cristo Wilderness

Proposed Wilderness Designation Rio Grande National Forest 4,100 acres Saguache Ranger District

General Description

The Butterfly Creek and Miller Creek additions bring the Sangre de Cristo Wilderness boundary to a more logical contour along the range’s lower slopes in the northern San Luis Valley. Large undulating alluvial fans characterize the wilderness additions, and a rare oak savanna ecosystem occurs across the lower slopes and riparian corridors of the two areas. It also includes sagebrush habitat for the only population of Gunnison sage grouse in the San Luis Valley.

The additions create a continuous wilderness ecosystem transition from sagebrush, oak and grasslands at the foot of the range through aspen and spruce‐fir forests to the crest of the Sangre de Cristo mountains. This is a remote and lightly visited portion of the Sangres, with outstanding sensation of isolation.

Naturalness

Butterfly Creek and Miller Creek have intact ecological processes in a setting free of substantially noticeable human imprints. Roads and ways are excluded from the boundary.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation

The draws and riparian corridors found within Butterfly Creek and Miller Creek create immediate opportunities to experience outstanding solitude and remoteness. For those willing to scale the steeply rising slopes, the elevation quickly establishes a strong sense of separation from the San Luis Valley’s rural landscapes and distant Highway 285.

Butterfly Creek and Miller Creek are both free of trails, but two‐track vehicle ways provide access through adjacent BLM lands and terminate at the area’s boundary. Visitors take advantage of the area’s remote character for high‐quality, backcountry hunting opportunities in fall.

Size and Roadlessness The proposed Butterfly Creek and Miller Creek wilderness additions comprise about 4,100 acres and both share extensive boundaries with the adjacent Sangre de Cristo Wilderness. The boundary includes the now closed and revegetating ends of several forest roads. Forest Road #993 along Eaglebrook Creek does not exist on the ground, is marked as closed to motorized use, and there is no evidence that any motorized use has occurred on this route for many years (see photo). The last one‐third mile of Forest Road #992 along Butterfly Creek receives no motor vehicle use after it crosses Butterfly Creek, and is being reclaimed by vegetation. The former road (#994) along Raspberry Creek ends on BLM land one‐half mile below the national forest boundary.

Supplemental Values

The rare oak savanna at the lowest elevations of the Butterfly Creek and Miller Creek additions lies within the Sangres Alluvial Fan Potential Conservation Area, ranked by the Colorado Natural Heritage Program as High Biodiversity Significance. The Sangres Alluvial Fan PCA supports an excellent and large occurrence of an unusual association of Gambel's oak (Quercus gambelii) with needle‐and‐thread grass (Hesperostipa comata), the only documented occurrence in the world. In addition, the creeks that run through the savanna from the Sangre de Cristo mountains exhibit unusually high quality occurrences of riparian forest dominated by either aspen or oak. (CNHP PCA Report, 2015)

The lower portion of the Butterfly Creek addition is also within the Decker Creek PCA, which Colorado Natural Heritage Program also ranks as High Biodiversity Significance. This PCA was identified for its value as sagebrush habitat for the small and only population of Gunnison sage grouse in the San Luis Valley. (CNHP PCA Report, 2015)

The proposed Butterfly Creek and Miller Creek additions enhance the ecological effectiveness of the Sangre de Cristo Wilderness by expanding the size of the protected area. In these locations, the current wilderness boundary extends less than one mile down from the crest of the range. With the additions, the boundary would double in width and incorporate a more defensible topographic contour. Larger protected areas are more likely to provide conditions for species persistence over the long term than smaller areas. (SREP Wildlands Network Vision 2003; Aplet et al Indicators of Wildness 2000.)

Butterfly Creek and Miller Creek are particularly valuable wilderness additions for their contribution of Rocky Mountain Gambel Oak‐Mixed Montane Shrubland to the range of ecological representation within Rio Grande National Forest wilderness areas. This is a very poorly represented ecosystem both within the Rio Grande as well as nationally. Wilderness designation of these two additions will bring representation of this oak savanna ecosystem to over 20% on the forest. (TWS ecosystem representation report, 2016)

Manageability

The Butterfly Creek and Miller Creek additions can be managed to preserve their wilderness characteristics. The additions are bounded on one side by the existing wilderness and on the other by undeveloped lands managed by BLM. There is one patented mining claim in the steep headwaters of South Rock Creek that lacks vehicle access, but the only two other similar inholdings in the Sangres were quickly acquired 20 years ago soon after wilderness designation. There are no oil and gas leases.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values High Biodiversity Significance CNHP PCA Report 2015 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem representation TWS Ecosystem Representation 2016

Cotton Creek–Crestone addition to Sangre de Cristo Wilderness

Proposed Wilderness Designation Rio Grande National Forest 11,000 acres Saguache Ranger District

General Description

The proposed Cotton Creek–Crestone addition refers to approximately 11,000 acres along the front of the Sangre de Cristo mountains ranging over a dozen miles between Crestone and Valley View Hot Springs. This one or two‐mile wide strip extends the wilderness boundary to a more obvious contour at the national forest boundary.

This addition incorporates the lower few miles of six or seven trails leading into the adjacent wilderness from wilderness trailheads at the forest boundary. The addition is extremely rich in biodiversity, encompassing significant portions of a half‐dozen conservation areas identified for their biodiversity value by the Colorado Natural Heritage Program largely because of the excellent condition and uncommon quality of the riparian corridors. Not surprisingly, these low elevation lands are dominated by ecosystem types poorly represented within existing wilderness, such as pinyon‐juniper woodlands, montane grasslands, and ponderosa pine.

Naturalness

The Cotton Creek–Crestone addition is characterized by steep slopes and deep canyons with few apparent unnatural impacts. The riparian corridors in these canyons are almost uniformly pristine and in excellent ecological condition. The few areas with more substantial historic mineral prospecting impacts situated nearby clusters of patented mining claims are excluded from the boundary.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation

The Cotton Creek–Crestone addition is a region of rugged terrain, with steep mountainsides and plunging valley bottoms. Each of the parallel valleys is topographically isolated from its neighbors, and each provides an outstanding sense of remoteness and solitude.

The Cotton Creek–Crestone wilderness addition abuts a half‐dozen wilderness trailheads along the lower flanks of the Sangre de Cristo mountains between Crestone and Valley View Hot Springs. The addition takes in the first mile or two of these wilderness access trails that include Cotton Creek, Wild Cherry Creek, Rito Alto Creek, San Isabel Creek, Major Creek, Garner Creek, and Hot Springs Canyon. Many of these trails lead to high alpine basins and lakes and find great popularity among hikers, anglers, and horsepackers enjoying the outstanding opportunities for primitive recreation pursuits. Most of the high lakes accessed by these trails contain recreational populations of Rio Grande cutthroat trout. The wilderness addition provides key winter range for bighorn sheep, mule deer, and elk and draws backcountry hunters in fall seeking an outstanding primitive hunting experience.

Size and Roadlessness The proposed Cotton Creek–Crestone wilderness addition spans about 11,000 acres and shares over a dozen miles of boundary with the adjacent Sangre de Cristo Wilderness.

Supplemental Values

The long length of the proposed Cotton Creek–Crestone wilderness addition spans six Potential Conservation Areas identified by the Colorado Natural Heritage Program. Each of these incorporate several miles of drainages that possess uncommon riparian forest and streamside ecological communities in excellent condition.  Starting at the northernmost end of the addition, Valley View PCA is a site of High Biodiversity Significance that includes the slopes and stream bottom of Hot Springs Canyon. The site was identified because of the excellent example of bristle cone pine distributed throughout the canyon.  The Garner Creek PCA supports a dense stand of Douglas‐fir with an understory of Rocky Mountain maple. Garner Canyon is wider than most of the other gorges draining the western flank of the Sangre de Cristo Mountains, and the valley bottom is less steep. It is of Moderate Biodiversity Significance.  The lower end of the Cotton Creek PCA includes a streamside community that is a very diverse collection of aspen, river birch, Rocky Mountain maple, Drummond's willow, and Woods rose. A key feature of the Cotton Creek PCA is its unusually healthy and large stands of river birch occurring in a high‐quality montane riparian forest, along with adjacent foothills riparian shrubland. It ranks as a site of High Biodiversity Significance.  The addition includes the lower segment of the Wild Cherry Creek PCA, where a good example of a quaking aspen and red‐osier dogwood community fills the canyon and ranks as Moderate Biodiversity Significance.  The upper portion of Rito Alto Bosque PCA is located within the wilderness addition and ranks as High Biodiversity Significance. Extensive stands of aspen/western birch and narrow‐leaf cottonwood/western birch riparian forests line the riparian corridor that extends along the alluvial fan from the mouth of Rito Alto Canyon.  The Dimick Gulch PCA is the highest ranked site within the wilderness addition, and is considered of Very High Biodiversity Significance. The entirety of this 1,747‐acre conservation area is situated within the proposed wilderness addition. The site contains very uncommon narrowleaf cottonwood and Rocky Mountain juniper dominated riparian areas, and occurs here because of the narrow character of this steep‐sided canyon. (CNHP PCA Report, 2015)

Mill Creek is a seventh drainage of biodiversity significance. The lower half of the designated Mill Creek Research Natural Area is located within the proposed wilderness addition. The RNA is notable for its extensive and high quality pinyon‐juniper woodlands on gentle alluvial fan slopes as well as adjacent steeper bedrock.

The proposed Cotton Creek–Crestone addition enhances the ecological effectiveness of the Sangre de Cristo Wilderness by expanding the size of the protected area. This addition would create the widest portion of the entire Sangre de Cristo Wilderness, expanding the boundary to a full 10 miles across the range for almost the entire length of this dozen‐mile long expansion. Larger protected areas are more likely to provide conditions for species persistence over the long term than smaller areas. (SREP Wildlands Network Vision 2003; Aplet et al Indicators of Wildness 2000.)

As to be expected with the abundance of lower elevation slopes along the foot of the Sangre de Cristo mountains, the Cotton Creek–Crestone addition would significantly contribute to several ecosystem types most under‐represented within the Rio Grande’s existing designated wilderness. The most substantial increases in ecological representation occur for Southern Rocky Mountain Montane‐Subalpine Grassland, Southern Rocky Mountain Ponderosa Pine Woodland, and Southern Rocky Mountain Pinyon‐Juniper Woodland. Collectively, the addition would add over 6,000 acres of these poorly represented ecosystem types for which less than 5% of available acreage is presently contained within designated wilderness. (TWS ecosystem representation report, 2016)

Manageability

The Cotton Creek–Crestone addition can be readily managed to preserve its wilderness characteristics. The additions are bounded on one side by the existing wilderness and on the valley side either by undeveloped lands managed by BLM or rural agricultural lands. The proposed boundary generally excludes the patented mining claims in North Crestone Creek, but does include the single isolated patented mining claims in Cedar Creek and Wild Cherry Creek. These inholdings lack vehicle access. The Forest Service successfully acquired similar inholdings after the Sangre de Cristo Wilderness was first designated in1993. There are no oil and gas leases.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values High Biodiversity Significance CNHP PCA Report 2015 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem representation TWS Ecosystem Representation 2016

Kit Carson Peak addition to Sangre de Cristo Wilderness

Proposed Wilderness Designation Rio Grande National Forest 12,300 acres Saguache Ranger District

General Description

The proposed Kit Carson Peak wilderness addition is most renowned for the three 14,000- foot summits of the Kit Carson massif, including Challenger Point and Columbia Point. The 12,300-acre addition consists entirely of that portion of the Baca Mountain Tract conveyed into Forest Service jurisdiction by the Great Sand Dunes National Park Act of 2000. The peaks form the backdrop of one of the San Luis Valley’s most photogenic settings as the towering crest at the heart of the Sangre de Cristos.

As this was previously part of a private ranch for the prior hundred years, there are no formal forest recreation trails, though the summits of the peaks draw numerous mountaineers. This isolation has helped preserve an area of remarkable biological significance, with the four major drainages all encompassed by one of a half-dozen conservation areas identified for their biodiversity value by the Colorado Natural Heritage Program. Each stream corridor has an excellent condition narrowleaf cottonwood–Rocky Mountain juniper montane riparian forest. A designated Research Natural Area is located immediately adjacent within the existing wilderness.

Photo USDA Forest Service

Naturalness

The proposed Kit Carson Peak wilderness addition has been isolated and largely inaccessible to most development activities owing to its private status. The area is characterized by the steep western slopes of the Sangre de Cristo mountains and deep canyons with few apparent unnatural impacts. The riparian corridors in these valleys are almost uniformly pristine and in excellent ecological condition. The southern end of the area with impacts associated with historic mining activity around Liberty and Duncan is cherry-stemmed out of the proposed wilderness boundary.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation

The Kit Carson Peak proposed wilderness addition consists of the rugged west slope of the Sangre de Cristo range south of Crestone. The fault block uplift creates a region of craggy terrain, with steep mountainsides and plunging valley bottoms. The area includes several parallel valleys, each topographically isolated from its neighbors, and each provides an outstanding sense of remoteness and solitude.

The Kit Carson Peak addition has no designated national forest system trails owing to its prior status as part of a private ranch, and thus receives significantly less use than other valleys on the western slope of the Sangres. The Baca Grande subdivision blocks public access from the west, but there are informal routes along several of the valleys, including Cottonwood, Spanish, and Deadman creeks. These routes provide some of the most challenging primitive recreation opportunities for hikers and backpackers in the Sangre de Cristo mountains. Lower Deadman Creek does have public access from the Liberty Road and provides outstanding opportunities for equestrians as well as hikers and backpackers. A substantial number of mountaineers climb the collection of fourteeners as part of the Kit Carson Peak massif, and while the summits are within the wilderness addition in its far northeast corner, the hiking access routes to the summits such as along Willow Creek are located in the existing wilderness. (Baca Mountain Tract EA, 2009)

Size and Roadlessness The proposed Kit Carson Peak wilderness addition is about 12,300 acres in size, and is bounded on the north and east by the adjacent Sangre de Cristo Wilderness.

Supplemental Values

The proposed Kit Carson Peak wilderness addition spans six Potential Conservation Areas identified by the Colorado Natural Heritage Program. These encompass each of the primary drainages that flow west off the crest of the Sangres – Willow Creek, Spanish Creek, Cottonwood Creek, and Deadman Creek. As with the drainages farther north of Crestone, the biodiversity values are associated with healthy riparian corridors.  The upper portion of the Willow Creek-Western Sangres PCA in Copper Gulch is located within the proposed wilderness addition. The PCA is ranked as High Biodiversity Significance, but primarily for a narrowleaf cottonwood–Rocky Mountain juniper woodland at the lowest elevations below the proposed wilderness. At the elevation of subalpine forest within the potential wilderness unit, the riparian corridor is a mixed conifer and deciduous forest and shrubland that includes Douglas-fir, white fir, blue spruce, Engelmann spruce, aspen, Rocky Mountain maple, and mountain spray.  The Head of Spanish Creek PCA site encompasses the ridge and south-facing open slopes above Spanish Creek and below Challenger Point, and is entirely within the proposed wilderness. This 110-acre site is ranked as High Biodiversity Significance for a globally rare mustard species.  The entire length of the Spanish Creek drainage comprises the Spanish Creek PCA, most of which is located within the proposed wilderness. This is a site of Very High Biodiversity Significance owing to its narrowleaf cottonwood–Rocky Mountain juniper montane riparian forest. The upstream watershed is included within the site boundary to protect the floodplain and the sources of both surface and groundwater recharge and flow, which are responsible for supplying water to the riparian plant community.  Cottonwood Creek–Western Sangres is another PCA of Very High Biodiversity Significance, also for its globally imperiled narrowleaf cottonwood–Rocky Mountain juniper montane riparian forest. In addition, the site includes a Douglas fir–water birch community, which is considered globally rare. As with Spanish Creek, the majority of the PCA is within the proposed wilderness, and the upstream watershed is included to protect water sources.  The central portion of the Deadman Creek–Western Sangres PCA is located within the proposed wilderness. Deadman Creek is ranked as Very High Biodiversity Significance owing to the state’s exemplary and largest occurrence of narrowleaf cottonwood–Rocky Mountain juniper montane riparian forest. The PCA also includes an excellent example of aspen–Rocky Mountain maple, a breeding colony of the pale lump-nosed bat and a hybridized Rio Grande cutthroat trout population.  Cedar Canyon is another PCA with a quality example of narrowleaf cottonwood– Rocky Mountain juniper montane riparian forest. It is also ranked Very High Biodiversity Significance. The creek is a clear stream that runs over the alluvial fan at the canyon’s mouth. (CNHP PCA Report, 2015)

Immediately upstream on Deadman Creek is a designated Research Natural Area. The RNA was designated for its good representation of aspen over a wide range of elevations, slopes, and aspects. The RNA includes the riparian corridor and source water for the downstream CNHP Potential Conservation Area.

The higher elevations of the proposed wilderness are bighorn sheep habitat, which is relatively uncommon on the Rio Grande National Forest. Bighorn sheep habitat comprises about one-half of the proposed wilderness addition.

The proposed Kit Carson Peak addition enhances the ecological effectiveness of the Sangre de Cristo Wilderness by expanding the size of the protected area. This addition would complete the wilderness boundary and eliminate the unnatural 90-degree corner boundary of the existing wilderness that is a relic of the Baca Grant. The addition would also take this portion of the Sangre de Cristo Wilderness to a width of eight miles or more. Larger protected areas are more likely to provide conditions for species persistence over the long term than smaller areas. (SREP Wildlands Network Vision 2003; Aplet et al Indicators of Wildness 2000.)

The area’s prevalence of lower elevation slopes along the foot of the Sangre de Cristo mountains means the Kit Carson Peak addition would greatly expand several ecosystem types most under-represented within the Rio Grande’s existing designated wilderness. Substantial increases would occur in ecological representation for Southern Rocky Mountain Montane-Subalpine Grassland, Southern Rocky Mountain Ponderosa Pine Woodland, and Southern Rocky Mountain Pinyon-Juniper Woodland. Collectively, the addition would add over 5,000 acres of these poorly represented ecosystem types for which less than 5% of available acreage is presently contained within designated wilderness. (TWS ecosystem representation report, 2016)

Manageability

The Kit Carson Peak addition is comprised of remote, steep, and largely inaccessible western slopes of the Sangre de Cristos. The topography creates impediments to incompatible activities, and allows managers to preserve its wilderness characteristics. The area is bounded on north and east by the existing wilderness and on the valley side by Great Sand Dunes National Park and by the agricultural-zoned open space component of the Baca Grande.

The mineral estate beneath the wilderness addition is privately held. A Mineral Assessment Report completed in 2011 concluded slight likelihood of development of metallic minerals beneath the proposed wilderness, although there could be high potential for occurrence of gold, silver or other metallic minerals. The low prospect of development is predicated on several factors – lack of mining infrastructure, societal resistance as per experience from other large mining operations around the San Luis Valley, and likely removal of high-grade deposits by historic mining operations. Although the current mineral owner drilled several prospecting holes in the early 1990s, there has not been any viable commercial mineral extraction from the Sangre de Cristos since the 1930s. (Rare Earth Science Mineral Assessment Report, 2011)

The National Park Service identified 53,000 acres of adjacent lands as wilderness eligible in Great Sand Dunes National Park with the identical split-estate mineral ownership as the Kit Carson Peak unit. The National Park Service concluded likelihood of mineral extraction was low, and combined with the expected eventual acquisition of the mineral interests, NPS determined its lands wilderness-eligible and formally recommended its lands overlying the private mineral estate for wilderness designation. The NPS recommended wilderness is directly adjacent to the Kit Carson Peak unit south of the Liberty Road. If the Forest Service declines to pursue wilderness designation for the Kit Carson Peak area, it will still be surrounded on three sides by designated and recommended wilderness. (Great Sand Dunes NP GMP/Wilderness Study, 2007)

The Great Sand Dunes National Park Act of 2000 authorized the acquisition of lands and interests therein, such as mineral rights, and transfer to the appropriate agency jurisdiction for management. The Forest Service has the authority, as does the National Park Service, to pursue future acquisition of the split-estate minerals in proposed or potential wilderness.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR xx Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values High Biodiversity Significance CNHP PCA Report 2015 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem representation TWS Ecosystem Representation 2016 Manageability Mineral Assessment Report Rare Earth Science, 2011 NPS Wilderness Recommendation Great Sand Dunes NP General Management Plan/Wilderness Study, 2007 Wilderness eligibility analysis Baca Mountain Tract EA, 2009

Sawlog recommended wilderness

Proposed Wilderness Designation Rio Grande National Forest 17,900 acres Saguache Ranger District

General Description

The proposed Sawlog wilderness generally encompasses the watershed of the North Fork of Carnero Creek, northwest of La Garita. It extends from the foothills of the San Luis Valley to 10,849‐foot Storm King Mountain, spanning ecosystems ranging from grasslands and ponderosa pine woodlands at the lowest elevations to aspen and spruce‐fir at highest elevations.

The North Fork of Carnero Creek is a stronghold for Rio Grande cutthroat trout and its headwaters have been identified as one of the premier wetland complexes on the Rio Grande National Forest. Sawlog provides important big game habitat year‐round for elk, deer, and bighorn sheep, and offers excellent backcountry hunting for those willing to invest the effort.

Naturalness

The proposed Sawlog wilderness includes areas with prior two‐track vehicle routes made by hunters and wood gatherers that have since been closed and rehabilitated. The boundary is drawn to exclude exterior roads and timber harvest areas.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation The valley of the North Fork of Carnero Creek and its tributary creeks are isolated by rugged surrounding ridges, creating outstanding opportunities for solitude. The area lacks a well‐developed trail system other than the non‐motorized trail along the North Fork, a factor that enhances opportunities for solitude in tributaries including Sawlog Creek and Poison Gulch. Sawlog provides abundant, quality opportunities for primitive backcountry hunting and fishing. The areas of Sawlog Creek and the North Fork of Carnero Creek provide important production habitat for the local bighorn sheep herd. Elk and deer winter on the southern aspects and will move up and down in elevations depending on the winter and are often discovered during the remainder of the year. The prime habitat draws hunters seeking a more remote and challenging hunting opportunity during fall months. Size and Roadlessness The proposed Sawlog wilderness is ample size at 17,900 acres. It is bounded on the east and south by the national forest boundary and adjacent BLM lands for the most part. The western boundary is well‐delineated by County Road 41G along Carnero Creek’s Middle Fork, and the northern boundary is defined by Forest system roads and past areas of timber harvest.

Supplemental Values

The proposed Sawlog wilderness includes a portion of the Carnero Creek Potential Conservation Area identified by the Colorado Natural Heritage Program. Carnero Creek is ranked as High Biodiversity Significance owing to its bristlecone pine woodland, a montane grassland, and a Rio Grande cutthroat trout population, all of which are state rare. This population of Rio Grande cutthroat progresses in quality as one continues up the stream. (CNHP PCA Report for Saguache Creek, 2015).

The North Fork of Carnero Creek hosts a high purity, core conservation population for Rio Grande cutthroat trout. (Conservation Plan for Rio Grande Cutthroat Trout in Colorado, CDOW, 2004)

The proposed Sawlog wilderness addition greatly increases the ecological representation within Rio Grande National Forest wilderness areas of several of the most under‐ represented ecosystem types on the forest. Sawlog includes thousands of acres of Southern Rocky Mountain Montane‐Subalpine Grassland, Southern Rocky Mountain Ponderosa Pine Woodland, and Southern Rocky Mountain Pinyon‐Juniper Woodland – all ecosystem types currently with less than 5% representation of the overall ecosystem acreage on the forest. (TWS ecosystem representation report, 2016)

Manageability

The proposed Sawlog wilderness is manageable as wilderness. The area is bounded on two sides by adjacent unroaded BLM lands. The western boundary is well‐defined by County Road 41G and the steep slopes of Storm King Mountain. Forest system roads and past timber management areas define the northern boundary. There is just one trail within the area, the non‐motorized trail along the North Fork of Carnero Creek. One 160‐acre private inholding exists in the center of the area, but there is presently no motorized access to it. There are no oil and gas leases.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values High Biodiversity Significance CNHP PCA Reports 2015 Rio Grande Cutthroat Trout Conservation Plan for the Rio Grande Cutthroat Trout in Colorado. Colorado Division of Wildlife; CNHP PCA Report 2015 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem Representation TWS Ecosystem Representation 2016

Snowshoe Mountain addition to Weminuche Wilderness

Proposed Wilderness Designation Rio Grande National Forest 34,300 acres Divide Ranger District

General Description

Snowshoe Mountain is the largest roadless area adjacent to the Weminuche Wilderness. Moderate to steep forested slopes rise out of the Rio Grande valley immediately south of Creede, with the mountain bisected by the long undeveloped watershed of Deep Creek. The proposed wilderness addition is split into two units along the Deep Creek trail in order to accommodate mountain bike use of the trail.

This large forested extension north of the Weminuche comprises important and highly utilized habitat for lynx. Snowshoe Mountain also provides valuable habitat for big game and outstanding backcountry recreation opportunities at Creede’s doorstep. The mountain offers intriguing geologic interest as a resurgent dome within the Creede caldera bisected by conspicuous graben faults.

Naturalness

Snowshoe Mountain is a compact oval‐shaped unit nearly 9 miles across. The Lime Creek Road (FDR #528) accesses areas previously managed for timber harvest at the southern end of the area, but the road and past timber management areas are excluded from the proposed wilderness addition. The area is free of noticeable human improvements and possesses ecologically intact forest and grassland ecosystems.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation Snowshoe Mountain consists of steeply forested slopes looming over the Rio Grande valley. The area’s size and forbidding slopes create ideal opportunities for outstanding solitude.

This large area is bisected by a non‐motorized trail along Deep Creek. The Deep Creek Trail is easily accessible from Creede and is popular among hikers, anglers, and horse users. It offers an easy gradient for recreationists to quickly penetrate the area’s remote interior. A second trail atop the mountain descends to a dead‐end at private property on Pierce Creek. This trail provides access to a very remote and lightly visited portion of the area. Both trails provide access to outstanding opportunities for primitive and unconfined recreation.

Size and Roadlessness

The proposed Snowshoe Mountain wilderness addition contains 34,300 acres. It is bounded on the north, west and east by the private lands of the Rio Grande valley. The area is split into two units by the Deep Creek Trail. The Lime Creek Road and associated past timber harvest areas define the remainder of the boundary. The area connects at the south to the adjacent Weminuche Wilderness across a two‐mile wide neck of forest and ridges.

Supplemental Values

The existence of highly utilized, high‐quality lynx habitat comprises a significant supplement wilderness value for Snowshoe Mountain. Important habitat for western boreal toad occurs at the southern end of the area.

Snowshoe Mountain provides geologic features of interest. The mountain is a resurgent volcanic dome formed in the Creede caldera, and the Deep Creek graben is conspicuous at the mountain’s crest. (USGS pamphlet Central San Juan Caldera Cluster, 2006)

Snowshoe Mountain includes the entirety of the 417‐acre Deep Creek Uplands West PCA, which is a Potential Conservation Area ranked as Very High Biodiversity Significance. This PCA includes one of the best known populations of Smith whitlow‐grass, a Colorado endemic and globally imperiled species, as well as a population of globally imperiled black canyon gilia. Snowshoe Mountain includes a portion of the 3,346‐acre Spar City Potential Conservation Area identified by the Colorado Natural Heritage Program. Spar City PCA is ranked as Moderate Biodiversity Significance owing to its large and excellent quality occurrence of a state rare bristlecone pine/Thurber fescue (Pinus aristata/Festuca thurberi) montane woodland, a plant association limited to the southern Rocky Mountain ecoregion. (CNHP PCA Report, 2015).

Snowshoe Mountain contributes thousands of acres of one of the most under‐represented ecosystem types among existing wilderness areas on the Rio Grande National Forest. By protecting this area, the Rio Grande NF can significantly increase the ecological representation within its wilderness areas of Southern Rocky Mountain Montane‐ Subalpine Grassland. (TWS ecosystem representation report, 2016)

Manageability

Snowshoe Mountain is readily manageable as wilderness owing to its compact configuration. The mountain rises steeply from the surrounding valley floor on the north and east, which offers an imposing topographic delineation. The proposed wilderness addition excludes the Deep Creek Trail in order to avoid conflicts with mountain biking. Identified areas of potential snowmobiling interest in the Seven Parks are excluded along the southern boundary. The area has no geologic potential for oil and gas resources, and there are no oil and gas leases or non‐federal inholdings within the area. Portions of Snowshoe Mountain are within a Wildland Urban Interface area along the national forest boundary at Kid Peak Estates and at Wagon Wheel Gap identified within the Mineral County Community Wildfire Protection Plan. These can be buffered out of the wilderness boundary if determined necessary.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values High Biodiversity Significance CNHP PCA Reports 2015 Geologic USGS pamphlet Central San Juan Caldera Cluster, 2006 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem representation TWS Ecosystem Representation 2016

Adams Fork – Three Forks Addition to South San Juan Wilderness

Proposed Wilderness Designation Rio Grande National Forest 2,700 acres Conejos Peak Ranger District

General Description

The proposed Adams Fork–Three Forks addition to the South San Juan Wilderness consists of the slopes surrounding the Three Forks and Adams Fork trailheads at the headwaters of the Conejos River above Platoro Reservoir. The addition incorporates the lowest mile of the Adams Fork trail into the adjacent wilderness and encompasses steep and forested slopes of the Conejos River valley. This addition enhances wilderness protection for the area surrounding these two wilderness trailheads that are popular with anglers, hikers, backpackers and horse users. The additions are part of two larger Colorado Roadless Areas, Gold Creek‐Cascade Creek and Tobacco Lakes.

Naturalness

The proposed Adams Fork–Three Forks wilderness addition is affected primarily by the forces of nature. Much of the unit’s mature spruce has succumbed to beetles, similar to surrounding forests. The Adams Fork component consists of the lower mile of the Adams Fork creek corridor. The Three Forks portion includes the steep, forested slopes rising to hanging glacial valleys looming over the Conejos River valley. Topography excludes roads or any other management activities.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation The Adams Fork is a deep, forested stream corridor where visitors immediately encounter a sense of remoteness and solitude upon departing the trailhead. The steep slopes of the Three Forks component is free of trails and consequently receives little to no recreational use, but from the highest points above the Conejos River valley visitors experience an enhanced sense of solitude owing to the separation from the valley floor and expansive vistas.

The Adams Fork trail provides outstanding opportunities for primitive and unconfined recreation in the form of wilderness‐related activities such as hiking, backpacking, horsepacking, angling, and backcountry hunting. The Three Forks addition enhances the primitive recreation experience by ensuring protection of the wilderness qualities of the landscape that envelops the Three Forks wilderness trailhead. Both trailheads are easily accessed from Platoro Reservoir.

Size and Roadlessness The Adams Fork‐Three Fork wilderness addition is 2,700 acres and is adjacent to the existing South San Juan wilderness to the west and south. The wilderness addition surrounds forest road #247 and effectively creates a short cherry‐stem along the road to the Three Forks trailhead.

Supplemental Values

The Adams Fork addition is a documented high use area for lynx and was part of one of the initial core areas lynx established after reintroduction. The steep north‐facing slopes and drainages of the Adams Fork–Three Forks addition potentially support lynx reproduction and serve as hunting territory. (USDA Forest Service, R2, Profiles of Colorado Roadless Areas, 2008)

The Adams Fork addition includes a portion of the Adams Fork of the Conejos River Potential Conservation Area identified by the Colorado Natural Heritage Program. The PCA is drawn to include the riparian habitat necessary to support the Rio Grande cutthroat trout, and the PCA is ranked as High Biodiversity Significance. The Adams Fork supports a recreation population of Rio Grande cutthroat trout. (Conservation Plan for Rio Grande Cutthroat Trout in Colorado, CDOW, 2004; CNHP PCA Report, 2015)

The proposed Adams Fork–Three Forks wilderness addition enhances the ecological effectiveness of the South San Juan Wilderness by expanding the size of the protected area. Larger protected areas are more likely to provide conditions for species persistence over the long term than smaller areas. (SREP Wildlands Network Vision 2003; Aplet et al Indicators of Wildness 2000.)

Manageability

The Adams Fork–Three Forks unit adds areas with easily distinguishable boundaries to the adjacent South San Juan Wilderness. The Adams Fork portion extends the existing wilderness boundary about one mile downstream to a new boundary along forest road #247 and effectively results in the entirety of the Adams Fork drainage being included within the wilderness boundary. The Three Forks component lies east of the Conejos River and its steep slopes provide a topographic barrier to incompatible uses. There are no oil and gas leases and no non‐federal inholdings within the area.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values High Biodiversity Significance CNHP PCA Reports 2015 Rio Grande Cutthroat Trout Conservation Plan for the Rio Grande Cutthroat Trout in Colorado. Colorado Division of Wildlife; CNHP PCA Report 2015 Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem Representation TWS Ecosystem Representation 2016

Elk Creek addition to South San Juans Wilderness

Proposed Wilderness Designation Rio Grande National Forest 3,200 acres Conejos Peak Ranger District

General Description

The proposed Elk Creek addition to the South San Juan Wilderness adds the lower four miles of the stream valley to the wilderness. The lowermost elevations of Elk Creek at less than 9,000 feet include impressive stands of several‐hundred‐year‐old ponderosa pines, many of which display old‐growth characteristics. The low‐elevation ponderosa pine‐ grassland ecosystem adds substantial diversity to the existing wilderness, and the majestic trees offer an appealing contrast to the generally subalpine and alpine character of the wilderness.

Elk Creek is a large tributary of the Conejos River and drains the southern quadrant of the wilderness. The Elk Creek trail is a gentle gradient along a clear tumbling stream that provides a popular wilderness access point for hikers, anglers, and horse users. The proposed wilderness addition creates a topographically defined boundary that incorporates the entirety of the stream valley into the wilderness, as opposed to only a portion of the south half as is currently within the wilderness.

Naturalness

The Elk Creek addition to the South San Juans is a smaller subset of the Cumbres roadless area. The addition is entirely natural with no evidence of past management activities. The unit’s ponderosa pine‐grasslands are a particularly good example of a pine forest in the condition expected from a natural fire regime. Other portions of the Cumbres roadless area that might display more evidence of noticeable human activities are excluded from the proposed wilderness addition.

Outstanding Opportunities for Solitude or Unconfined Primitive Recreation The Elk Creek watershed is a premier destination within the existing South San Juan Wilderness owing to its outstanding opportunities for solitude. The lower Elk Creek addition contributes to that through its topographic isolation as it carves a deep and narrow valley downstream of the existing wilderness boundary. Soon after departing the Elk Creek trailhead, visitors round into the valley’s secluded confines and immediately leave behind civilization’s hustle and bustle. The non‐motorized Elk Creek trail traverses the length of the proposed wilderness addition to the wilderness boundary approximately four miles distant from the trailhead. Elk Creek is an easily accessible and popular wilderness access point for both hikers and horse users. Many day‐hikers and overnight backpackers enjoy outstanding opportunities for fishing, photography, and wildlife viewing. Horsepackers share the trail and similarly enjoy access to the longest wilderness valley in the South San Juans. The area provides excellent habitat for elk and mule deer, which in turns leads to high‐quality backcountry hunting opportunities in the fall. Size and Roadlessness

The proposed Elk Creek addition to the South San Juan Wilderness consists of 3,200 acres adjacent to the existing wilderness. Elk Creek is bounded on the west by the wilderness boundary, and significant topographic features in the form of cliff rims and precipitous ridge tops create boundaries to the north and south.

Supplemental Values

Adding lower Elk Creek to the wilderness notably expands the range of ecosystems present within the existing wilderness because of the presence of uncommon stands of robust ponderosa pine at its lower end. These classic stands of stately ponderosa pine intermixed with park‐like grasslands create a welcome entrance to the wilderness. This is an ecosystem type noticeably absent within the existing wilderness on the Rio Grande National Forest. (TWS ecosystem representation report, 2016)

The proposed Elk Creek addition enhances the ecological effectiveness of the South San Juan Wilderness by expanding the size of the protected area. Larger protected areas are more likely to provide conditions for species persistence over the long term than smaller areas. (SREP Wildlands Network Vision 2003; Aplet et al Indicators of Wildness 2000.)

Manageability

The Elk Creek addition is readily manageable as wilderness and significantly enhances the existing wilderness boundary by bringing the entirety of the Elk Creek valley into the wilderness as compared to the current boundary that protects only the southern half of the valley. The significant topographic barriers of the proposed addition separate the addition from influences on adjacent national forest lands. There are no oil and gas leases or non‐ federal inholdings.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR 294 subpart D Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities for Forest Service inventory pursuant to FSH Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 SLVEC Roadless area description 2002 Supplemental Values Connectivity SREP Wildlands Network 2003, Aplet et al Indicators of Wildness 2000 Ecosystem representation TWS Ecosystem Representation 2016

Rare Earth Science www.rareearthscience.com

August 1, 2011

Christine Canaly San Luis Valley Ecosystem Council Post Office Box 223 Alamosa, Colorado 81101

Re: Mineral Assessment Report Luis Maria Baca Grant No. 4 Property - Saguache County, Colorado

Dear Christine:

Rare Earth Science, LLC (Rare Earth) has completed this Mineral Assessment Report (MAR) for the Luis Maria Baca Grant No. 4 (Baca Grant) property located in southeast Saguache County. The purpose of the MAR was to evaluate the mineral-resource and mineral- development potential in those areas of the Baca Grant, and adjoining lands, where Lexam Explorations (USA) Inc. (also known as Lexam VG Gold Inc. [hereafter, “Lexam”]) holds the subsurface mineral rights.

1. Project Overview

The MAR project included a review of documented historical, or currently-permitted and active, mineral mining or drilling operations in Baca Grant vicinity. A general location map for the study area is attached as Figure 1. For this project, Rare Earth reviewed a variety of published geologic, mining and economic mineral-resource data. Available maps, mining-related permit files, and scientific literature were acquired from sources that include the U.S. Geological Survey (USGS); Bureau of Land Management (BLM); U.S. Forest Service (USFS); U.S. Fish & Wildlife Service (USFWS); National Park Service (NPS); Colorado Division of Reclamation, Mining and Safety (DRMS); Colorado Geological Survey (CGS); Colorado Oil & Gas Conservation Commission (COGCC); San Luis Valley Ecosystem Council and their associates; and Alamosa & Saguache Counties.

This report presents a brief description of the Baca Grant and the local geology, a review of various economic mineral resources (categorized separately as locatable, leasable and saleable minerals), along with a summary of our findings. Rare Earth did not perform a detailed review of land-ownership records or title information for any of the study area; nor was site reconnaissance performed, or sampling & analysis of geologic materials. This MAR is in no way intended to be a mineral appraisal or mineral-examination report. Nor is this report considered to be an opinion on mineral title, mineral valuation or mining-claim validity; or a quantitative analysis of actual mineral resources and/or reserves.

PO Box 4523 | Grand Junction, Colorado 81502-4523 | 970.241.1762 | [email protected] Mineral Assessment Report: Baca Grant No. 4 Property (Saguache County, CO) August 1, 2011 Page 2 of 18

2. Site Location & Description

The attached Figures 1 & 2 show the boundaries of the Baca Grant, which encompass approximately 100,000 acres (12.5 square miles) in all, or portions of, Townships 41 to 43 North and Ranges 10 to 12 East (New Mexico Principal Meridian). Surface ownership and administration of the Baca Grant includes NPS (Great Sand Dunes National Park), USFWS (Baca National Wildlife Refuge [NWR]), Rio Grande National Forest, and numerous private landowners in the Baca Grande Subdivision adjacent to the town of Crestone.

The Baca Grant is located about 25 miles north-northeast of the City of Alamosa and 4 miles east of Colorado State Highway 17. Adjoining lands to the south-southeast are administered by the NPS, by the USFWS to the south and west, and by the Rio Grande National Forest to the north and east. Smaller tracts of privately-owned land also adjoin the Baca Grant in all directions. The terrain is quite varied and encompasses part of the level San Luis Valley floor, upslope over the mountain front and to the crest of the Sangre de Cristo Range.

USGS topographic maps show the ground surface elevation ranging from a low point of approximately 7,500 feet above mean sea level along the west boundary, to a high point of more than 14,000 feet near the northeast corner of the Baca Grant on Kit Carson Mountain and Challenger Point. Numerous drainages traverse all or part of the Baca Grant in a general northeast-to-southwest direction, including (from north to south): Crestone Creek, Willow Creek, Spanish Creek, Cottonwood Creek, Deadman Creek, Pole Creek and Sand Creek. The Baca Grant area is also located within the San Luis Creek district within a closed basin having no known external drainage.

3. Geologic Overview of the Baca Grant Area

The Baca Grant is positioned within the Southern Rocky Mountains physiographic province, with its characteristic rugged, high-elevation peaks and broad intermontane basins. In general, the topography and geology of this area were influenced by several major features including the Sangre de Cristo Range to the east and the San Juan Volcanic Field to the west-southwest. The Baca Grant also lies on the eastern margin of the San Luis Valley and along the western front of the Sangre de Cristo Range. The San Luis Valley coincides with the structural feature called the San Luis Basin, which is a broad, east-dipping half graben that is hinged on the west in the San Juan Mountains and bounded on the east by the Sangre de Cristo Fault at the base of the Sangre de Cristo Range. The San Luis Basin is part of the Rio Grande Rift, a major intracontinental extensional feature from Mexico to central Colorado that originated about 26 to 27 million years ago late during the Oligocene Epoch.

The study area lies on the Baca Half Graben adjacent to the Sangre de Cristo Range to the east. Two major southeast-northwest-trending faults traverse the Baca Grant, in the western part of the property and at the base of the mountains to the east (known as the Sangre de Cristo Fault). Thrust faulting is a common feature in the east-central and northeast corner of the Baca Grant, in those areas east of the Sangre de Cristo Fault.

The Geologic Map of Saguache County (CGS Resource Series 44, 2007) was reviewed for an understanding of local surface and subsurface geologic conditions. According to the map, a

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majority of the Baca Grant is comprised of Quaternary- to Oligocene-age rocks in the Santa Fe Group (Map Unit QTs), described as red sand and conglomerate, volcanic-rich conglomerate, and interbedded basaltic andesite flows in the lower part. Map Unit QTs ranges in thickness from 300 to 11,000 feet. Along the mountain front to the east, there are Holocene & Pleistocene glacial and alluvial surficial deposits (Map Units Qa and Qpt), along with Quaternary eolian deposits ([transverse & parabolic dunes] Map Units Qdt, Qdpf, and Qdpa) in the southeast corner of the Baca Grant in Great Sand Dunes National Park.

Bedrock Paleoproterozoic exposures in the rugged Sangre de Cristo Range along the east boundary and northeast corner of the Baca Grant include a broad area of mafic & felsic gneiss (Map Unit Xgn), and a lesser amount of quartz monzonite of Music Pass (Map Unit Xqm) found between Deadman and Pole Creeks. An overturned bed of Lower Mississippian to Upper Cambrian Leadville Limestone, Chaffee Group, Fremont Dolomite, Harding Quartzite, Manitou Formation and isolated patches of Sawatch Quartzite, undivided (Map Unit MOr) is also exposed at the Deadman Creek thrust fault, which forms an asymmetric east-verging anticline. The northeast corner (and highest reach) of the Baca Grant consists primarily of Middle or Upper Pennsylvanian & Lower Permian Sangre de Cristo Formation (Map Unit PPsc), with a lesser amount of Middle Pennsylvanian Minturn Formation (Map Unit Pm).

3.1. Review of Regional Geology

Precambrian rocks, also known as basement rocks, underlie the entire Baca Grant. They crop out in the Sangre de Cristo Range and are buried by younger rocks and deposits west of the mountains. Most of the Precambrian rocks are estimated to be around 1.7 billion years old. A thick package of younger rocks overlies these Precambrian rocks at the Baca Grant. A sequence of relatively thin clastic and carbonate rocks were deposited over the Precambrian during the lower and middle Paleozoic throughout much of Colorado, probably including the Baca Grant area. During the Pennsylvanian Period the Ancestral Rocky Mountains rose in a series of uplifted highlands and depositional basins developed between the uplifts. Lower and Middle Paleozoic rocks were stripped off the Ancestral Rocky Mountain highlands, and Pennsylvanian sediments accumulated in the basins.

Much, and perhaps all, of modern San Luis Valley was a highland during the Pennsylvanian Period (known as either the San Luis or San Luis-Uncompahgre highland). The exact eastern margin of the ancestral San Luis Highland is not well constrained. Lower and Middle Paleozoic rocks, as well as Pennsylvanian sediments are preserved in the Sangre de Cristo Range, so these areas were likely in the depositional basin known as the Central Colorado Trough, which lay east of the ancestral San Luis Highland.

During Late Cretaceous time, the Western Interior Seaway transgressed across the region depositing sand along the shoreline that would eventually become sandstone; mud beneath the bottom of the sea that would lithify into shale; and local deposits of limestone. These sediments would later become the source and host of much of the oil & gas in Colorado. More sediment was deposited as the seaway retreated from the area, including thick beds of peat on the landward side of the retreating seaway. The peat beds turned into coal as they were subsequently buried by younger sediment.

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Another major period of mountain-building, the Laramide Orogeny, was initiated around 70 million years ago (mya). Rocks were again eroded off the uplifts, including the Mesozoic rocks, and sediment deposition occurred in adjacent basins. Modern San Luis Valley was again the site of an ancient mountain uplift whose boundaries are also poorly understood. Drill holes scattered across much of the San Luis Valley encountered Precambrian rocks beneath the Tertiary fill, indicating those locations were the site of the Laramide uplifts. However, two small remnants of the Mesozoic rocks reportedly crop out in arroyos cut into the alluvial fans in the vicinity of Deadman Creek on the Baca Grant, and Lexam has reported the existence of Mesozoic rocks in the subsurface beneath the Baca Grant based on their Baca Nos. 1 and 2 drill holes (discussed below in Section 4.2.1.) and geophysical studies, suggesting those areas did not undergo mountain uplift and erosional stripping of the Mesozoic sediment.

These Laramide uplifts formed in response to compressional squeezing of the earth’s crust. This led to the development of large, low-angle, thrust faults along the flanks of the uplifts where Precambrian rocks were thrust up and over younger rocks. Scattered igneous intrusions were also emplaced during the Laramide Orogeny, which ended around 45 mya. Starting about 35 mya, widespread volcanism began in the San Juan Mountains west of the San Luis Valley.

Initially the volcanic activity involved andesitic lava flows and volcanic mudflows associated with stratovolcanoes. Rocks from this period of volcanism are commonly called the Conejos Formation; they extended eastward from the San Juan Volcanic Field, perhaps as far east as the Baca Grant. Around 30 mya the volcanism became more silicic and explosive, resulting in the formation of multiple calderas, many of which collapsed when large volumes of ash-flow tuff were violently erupted. Thick sequences of ash-flow tuff filled many of the collapsed calderas, and rapidly moving flows of ash flowed downslope away from the calderas, extending locally at least as far as the modern range front of the Sangre de Cristo Range. Available data suggest ash-flow tuffs may exist in the subsurface beneath the Baca Grant.

Minor precious metal deposits developed in and near the igneous intrusions associated with the Conejos Formation stratovolcanoes, and major precious metal deposits such as those at Creede, Bonanza and Summitville formed in and near the calderas. These types of metal deposits are unlikely to exist at the Baca Grant because neither the Conejos stratovolcanoes nor the calderas associated with the ash-flow tuffs are known to exist in the vicinity of the Baca Grant.

Starting about 27 to 26 mya, the earth’s crust began to pull apart in response to east-west- directed extension. A major tear in the earth’s crust called the Rio Grande Rift broke open from Mexico at least as far north as central Colorado. San Luis Valley coincides with one of the major structural depressions that formed along the rift, the San Luis Basin. Subsurface sediments and volcanic rocks in the San Luis Basin and beneath the Baca Grant property include Map Unit QTs along with other formations. Attached Figure 3 presents a geologic cross-section (from Brister & Gries, 1994), which depicts the subsurface geology in an east-west alignment just south of the Baca Grant. The cross-section indicates that Oligocene ash-fluffs likely overlie Precambrian rocks beneath much of the Baca Grant, and the western part of the property may have an eastward-thinning wedge of Oligocene Conejos Formation volcanics (mostly andesitic flows and volcaniclastic rocks) between the Precambrian rocks and the ash-flow tuffs. These

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rocks were deposited in San Luis Basin prior to initiation of rifting; and, rift-related Map Unit QTs overlies the ash-flow tuffs.

4. Evaluation of Mineral Resources

Although Rare Earth did not review land-title records or County assessor’s records as part of this project, it is understood that Lexam holds an undivided 75% interest in the subsurface oil & gas rights, and ConocoPhillips owns the remaining 25% oil & gas interests on the 100,000-acre Baca Grant. Lexam also apparently holds 100% of the subsurface rights for all other minerals on the entire Baca Grant. According to Watts, et al (2006), 50% of the hard mineral rights were acquired from Baca Minerals, Inc. in 1987, and the other 50% interest in the hard mineral rights and 50% of the oil & gas rights were purchased from the Newhall Land and Farming Company in 1997. Lexam’s additional 25% interest in oil & gas rights were acquired from the Baca Corporation in 1996.

For this project, mineral resources were evaluated on the Baca Grant where Lexam holds a majority interest in subsurface oil & gas rights, and 100% interest in the rights to other minerals. This study also includes a lesser amount of acreage to the west and north of the Baca Grant (in Townships 42 & 43 North, Range 10 East; and Township 43 North, Range 11 East) where Lexam apparently owns mineral rights (ranging from an undivided one-sixth to one-half interest) on a patchwork of Baca NWR and private lands (see attached Figure 2) totaling roughly 5,400 acres.

A number of information sources were reviewed for documented historical, or currently permitted, mining activities at the Baca Grant and adjoining properties, and for determining the likelihood of potential on-site mineral resources. For purposes of this report, “minerals” do not include surface water or groundwater. Mineral resources are typically divided by USGS and other Federal agencies into three distinct categories: locatable, leasable and saleable. Each of these categories is described in detail below in the following Sections 4.1., 4.2. and 4.3.

Examples of the geological & mineral-resource data sources utilized for this project include:

 Mineral and Surface Management Status Map, Blanca Peak (BLM, 2010);

 Great Sand Dunes National Monument, Colorado: A Preliminary Literature Search, Inventory, and Assessment of Mines and Prospects in and near the National Monument with Emphasis on Potential Water Quality Degradation (Colorado Division of Water Resources [DWR], 1995);

 Colorado’s Hydrothermal Resource Base - An Assessment (CGS Resource Series 6, 1979);

 Inventory of Nonmetallic Mining and Processing Operations in Colorado (CGS Map Series 17, 1981);

 Location Map and Descriptions of Metal Occurrences in Colorado with Notes on Economic Potential (CGS Map Series 28, 1994);

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 Evaluation of Mineral and Mineral Fuel Potential of Saguache County, State Mineral Lands Administered by the Colorado State Land Board (CGS Open-File Report 00- 11, 2000);

 Oil and Gas Fields Map of Colorado (CGS Map Series 33, 2002);

 Radioactive Mineral Occurrences of Colorado (CGS Bulletin 40, 2005);

 Coal Resource Maps of Colorado (CGS Map Series 43, 2006);

 Geology and Mineral Resources of Saguache County, Colorado (CGS Resource Series 44, 2007);

 Critical and Strategic Minerals - Can Colorado Play a Role? (CGS Information Circular, 2011);

 BLM’s National Integrated Land System transaction applications (online at www.geocommunicator.gov/GeoComm/index.shtm) and Land & Mineral Legacy Rehost 2000 System (online at www.blm.gov/lr2000/index.htm);

 DRMS database for active and inactive mines (online at www.mining.state.co.us/GIS%20Data.htm);

 COGCC database for oil & gas wells (online at www.oil-gas.state.co.us/);

 7.5-minute series Crestone, Deadman Camp, Deadman Camp Southwest, Hooper East, Medano Ranch, Moffat South, Sand Camp and Sheds Camp, Colorado topographic maps (USGS, 1967-2010);

 Mineral Resource Potential of the Sangre de Cristo Wilderness Study Area, South- Central Colorado (USGS Miscellaneous Field Studies Map MF-1635-A, 1984);

 An Assessment of the Mineral Resource Potential of the San Isabel National Forest, South-Central Colorado (USGS Bulletin 1638, 1984);

 Petroleum Geology and Hydrocarbon Plays of the Albuquerque-San Luis Rift Basin, New Mexico and Colorado (USGS Open-File Report 87-450-S, 1988);

 Copper and Uranium in Pennsylvanian and Permian Sedimentary Rocks, Northern Sangre de Cristo Range, Colorado (USGS Bulletin 2116, 1995);

 The Principal Rare Earth Element Deposits of the United States - A Summary of Domestic Deposits and a Global Perspective (USGS Scientific Investigations Report 2010-5220, 2010);

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 Final Scoping Report - San Luis Valley Geothermal Leasing Analysis, Environmental Assessment and Resource Management Plan Amendment (BLM San Luis Valley Public Lands Center, November 2010);

 Environmental Assessment of Proposed Oil and Gas Exploration, Baca National Wildlife Refuge, Saguache County, Colorado (USFWS, April 2011);

 Tertiary Stratigraphy and Tectonic Development of the Alamosa Basin (Northern San Luis Valley), Rio Grande Rift, South-Central Colorado (Brister & Gries [in Geological Society of America Special Paper 291], 1994);

 General Geology of the Northern San Luis Valley, Colorado (GEO-HAZ Consulting, 1996);

 A Summary Review Including A Work Plan And Budget Proposal To Test Oil And Gas Prospects On The San Luis Basin Property, Colorado, USA - For Lexam Explorations Inc. (Watts, Griffis and McOuat Limited, June 2006); and

 Personal communication with Federal- and State-agency geologists and permitting representatives, along with local geologist Robert Kirkham (GeoLogical Solutions [Alamosa, CO]).

The following sections present an overview of mining and drilling history in the Baca Grant vicinity along with a discussion of known/documented mineral resources, which primarily include precious metals and sand & gravel.

4.1. Locatable Minerals

This category includes all minerals for which exploration, production and development are regulated by the Federal General Mining Law of 1872, including most of the metallic minerals (e.g., gold, silver, copper, molybdenum, lead, rare-earth elements, zinc, tungsten, uranium, vanadium, etc.) and some industrial minerals (e.g., high-calcium limestone, gypsum, fluorite, perlite, vermiculite, pegmatite-hosted non-metallics, etc.). Locatable minerals are typically found in lode, vein, disseminated, or placer deposits. The known metallic-mineral deposits in Colorado have been widely studied and are well documented in the literature.

4.1.1. Precious & Base Metals

The Baca Grant is located outside and southeast of the Colorado Mineral Belt, a 10- to 60-mile- wide southwest-northeast-trending zone of hydrothermal mineral deposits that extends roughly from the La Plata Mountains near Durango to the Front Range north of Boulder. However, the eastern part of the Baca Grant falls within two mineralized areas and named mining districts known as Crestone and Liberty (see attached Figure 4). The east-central boundary and northeast corner of the Baca Grant (comprised of both Rio Grande National Forest and privately-owned surface estates) contain both known and geologically-favorable areas for the occurrence of base & precious metal deposits. USGS has assigned a moderate potential for the

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occurrence of locatable mineral deposits in this mineralized area following the northwest- trending fault zone on the east side of the Sangre de Cristo Fault.

Archaeological evidence in the Crestone area indicates that oxidized quartz veins containing limonite and pyrite were first worked by Spanish explorers (USGS, 1984). Mining activity peaked during the years 1880 to 1904 from numerous underground and placer mines throughout the surrounding mountainous and outwash areas. The largest mine and primary producer was the Independence Mine (also known as the Independent Mine) situated south of Spanish Creek in the northeast corner of the Baca Grant, about 4 miles southeast of Crestone in the mountain foothills. Between 1890 and 1900, several prospectors began mining operations in the Crestone area and produced precious metals worth approximately 7 to 8 million US dollars (CGS, 2007).

The former townsite of Duncan (approximately 9.5 miles southeast of Crestone on the east- central boundary of the Baca Grant, north of Pole Creek) was another base for mining operations in the area during the 1880’s and 1890’s. Since it was court-determined that mineral rights were privately owned on the Baca Grant, the trespassing miners were forced to relocate around 1900-1904 to the newly-created Liberty townsite about 1.4 miles southeast of Duncan and immediately east of the Baca Grant boundary. At least five different mining & milling companies operated out of Liberty until about 1915 at the Myrtle K, Aztac [sic], Irena A lode mines and the Revenue placer claim (DWR, 1995). The cyanide process was also used in the 1930’s for gold extraction in the Crestone District prior to World War II. According to CGS 1,337 ounces of gold and 533 ounces of silver, plus minor amounts of copper and lead, were produced from the Crestone District between 1932 and 1939.

Mining in the Crestone and Liberty Districts is generally associated with northwest-trending quartz veins and thrust faults commonly found along the west flank of the Sangre de Cristo Range in Proterozoic rocks. The dominant mineral deposits are quartz-hematite and quartz- pyrite-chalcopyrite veins, with some of the veins having grades as high as 5 ounces of gold per ton (CGS, 2007). These polymetallic veins host important base & precious metals such as gold, silver, copper, lead, zinc and iron. Historic placer gold mining is also reported southeast of the Baca Grant in the Great Sand Dunes vicinity along Medano Creek in the 1927-1938 timeframe. The placer mining proved to be unsuccessful on a commercial basis.

Around 1990, Lexam’s predecessor (“Challenger Gold Inc.”; referred to as Lexam in this report) began prospecting for gold in the Deadman Creek area of the Baca Grant, about 8 miles southeast of Crestone, by drilling and sampling 42 shallow boreholes. Gold mineral deposits at this prospect are related to a low-angle detachment fault similar to that found at the San Luis Gold Mine, which is about 50 miles south in Costilla County (CGS, 2007). The Deadman Creek prospect is located in strongly silicified breccia of feldspar and quartz in a chloritic matrix; the gold is associated with pyrite, and the gold grades are as rich as 0.13 ounces per ton (CGS, 2007). Lexam had apparently obtained a DRMS prospecting permit (No. P1992-002) for this project; however, no information was available in the online DRMS database. Rare Earth also contacted DRMS’ Grand Junction office and was told that these prospecting files were confidential and could not be released to the public. Therefore, no actual borehole or assay data were available for review.

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Another large, historic mine in the Baca Grant vicinity is the Orient Mine, approximately 15 miles north in Section 25, T46N, R10E. The Orient Mine was the only commercially important iron mine ever developed in Colorado (CGS, 2000). The mine produced about 2 million tons of iron ore (limonite) from an oxidized replacement deposit in a sheared zone in the lower part of the Mississippian Leadville Limestone, just east of the Sangre de Cristo Fault. Colorado Fuel & Iron Company (CF&I) acquired the mine in 1880 and shipped the iron ore to their Pueblo smelter via railroad until 1905, when there was an apparent exhaustion of high-grade ore. The mine was operated intermittently by CF&I and other lessees until 1931. According to USGS, the Orient Mine still contains identified resources estimated at 5 million tons of 43 percent iron.

The most recent mining permit identified in the DRMS database for the surrounding area was issued in 1981 at the Blue Moon Mine, about 10 miles north of the Baca Grant (in the SE ¼ of the NE ¼ of Section 20, T45N, R11E). This was a small gold, silver and copper operation owned by Demure Mining Company, Inc. (Villa Grove, CO) on 9.8 acres of Rio Grande National Forest land. The permit has since been revoked & terminated by DRMS. The nearest active gold & silver mine listed in the DRMS database is Indian Creek Mining Corporation’s Profitt Mine, located near the Bonanza District (T47N, R7E in northeastern Saguache County), more than 28 miles northwest of the Baca Grant.

4.1.2. Other Locatable Minerals

Historically, Saguache County has been a fairly large uranium-producing county in Colorado, primarily from the Cochetopa, Marshall Pass, and Kerber Creek mining districts. The nearest active uranium mine listed in the DRMS database is Homestake Mining Company’s Pitch Project, located in the Marshall Pass Uranium District (T48N, R6E in northern Saguache County & southern Gunnison County), more than 35 miles northwest of the Baca Grant. Open-pit mining at the Pitch Project occurs in the Pennsylvanian Belden Formation on or near the Chester Fault, which displaces Precambrian rocks against remnants of Paleozoic rocks (CGS, 2007).

Other favorable uranium host rocks in Saguache County include the Lower Cretaceous Dakota Sandstone and Jurassic Morrison Formation. There are small USGS-reported occurrences of uranium mapped about 2 miles northeast of Crestone, known as the historic Mercury-Alpine and Venus 1-14 claims (in Section 33, T44N, R12E); and 1.5 miles east of the Baca Grant in Custer County at the King Midas, Damn Fool and Bonanza claims near the east foot of Crestone Needle (in Section 17, T24S, R73W). These uranium occurrences are typically found in bedded carbonaceous sandstone deposits of the Permian Sangre de Cristo Formation. According to CGS, there are no reported uranium occurrences in nearby Alamosa County.

No actively-permitted rare-earth elements (REE) mines were identified in the study area or in Colorado. The geology of this study area in the San Luis Valley and north-central Sangre de Cristo Range does not fit the USGS profile for REE occurrences on a commercially-minable scale. The majority of viable REE deposits in Colorado are found in Fremont, Gunnison and Moffat Counties. USGS classifies the major United States REE deposits as occurring only in four distinct geologic associations:

 Carbonatites & alkaline igneous complexes;

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 Veins related to alkaline intrusions;  Some iron-ore deposits associated with magmatic-hydrothermal processes; and  Stream and beach deposits (placers) derived from the erosion of alkaline igneous terranes.

Pegmatites (i.e., dike- or vein-like features characterized by coarse grain sizes & interlocking crystal texture with bulk feldspar, high-purity quartz, and several mica minerals) are known to intrude Proterozoic rocks found north-northwest of the Baca Grant in the Crestone District on the west flank of the Sangre de Cristo Range. CGS reports that small amounts of thorium, REE, uranium and vanadium were produced from pits at the Bob Cat Mine pegmatite area, about 4 miles north of the Baca Grant. Accessory minerals in pegmatites can also include beryl, lithium, garnet, and tourmaline. In Colorado, the known REE mineral deposits in pegmatites are found in Chaffee County (Mount Antero) and Jefferson County (South Platte Pegmatite District).

Outcrops of high-purity limestone & dolomite are also known to be present east of Villa Grove and in the Hayden Pass area. However, these resources are probably not economically competitive with larger deposits found close to railroad & highway transportation routes, and commercial markets, near Salida and along the Arkansas River valley to the north.

No currently-permitted locatable mineral operations were identified in the DRMS database for the study area in Saguache County, or nearby lands in Alamosa and Custer Counties. At the time of preparing this mineral assessment report, no plans, permits or proposals were identified for metallic-mineral, REE, uranium or other locatable-mineral mining operations that would impact the Baca Grant.

4.2. Leasable Minerals

This category includes oil, natural gas, coal, coalbed methane, oil shale, geothermal energy, and several other minerals (e.g., potash, sodium, phosphate, native asphalt, bitumen or bituminous rock, etc.). These minerals are defined as “leasable commodities” by the Mineral Leasing Act of 1920 and the Geothermal Steam Act of 1970.

4.2.1. Oil & Gas Resources

According to CGS, Saguache County does not contain any commercial oil & gas resources. A total of 17 oil and gas wells were drilled in the County since the early 1920’s, mostly in the San Luis Basin, with total depths ranging from 365 to 12,000 feet. All failed in discovery of producible hydrocarbons and accordingly all these wells were plugged and abandoned. The only productive oil well in the San Luis Basin was the Kirby Jynnifer No. 1, which was drilled in 1985 just south of the Saguache County line in Section 9, T40N, R 5E. This well produced 30 barrels of oil per day from a volcanic sill in the Cretaceous Mancos Shale. (CGS, 2000 & 2007)

No oil & gas fields have been mapped in the area by USGS & CGS or are known to underlie the Baca Grant. A search of the COGCC database revealed two wells that were drilled on the Baca Grant by Lexam in September & October 1995. Both wells are reported as dry & abandoned, meaning they were either “dry holes” (with no hydrocarbons) or unable to produce marketable quantities of oil and/or gas. The wells, known as Baca Nos. 1 & 2, were drilled immediately west

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of the Deadman Creek area (see attached Figure 2) where Lexam had performed its gold prospecting program that was discussed previously in Section 4.1.1. of this report. During their gold prospecting activities in 1992 & 1993, Lexam apparently encountered biodegraded crude- oil shows in several (either 17, 27 or 28, depending upon the publication) of the 42 shallow boreholes that were drilled in breccia and fractured gneiss.

At the time, Lexam’s laboratory analysis claimed that the crude oil was sourced from Cretaceous sediments underlying the thrust-fault zone. Lexam also claimed that they had identified surface outcrops of Jurassic-Cretaceous sediments (i.e., Morrison Formation, Dakota Sandstone, and Mancos Shale) along the west flank of the Sangre de Cristo Range. Portions of these outcrops have apparently been viewed by local geologists and NPS employees.

The Baca Nos. 1 & 2 wells were drilled as wildcats to explore the underlying Cretaceous section on the Deadman Creek block. Both wells encountered a thin, faulted section of Mancos Shale in the hanging wall of the detachment fault, and traces of biodegraded oil were observed in thick intervals (including the Santa Fe Formation, Mancos Shale, and Precambrian gneiss) of both wells. The strongest oil shows were present in a 350-foot interval of the Baca No. 2 well starting at 6,620 feet. (Watts, et al, 2006)

According to the COGCC well-completion reports, the Baca No. 1 was drilled to a total depth of 4,322 feet into Precambrian rock, with 3,566 feet of overlying Santa Fe Formation and 18 feet of Mancos Shale. And, the Baca No. 2 was drilled to a total depth of 6,932 feet into Precambrian rock, with 6,272 feet of Alamosa & Santa Fe Formations and 115 feet of Mancos Shale. The COGCC completion report indicates that the Baca No. 2 was converted to a water well. DWR records show that the well was abandoned by Lexam to a depth of 1,000 feet and converted to a monitoring well for use by Stockman’s Water Company.

Lexam continued their evaluation of the Baca Grant though geophysical exploration programs in 1996 and 1998-2004. From this data they delineated the Crestone Prospect, which was further divided into eastern and western fault blocks known as the Crestone East and Crestone West Prospects. Between 2000 and 2009, Lexam filed COGCC Applications for Permit to Drill (APDs) on five single-zone gas wells located generally 6-7 miles northwest of the Baca No. 2 in the newly-created Baca NWR. Baca Nos. 3 & 4 are identified by COGCC as abandoned locations, and Baca Nos. 5-7 all have expired APDs as of May 2010.

The Baca Nos. 5 & 7 wells (see Figure 2) became the subject of the USFWS’ April 2011 Environmental Assessment (EA) for proposed oil & gas exploration in the Baca NWR. Lexam’s proposal calls for two 14,000-foot-deep vertical wells with the Dakota Sandstone as the objective formation on the Crestone East Prospect. Their 2006 Work Plan and Budget Proposal estimated the costs for drilling & completion of one of these wells to be roughly $8.8 million. It should be noted that two of the three authors of the work plan & budget include a former Lexam employee (Tom Watkins) and a Lexam shareholder (Kim Parsons). On April 1, 2011 USFWS issued a Finding of No Significant Impact (FONSI) for Lexam’s drilling proposal. A FONSI is issued when the environmental analysis & interagency review find a project proposal to have no significant impacts on the quality of the environment.

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The EA’s preferred alternative outlines 43 terms & conditions to be imposed upon Lexam by USFWS in addition to those required by COGCC and Saguache County, which ensure the exploration program will not have a significant impact on the natural and human environment. Of particular interest are those measures intended to minimize disturbance to wildlife by restricting the seasons of exploration activity to reduce or eliminate interference with migratory bird breeding and big game calving; minimize the risk of ground and surface water contamination; minimize or eliminate impacts to wetland habitat, sensitive fish populations and plant types; reduce probability of noxious weed infestations; manage fugitive dust; and reduce air, noise and light pollution from exploration activities. Appendix D of the final EA contains a full description of the required protective measures. (USFWS, 2011)

About half of the Baca Grant is mapped as “Sensitive Wildlife Habitat” (SWH) for all species, and the northeast high-elevation corner and Sand Creek drainage corridor are mapped by COGCC as “Restricted Surface Occupancy” (RSO), as defined and regulated by their 1200- Series Rules. These rules require oil & gas operators to consult with the Colorado Division of Wildlife, the surface owner, and the COGCC Director whenever a new oil & gas location is proposed in SWH or RSO areas. The proposed Baca No. 5 well location is included in the SWH area.

According to CGS, Saguache County is considered to have only two hypothetical hydrocarbon plays: the San Luis Valley Biogenic Gas Play, and the San Juan Sag. The gas play covers an elongate area about 70 miles long and 20 miles wide in the east-central part of the San Luis Valley where shallow biogenic gas has been historically produced from the underlying Alamosa Formation. Whether or not a commercial accumulation of gas exists in this play is speculative. The San Juan Sag is located on the west side of the San Luis Valley in hydrocarbon traps found below a thick section of volcanic rocks along the foothills of the San Juan Mountains. The Sag extends from the Del Norte area westward beneath the San Juan volcanic field and connects with the San Juan Basin. The San Juan Sag in Saguache County is considered to have a fair potential for hydrocarbon accumulations (CGS, 2000).

No active Federal oil & gas leases are indicated on adjoining lands with Federal-owned oil & gas rights. As mentioned above, the only reported hydrocarbon production activity in the regional area was the Jynnifer No. 1 well located in the small Del Norte Field, about 33 miles west-southwest of the Baca Grant. Due to sub-economic production, the well was abandoned in July 1998 by Faith Energy Exploration Inc. (Ennis, TX); however, the wellsite has yet to be reclaimed. The nearest oil and/or gas production occurs about 32 miles northeast in the Florence-Cañon City Field in Fremont County, where oil is produced from numerous wells in the Upper Cretaceous Pierre Shale. The Sheep Mountain Field (more than 20 miles southeast in Huerfano County) has also produced more than a trillion cubic feet of carbon dioxide (CO2) since its discovery in 1971.

4.2.2. Coal Resources

No on-site or nearby coal mines, coal fields, or coalbed methane operations were identified in the CGS, DRMS, or USGS literature. The Upper Cretaceous Vermejo Formation or Mesaverde Group coal-bearing intervals do not underlie the Baca Grant, nor is coalbed methane known to be present beneath the area. The nearest historic coal mines are located more than 35 miles

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east-northeast in the Cañon City Coal Field in Fremont County, where coal was produced from more than 175 mines in the lower part of the Vermejo Formation. In 2000, the last underground mine in the field closed, ending 122 years of continuous coal production. The nearest, active coal mining currently occurs more than 60 miles southeast of the Baca Grant at the New Elk Mine located west of Trinidad in Las Animas County (in the Trinidad Coal Field).

4.2.3. Other Leasable Minerals

Because the Rio Grande Rift is characterized by high heat flow, there are several geothermal springs identified in the San Luis Valley. The nearest geothermal resource is located about 2.5 miles northeast of Hooper in Section 27, T41N, R10E, known as the Sand Dunes Swimming Pool Hot Water Well. The operation includes public pools, a restaurant, and RV/camping facilities. The hot-water well was originally drilled as an oil & gas test by San Luis Valley Oil & Gas Company in 1924, to a total depth of 4,308 ft in the deepest part of the San Luis Valley where there are 20,000+ feet of valley-fill sediments.

This artesian well flows at a rate of 340 gallons per minute and can be pumped at a rate of 1,480 gallons per minute; the temperature of the water flowing from the well is 111° to 115° F (CGS, 2007). In 1979, CGS estimated that this is a sedimentary reservoir with an areal extent of approximately 1.5 square miles around the well. More than 10 miles north of the Baca Grant (and east of the town of Saguache), Valley View Hot Springs and Mineral Hot Springs are also developed as spa resorts for public use.

The Baca Grant is not currently identified by BLM as a known geothermal leasing area or geothermal lease nomination area. However, BLM and USFS lands in Colorado include about 5.8 million acres that are open to geothermal leasing. And, there are current nominations for geothermal leases in Chafee and Gunnison Counties on both public & private lands with Federal mineral estates. The San Luis Valley Public Lands Center is also currently preparing an EA to consider whether to issue geothermal leases. The EA includes an amendment to BLM’s San Luis Resource Management Plan, which is necessary since their 1991 plan did not adequately address geothermal resources.

4.3. Saleable Minerals

This category includes both nonmetallic and several industrial minerals (e.g., dimension stone, sand & gravel, clay, petrified wood, volcanic cinders, etc.), falling under the purview of the Materials Act of 1947 and the Multiple Surface Use Mining Act of 1955. None of these commodities has been commercially mined at the Baca Grant according to the CGS, DRMS and USGS literature reviewed for this report, other than possible small historic borrow-pit areas that were utilized for extraction of road-fill material during construction of local ranch roads.

According to DRMS, the nearest active sand & gravel mine (known as the Skoglund Pit) is located about 2 miles north of the Baca Grant in the SE ¼ of Section 34, T44N, R11E, in Pleistocene outwash (Map Unit Qpf) and Holocene/Pleistocene eolian sand (Map Unit Qes) deposits found south of San Isabel Creek. This 30-acre pit is operated by Skoglund Excavating Inc. near Crestone and was permitted by DRMS in 1997 under Permit No. M1996089. Another nearby pit (about 3.5 miles southwest of the Baca Grant near Hooper) is identified as the Curtis

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Pit in the SE ¼ of Section 33, T41N, R10E. This 9.5-acre pit is operated by the Colorado Department of Transportation near Highway 17 and was permitted by DRMS in 1985 under Permit No. M1985084. The pit appears to be located in similar geologic materials as those found at the Baca Grant (i.e., Map Unit QTs).

Local streams have created large alluvial-fan gravel deposits where they emerge from steep mountain fronts into the San Luis Valley, and there are large deposits of valley-fill alluvium (i.e., common varieties of sand & gravel, with abundant silt & clay in Map Unit QTs). However, all of these resources have only been used to a very small degree due to the remoteness of major population and growth centers to the County (CGS, 2000). Saleable minerals generally have a low unit value (i.e., value per ton), and their exploitation is dependent on easy access to transportation and local markets.

USGS also reports that a small vein near Crestone was historically worked for decorative quartz. Pegmatites and gneiss (and other Precambrian rocks) can be utilized for decorative materials or building stone. No clay, dimension stone, high-purity silica sand (i.e., oil- & gas-field fracking sand) or other saleable mineral mining activities were identified near the Baca Grant.

5. Conclusion

Rare Earth prepared this MAR for the Baca Grant property located within southeast Saguache County in south-central Colorado. The project included a review of published documents related to historical and currently-permitted mining and drilling operations for the study area. This report is intended to provide an overview of the various mineral resources and the mineral- development potential for those areas of Lexam’s holdings on and near the Baca Grant. Based upon our findings during this MAR process, we conclude the following:

5.1. Oil & Gas Resource Development Potential

The potential for commercial oil & gas reserves beneath the Baca Grant is reliant on limited data and is the subject of geologic controversy regarding the likelihood of underlying Cretaceous sediments. Unfortunately, the controversy between Lexam’s data and the published literature extends beyond the scope and budget of this MAR. The reality is that Lexam’s former attempt at locating oil & gas by drilling the Baca Nos. 1 & 2 wells proved unsuccessful, and other geologic studies in the area by CGS and USGS have similarly concluded that there is a low probability of discovering commercial oil & gas reserves at the Baca Grant. In January 2005, BLM prepared a Mineral Potential Report as part of a land-exchange program which involved approximately 61,000 acres of State-owned surface and mineral estates located west and south of the Baca Grant, including adjoining lands to the west. BLM stated that the oil & gas resource potential on these lands was low, based upon insufficient data; however, they concluded that “the lands are prospectively valuable for oil and gas.”

As owner of the subsurface oil & gas rights on the Baca Grant and other nearby & adjoining lands, Lexam is entitled to make continued use of the surface lands for exploration activities according to Colorado’s split-estate laws. Since their failed attempt at locating oil & gas in 1995, Lexam has committed additional resources for acquiring seismic data and preparing well- planning and -permitting documents. In our opinion, this could be viewed as: A) a method of

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attracting potential investors for funding drilling on the high-risk Crestone East Prospect; B) a way to justify the valuation of underlying mineral rights on the Baca Grant; or, C) a legitimate attempt at locating previously undiscovered oil & gas resources in the San Luis Valley.

Because a majority of the surface estate at the Baca Grant is owned by the Federal government, there are additional protections in place for wildlife and surface usage as prescribed by USFWS, USFS and NPS. Given the high level of concern for protection of wildlife and their habitat on these lands, not to mention protection of water quality & quantity, any future drilling plan at the Baca Grant would be carefully evaluated by those Federal agencies along with COGCC and possibly the Colorado Division of Wildlife.

As evidenced by USFWS’ recent EA for the proposed Baca Nos. 5 & 7 wells, this results in increased overall costs for Lexam and longer time frames to complete the necessary site analysis and permitting process; stricter conditions on siting well pads, roads, flow lines and other infrastructure; and stringent mitigation measures. Further complicating the situation and increasing any production costs are the lack of hydrocarbon infrastructure and transportation (i.e., pipelines) options in the San Luis Valley. All of this adds up to an expensive and challenging location for economical recovery of hydrocarbons.

Future oil and/or natural-gas exploration activities are very difficult to project & predict since they are primarily market-driven. Lexam’s APDs for the Baca Nos. 5, 6 and 7 wells expired in May 2010. And, as of July 26th, Lexam has filed for COGCC bond release on the Baca Nos. 6 & 7 wells, which are now shown as “abandoned locations.” Lexam would need to resubmit an APD to COGCC in order to restart the permitting process for the Baca No. 5 well. The COGCC website and permitting records should be monitored for future oil & gas activities that may adversely affect the Baca Grant and adjoining lands. This also includes the potential for additional geophysical or seismic exploratory programs.

Since ConocoPhilips owns 25% of the oil & gas rights on the Baca Grant, their involvement in the Crestone East Prospect should also be evaluated. Oil & gas operators sometimes have lease agreements and funding mechanisms amongst themselves, which are not recorded or transparent to the public. ConocoPhillips’ level of interest or involvement for oil & gas exploration on the Baca Grant is unknown. The Saguache County Assessor’s records should also be checked for the status of Lexam’s mineral-estate tax assessments.

5.2. Metallic Mineral Resource Development Potential

There is a moderate to high potential for the occurrence of metallic mineral deposits (predominantly gold & silver, with lesser amounts of copper & lead) along the east-central boundary and northeast corner of the Baca Grant property (primarily in the Rio Grande National Forest [Baca Mountain Tract] and underlying parts of the Baca Grande Subdivision), due to identified resources and nearby historic mining activity in the Crestone and Liberty Districts. The development potential is also moderate to high, based largely on the sustained high market price for gold (currently at $1,630 per ounce). Typically, as market prices rise and fall, so do the levels of exploration & production. Additionally, Lexam has already acquired on-site borehole and assay data from their previous exploration activities in the Deadman Creek area during the early 1990’s, and CGS reports gold grades up to 0.13 ounces per ton on the Lexam prospect.

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The viability of any mineralized area is usually dependent more on economic factors rather than local geology. USGS describes typical impediments to future hard-rock mining that include: A) lack of mining infrastructure, including mills and mining experience; B) fluctuating market prices for metals; and C) societal resistance to mining and fear of environmental pollution from mining. In order for commercial mining of vein deposits to produce a significant tonnage, a large mining & milling operation is mandated.

Because of the mixed surface land status in the Baca Grant area (i.e., Baca NWR, Great Sand Dunes National Park, private lands, nearby Sangre de Cristo Wilderness), a large mining & milling operation would face enormous public resistance and a lengthy permitting process. Modern-day gold-mining operations in the regional area (including Galactic Resources’ Summitville mine [to the southwest in Rio Grande County] and the Battle Mountain/Newmont San Luis Project [to the south-southeast in San Luis County]) have all realized severe environmental limitations due to permitting & litigation costs, surface- and groundwater contamination, and mine waste disposal issues.

It is likely that many of the historic mining operations in the Baca Grant area have extracted the highest-grade ores; however, small-scale mining of local pockets of rich ore may be viable, particularly if an operator can find a way to mill and smelt their ore off site. At the time of preparing this MAR, no plans, permits or proposals were identified for metallic-mineral mining operations that would impact the Baca Grant property.

5.3. Aggregate Resource Development Potential

There is a moderate to high potential for large deposits of aggregate in Map Unit QTs at the Baca Grant property; however, the commercial demand is deemed to be fairly low. It is not known whether these mineral rights for common varieties of sand & gravel are united with the current surface estate (which includes the Federal government and other private landowners), or owned by Lexam. Typically in Colorado, the mineral rights for sand & gravel remain united with the current surface estate unless those rights have been expressly reserved in mineral deeds affecting the Baca Grant. However, a legal opinion would be necessary in order to make that determination.

It is our opinion that commercial sand & gravel mining would not be a permissible or permittable activity at the Baca Grant since an access agreement, lease or easement (i.e., a legal “right-to- enter”) must be in place with all affected landowners prior to DRMS issuing a mining permit.

5.4. Geothermal Resource Development Potential

There is also a moderate potential for private development of geothermal resources beneath the Baca Grant property. Subsurface geothermal fluids are considered to be part of Colorado’s groundwater resources, and are therefore administered by the State Engineer. As a result, well drilling for direct-use geothermal projects (e.g., greenhouse heating, warm-water aquaculture, space heating, swimming pools & and spas) is regulated by DWR. However, it is our opinion that private development of geothermal resources for direct-use or electrical power generation would not be a compatible use with the existing surface estates on the Baca Grant.

Rare Earth Science

Mineral Assessment Report: Baca Grant No. 4 Property (Saguache County, CO) August 1, 2011 Page 17 of 18

The Geothermal Steam Act of 1970 also authorizes BLM to lease development rights to the “heat” of the public’s mineral estate which could, at some point, potentially affect lands adjoining the Baca Grant with Federal subsurface mineral ownership. SLVEC or other stakeholders should continually monitor the BLM geothermal EA process and their leasing & permitting activities on adjoining lands, which have the potential to adversely affect the surface and subsurface of the Baca Grant.

We appreciate the opportunity to provide SLVEC with these mineral assessment services. Please contact me at 970/241-1762 or [email protected] if you have any questions or need additional information about the content of this report.

Respectfully Submitted,

Rare Earth Science, LLC

James C. Armstrong Principal Geologist

cc: J. Corzine (TPL)

Attachments

 Preparer’s Qualifications  Figure 1 - Locator Map  Figure 2 - Lexam Mineral Rights  Figure 3 - Geologic Cross Section  Figure 4 - Map Showing Mineralized Areas

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Mineral Assessment Report: Baca Grant No. 4 Property (Saguache County, CO) August 1, 2011 Page 18 of 18

Preparer’s Qualifications

James Armstrong is a professional geologist with 18 years residency in Colorado, and has lived in Grand Junction and Gunnison since 1998. He received a BS in Petroleum Geology from Kansas State University in 1983, and completed additional graduate-level coursework in environmental and natural resource studies at the University of Alaska/Anchorage. Mr. Armstrong spent 7 years working in various private-industry technical positions related to oil and gas exploration & production, geophysical consulting, and petroleum refining & marketing operations in the central U.S., Texas and the Gulf of Mexico.

Since 1990, he has been employed as a consulting geologist and environmental scientist serving oil & gas, mining, private-sector, non-profit, and government-agency clients in Alaska, Hawaii, and the central & western United States. Mr. Armstrong is accomplished in field studies, mineral-reserve evaluations, project management and regulatory compliance, and has prepared numerous mineral assessment reports for conservation-easement and habitat-protection projects. He has completed mineral studies for a diverse client base in south-central Colorado that includes Colorado Division of Wildlife, Colorado Open Lands, Costilla County, Orient Land Trust, Rocky Mountain Elk Foundation, and The Nature Conservancy. Mr. Armstrong is the founder of (and a partner in) Rare Earth Science, LLC.

Rare Earth Science

COLORADO

Locations of boundaries and Figure 1: Locator Map features are approximate. Baca Grant No. 4

Base Map Source: Legend http://services.arcgisonline.com/ Luis Maria Baca Grant No. 4 July 25, 2011 World Base Map Additional Lexam Mineral Holdings

Rare Earth Science, LLC ± 1:620,000 PO Box 4523 0 15 Grand Junction, CO 81502 Miles Phone: 970/241-1762 Baca 5

Baca 7

Baca 2 Baca 1 A!! A!!

Locations of boundaries and Figure 2: Lexam Mineral Rights features are approximate. Baca Grant No. 4 Legend Base Map Source: http://services.arcgisonline.com/ A!! Dry and Abandoned Lexam Wells Baca National Wildlife Refuge July 25, 2011 USA Topographic Map Proposed Lexam Well Locations Great Sand Dunes National Park Luis Maria Baca Grant No. 4* Rio Grande National Forest Additional Lexam Mineral Holdings** TNC Conservation Easement

* Lexam 75% / ConocoPhillips 25% oil & gas rights; Lexam 100% other mineral rights Rare Earth Science, LLC 1:160,000 PO Box 4523 ± ** Varying percentages of mineral rights 0 4 Grand Junction, CO 81502 Miles Phone: 970/241-1762

BACABACA GRANTGRANT BOUNDARYLOCATION

Adapted From: USGS, 1984 N Mineral Resource Potential of the Sangre de Cristo Wilderness Study Area

DATE: July 2011 MAP SHOWING CRESTONE & CHECKED BY: J. Armstrong Rare Earth Science LIBERTY MINERALIZED AREAS FIGURE DRAWN: J. Armstrong Post Office Box 4523 Grand Junction, Colorado 81502 PROJECT: Baca MAR ON THE BACA GRANT NO. 4 PROPERTY 4 (970) 241-1762 Saguache County, Colorado FILE NAME: BacaFig4 www.rareearthscience.com Indicators of Wildness: Using Attributes of the Land to Assess the Context of Wilderness

Gregory Aplet Janice Thomson Mark Wilbert

Abstract—Land can be described in a space defined by two funda- …an area of undeveloped Federal land retaining its prime- mental qualities: naturalness and freedom. The axis of naturalness val character and influence, without permanent improvements or human habitation, which is protected and man- describes the wholeness of the ecosystem relative to a historical aged so as to preserve its natural conditions and which (1) norm, while the axis of freedom describes the degree to which land generally appears to have been affected primarily by the remains outside of human control. Some land can be natural but not forces of nature, with the imprint of man’s work substan- free, and vice versa, but the most natural and free are the most wild tially unnoticeable; (2) has outstanding opportunities for — they are the lands we recognize as wilderness. These concepts are solitude or a primitive and unconfined type of recreation; (3) illustrated through the mapping of indicators of wildness, derived has at least five thousand acres of land or is of sufficient size from readily available data in a Geographic Information System. as to make practicable its preservation and use in an unimpaired condition; and (4) may also contain ecological, geological, or other features of scientific, educational, scenic, or historical value. The past few years have witnessed considerable attention to conceptions of wilderness. Generally, this attention has But this is a carefully crafted legal definition resulting from taken the form of a “debate” between critics of wilderness as years of debate and compromise. Surely, we are not to idea on one side and defenders of wilderness as place on the believe that all the places wild enough to count as wilderness other (see for example, Callicott and Nelson 1998). Critics are limited to federal land. And why 5,000 acres? These are contend that white, male, American minds have produced a legal constraints necessary for the implementation of the concept that separates humans from nature, denigrates Wilderness Act. A general definition of wilderness remains native peoples, and freezes ecosystems in time. Defenders elusive. point out all the myriad values, including wildlife habitat, In his exploration of the legislative direction provided by watershed protection and spiritual healing, provided by the the Wilderness Act, ecologist David Cole (1996) notes that places we call wilderness and conclude that wilderness wilderness is expected to be both “untrammeled,” or uncon- therefore must be good. Both sides assume they understand trolled and free, and “pristine,” or “what would have existed what they mean by wilderness; neither states it clearly. in the absence of post-aboriginal humans.” Cole concludes Robert Marshall begins his classic 1930 essay, The Prob- that these two goals provide conflicting direction for manag- lem of the Wilderness, “It is appalling to reflect how much ers, as manipulation is often needed to repair damage useless energy has been expended in arguments which caused by overuse, exotic species invasions, fire exclusion would have been inconceivable had the terminology been and other processes that have altered ecosystems away from defined.” Seventy years after Marshall offered his observa- natural conditions. Cole argues that these goals are “to some tions, it appears we are still suffering from the same misun- extent mutually exclusive” and suggests that we must choose derstandings. The debate over the value of wilderness is one or the other of these goals to emphasize when managing being conducted without a common understanding of its wilderness. meaning. Before any more “useless energy” is expended, it is Alternatively, Aplet (1999) suggests that these two out- worthwhile to stop and consider what exactly we mean by comes, freedom and naturalness, rather than providing wilderness. conflicting direction, actually describe two independent quali- One of the first places to look, of course, is the Wilderness ties of wilderness. Wilderness is that portion of the land that Act itself. The Act (Public Law 88-577) defines wilderness is most wild, and wildness is a function of both naturalness straightforwardly enough as: and freedom from human control. This dualistic nature of wildness can be illustrated with a simple figure (fig. 1) that represents landscapes in the two-dimensional space created by freedom and naturalness. In this conception, wildness In: McCool, Stephen F.; Cole, David N.; Borrie, William T.; O’Loughlin, increases in two directions: from the controlled to the “self- Jennifer, comps. 2000. Wilderness science in a time of change conference— willed” along a gradient of freedom, and from the artificial to Volume 2: Wilderness within the context of larger systems; 1999 May 23–27; Missoula, MT. Proceedings RMRS-P-15-VOL-2. Ogden, UT: U.S. Department the pristine along a gradient of naturalness. At the most of Agriculture, Forest Service, Rocky Mountain Research Station. controlled and artificial ends of the continuum are the least Gregory Aplet is Forest Ecologist and Director, Center for Landscape wild lands – the built environment of the city. Where freedom Analysis, The Wilderness Society, 7475 Dakin Street, Suite 410, Denver, CO, 80221 U.S.A. Janice Thomson is Remote Sensing Coordinator and Mark and naturalness are highest is the wilderness, regardless of Wilbert is GIS Analyst, Center for Landscape Analysis, The Wilderness size or ownership. In between, lands can possess any combi- Society, 1424 Fourth Ave., Suite 816, Seattle, WA, 98101 U.S.A. nation of freedom and naturalness, and an intermediate

USDA Forest Service Proceedings RMRS-P-15-VOL-2. 2000 89 19th century as a place to escape the stranglehold of civilization. In contrast, The Wilderness Act speaks of wilderness as “an area where the earth and its community of life are untrammeled by man,” suggesting that it is the land itself that is free in wilderness. While wilderness will likely always be highly valued for the experience it provides, it is this second sense, the character of wild land itself, that is the focus of the following discussion. Though perceptions of wildness vary with each individual, there appears to be a limited set of characteristics that contribute to the freedom and naturalness of a place. Gener- ally, the literature exploring wild land characteristics suggests that the attributes of the land that contribute to its freedom are 1) the degree to which land provides opportunities for solitude, 2) the remoteness of the land from mechanical devices and 3) the degree to which ecological processes remain uncontrolled by human agency. The attributes that Figure 1—The “continuum of wildness.” Wildness increases as a contribute to the naturalness of the land are 1) the degree to function of both its naturalness and its freedom from human control. which it maintains natural composition, 2) the degree to which it remains unaltered by artificial human structure and 3) the degree to which it is unpolluted. Each of these attributes need not exist at an absolute maximum in wilderness, but, collectively, they define the qualities of freedom and degree of wildness. All lands fall somewhere within this two- naturalness and therefore facilitate the measurement of dimensional continuum of wildness. wildness. If wilderness is that portion of the landscape that is most natural and free, it follows that the wilderness manager’s job is to maximize simultaneously both of these characteristics. Solitude This is where the job becomes difficult, and tradeoffs arise. Solitude has been described as “the opportunity to meet Maintaining freedom may compromise naturalness — for the wilderness, or its maker, personally, quietly, on terms example, where exotic species are allowed to invade from the only you prescribe” (Whitney 1997). The “outstanding oppor- outside. Likewise, restoring natural conditions often re- tunities for solitude” afforded by wilderness have long been quires bringing the land under tighter control. Just like the recognized as a key part of the “wilderness experience.” parent who simultaneously struggles to instill discipline Thoreau (1862) enjoyed his opportunity to “walk ten, fifteen, and independent thought, the key for managers is to strive twenty, any number of miles, commencing at my own door, always toward both goals. When intervention is required, without going by any house, without crossing a road except heed Wilderness Watch president Bill Worf’s good advice: where the fox and mink do.” Robert Marshall (1933) required “Manipulation should generally be limited to those mini- that wilderness have “no permanent inhabitants,” and Sigurd mum actions that will establish conditions that will allow Olson (1938) exalted in “the ordinary phenomena of life in natural processes to hold sway once again” (Worf 1997). the open.” Though solitude is clearly an experience of the These qualities of freedom and naturalness help clarify wild, the ability to provide it is a measurable attribute of the what we mean by wildness, but they themselves are rather land. That the most wild land must be the least inhabited vague descriptors that cry out for further explanation. Man- follows naturally from the notion that, at some population agers need to know what exactly to pay attention to in order density, people necessarily bring land under control to serve to achieve these twin goals. The remainder of this paper is their purposes (such as occupancy, transportation, recre- devoted to exploring the attributes of the land that contrib- ation and hygiene). The degree of human-to-human contact ute to its naturalness and freedom from control. Ultimately, is one of the defining measures of the freedom of the land. we would like to be able to measure these qualities to ensure The requirement that wilderness be uninhabited has been that we are protecting and sustaining the wildness of wilder- interpreted by some as ignoring or even subjugating indig- ness. The measurement of wildness raises the possibility of enous people, who occupied (or occupy) the land even as it mapping the wildness of the land, and this paper presents was (or is) considered wilderness (see Bayet 1994; Birch the results of some recent progress toward this goal and 1990; Denevan 1992; Gomez-Pompa and Kaus 1992; Nabhan discusses how this method differs from other approaches to 1995; Plumwood 1998). But it need not be. As the poet Gary mapping our precious wild places. Snyder (1990) has pointed out, every landscape has its “fire in the kitchen” and its “place less traveled.” Where popula- Indicators of Wildness ______tion density is high, whether in the pre-Columbian or modern era, the ability of the land to afford solitude is dimin- Throughout the history of the idea, wilderness has been ished. In the “kitchen,” the land may still be “natural” (see thought of both as a place that is free and as a place in which below), but it will not be as free. to be free. In other words, wilderness has been thought of In practice, we may gauge opportunity for solitude by both as a real place and as an experience. For example, Nash measuring population density. Over large areas, such as (1982) notes the value of wilderness to the Romantics of the states or continents, we are usually limited to looking at

90 USDA Forest Service Proceedings RMRS-P-15-VOL-2. 2000 where people reside, but how people use the land is also a The equation of uncontrolled processes with presettlement factor. Over smaller landscapes, we may be able to gauge the influences again raises the question of the role of indigenous opportunity for solitude by examining recreation use pat- people in landscape dynamics. Clearly, indigenous people terns. In any case, we look to represent some measure of the have had tremendous influence on the character of the land probability of encountering others. in localized instances and may have altered the nature of ecosystems over broad areas through the use of fire and hunting practices (see, for example, Denevan 1992). Where Remoteness this influence was intensive, we must view the land as under Roadlessness is also widely recognized as a defining char- tight control and not free. However, where influence was acteristic of wilderness. Aldo Leopold (1921) insisted that extensive, aboriginal fire and hunting joined other sources of wilderness be “devoid of roads,” while his son Starker’s ignition and mortality, making it very difficult to distinguish Commission on Wildlife Management in the National Parks between aboriginal control and “the will of the land.” In this considered the roadgrader to be “the most dangerous tool of case, if only for practical purposes, we should consider all” (Leopold and others 1963). Marshall’s (1933) definition extensive aboriginal influences to be part of the processes required wilderness to “possess no means of mechanical altered by the invasion of modern technological society. conveyance” in order that wilderness remain “free from Alteration of processes is probably the most difficult to mechanical sights and sounds and smells.” Environmental measure of the six attributes that contribute to wildness. historian Michael Cohen (1984) believes road construction is The science of historical ecology is just beginning to reveal the first act of “trammeling” the wilderness. He writes, “I am the degree to which disturbance, hydrology, nutrient cy- troubled by the term ‘untrammeled’. At what point have we cling, long-range migration and other ecological processes caught and trapped the wilderness? I would presume that a have been changed over the past few centuries. And even process of capturing or trapping begins when men try to when we know something about rates of change, it is difficult ‘open out routes’ among the mountains.” Thus, the very to ascribe that information to the broader landscape. Never- presence of a road diminishes the freedom of the land, and theless, progress has been made in mapping altered fire distance from roads is clearly a time-honored measure of regimes, indices of watershed integrity and other metrics wildness. that may allow us to quantify land’s freedom from control of The measurement of remoteness is fairly straightforward ecological processes. where we know the location of the road system. Land may be assigned a value depending on the distance from roads of Natural Composition various types, assuming that roads vary in their impact on remoteness. For example, an interstate highway is louder Composition, the relative abundance of genes, species, and will bring more people near an area than will a dirt road. communities and other components of ecosystems, is one of Of course, measuring remoteness requires an accurate de- the defining characteristics of ecosystems. An ecosystem scription of an area’s road system, which often is not avail- that has lost its native species or has been invaded by non- able for the most remote lands. natives has been altered in a fundamental way. In general, we recognize as most natural those ecosystems that have retained their full complement of native species and harbor Uncontrolled Processes no exotics. The most free land is the least controlled land. With the The protection of intact native ecosystems has long been invasion of new technologies that attended the recent settle- recognized as a goal of wilderness designation. The Wilder- ment of North America, ancient ecological processes were ness Act specifically intended to protect “the earth and its radically altered in many parts of the country. Where once community of life...” The protection of species that are easily fires (whether lightning-caused or anthropogenic), floods harmed by, or are harmful to, human contact is a role often and migrations marked the passage of the seasons, fire relegated to wilderness. Eliminated from much of their suppression, dams and extermination replaced them. If historical range, native predators, especially, are considered wilderness is to live up to one of its definitions, “self-willed by many to be a vital part of the wilderness experience. As land” (Turner 1996), its historical ecological processes must Turner (1996) says, “Predators are perhaps our most acces- be maintained. sible experience of the wild.” The importance of uncontrolled processes to wilderness is The invasion of non-native species also can decrease the amply noted in the literature. Wilderness has been de- naturalness and therefore the wildness of an area. Severe scribed as a place where “a diversity of beings [flourish] invasions can even alter the structure and function of eco- according to their own sorts of order” (Turner 1996) and systems. As wilderness manager Andy Kulla (1998) has said “where nature prevails or might prevail given the passage of about invasive exotic plants, “Weeds take the wild out of the time...so long as active ecological succession, structural wilderness.” Growing realization of the damage to native diversity, and naturalness are permitted” (Frome 1997). ecosystems done by exotic species has led many managers to Wilderness pioneer Arthur Carhart (1961) asserts, “[L]ands implement weed control programs, halt stocking of fish, called ‘wild’ have retained the attribute of freedom. They especially non-natives, and to insist on the use of weed-free have their own integrity intact. They have not been skinned, hay and revegetation mixes. scraped, dug up, regimented and pounded into shapes and The measure of natural composition is reasonably straight- services desired and demanded by ‘civilized’ man.” Even the forward, to a point. Most species are understood to be either Wilderness Act itself insists that wilderness “retain its native or the result of recent artificial introduction. The primeval character and influence” (emphasis added). species composition of any area, therefore, can be quantified

USDA Forest Service Proceedings RMRS-P-15-VOL-2. 2000 91 in terms of proportion of native species. Determining the deposition; others, such as the influence of city lights, affect degree to which native species composition has changed as mostly the quality of the visitor experience. Even where the a result of human agency is more difficult. Recent develop- effect is only on experience, pollution remains a measurable ments in historical ecology and (recent) paleobotany are attribute of the land that affects its wildness. shedding light on changes in species composition. Because of national laws like the Clean Air Act and the Clean Water Act, pollution is one of the best studied and best documented of the indicators of wildness. Depending on the Unaltered Structure part of the country, good maps are available for a number of Ecosystem structure refers to the spatial arrangement of air pollutants and for the quality of surface waters. The the components of ecosystems. This can refer to the gross- Environmental Protection Agency monitors sources of pollu- scale features of geomorphology, the arrangement of vegetation across the country and maintains data in a Geographic tion patches or the arrangement and spacing of trees in a Information System. In addition, NASA has used remote forest stand. The degree to which ecosystem components sensing to measure from space the light emitted to the night retain their historical arrangement contributes to the natu- sky. It should be possible to quantify the degree to which any ralness of the system. piece of land remains free from pollution. The maintenance of unaltered structure has long been a Each of these attributes contributes to the freedom or the litmus test of wilderness character and is the most familiar naturalness of a place and therefore to its wildness. But just criterion for designation. The Wilderness Act requires wil- because they contribute does not mean there will not be derness to be “without permanent improvements or human cases when they conflict. For example, the maintenance of habitation...with the imprint of man’s work substantially highly anthropogenic vegetation types (such as indigenous unnoticeable.” Bob Marshall’s (1933) definition stressed agricultural fields), which would be natural by the above that “all roads, settlements, and power transportation are definition, would require such intensive manipulation that barred.” it would diminish freedom. Nevertheless, these attributes, Again, the standard against which alteration is to be when considered in aggregate, should indicate much about judged is the condition of the ecosystem prior to the invasion the wildness of any given area. by modern technological society, begun in North American 300-400 years ago. As has been noted, pre-Columbian North America was a network of trails and settlements (Denevan Mapping Wildness______1992; Snyder 1990). Some structures, such as the earthworks In this section, we present results of an application of the of the Southeast, were large by any standard. These struc- attributes discussed above to the measurement of relative tures were part of the historical ecosystem and should be wildness at one scale – that of the contiguous United States. considered natural. Interestingly, Marshall (1933) recog- Though there are no hard and fast rules guiding how to apply nized historical structures as entirely consistent with his these concepts, their application does require the selection of view of wilderness: “Trails and temporary shelters, features a consistent approach. In this case, our approach was to such as were common long before the advent of the white locate the best spatial data we could find to represent each race, are entirely permissible.” attribute in a GIS data layer, assign each raster cell of the As with composition, the measurement of alteration of data layer a value for each attribute and, finally, sum the structure is fairly straightforward. Roads, dams, airstrips, values to derive the “wildness index” for each cell. To accom- mines, stockponds and other built structures diminish natu- modate work at a continental scale, we represented the ralness. Also, the substitution of square blocks of perfectly United States as a matrix of just less than 8 million one- spaced plantations for natural forest, even if they comprise square-kilometer cells for analysis. The analysis was con- native species, alters ecosystem structure and diminishes ducted with the GRID module of Arc/Info GIS software. Each naturalness. The science of landscape ecology has developed attribute was represented with a value ranging between one rapidly in the past few decades and has yielded a number of and five. Some attributes (for example, solitude) were de- metrics that can be applied to land to measure its departure rived from a single data set; others resulted from a combina- from historical structure. tion of several data sets (see below). Although our wildness index suffers from many of the same shortcomings attending other indices (such as the addition of unlike units as though Pollution they were commensurate), we feel it represents much of Wilderness carries with it an expectation of purity: clean what contributes to the wildness of a place. water, fresh air, clean soil, darkness. When air, streams and the night sky are dirtied with coal exhaust, road dust, bovine feces and distant industrial light, it diminishes the natural- Solitude ness of the land and the experience it provides. The poet Ideally, the spatial representation of opportunity for soli- Mark Strand (1996) makes clear the relationship between tude would display the probability distribution of encounter- pollution and wilderness when he writes, “First we pollute ing another person over a landscape. It would account not the wilderness, then we pollute our minds with the belief only for the presence of occupants of the land, but for visitors that we’ve done the right thing. Then we pollute the wilder- to popular locations like national parks. Unfortunately, ness more because we’ve lost our ability to see it. Soon the there are no such data sets available for the entire continen- wilderness ceases to exist.” Some forms of pollution have tal United States. However, the U.S. Bureau of the Census direct effects on the ecosystem, such as ozone and nitrogen keeps track of the distribution of the resident population

92 USDA Forest Service Proceedings RMRS-P-15-VOL-2. 2000 across the country. Map 1 shows the distribution of census versions may dissolve the five distance classes into one block groups assigned to five classes, where the value 1 continuous distance “surface.” (lightest) was assigned to cells with a 1990 population density greater than 1,000 persons/km2, the value 2 was assigned to cells with a population density between 100 and Uncontrolled Processes 2 1,000 persons/km and so on to the value 5 (darkest), which Ecological processes are inherently difficult to measure, was assigned to census block groups with a population 2 since we rarely are able to measure rates directly; instead, density of less than one person/km . Not surprisingly, the we generally measure states at different times and infer results show high population densities along the Eastern rates. Mapping processes is even more difficult, as it re- seaboard and very few residents in vast parts of the West. quires tying process measurements to particular places. This map represents only where people live; it does not Such data with national coverage are extremely difficult to consider the accessibility of the land to visitors. Future obtain. One of the few data sets that suggests process renditions of the data may take accessibility into account by impacts is the national inventory of dams available from the representing distance from population centers as well as USGS. To account for changes in hydrologic function, we their location. evaluated the number of dams in major hydrologic units (watersheds) and divided the nation into five classes We Remoteness assigned a value of 5 to cells within watersheds with no dams; a value of 4 to watersheds with 1-6 dams; a value of 3 to An ideal road data set would include all roads from watersheds with 7-20 dams; a value of 2 to watersheds with 21- interstate highways to natural surfaces and include all of 50 dams; and a value of 1 to watersheds with more than 50 the attributes needed to assess their relative influence on dams per watershed. remoteness. Unfortunately, such a data set does not exist for In future renditions, we plan to build on concepts devel- the continental United States. Instead, we used a “major oped by The Nature Conservancy (1998) to develop a surro- highways” (essentially paved intercity routes) data set com- gate for terrestrial processes based on patch metrics (area, piled by the U.S. Geological Survey (USGS). To assign a distance to edge, major axis) for polygons of natural vegeta- remoteness value to each cell, we “buffered” the road system tion (see below) delimited by major highways, agricultural at five different distances. Cells within 2 km of a road were lands and urban areas. The approach assumes that ecologi- assigned a value of 1; between 2 and 5 km a value of 2; 5-10 cal processes in larger, well-connected patches are under km a value of 3; 10-25 km a value of 4; and greater than 25 less human control than in smaller, disconnected patches. km a value of 5. The results are displayed in map 2. Future

Map 1—Opportunity for solitude. Population density by census block group.

USDA Forest Service Proceedings RMRS-P-15-VOL-2. 2000 93 Map 2—Remoteness. Distance from major highways.

Natural Composition Pollution There are a number of ways in which ecosystem composi- Despite the abundance of data on pollution compiled for tion can be measured. Conceptually, one of the most straight- various locations, there exist very little data describing the forward is species composition. Data sets should provide distribution of pollution across the entire country in a GIS information on the degree to which ecosystems retain the format. The EPA maintains a “national priority list” in GIS species typical of the area and the degree to which exotic format, recording the locations of all sites they regulate as species have displaced natives. One of the few data sets sources of pollution. In order to assess the influence of light available with coast-to-coast coverage of species composition pollution, we evaluated NASA’s image of “lights at night” for is the North American Land Cover Characteristics satellite the U.S. Again, cells were assigned a value from one to five image classification conducted by the USGS, which assigns based on a combination of these data sets. As we further refine surface vegetation to over 200 different classes of natural the map, we intend to bring in data that reflect actual air and and anthropogenic vegetation. We combined this data set water quality, not simply sources. with the urban classes from a separate USGS Land Use and To construct the map of wildness (map 4), we summed the Land Cover data set. To conduct our analysis, we assigned values of the six attributes into an overall “wildness index” each one-square-kilometer cell to one of five classes, from and displayed that index spatially. Beyond the trivial result unnatural (urban and cropland) to natural vegetation types. showing that the West is notably more wild than the East, Cells exhibiting a mixture of use/cover fell in between. some results were somewhat surprising. Because the map Map 3 illustrates the distribution of natural (darkest) and was generated without regard for ownership or physiogra- unnatural (lightest) vegetation across the United States. phy, it bears little resemblance to maps of the distribution of wilderness areas, federal lands, mountain ranges or river basins. Instead, the map exhibits “features,” such as the Unaltered Structure swaths of wild land running from southwestern Arizona to Humans alter ecosystem structure in a number of ways, eastern Utah and from Death Valley to southwest Idaho, from the construction of buildings, dams and roads to the that have nothing in common but their wildness. Other leveling of agricultural fields and the clearcutting of forests. places, like eastern New Mexico and central Nebraska, jump An ideal data set would account for all these effects. Unfor- out as particularly wild, though they are traditionally un- tunately, available data for the nation as a whole are limited heralded. The map also confirms what we already knew to “built structures.” We mapped the location of cities, towns, about places like the Boundary Waters, northern Maine, highways, dams and airstrips across the country. Cells that Okefenokee and the Everglades: These are very special wild included built structures were assigned a value of one; all places in an otherwise highly developed landscape. others were assigned a value of five.

94 USDA Forest Service Proceedings RMRS-P-15-VOL-2. 2000 Map 3—Natural composition. Natural and artificial land cover.

Map 4—Wildness.

USDA Forest Service Proceedings RMRS-P-15-VOL-2. 2000 95 As interesting as this map is, it is important to remember At the same time that we are moving forward with these that it is simply one analysis at one scale. Wild land exists other analyses, we will be working to improve our analytical in all landscapes at all scales. Aldo Leopold said it best when approach. Currently, the analysis is plagued by a number of he wrote, “[W]ilderness exists in all degrees, from the little problems. For example, by displaying the data in a one- accidental wild spot at the head of a ravine in a Corn Belt square-kilometer grid, we have implied a level of precision to woodlot to vast expanses of virgin country.... Wilderness is a the data that is inappropriate for an index based on data relative condition” (Leopold 1925). Figure 2 illustrates this collected at a number of scales, some of them quite coarse. sentiment by showing that the wild land continuum does not We are currently working to identify an appropriate level of exist only at the scale of large landscapes from city to precision for display. Also, the current approach has the wilderness. Within the portion of the land that we call rural potential to overemphasize the influence of some factors. For are land uses ranging from agribusiness to ranch. We may example, roads factor in the estimation of remoteness, un- determine that tilled or developed land is not wild, but that controlled processes and unaltered structure. We are work- a large ranch is. Even on the nonwild farm landscape, land ing toward a more sophisticated way to combine data sets to can range from developed homesites to uncultivated pasture account for all six attributes without unduly emphasizing and forest. Within this landscape, these uncultivated areas any particular factor. provide a glimpse of the natural and free and are highly prized for their wildness. The next step in our process will be to repeat this type of Relationship to Other Efforts ______analysis at the scale of a region (a state) and a subregion to The approach to mapping wildness described above is show that patterns of wildness emerge at all scales. At these based on an understanding that wildness inheres in varying scales, new (and hopefully better) data sets will be applied to degrees in all lands as a function of the relative freedom and show that relatively wild land exists all around us. For naturalness of the place. This allows the mapping of all lands example, though it appears as a highly developed patch at as possessing some degree of wildness and the production of the scale of the nation, the city of Chicago is home to a continuous surface describing the wildness of any land- hundreds of thousands of acres of precious wild places whose scape. Such an approach allows us to discern connections protection is being sought by a coalition known as “Chicago across wild landscapes that are not readily apparent in maps Wilderness.” The next stage of our analysis will demonstrate based on any one of the attributes (for example, land use/ that the wildness of places like these can be illustrated land cover) or on land ownership. As a result, our method through the application of the very same approach to smaller represents a new approach to the study of wild lands, landscapes. complementary to other existing efforts.

Rural “Multiple-use”

Ranchette Family Farm

Figure 2—Wild lands can be found in any landscape at any scale.

96 USDA Forest Service Proceedings RMRS-P-15-VOL-2. 2000 Generally, efforts to map wild places have been of two sorts: buffer zones, The Wildlands Project begins to address some those that focus on biological diversity and those that identify of the shortcomings of traditional wild land mapping, but special wild places. Traditionally, mapping efforts have iden- because mapping generally begins with existing designated tified special wild places such as nature sanctuaries (Kendeigh areas and builds out, it is a very “bottom-up” approach in the and others 1950-51) and wilderness areas (The Wilderness traditional mode of wild land identification. Our approach, Society 1989), with the implication that lands not identified in in contrast, is very “top down,” representing wildness the map are not wild. Similarly, a 1997 report by the World unanchored by existing land designations. We believe our Resources Institute characterized the world’s forests as either approach complements the “bottom-up” approach and will “frontier” or “non-frontier,” based on their ability to support a bring a new perspective to understanding the context of full complement of native species and ecological processes wilderness. (Bryant and others 1997). Our method allows us to identify lands of particularly high value, while acknowledging the wildness inherent in all lands. Wild Land Mapping: Toward a One of the most sophisticated wildland mapping efforts is Blueprint for Wilderness ______the National Wilderness Inventory of Australia (Lesslie and Maslen 1995). This effort represents a significant advance The identification of quantifiable attributes of wildness over previous efforts because it provides an objective proto- makes possible the representation of wildness and the map- col for evaluating the wildness (“Total Wilderness Quality ping of wildness across the landscape. The mapping of Index”) of any particular place based on four indicators: wildness is important for a number of reasons. First, it “remoteness from settlement, remoteness from access, ap- allows us to point to specific places, places that are impor- parent naturalness, and biophysical naturalness.” The ap- tant because they are wild, whether those places occur at the proach described in the Australian National Wilderness scale of a region, as they do in southern Utah, or at the scale Inventory Handbook (Lesslie and Maslen 1995) shares much of open space in such urban gems as L.A.’s Santa Monica in common with ours but still must be considered in the Mountains or Washington, D.C.’s Rock Creek Park. Maps traditional mode, as it evaluates the wilderness quality of help make places tangible and the subject of action. They can distinct land units identified as “natural.” help educate about wilderness, and they can help conserva- The past decade or so has witnessed great progress in the tionists visualize the scope of their work. Maps can also mapping of areas critical to biological diversity. Efforts like serve as a graphic record of our success. the Gap Analysis Project of the USGS Biological Resources Second, a map of where the wild places are can help us, as Division (Caicco and others 1995, Edwards and others 1995) conservationists, set priorities for our limited resources. The and similar initiatives, such as that undertaken by the wildest places are not necessarily the highest priorities for Florida Game and Freshwater Fish Commission (Cox and attention, but we should understand the context of the others 1994), have sought to identify lands of particular places that we do work to protect. Also, maps that show the conservation value for protecting wildlife in each state. relative importance of various wild land tracts can provide Studies like these improve on traditional conservation map- convincing arguments for wild land protection. Maps that ping initiatives because they acknowledge a continuum or show a tract or subregion (for example, Okefenokee or the gradient in wildland quality, irrespective of ownership. By Grand Staircase-Escalante National Monument) to be the including natural composition and uncontrolled processes in “wildest in the land” contribute to the argument for protection. our analysis, we, too, recognize biodiversity as critical to Third, maps of wild places can be powerful tools of inclu- wildland quality (although we do not pretend to achieve the sion. Wild land maps can help direct people who wish to level of detail of these other approaches). However, by also contribute to wilderness protection toward high-priority recognizing factors like solitude and unaltered structure, we lands. They can also help recruit new voices for wild land assert that biodiversity is a necessary, but not a sufficient protection by showing people who otherwise think of wild component of wildness. lands only in the abstract just how close these places are. One particularly noteworthy biodiversity-oriented map- Finally, maps can help illuminate possibility. As The ping effort is The Wildlands Project, whose founders believe Wildlands Project has shown, dreaming with a map and that “wilderness is absolutely essential to the comprehen- crayon can motivate people to work toward a future that is sive maintenance of biodiversity” (The Wildlands Project better than the present. A wild land map can show not just 1992). Such a philosophy turns the liabilities of other where the wild lands are, but where they could be. If done biodiversity mapping approaches into assets for the map- well, wild land maps based on the attributes described above ping of wild places. Because wilderness is essential to can help identify the specific changes necessary to restore biodiversity, protecting biodiversity necessarily must result wildness to degraded landscapes and begin the job of build- in the protection of nonbiological wilderness values. ing a system of wild lands, rather than simply defending an Mapping under The Wildlands Project begins with the ever-shrinking wild land base. identification of “core reserves” essential to the conservation of wildlife – often large predators that have been exploited to extinction elsewhere. To these core reserves are added Acknowledgments ______nonwilderness “buffer zones” and “corridors” to connect the This paper was originally presented at the Sixth World core reserves. Core reserves are usually national parks and Wilderness Congress in Bangalore, India, in October 1998 existing wilderness areas, augmented with roadless areas and was greatly improved by the feedback received from and places of particular conservation concern. By adding Congress delegates.

USDA Forest Service Proceedings RMRS-P-15-VOL-2. 2000 97 The authors would like to express their gratitude to Susan Kulla, A. 1998. Effects of noxious weeds on wilderness, recreation, Balikov, who developed some of the original ideas that made and tourism. Speech presented April 7, 1998, at the Colorado Weed Summit, Denver, CO (unpublished). this work possible but who left The Wilderness Society prior Leopold, A. 1921. The wilderness and its place in forest recreational to its completion. We miss you. policy. Journal of Forestry XIX(7):718-721. p. 719 Leopold, A. 1925. Wilderness as a form of land use. Reprinted as pages 75-84 in: The great new wilderness debate (J. Baird References ______Callicott and Michael P. Nelson, eds.). University of Georgia Press, Athens. 997 pp. Aplet, G. H. 1999. On the nature of wildness: exploring what Leopold, A. S.; Cain, S. A.; Cottam, C. M.; Gabrielson, I. N.; Kimball, wilderness really protects. Denver University Law Review 76: T. L. 1963. Wildlife management in the national parks. Reprinted 347-367. as pages 103-119 in: The great new wilderness debate (J. Baird Bayet, F. 1994. Overturning the doctrine: indigenous people and Callicott and Michael P. Nelson, eds.). University of Georgia wilderness – being aboriginal in the environmental movement. Press, Athens. 997 pp. Reprinted as pages 314-324 in: The great new wilderness debate Lesslie, R.; Maslen, M. 1995. National Wilderness Inventory hand- (J. Baird Callicott and Michael P. Nelson, eds.). University of book of procedures, content, and usage (Second edition). Austra- Georgia Press, Athens. 997 p. lian Heritage Commission. Australian Government Publishing Birch, T. H. 1990. The incarceration of wildness: wilderness areas Service, Canberra. as prisons. Reprinted as pages 443-470 in: The great new wilder- Marshall, R. 1930. The problem of the wilderness. Reprinted as ness debate (J. Baird Callicott and Michael P. Nelson, eds.). pages 85-96 in: The great new wilderness debate (J. Baird University of Georgia Press, Athens. 997 p. Callicott and Michael P. Nelson, eds.). University of Georgia Bryant, D.; Nielsen, D.; Tangley, L. 1997. The last frontier forests: Press, Athens. 997 pp. ecosystems and economies on the edge. World Resources Insti- Marshall, R. 1933. The people’s forests. Harrison Smith, and Robert tute, Washington, DC. Haas, New York. pp. 177-178. Caicco, S. L.; Scott, J. M; Butterfield, B.; Csuti, B. 1995. A gap Nabhan, G. P. 1995. Cultural parallax in viewing North American analysis of the management status of the vegetation of Idaho habitats. Reprinted as pages 628-641 in: The great new wilder- (U.S.A.). Conservation Biology 9:498-511. ness debate (J. Baird Callicott and Michael P. Nelson, eds.). University of Georgia Press, Athens. 997 pp. Carhart, A. H. 1961. Planning for America’s wildlands: a handbook rd for land-use planners, managers and executives, committee and Nash, R. 1982. Wilderness and the American mind, 3 edition. Yale commission members, conservation leaders, and all who face University Press, New Haven, CT. 425 pp. problems of wildland management. National Audubon Society, The Nature Conservancy. 1998. Ecological processes at the National Parks Association, The Wilderness Society, and the ecoregional scale: considerations for portfolio design: guidelines Wildlife Management Institute. The Telegraph Press, Harris- for ecoregional team leaders from the stewardship expert team. burg, PA. 97 pp. Unpublished draft manuscript, August 1998. 19 p. Cohen, M. P. 1984. The pathless way: John Muir and American Olson, S. 1938. Why wilderness? Pages 97-102 in: The great new wilderness. University of Wisconsin Press, Madison. 408 pp. wilderness debate (J. Baird Callicott and Michael P. Nelson, Cole, D. 1996. Ecological manipulation in wilderness: an emerging eds.). University of Georgia Press, Athens. 997 pp. management dilemma. International Journal of Wilderness Plumwood, V. 1998. Wilderness skepticism and wilderness dual- 2(1):15-19. ism. Pages 652-690 in: The great new wilderness debate (J. Baird Cox, J.; Kautz, R.; MacLaughlin, M.; Gilbert, T. 1994. Closing the Callicott and Michael P. Nelson, eds.). University of Georgia gaps in Florida’s wildlife habitat conservation system. Florida Press, Athens. 997 pp. Game and Freshwater Fish Commission, Tallahassee, FL. Snyder, G. 1990. The practice of the wild. North Point Press, New Denevan, W. 1992. The pristine myth: the landscape of the Americas York. 190 pp. p.14. in 1492. Reprinted as pages 414-442 in: The great new wilderness Strand, M. 1996. Untitled. In: Testimony: writers of the West speak debate (J. Baird Callicott and Michael P. Nelson, eds.). University out on behalf of Utah wilderness (S. Trimble and T.T. Williams, of Georgia Press, Athens. 997 pp. comps.). Milkweed Editions, Minneapolis, MN. Edwards, T.; Homer, C. G.; Bassett, S. D.; Falconer, A.; Ramsey, R. Thoreau, H. D. 1862. Walking. Pages 592-630 in: The portable D.; Wight D. W. 1995. Utah Gap Analysis: an environmental Thoreau (Carl Bode, ed.). Penguin Books, New York. (1982). information system.. Final Project Report 95-1, Utah Coopera- 698 pp. tive Fish and Wildlife Research Unit, Utah State University, Turner, J. 1996. The abstract wild. University of Arizona Press, Logan. Tucson. Frome, M. 1997. Battle for the wilderness, Rev. ed. University of The Wildlands Project. 1992. The Wildlands Project: plotting a Utah Press. 278 pp. p.12 North American wilderness recovery strategy. Wild Earth (Spe- Gomez-Pompa, A.; Kaus, A. 1992. Taming the wilderness myth. cial issue). Reprinted as pages 293-313 in: The great new wilderness debate The Wilderness Society. 1989. The National Wilderness Preservation (J. Baird Callicott and Michael P. Nelson, eds.). University of System 1964-1989 (map). The Wilderness Society, Washington, Georgia Press, Athens. 997 pp. DC. Kendeigh, S. C.; Baldwin, H. I.; Cahalane, V. H.; Clarke, C. H. D.; Whitney, S. 1997. Solitude: an endangered value of wilderness. Cottam, C.; Cottam, W. P.; Cowan, I. M.; Dansereau, P.; Davis, Signpost for Northwest trails. April 1997:33-34. Jr., J. H.; Emerson, F. W.; Haig, I. T.; Hayden, A.; Hayward, C. L.; Worf, B. 1997. Response to “Ecological manipulation in wilderness” Linsdale, J. M.; Macnab, J. A.; Potzger, J. E. 1950-51. Nature by Dr. David Cole. International Journal of Wilderness 3(2): sanctuaries in the United States and Canada, a preliminary 30-31. inventory. The Living Wilderness 15(35):1-45.

98 USDA Forest Service Proceedings RMRS-P-15-VOL-2. 2000

Appendix F

Transportation Infrastructure and Access on National Forests and Grasslands: A Literature Review Developed by The Wilderness Society

Transportation Infrastructure and Access on National Forests and Grasslands A Literature Review

Introduction The Forest Service transportation system is very large with 374,883 miles (603,316 km) of system roads and 143,346 miles (230,693 km) of system trails. The system extends broadly across every national forest and grasslands and through a variety of habitats, ecosystems and terrains. An impressive body of scientific literature exists addressing the various effects of roads on the physical, biological and cultural environment – so much so, in the last few decades a new field of “road ecology” has emerged. In recent years, the scientific literature has expanded to address the effects of roads on climate change adaptation and conversely the effects of climate change on roads, as well as the effects of restoring lands occupied by roads on the physical, biological and cultural environments.

The following literature review summarizes the most recent thinking related to the environmental impacts of forest roads and motorized routes and ways to address them. The literature review is divided into three sections that address the environmental effects of transportation infrastructure on forests, climate change and infrastructure, and creating sustainable forest transportation systems.

I. Impacts of Transportation Infrastructure and Access to the Ecological Integrity of Terrestrial and Aquatic Ecosystems and Watersheds II. Climate Change and Transportation Infrastructure Including the Value of Roadless Areas for Climate Change Adaptation III. Sustainable Transportation Management in National Forests as Part of Ecological Restoration

I. Impacts of Transportation Infrastructure and Access to the Ecological Integrity of Terrestrial and Aquatic Ecosystems and Watersheds

It is well understood that transportation infrastructure and access management impact aquatic and terrestrial environments at multiple scales, and, in general, the more roads and motorized routes the greater the impact. In fact, in the past 20 years or so, scientists having realized the magnitude and breadth of ecological issues related to roads; entire books have been written on the topic, e.g., Forman et al. (2003), and a new scientific field called “road ecology” has emerged. Road ecology research centers have been created including the Western

Transportation Institute at Montana State University and the Road Ecology Center at the University of California ‐ Davis.1

Below, we provide a summary of the current understanding on the impacts of roads and access allowed by road networks to terrestrial and aquatic ecosystems, drawing heavily on Gucinski et al. (2000). Other notable recent peer‐reviewed literature reviews on roads include Trombulak and Frissell (2000), Switalski et al. (2004), Coffin (2007), Fahrig and Rytwinski (2009), and Robinson et al. (2010). Recent reviews on the impact of motorized recreation include Joslin and Youmans (1999), Gaines et al. (2003), Davenport and Switalski (2006), Ouren et al. (2007), and Switalski and Jones (2012). These peer‐reviewed summaries provide additional information to help managers develop more sustainable transportation systems

Impact on geomorphology and hydrology The construction or presence of forest roads can dramatically change the hydrology and geomorphology of a forest system leading to reductions in the quantity and quality of aquatic habitat. While there are several mechanisms that cause these impacts (Wemple et al. 2001 , Figure 1), most fundamentally, compacted roadbeds reduce rainfall infiltration, intercepting and concentrating water, and providing a ready source of sediment for transport (Wemple et al. 1996, Wemple et al. 2001). In fact, roads contribute more sediment to streams than any other land management activity (Gucinski et al. 2000). Surface erosion rates from roads are typically at least an order of magnitude greater than rates from harvested areas, and three orders of magnitude greater than erosion rates from undisturbed forest soils (Endicott 2008).

1 See http://www.westerntransportationinstitute.org/research/roadecology and http://roadecology.ucdavis.edu/

Figure 1: Typology of erosional and depositional features produced by mass‐wasting and fluvial processes associate with forest roads (reprinted from Wemple et al. 2001)

Erosion of sediment from roads occurs both chronically and catastrophically. Every time it rains, sediment from the road surface and from cut‐ and fill‐slopes is picked up by rainwater that flows into and on roads (fluvial erosion). The sediment that is entrained in surface flows are often concentrated into road ditches and culverts and directed into streams. The degree of fluvial erosion varies by geology and geography, and increases with increased motorized use (Robichaud et al. 2010). Closed roads produce less sediment, and Foltz et al. (2009) found a significant increase in erosion when closed roads were opened and driven upon. In drier landscapes, wind erosion following vehicle use can be a significant source of soil loss as well (Belnap 2003).

Roads also precipitate catastrophic failures of road beds and fills (mass wasting) during large storm events leading to massive slugs of sediment moving into waterways (Endicott 2008; Gucinski et al. 2000). This typically occurs when culverts are undersized and cannot handle the volume of water, or they simply become plugged with debris. The saturated roadbed can fail entirely and result in a landslide, or the blocked stream crossing can erode the entire fill down to the original stream channel.

The erosion of road‐ and trail‐related sediment and its subsequent movement into stream systems affects the geomorphology of the drainage system in a number of ways. The magnitude of their effects varies by climate, geology, road age, construction / maintenance practices and storm history. It directly alters channel morphology by embedding larger gravels as well as filling pools. It can also have the opposite effect of increasing peak discharges and scouring channels, which can lead to disconnection of the channel and floodplain, and lowered base flows (Furniss et al. 1991; Joslin and Youmans 1999). The width/depth ratio of the stream changes which then

3 can trigger changes in water temperature, sinuosity and other geomorphic factors important for aquatic species survival (Joslin and Youmans 1999; Trombulak and Frissell 2000).

Roads also can modify flowpaths in the larger drainage network. Roads intercept subsurface flow as well as concentrate surface flow, which results in new flowpaths that otherwise would not exist, and the extension of the drainage network into previously unchannelized portions of the hillslope (Gucinski et al. 2000; Joslin and Youmans 1999). Severe aggradation of sediment at stream structures or confluences can force streams to actually go subsurface or make them too shallow for fish passage (Endicott 2008; Furniss et al. 1991).

Impacts on aquatic habitat and fish Roads can have dramatic and lasting impacts on fish and aquatic habitat. Increased sedimentation in stream beds has been linked to decreased fry emergence, decreased juvenile densities, loss of winter carrying capacity, and increased predation of fishes, and reductions in macro‐invertebrate populations that are a food source to many fish species (Rhodes et al. 1994, Joslin and Youmans 1999, Gucinski et al. 2000, Endicott 2008). On a landscape scale, these effects can add up to: changes in the frequency, timing and magnitude of disturbance to aquatic habitat and changes to aquatic habitat structures (e.g., pools, riffles, spawning gravels and in‐channel debris), and conditions (food sources, refugi, and water temperature) (Gucinski et al. 2000).

Roads can also act as barriers to migration (Gucinski et al. 2000). Where roads cross streams, road engineers usually place culverts or bridges. Culverts in particular can and often interfere with sediment transport and channel processes such that the road/stream crossing becomes a barrier for fish and aquatic species movement up and down stream. For instance, a culvert may scour on the downstream side of the crossing, actually forming a waterfall up which fish cannot move. Undersized culverts and bridges can infringe upon the channel or floodplain and trap sediment causing the stream to become too shallow and/or warm such that fish will not migrate past the structure. This is problematic for many aquatic species but especially for anadromous species that must migrate upstream to spawn. Well‐known native aquatic species affected by roads include Colorado River cutthroat trout (Oncorhynchus clarki pleuriticus), the Threatened Greenback cutthroat trout (O. c. stomias), and Rio Grande cutthroat trout (O. c. virginalis), as well as other native fishes and amphibians (Endicott 2008).

Impacts on terrestrial habitat and wildlife Roads and trails impact wildlife through a number of mechanisms including: direct mortality (poaching, hunting/trapping) changes in movement and habitat use patterns (disturbance/avoidance), as well as indirect impacts including alteration of the adjacent habitat and interference with predatory/prey relationships (Wisdom et al. 2000, Trombulak and Frissell 2000). Some of these impacts result from the road itself, and some result from the uses on and around the roads (access). Ultimately, roads have been found to reduce the abundance and distribution of several forest species (Fayrig and Ritwinski 2009, Benítez‐López et al. 2010).

Direct mortality and disturbance from road and trail use impacts many different types of species. For example, wide‐ranging carnivores can be significantly impacted by a number of factors including trapping, poaching, collisions, negative human interactions, disturbance and displacement (Gaines et al. 2003). Road access has slowed the recovery of the Mexican Wolf (Canis lupus baileyi) with more than half of of mortalities due to illegal shootings (USDI FWS 2012). Hunted game species such as elk (Cervus canadensis), become more vulnerable from

4 access allowed by roads and motorized trails resulting in a reduction in effective habitat among other impacts (Rowland et al. 2005, Switalski and Jones 2012). Slow‐moving migratory animals such as amphibians, and reptiles who use roads to regulate temperature are also vulnerable (Gucinski et al. 2000, Brehme et al. 2013). Several bird species are sensitive to disturbance on roads (Barton and Holmes 2007), and several authors have identified buffer zones (Table 1, Switalski and Jones 2008, Whittington and Allen 2008).

Habitat alteration is a significant consequence of roads as well. At the landscape scale, roads fragment habitat blocks into smaller patches that may not be able to support successfully interior forest species. Smaller habitat patches also results in diminished genetic variability, increased inbreeding, and at times local extinctions (Gucinski et al. 2000; Trombulak and Frissell 2000). Motorized trails and routes can also have cascading effects throughout the ecosystem. For example, on an intensively used ORV route in Idaho, native shrubs, bunch grasses, and microbiotic crust were greatly reduced close to the route and replaced with non‐native cheat grass (Bromus tectorum) and the native shrub rabbitbrush (Chrysothamnus spp.; Munger et al. 2003). Because of these habitat changes, fewer reptiles were found alongside the route than were found 100 m away.

Table 1. A summary of raptor nest buffer zones recommended for areas associated with human disturbance (Reprinted from Switalski and Jones 2008)

Species Median nest buffer (m) Reference (range in parentheses) American kestrel Falco sparverius 125 (50‐200) Richardson and Miller (1997) Ferruginous hawk Buteo regalis 300 Hamann et al. (1999) Bald eagle Haliaeetus leucocephalus 400 Hamann et al. (1999) Northern goshawk Accipiter gentilis 450 (400‐500) Jones (1979) Sharp‐shinned hawk Accipiter striatus 450 (400‐500) Jones (1979) Cooper’s hawk Accipiter cooperii 525 (400‐500) Richardson and Miller (1997) Prairie falcon Falco mexicanus 650 (50‐800) Richardson and Miller (1997) Golden eagle Aquila chrysaetos 800 (200‐1600) Richardson and Miller (1997) Peregrine falcon Falco peregrinus 800 (800‐1600) Richardson and Miller (1997) Red‐tailed hawk Buteo jamaicensis 800 Call (1979) Mexican spotted owl Strix occidentalis lucida 900 US Fish and Wildlife Service (1995) Osprey Pandion haliaetus 1000 (400‐1500) Richardson and Miller (1997)

Roads also change the composition and structure of ecosystems along buffer zones, called edge‐ affected zones. The width of edge‐affected zones varies by what metric is being discussed; however, researchers have documented road‐avoidance zones a kilometer or more away from a road (Table 2). In heavily roaded landscapes, edge‐affected acres can be a significant fraction of total acres. For example, in a landscape area where the road density is 3 mi/mi2 (not an uncommon road density in national forests) and where the edge‐affected zone is estimated to be 500 ft from the center of the road to each side, the edge‐affected zone is 56% of the total acreage.

Table 2: A summary of some documented road‐avoidance zones for various species (adapted from Robinson et al. 2010).

Avoidance zone Species m (ft) Type of disturbance Reference Snakes 650 (2133) Forestry roads Bowles (1997) Salamander 35 (115) Narrow forestry road, light traffic Semlitsch (2003) Woodland birds 150 (492) Unpaved roads Ortega and Capen (2002) Spotted owl 400 (1312) Forestry roads, light traffic Wasser et al. (1997) Marten <100 (<328) Any forest opening Hargis et al. (1999) Elk 500–1000 (1640‐3281) Logging roads, light traffic Edge and Marcum (1985) 100–300 (328‐984) Mountain roads depending on Rost and Bailey (1979) traffic volume Black bear 274 (899) Spring, unpaved roads Kasworm and Manley (1990) 914 (2999) Fall, unpaved roads

Roads and trails also affect ecosystems and habitats because they are also a major vector of non‐native plant and animal species. This can have significant ecological and economic impacts when the invading species are aggressive and can overwhelm or significantly alter native species and systems. In addition, roads can increase harassment, poaching and collisions with vehicles, all of which lead to stress or mortality (Wisdom et al. 2000).

Recent reviews have synthesized the impacts of roads on animal abundance and distribution. Fahrig and Rytwinski (2009) did a complete review of the empirical literature on effects of roads and traffic on animal abundance and distribution looking at 79 studies that addressed 131 species and 30 species groups. They found that the number of documented negative effects of roads on animal abundance outnumbered the number of positive effects by a factor of 5. Amphibians, reptiles, most birds tended to show negative effects. Small mammals generally showed either positive effects or no effect, mid‐sized mammals showed either negative effects or no effect, and large mammals showed predominantly negative effects. Benítez‐López et al. (2010) conducted a meta‐analysis on the effects of roads and infrastructure proximity on mammal and bird populations. They found a significant pattern of avoidance and a reduction in bird and mammal populations in the vicinity of infrastructure.

Road density2 thresholds for fish and wildlife

It is well documented that beyond specific road density thresholds, certain species will be negatively affected, and some will be extirpated. Most studies that look into the relationship between road density and wildlife focus on the impacts to large endangered carnivores or hunted game species, although high road densities certainly affect other species – for instance, reptiles and amphibians. Gray wolves (Canis lupus) in the Great Lakes region and elk in Montana and Idaho have undergone the most long‐term and in depth analysis. Forman and Hersperger (1996) found that in order to maintain a naturally functioning landscape with sustained populations of large mammals, road density must be below 0.6 km/km² (1.0 mi/mi²). Several studies have since substantiated their claim (Robinson et al. 2010, Table 3).

A number of studies at broad scales have also shown that higher road densities generally lead to greater impacts to aquatic habitats and fish density (Table 3). Carnefix and Frissell (2009) provide a concise review of studies that correlate cold water fish abundance and road density, and from the cited evidence concluded that “1) no truly “safe” threshold road density exists, but rather negative impacts begin to accrue and be expressed with incursion of the very first road segment; and 2) highly significant impacts (e.g., threat of extirpation of sensitive species) are already apparent at road densities on the order of 0.6 km/km2 (1.0 mi/mi²) or less” (p. 1).

2 We intend the term “road density” to refer to the density all roads within national forests, including system roads, closed roads, non‐system roads administered by other jurisdictions (private, county, state), temporary roads and motorized trails. Please see Attachment 2 for the relevant existing scientific information supporting this approach.

Table 3: A summary of some road‐density thresholds and correlations for terrestrial and aquatic species and ecosystems (reprinted from Robinson et al. 2010).

Species (Location) Road density (mean, guideline, threshold, correlation) Reference

Wolf (Minnesota) 0.36 km/km2 (mean road density in primary range); Mech et al. (1988) 0.54 km/km2 (mean road density in peripheral range) Wolf >0.6 km/km2 (absent at this density) Jalkotzy et al. (1997) Wolf (Northern Great Lakes re‐ >0.45 km/km2 (few packs exist above this threshold); Mladenoff et al. (1995) gion) >1.0 km/km2 (no pack exist above this threshold) Wolf (Wisconsin) 0.63 km/km2 (increasing due to greater human tolerance Wydeven et al. (2001) Wolf, mountain lion (Minne‐ 0.6 km/km2 (apparent threshold value for a naturally Thiel (1985); van Dyke et sota, Wisconsin, Michigan) functioning landscape containing sustained popula‐ al. (1986); Jensen et al. tions) (1986); Mech et al. (1988); Mech (1989) Elk (Idaho) 1.9 km/km2 (density standard for habitat effectiveness) Woodley 2000 cited in Beazley et al. 2004 Elk (Northern US) 1.24 km/km2 (habitat effectiveness decline by at least Lyon (1983) 50%) Elk, bear, wolverine, lynx, and 0.63 km/km2 (reduced habitat security and increased Wisdom et al. (2000) others mortality) Moose (Ontario) 0.2‐0.4 km/km2 (threshold for pronounced response) Beyer et al. (2013) Black bear (North Carolina) >1.25 km/km2 (open roads); >0.5 km/km2 (logging Brody and Pelton (1989) roads); (interference with use of habitat) Black bear 0.25 km/km2 (road density should not exceed) Jalkotzy et al. (1997) Bobcat (Wisconsin) 1.5 km/km2 (density of all road types in home range) Jalkotzy et al. (1997) Large mammals >0.6 km/km2 (apparent threshold value for a naturally Forman and Hersperger functioning landscape containing sustained popula‐ (1996) tions) Fish populations (Medicine Bow (1) Positive correlation of numbers of culverts and Eaglin and Hubert (1993) National Forest) stream crossings and amount of fine sediment in cited in Gucinski et al. stream channels (2001) (2) Negative correlation of fish density and numbers of culverts Macroinvertebrates Species richness negatively correlated with an index of McGurk and Fong (1995) road density Non‐anadromous salmonids (1) Negative correlation likelihood of spawning and Lee et al. (1997) (Upper Columbia River basin) rearing and road density (2) Negative correlation of fish density and road density

Where both stream and road densities are high, the incidence of connections between roads and streams can also be expected to be high, resulting in more common and pronounced effects of roads on streams (Gucinski et al. 2000). For example, a study on the Medicine Bow National Forest (WY) found as the number of culverts and stream crossings increased, so did the amount of sediment in stream channels (Eaglin and Hubert 1993). They also found a negative correlation with fish density and the number of culverts. Invertebrate communities can also be impacted. McGurk and Fong (1995) report a negative correlation between an index of road density with macroinvertebrate diversity.

Anderson et al. (2012) also showed that watershed conditions tend to be best in areas protected from road construction and development. Using the US Forest Service’s Watershed Condition Framework assessment data, they showed that National Forest lands that are protected under the Wilderness Act, which provides the strongest safeguards, tend to have the healthiest watersheds. Watersheds in Inventoried Roadless Areas – which are protected from road building and logging by the Roadless Area Conservation Rule – tend to be less healthy than watersheds in designated Wilderness, but they are considerably healthier than watersheds in the managed landscape.

Impacts on other resources Roads and motorized trails also play a role in affecting wildfire occurrence. Research shows that human‐ignited wildfires, which account for more than 90% of fires on national lands, is almost five times more likely in areas with roads (USDA Forest Service 1996a; USDA Forest Service 1998). Furthermore, Baxter (2002) found that off‐road vehicles (ORVs) can be a significant source of fire ignitions on forestlands. Roads can affect where and how forests burn and, by extension, the vegetative condition of the forest. See Attachment 1 for more information documenting the relationship between roads and wildfire occurrence.

Finally, access allowed by roads and trails can increase of ORV and motorized use in remote areas threatening archaeological and historic sites. Increased visitation has resulted in intentional and unintentional damage to many cultural sites (USDI Bureau of Land Management 2000, Schiffman 2005).

II. Climate Change and Transportation Infrastructure including the value of roadless areas for climate change adaptation

As climate change impacts grow more profound, forest managers must consider the impacts on the transportation system as well as from the transportation system. In terms of the former, changes in precipitation and hydrologic patterns will strain infrastructure at times to the breaking point resulting in damage to streams, fish habitat, and water quality as well as threats to public safety. In terms of the latter, the fragmenting effect of roads on habitat will impede the movement of species which is a fundamental element of adaptation. Through planning, forest managers can proactively address threats to infrastructure, and can actually enhance forest resilience by removing unneeded roads to create larger patches of connected habitat.

Impact of climate change and roads on transportation infrastructure In addition to a much warmer climate, it is expected that climate change will be responsible for more extreme weather events, leading to increasing flood severity, more frequent landslides, changing hydrographs (peak, annual mean flows, etc.), and changes in erosion and

9 sedimentation rates and delivery processes3. Roads and trails in national forests, if designed by an engineering standard at all, were designed for storms and water flows typical of past decades, and hence may not be designed for the storms in future decades. Hence, climate driven changes may cause transportation infrastructure to malfunction or fail (ASHTO 2012, USDA Forest Service 2010). The likelihood is higher for facilities in high‐risk settings—such as rain‐on‐snow zones, coastal areas, and landscapes with unstable geology (USDA Forest Service 2010).

Forests fragmented by roads will likely demonstrate less resistance and resilience to stressors, like those associated with climate change (Noss 2001). First, the more a forest is fragmented (and therefore the higher the edge/interior ratio), the more the forest loses its inertia characteristic, and becoming less resilient and resistant to climate change. Second, the more a forest is fragmented characterized by isolated patches, the more likely the fragmentation will interfere with the ability of species to track shifting climatic conditions over time and space. Noss (2001) predicts that weedy species with effective dispersal mechanisms might benefit from fragmentation at the expense of native species.

Modifying infrastructure to increase resilience To prevent or reduce road failures, culvert blow‐outs, and other associated hazards, forest managers will need to take a series of actions. These include replacing undersized culverts with larger ones, prioritizing maintenance and upgrades (e.g., installing drivable dips and more outflow structures), and obliterating roads that are no longer needed and pose erosion hazards (USDA Forest Service 2010, USDA Forest Service 2012a, USDA Forest Service 2011, Table 4).

Olympic National Forest has developed a number of documents oriented at oriented at protecting watershed health and species in the face of climate change, including a 2003 travel management strategy and a report entitled Adapting to Climate Change in Olympic National Park and National Forest. In the travel management strategy, Olympic National Forest recommended that 1/3rd of its road system be decommissioned and obliterated (USDA Forest Service 2011a). In addition, the plan called for addressing fish migration barriers in a prioritized and strategic way – most of these are associated with roads. The report calls for road decommissioning, relocation of roads away from streams, enlarging culverts as well as replacing culverts with fish‐friendly crossings (USDA Forest Service 2011a, Table 4).

3 http://www.epa.gov/climatechange/impacts‐adaptation/southwest.html

Table 4: Current and expected sensitivities of fish to climate change on the Olympic Peninsula, associated adaptation strategies and action for fisheries and fish habitat management and relevant to transportation management at Olympic National Forest and Olympic National Park (excerpt reprinted from USDA Forest Service 2011a).

Current and expected sensitivites Adaptation strategies and actions Changes in habitat quantity and quality • Implement habitat restoration projects that focus on re‐creating watershed processes and functions and that create diverse, resilient habitat. Increase in culvert failures, fill‐slope failures, • Decommission unneeded roads. stream adjacent road failures, and encroach‐ • Remove sidecast, improve drainage, and increase culvert sizing ment from stream‐adjacent road segments on remaining roads. • Relocate stream‐adjacent roads. Greater difficulty disconnecting roads from • Design more resilient stream crossing structures. stream channels Major changes in quantity and timing of • Make road and culvert designs more conservative in transitional streamflow in transitional watersheds watersheds to accommodate expected changes. Decrease in area of headwater streams • Continue to correct culvert fish passage barriers. • Consider re‐prioritizing culvert fish barrier correction projects. Decrease in habitat quantity and connectivity • Restore habitat in degraded headwater streams that are for species that use headwater streams expected to retain adequate summer streamflow (ONF).

In December 2012, the USDA Forest Service published a report entitled “Assessing the Vulnerability of Watersheds to Climate Change.” This document reinforces the concept expressed by Olympic National Forest that forest managers need to be proactive in reducing erosion potential from roads:

“Road improvements were identified as a key action to improve condition and resilience of watersheds on all the pilot Forests. In addition to treatments that reduce erosion, road improvements can reduce the delivery of runoff from road segments to channels, prevent diversion of flow during large events, and restore aquatic habitat connectivity by providing for passage of aquatic organisms. As stated previously, watershed sensitivity is determined by both inherent and management‐related factors. Managers have no control over the inherent factors, so to improve resilience, efforts must be directed at anthropogenic influences such as instream flows, roads, rangeland, and vegetation management….

[Watershed Vulnerability Analysis] results can also help guide implementation of travel management planning by informing priority setting for decommissioning roads and road reconstruction/maintenance. As with the Ouachita NF example, disconnecting roads from the stream network is a key objective of such work. Similarly, WVA analysis could also help prioritize aquatic organism passage projects at road‐stream crossings to allow migration by aquatic residents to suitable habitat as streamflow and temperatures change” (USDA Forest Service 2012a, p. 22‐23).

Reducing fragmentation to enhance aquatic and terrestrial species adaptation Decommissioning and upgrading roads and thus reducing the amount of fine sediment deposited on salmonid nests can increase the likelihood of egg survival and spawning success (McCaffery et al. 2007). In addition, this would reconnect stream channels and remove barriers such as culverts. Decommissioning roads in riparian areas may provide further benefits to salmon and other aquatic organisms by permitting reestablishment of streamside vegetation, which provides shade and maintains a cooler, more moderated microclimate over the stream (Battin et al. 2007).

One of the most well documented impacts of climate change on wildlife is a shift in the ranges of species (Parmesan 2006). As animals migrate, landscape connectivity will be increasingly important (Holman et al. 2005). Decommissioning roads in key wildlife corridors will improve connectivity and be an important mitigation measure to increase resiliency of wildlife to climate change. For wildlife, road decommissioning can reduce the many stressors associated with roads. Road decommissioning restores habitat by providing security and food such as grasses and fruiting shrubs for wildlife (Switalski and Nelson 2011).

Forests fragmented by roads and motorized trail networks will likely demonstrate less resistance and resilience to stressors, such as weeds. As a forest is fragmented and there is more edge habitat, Noss (2001) predicts that weedy species with effective dispersal mechanisms will increasingly benefit at the expense of native species. However, decommissioned roads when seeded with native species can reduce the spread of invasive species (Grant et al. 2011), and help restore fragmented forestlands. Off‐road vehicles with large knobby tires and large undercarriages are also a key vector for weed spread (e.g., Rooney 2006). Strategically closing and decommissioning motorized routes, especially in roadless areas, will reduce the spread of weeds on forestlands (Gelbard and Harrison 2003).

Transportation infrastructure and carbon sequestration The topic of the relationship of road restoration and carbon has only recently been explored. There is the potential for large amounts of carbon (C) to be sequestered by reclaiming roads. When roads are decompacted during reclamation, vegetation and soils can develop more rapidly and sequester large amounts of carbon. A recent study estimated total soil C storage increased 6 fold to 6.5 x 107g C/km (to 25 cm depth) in the northwestern US compared to untreated abandoned roads (Lloyd et al. 2013). Another recent study concluded that reclaiming 425 km of logging roads over the last 30 years in Redwood National Park in Northern California resulted in net carbon savings of 49,000 Mg carbon to date (Madej et al. 2013, Table 5).

Kerekvliet et al. (2008) published a Wilderness Society briefing memo on the impact to carbon sequestration from road decommissioning. Using Forest Service estimates of the fraction of road miles that are unneeded, the authors calculated that restoring 126,000 miles of roads to a natural state would be equivalent to revegetating an area larger than Rhode Island. In addition, they calculate that the net economic benefit of road treatments are always positive and range from US$0.925‐1.444 billion.

Table 5. Carbon budget implications in road decommissioning projects (reprinted from Madej et al. 2013).

Road Decommissioning Activities and Processes Carbon Cost Carbon Savings Transportation of staff to restoration sites (fuel emissions) X Use of heavy equipment in excavations (fuel emissions) X Cutting trees along road alignment during hillslope recontouring X Excavation of road fill from stream crossings X Removal of road fill from unstable locations X Reduces risk of mass movement X Post‐restoration channel erosion at excavation sites X Natural revegetation following road decompaction X Replanting trees X Soil development following decompaction X

Benefits of roadless areas and roadless area networks to climate change adaptation Undeveloped natural lands provide numerous ecological benefits. They contribute to biodiversity, enhance ecosystem representation, and facilitate connectivity (Loucks et al. 2003; Crist and Wilmer 2002, Wilcove 1990, The Wilderness Society 2004, Strittholt and Dellasala 2001, DeVelice and Martin 2001), and provide high quality or undisturbed water, soil and air (Anderson et al. 2012, Dellasalla et al. 2011). They also can serve as ecological baselines to help us better understand our impacts to other landscapes, and contribute to landscape resilience to climate change.

Forest Service roadless lands, in particular, are heralded for the conservation values they provide. These are described at length in the preamble of the Roadless Area Conservation Rule (RACR)4 as well as in the Final Environmental Impact Statement (FEIS) for the RACR5, and include: high quality or undisturbed soil, water, and air; sources of public drinking water; diversity of plant and animal communities; habitat for threatened, endangered, proposed, candidate, and sensitive species and for those species dependent on large, undisturbed areas of land; primitive, semi‐primitive non‐ motorized, and semi‐primitive motorized classes of dispersed recreation; reference landscapes; natural appearing landscapes with high scenic quality; traditional cultural properties and sacred sites; and other locally identified unique characteristics (e.g., include uncommon geological formations, unique wetland complexes, exceptional hunting and fishing opportunities).

The Forest Service, National Park Service, and US Fish and Wildlife Service recognize that protecting and connecting roadless or lightly roaded areas is an important action agencies can take to enhance climate change adaptation. For example, the Forest Service National Roadmap for Responding to Climate Change (USDA Forest Service 2011b) establishes that increasing connectivity and reducing fragmentation are short and long term actions the Forest Service

4 Federal Register .Vol. 66, No. 9. January 12, 2001. Pages 3245‐3247. 5 Final Environmental Impact Statement, Vol. 1, 3–3 to 3–7

13 should take to facilitate adaptation to climate change.6 The National Park Service also identifies connectivity as a key factor for climate change adaptation along with establishing “blocks of natural landscape large enough to be resilient to large‐scale disturbances and long‐term changes” and other factors. The agency states that: “The success of adaptation strategies will be enhanced by taking a broad approach that identifies connections and barriers across the landscape. Networks of protected areas within a larger mixed landscape can provide the highest level of resilience to climate change.”7 Similarly, the National Fish, Wildlife and Plants Climate Adaptation Partnership’s Adaptation Strategy (2012) calls for creating an ecologically‐connected network of conservation areas.8

Roadless lands also are responsible for higher quality water and watersheds. Anderson et al. (2012) assessed the relationship of watershed condition and land management status and found a strong spatial association between watershed health and protective designations. Dellasalla et al. (2011) found that undeveloped and roadless watersheds are important for supplying downstream users with high‐quality drinking water, and developing these watersheds comes at significant costs associated with declining water quality and availability. The authors recommend a light‐touch ecological footprint to sustain the many values that derive from roadless areas including healthy watersheds.

6 Forest Service, 2011. National Roadmap for Responding to Climate Change. US Department of Agriculture. FS‐957b. Page 26. 7 National Park Service. Climate Change Response Program Brief. http://www.nature.nps.gov/climatechange/adaptationplanning.cfm. Also see: National Park Service, 2010. Climate Change Response Strategy. http://www.nature.nps.gov/climatechange/docs/NPS_CCRS.pdf. Objective 6.3 is to “Collaborate to develop cross‐jurisdictional conservation plans to protect and restore connectivity and other landscape‐ scale components of resilience.” 8 See http://www.wildlifeadaptationstrategy.gov/pdf/NFWPCAS‐Chapter‐3.pdf. Pages 55‐ 59. The first goal and related strategies are:

Goal 1: Conserve habitat to support healthy fish, wildlife, and plant populations and ecosystem functions in a changing climate. Strategy 1.1: identify areas for an ecologically‐connected network of terrestrial, freshwater, coastal, and marine conservation areas that are likely to be resilient to climate change and to support a broad range of fish, wildlife, and plants under changed conditions. Strategy 1.2: Secure appropriate conservation status on areas identified in Strategy 1.1 to complete an ecologically‐connected network of public and private conservation areas that will be resilient to climate change and support a broad range of species under changed conditions. Strategy 1.4: Conserve, restore, and as appropriate and practicable, establish new ecological connections among conservation areas to facilitate fish, wildlife, and plant migration, range shifts, and other transitions caused by climate change.

III. Sustainable Transportation Management in National Forests as Part of Ecological Restoration

At 375,000 miles strong, the Forest Service road system is one of the largest in the world – it is eight times the size of the National Highway System. It is also indisputably unsustainable – that is, roads are not designed, located, or maintained according to best management practices, and environmental impacts are not minimized. It is largely recognized that forest roads, especially unpaved ones, are a primary source of sediment pollution to surface waters (Endicott 2008, Gucinski et al. 2000), and that the system has about 1/3rd more miles than it needs (USDA Forest Service 2001). In addition, the majority of the roads were constructed decades ago when road design and management techniques did not meet current standards (Gucinski et al. 2000, Endicott 2008), making them more vulnerable to erosion and decay than if they had been designed today. Road densities in national forests often exceed accepted thresholds for wildlife.

Only a small portion of the road system is regularly used. All but 18% of the road system is inaccessible to passenger vehicles. Fifty‐five percent of the roads are accessible only by high clearance vehicles and 27% are closed. The 18% that is accessible to cars is used for about 80% of the trips made within National Forests.9 Most of the road maintenance funding is directed to the passenger car roads, while the remaining roads suffer from neglect. As a result, the Forest Service currently has a $3.7 billion road maintenance backlog that grows every year. In other words, only about 1/5th of the roads in the national forest system are used most of the time, and the fraction that is used often is the best designed and maintained because they are higher level access roads. The remaining roads sit generally unneeded and under‐maintained – arguably a growing ecological and fiscal liability.

Current Forest Service management direction is to identify and implement a sustainable transportation system.10 The challenge for forest managers is figuring out what is a sustainable road system and how to achieve it – a challenge that is exacerbated by climate change. It is reasonable to define a sustainable transportation system as one where all the routes are constructed, located, and maintained with best management practices, and social and environmental impacts are minimized. This, of course, is easier said than done, since the reality is that even the best roads and trail networks can be problematic simply because they exist and usher in land uses that without the access would not occur (Trombulak and Frissell 2000, Carnefix and Frissell 2009, USDA Forest Service 1996b), and when they are not maintained to the designed level they result in environmental problems (Endicott 2008; Gucinski et al. 2000). Moreover, what was sustainable may no longer be sustainable under climate change since roads designed to meet older climate criteria may no longer hold up under new climate scenarios (USDA Forest Service 2010, USDA Forest Service 2011b, USDA Forest Service 2012a, AASHTO 2012).

Forest Service efforts to move toward a more sustainable transportation system The Forest Service has made efforts to make its transportation system more sustainable, but still has considerable work to do. In 2001, the Forest Service tried to address the issue by

9 USDA Forest Service. Road Management Website Q&As. Available online at http://www.fs.fed.us/eng/road_mgt/qanda.shtml. 10 See Forest Service directive memo dated March 29, 2012 entitled “Travel Management, Implementation of 36 CFR, Part 202, Subpart A (36 CFR 212.5(b))”

15 promulgating the Roads Rule11 with the purpose of working toward a sustainable road system (USDA 2001). The Rule directed every national forest to identify a minimum necessary road system and identify unneeded roads for decommissioning. To do this, the Forest Service developed the Roads Analysis Process (RAP), and published Gucinski et al. (2000) to provide the scientific foundation to complement the RAP. In describing the RAP, Gucinski et al. (2000) writes:

“Roads Analysis is intended to be an integrated, ecological, social, and economic approach to transportation planning. It uses a multiscale approach to ensure that the identified issues are examined in context. Roads Analysis is to be based on science. Analysts are expected to locate, correctly interpret, and use relevant existing scientific literature in the analysis, disclose any assumptions made during the analysis, and reveal the limitations of the information on which the analysis is based. The analysis methods and the report are to be subjected to critical technical review” (p. 10).

Most national forests have completed RAPs, although most only looked at passenger vehicle roads which account for less than 20% of the system’s miles. The Forest Service Washington Office in 2010 directed that forests complete a Travel Analysis Process (TAP) by the end of fiscal year 2015, which must address all roads and create a map and list of roads identifying which are likely needed and which are not. Completed TAPs will provide a blueprint for future road decommissioning and management, they will not constitute compliance with the Roads Rule, which clearly requires the identification of the minimum roads system and roads for decommissioning. Almost all forests have yet to comply with subpart A.

The Forest Service in 2005 then tried to address the off‐road portion of this issue by promulgating subpart B of the Travel Management Rule,12 with the purpose of curbing the most serious impacts associated with off‐road vehicle use. Without a doubt, securing summer‐time travel management plans was an important step to curbing the worst damage. However, much work remains to be done to approach sustainability, especially since many national forests used the travel management planning process to simply freeze the footprint of motorized routes, and did not try to re‐design the system to make it more ecologically or socially sustainable. Adams and McCool (2009) considered this question of how to achieve sustainable motorized recreation and concluded that:

As the agencies move to revise [off‐road vehicle] allocations, they need to clearly define how they intend to locate routes so as to minimize impacts to natural resources and other recreationists in accordance with Executive Order 11644....13

11 36 CFR 215 subpart A 12 36 CFR 212 subpart B 13 Recent court decisions have made it clear that the minimization requirements in the Executive Orders are not discretionary and that the Executive Orders are enforceable. See  Idaho Conservation League v. Guzman , 766 F. Supp. 2d 1056 (D. Idaho 2011) (Salmon‐Challis National Forest TMP) .  The Wilderness Society v. U.S. Forest Service, CV 08‐363 (D. Idaho 2012) (Sawtooth‐Minidoka district National Forest TMP).  Central Sierra Environmental Resource Center v. US Forest Service, CV 10‐2172 (E.D. CA 2012) (Stanislaus National Forest TMP).

…As they proceed with designation, the FS and BLM need to acknowledge that current allocations are the product of agency failure to act, not design. Ideally, ORV routes would be allocated as if the map were currently empty of ORV routes. Reliance on the current baseline will encourage inefficient allocations that likely disproportionately impact natural resources and non‐ motorized recreationists. While acknowledging existing use, the agencies need to do their best to imagine the best possible arrangement of ORV routes, rather than simply tinkering around the edges of the current allocations.14

The Forest Service only now is contemplating addressing the winter portion of the issue, forced by a lawsuit challenging the Forest Service’s inadequate management of snowmobiles. The agency is expected to issue a third rule in the fall of 2014 that will trigger winter travel management planning.

Strategies for identifying a minimum road system and prioritizing restoration Transportation Management plays an integral role in the restoration of Forestlands. Reclaiming and obliterating roads is key to developing a sustainable transportation system. Numerous authors have suggested removing roads 1) to restore water quality and aquatic habitats Gucinski et al. 2000), and 2) to improve habitat security and restore terrestrial habitat (e.g., USDI USFWS 1993, Hebblewhite et al. 2009).

Creating a minimum road system through road removal will increase connectivity and decrease fragmentation across the entire forest system. However, at a landscape scale, certain roads and road segments pose greater risks to terrestrial and aquatic integrity than others. Hence, restoration strategies must focus on identifying and removing/mitigating the higher risk roads. Additionally, areas with the highest ecological values, such as being adjacent to a roadless area, may also be prioritized for restoration efforts. Several methods have been developed to help prioritize road reclamation efforts including GIS‐based tools and best management practices (BMPs). It is our hope that even with limited resources, restoration efforts can be prioritized and a more sustainable transportation system created.

GIS‐based tools Girvetz and Shilling (2003) developed a novel and inexpensive way to analyze environmental impacts from road systems using the Ecosystem Management Decision Support program (EMDS). EMDS was originally developed by the United States Forest Service, as a GIS‐based decision support tool to conduct ecological analysis and planning (Reynolds 1999). Working in conjunction with Tahoe National Forest managers, Girvetz and Shilling (2003) used spatial data on a number of aquatic and terrestrial variables and modeled the impact of the forest’s road network. The network analysis showed that out of 8233 km of road analyzed, only 3483 km (42%) was needed to ensure current and future access to key points. They found that the modified network had improved patch characteristics, such as significantly fewer “cherry stem” roads intruding into patches, and larger roadlessness.

Shilling et al. (2012) later developed a recreational route optimization model using a similar methodology and with the goal of identifying a sustainable motorized transportation system for the Tahoe National Forest (Figure 2). Again using a variety of environmental factors, the model identified routes with high recreational benefits, lower conflict, lower maintenance and

14 Page 105.

17 management requirements, and lower potential for environmental impact operating under the presumption that such routes would be more sustainable and preferable in the long term. The authors combined the impact and benefit analyses into a recreation system analysis “that was effectively a cost‐benefit accounting, consistent with requirements of both the federal Travel Management Rule (TMR) and the National Environmental Policy Act” (p. 392).

The Wilderness Society in 2012 also developed a GIS decision support tool called “RoadRight” that identifies high risk road segments to a variety of forest resources including water, wildlife, and roadlessness (The Wilderness Society 2012, The Wilderness Society 2013). The GIS system is designed to provide information that will help forest planners identify and minimize road related environmental risks. See the summary of and user guide for RoadRight that provides more information including where to access the open source software.

Figure 2: A knowledge base of contributions of various environmental conditions to the concept ‘‘environmental impact’’ [of motorized trails]. Rectangles indicate concepts, circles indicate Boolean logic operators, and rounded rectangles indicate sources of environmental data. (Reprinted from Shilling et al. 2012)

Best management practices (BMPs) BMPs have also been developed to help create more sustainable transportation systems and identify restoration opportunities. BMPs provide science‐based criteria and standards that land managers follow in making and implementing decisions about human uses and projects that affect natural resources. Several states have developed BMPs for road construction, maintenance and decommissioning practices (e.g., Logan 2001, Merrill and Cassaday 2003, USDA Forest Service 2012b).

Recently, BMPs have been developed for addressing motorized recreation. Switalski and Jones (2012) published, “Off‐Road Vehicle Best Management Practices for Forestlands: A Review of Scientific Literature and Guidance for Managers.” This document reviews the current literature on the environmental and social impacts of off‐road vehicles (ORVs), and establishes a set of Best Management Practices (BMPs) for the planning and management of ORV routes on forestlands. The BMPs were designed to be used by land managers on all forestlands, and is consistent with current forest management policy and regulations. They give guidance to transportation planners on where how to place ORV routes in areas where they will reduce use conflicts and cause as little harm to the environment as possible. These BMPs also help guide managers on how to best remove and restore routes that are redundant or where there is an unacceptable environmental or social cost.

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Attachments

Attachment 1: Wildfire and Roads Fact Sheet

Attachment 2: Using Road Density as a Metric for Ecological Health in National Forests: What Roads and Routes should be Included? Summary of Scientific Information

Roads and Fire A roen Relaonship

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• • Sparks from cars, off-road vehi- h . (USD 2000, Tb 3-18) cles, and neglected campfires caused nearly 50,000 wildfire igni- • Th h b tions in 2000. (USDA 2000, Fuel . (S Nv E Pj, 1996) Management and Fire Suppression Specialist Report, Table 4.) • Hh h bb h- - . (H, W.J., . 1997) • More than 90% of fires on national • U hv hh- h lands are caused by humans b h h- . (DS, (USDA 1996 and 1998) . 1995)

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• H h , h h b b h There are 375,000 miles of roads (R-, . 2008) in our national forests.

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Attachment 2: Using Road Density as a Metric for Ecological Health in National Forests: What Roads and Routes should be Included? Summary of Scientific Information Last Updated, November 22, 2012

I. Density analysis should include closed roads, non‐system roads administered by other jurisdictions (private, county, state), temporary roads and motorized trails.

Typically, the Forest Service has calculated road density by looking only at open system road density. From an ecological standpoint, this approach may be flawed since it leaves out of the density calculations a significant percent of the total motorized routes on the landscape. For instance, the motorized route system in the entire National Forest System measures well over 549,000 miles.1 By our calculation, a density analysis limited to open system roads would consider less than 260,000 miles of road, which accounts for less than half of the entire motorized transportation system estimated to exist on our national forests.2 These additional roads and motorized trails impact fish, wildlife, and water quality, just as open system roads do. In this section, we provide justification for why a road density analysis used for the purposes of assessing ecological health and the effects of proposed alternatives in a planning document should include closed system roads, non‐system roads administered by other jurisdictions, temporary roads, and motorized trails.

Impacts of closed roads

It is crucial to distinguish the density of roads physically present on the landscape, whether closed to vehicle use or not, from “open‐road density” (Pacific Rivers Council, 2010). An open‐road density of 1.5 mi/mi² has been established as a standard in some national forests as protective of some terrestrial wildlife species. However, many areas with an open road density of 1.5 mi/mi² have a much higher inventoried or extant hydrologically effective road density, which may be several‐fold as high with significant aquatic impacts. This higher density occurs because many road “closures” block vehicle access, but do nothing to mitigate the hydrologic alterations that the road causes. The problem is

1 The National Forest System has about 372,000 miles of system roads. The forest service also has an estimated 47,000 miles of motorized trails. As of 1998, there were approximately 130,000 miles of non‐system roads in our forests. Non‐system roads include public roads such as state, county, and local jurisdiction and private roads. (USFS, 1998) The Forest Service does not track temporary roads but is reasonable to assume that there are likely several thousand miles located on National Forest System lands. 2 About 30% of system roads, or 116,108 miles, are in Maintenance Level 1 status, meaning they are closed to all motorized use. (372,000 miles of NFS roads ‐ 116,108 miles of ML 1 roads = 255,892). This number is likely conservative given that thousands of more miles of system roads are closed to public motorized use but categorized in other Maintenance Levels.

further compounded in many places by the existence of “ghost” roads that are not captured in agency inventories, but that are nevertheless physically present and causing hydrologic alteration (Pacific Watershed Associates, 2005).

Closing a road to public motorized use can mitigate the impacts on water, wildlife, and soils only if proper closure and storage technique is followed. Flow diversions, sediment runoff, and illegal incursions will continue unabated if necessary measures are not taken. The Forest Service’s National Best Management Practices for non‐point source pollution recommends the following management techniques for minimizing the aquatic impacts from closed system roads: eliminate flow diversion onto the road surface, reshape the channel and streambanks at the crossing‐site to pass expected flows without scouring or ponding, maintain continuation of channel dimensions and longitudinal profile through the crossing site, and remove culverts, fill material, and other structures that present a risk of failure or diversion. Despite good intentions, it is unlikely given our current fiscal situation and past history that the Forest Service is able to apply best management practices to all stored roads,3 and that these roads continue to have impacts. This reality argues for assuming that roads closed to the public continue to have some level of impact on water quality, and therefore, should be included in road density calculations.

As noted above, many species benefit when roads are closed to public use. However, the fact remains that closed system roads are often breached resulting in impacts to wildlife. Research shows that a significant portion of off‐road vehicle (ORV) users violates rules even when they know what they are (Lewis, M.S., and R. Paige, 2006; Frueh, LM, 2001; Fischer, A.L., et. al, 2002; USFWS, 2007.). For instance, the Rio Grande National Forest’s Roads Analysis Report notes that a common travel management violation occurs when people drive around road closures on Level 1 roads (USDA Forest Service, 1994). Similarly, in a recent legal decision from the Utah District Court , Sierra Club v. USFS, Case No. 1:09‐cv‐ 131 CW (D. Utah March 7, 2012), the court found that, as part of analyzing alternatives in a proposed travel management plan, the Forest Service failed to take a hard look at the impact of continued illegal use. In part, the court based its decision on the Forest Service’s acknowledgement that illegal motorized use is a significant problem and that the mere presence of roads is likely to result in illegal use.

In addition to the disturbance to wildlife from ORVs, incursions and the accompanying human access can also result in illegal hunting and trapping of animals. The Tongass National Forest refers to this in its EIS to amend the Land and Resources Management Plan. Specifically, the Forest Service notes in the EIS that Alexander Archipelego wolf mortality due to legal and illegal hunting and trapping is related not only to roads open to motorized access, but to all roads, and that total road densities of 0.7‐1.0 mi/mi² or less may be necessary (USDA Forest Service, 2008).

As described below, a number of scientific studies have found that ORV use on roads and trails can have serious impacts on water, soil and wildlife resources. It should be expected that ORV use will continue to

3 The Forest Service generally reports that it can maintain 20‐30% of its open road system to standard.

some degree to occur illegally on closed routes and that this use will affect forest resources. Given this, roads closed to the general public should be considered in the density analysis.

Impacts of non‐system roads administered by other jurisdictions (private, county, state)

As of 1998, there were approximately 130,000 miles of non‐system roads in national forests (USDA Forest Service, 1998). These roads contribute to the environmental impacts of the transportation system on forest resources, just as forest system roads do. Because the purpose of a road density analysis is to measure the impacts of roads at a landscape level, the Forest Service should include all roads, including non‐system, when measuring impacts on water and wildlife. An all‐inclusive analysis will provide a more accurate representation of the environmental impacts of the road network within the analysis area.

Impacts of temporary roads

Temporary roads are not considered system roads. Most often they are constructed in conjunction with timber sales. Temporary roads have the same types environmental impacts as system roads, although at times the impacts can be worse if the road persists on the landscape because they are not built to last.

It is important to note that although they are termed temporary roads, their impacts are not temporary. According to Forest Service Manual (FSM) 7703.1, the agency is required to "Reestablish vegetative cover on any unnecessary roadway or area disturbed by road construction on National Forest System lands within 10 years after the termination of the activity that required its use and construction." Regardless of the FSM 10‐year rule, temporary roads can remain for much longer. For example, timber sales typically last 3‐5 years or more. If a temporary road is built in the first year of a six year timber sale, its intended use does not end until the sale is complete. The timber contract often requires the purchaser to close and obliterate the road a few years after the Forest Service completes revegetation work. The temporary road, therefore, could remain open 8‐9 years before the ten year clock starts ticking per the FSM. Therefore, temporary roads can legally remain on the ground for up to 20 years or more, yet they are constructed with less environmental safeguards than modern system roads.

Impacts of motorized trails

Scientific research and agency publications generally do not decipher between the impacts from motorized trails and roads, often collapsing the assessment of impacts from unmanaged ORV use with those of the designated system of roads and trails. The following section summarizes potential impacts resulting from roads and motorized trails and the ORV use that occurs on them.

Aquatic Resources While driving on roads has long been identified as a major contributor to stream sedimentation (for review, see Gucinski, 2001), recent studies have identified ORV routes as a significant cause of stream sedimentation as well (Sack and da Luz, 2004; Chin et al.; 2004, Ayala et al.; 2005, Welsh et al;. 2006). It has been demonstrated that sediment loss increases with increased ORV traffic (Foltz, 2006). A study by

Sack and da Luz (2004) found that ORV use resulted in a loss of more than 200 pounds of soil off of every 100 feet of trail each year. Another study (Welsh et al., 2006) found that ORV trails produced five times more sediment than unpaved roads. Chin et al. (2004) found that watersheds with ORV use as opposed to those without exhibited higher percentages of channel sands and fines, lower depths, and lower volume – all characteristics of degraded stream habitat.

Soil Resources 4 Ouren, et al. (2007), in an extensive literature review, suggests ORV use causes soil compaction and accelerated erosion rates, and may cause compaction with very few passes. Weighing several hundred pounds, ORVs can compress and compact soil (Nakata et al., 1976; Snyder et al., 1976; Vollmer et al., 1976; Wilshire and Nakata, 1976), reducing its ability to absorb and retain water (Dregne, 1983), and decreasing soil fertility by harming the microscopic organisms that would otherwise break down the soil and produce nutrients important for plant growth (Wilshire et al., 1977). An increase in compaction decreases soil permeability, resulting in increased flow of water across the ground and reduced absorption of water into the soil. This increase in surface flow concentrates water and increases erosion of soils (Wilshire, 1980; Webb, 1983; Misak et al., 2002).

Erosion of soil is accelerated in ORV‐use areas directly by the vehicles, and indirectly by increased runoff of precipitation and the creation of conditions favorable to wind erosion (Wilshire, 1980). Knobby and cup‐shaped protrusions from ORV tires that aid the vehicles in traversing steep slopes are responsible for major direct erosional losses of soil. As the tire protrusions dig into the soil, forces far exceeding the strength of the soil are exerted to allow the vehicles to climb slopes. The result is that the soil and small plants are thrown downslope in a “rooster tail” behind the vehicle. This is known as mechanical erosion, which on steep slopes (about 15° or more) with soft soils may erode as much as 40 tons/mi (Wilshire, 1992). The rates of erosion measured on ORV trails on moderate slopes exceed natural rates by factors of 10 to 20 (Iverson et al., 1981; Hinckley et al., 1983), whereas use on steep slopes has commonly removed the entire soil mantle exposing bedrock. Measured erosional losses in high use ORV areas range from 1.4‐242 lbs/ft2 (Wilshire et al., 1978) and 102‐614 lbs/ft2 (Webb et al., 1978). A more recent study by Sack and da Luz (2003) found that ORV use resulted in a loss of more than 200 lbs of soil off of every 100 feet of trail each year.

Furthermore, the destruction of cryptobiotic soils by ORVs can reduce nitrogen fixation by cyanobacteria, and set the nitrogen economy of nitrogen‐limited arid ecosystems back decades. Even small reductions in crust can lead to diminished productivity and health of the associated plant community, with cascading effects on plant consumers (Davidson et al., 1996). In general, the deleterious effects of ORV use on cryptobiotic crusts is not easily repaired or regenerated. The recovery time for the lichen component of crusts has been estimated at about 45 years (Belnap, 1993). After this time the crusts may appear to have regenerated to the untrained eye. However, careful observation will reveal that the 45 year‐old crusts will not have recovered their moss component, which will take an additional 200 years to fully come back (Belnap and Gillette, 1997).

4 For a full review see Switalski, T. A. and A. Jones (2012).

Wildlife Resources 5 Studies have shown a variety of possible wildlife disturbance vectors from ORVs. While these impacts are difficult to measure, repeated harassment of wildlife can result in increased energy expenditure and reduced reproduction. Noise and disturbance from ORVs can result in a range of impacts including increased stress (Nash et al., 1970; Millspaugh et al., 2001), loss of hearing (Brattstrom and Bondello, 1979), altered movement patterns (e.g., Wisdom et al. 2004; Preisler et al. 2006), avoidance of high‐use areas or routes (Janis and Clark 2002; Wisdom 2007), and disrupted nesting activities (e.g., Strauss 1990).

Wisdom et al. (2004) found that elk moved when ORVs passed within 2,000 yards but tolerated hikers within 500 ft. Wisdom (2007) reported preliminary results suggesting that ORVs are causing a shift in the spatial distribution of elk that could increase energy expenditures and decrease foraging opportunities for the herd. Elk have been found to readily avoid and be displaced from roaded areas (Irwin and Peek, 1979; Hershey and Leege, 1982; Millspaugh, 1995). Additional concomitant effects can occur, such as major declines in survival of elk calves due to repeated displacement of elk during the calving season (Phillips, 1998). Alternatively, closing or decommissioning roads has been found to decrease elk disturbance (Millspaugh et al., 2000; Rowland et al., 2005).

Disruption of breeding and nesting birds is particularly well‐documented. Several species are sensitive to human disturbance with the potential disruption of courtship activities, over‐exposure of eggs or young birds to weather, and premature fledging of juveniles (Hamann et al., 1999). Repeated disturbance can eventually lead to nest abandonment. These short‐term disturbances can lead to long‐ term bird community changes (Anderson et al., 1990). However when road densities decrease, there is an observable benefit. For example, on the Loa Ranger District of the Fishlake National Forest in southern Utah, successful goshawk nests occur in areas where the localized road density is at or below 2‐3 mi/mi² (USDA, 2005).

Examples of Forest Service planning documents that use total motorized route density or a variant

Below, we offer examples of where total motorized route density or a variant has been used by the Forest Service in planning documents.

 The Mt. Taylor RD of the Cibola NF analyzed open and closed system roads and motorized trails together in a single motorized route density analysis. Cibola NF: Mt. Taylor RD Environmental Assessment for Travel Management Planning, Ch.3, p 55. http://prdp2fs.ess.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5282504.pdf.

 The Grizzly Bear Record of Decision (ROD) for the Forest Plan Amendments for Motorized Access

5 For a full review see:Switalski, T. A. and A. Jones (2012).

Management within the Selkirk and Cabinet‐Yaak Grizzly Bear Recovery Zones (Kootenai, Lolo, and Idaho Panhandle National Forests) assigned route densities for the designated recovery zones. One of the three densities was for Total Motorized Route Density (TMRD) which includes open roads, restricted roads, roads not meeting all reclaimed criteria, and open motorized trails. The agency’s decision to use TMRD was based on the Endangered Species Act’s requirement to use best available science, and monitoring showed that both open and closed roads and motorized trails were impacting grizzly. Grizzly Bear Plan Amendment ROD. Online at cache.ecosystem‐management.org/48536_FSPLT1_009720.pdf.

 The Chequamegon‐Nicolet National Forest set forest‐wide goals in its forest plan for both open road density and total road density to improve water quality and wildlife habitat.

I decided to continue reducing the amount of total roads and the amount of open road to resolve conflict with quieter forms of recreation, impacts on streams, and effects on some wildlife species. ROD, p 13.

Chequamegon‐Nicolet National Forest Land and Resource Management Plan Record of Decision. Online at http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5117609.pdf.

 The Tongass National Forest’s EIS to amend the forest plan notes that Alexander Archipelago wolf mortality due to legal and illegal hunting and trapping is related not only to roads open to motorized access, but to all roads, and that total road densities of 0.7‐1.0 mi/mi² or less may be necessary.

Another concern in some areas is the potentially unsustainable level of hunting and trapping of wolves, when both legal and illegal harvest is considered. The 1997 Forest Plan EIS acknowledged that open road access contributes to excessive mortality by facilitating access for hunters and trappers. Landscapes with open‐road densities of 0.7 to 1.0 mile of road per square mile were identified as places where human‐induced mortality may pose risks to wolf conservation. The amended Forest Plan requires participation in cooperative interagency monitoring and analysis to identify areas where wolf mortality is excessive, determine whether the mortality is unsustainable, and identify the probable causes of the excessive mortality.

More recent information indicates that wolf mortality is related not only to roads open to motorized access, but to all roads, because hunters and trappers use all roads to access wolf habitat, by vehicle or on foot. Consequently, this decision amends the pertinent standard and guideline contained in Alternative 6 as displayed in the Final EIS in areas where road access and associated human caused mortality has been determined to be the significant contributing factor to unsustainable wolf mortality. The standard and guideline has been modified to ensure that a range of options to reduce mortality risk will be considered in these areas, and to specify that total road densities of 0.7 to 1.0 mile per square mile or less may be necessary. ROD, p 24.

Tongass National Forest Amendment to the Land and Resource Management Plan Record of Decision and Final EIS. January 2008. http://tongass‐fpadjust.net/Documents/Record_of_Decision.pdf

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Appendix G

Descriptions of Special Interest Areas Recommended by The Wilderness Society BLANCA PEAK SPECIAL INTEREST AREA (CULTURAL)

Proposed Designated Area Rio Grande National Forest 4,300 acres Conejos Peak Ranger District

General Description

Blanca Peak holds tremendous cultural significance for many of the indigenous cultures in southwest Colorado and the upper Rio Grande valley. Navajo, Ute, Jicarilla Apache, and the Upper Rio Grande Pueblos all place great value on maintaining the pristine integrity of Blanca Peak.

The proposed Blanca Peak Special Interest Area comprises that portion of the massif located on the Rio Grande National Forest. The mountain is under overlapping jurisdictions with other portions administered by the Pike-San Isabel National Forest, the Bureau of Land Management, and the private Trinchera Blanca Ranch.

In addition to its cultural significance, Blanca Peak possesses outstanding recreational and scenic values as well. The Blanca Peak SIA includes three well-known Colorado fourteeners – Blanca Peak, Little Bear Peak, and Ellingwood Point – which attract several thousand mountaineers each year. All are drawn in large part by the dramatic alpine scenery of the high glacial basins and rugged granitic peaks.

The Rio Grande National Forest’s Assessment of Areas of Tribal Importance provides a thorough and compelling summary of Blanca Peak’s cultural significance to regional tribes:

“Mount Blanca, Sierra Blanca or Blanca Peak is sacred to the Navajo, Ute and Jicarilla Tribes. It is also an important anchor point within the cultural landscape of the Upper Rio Grande pueblos, known as Pintsae’i’i or “White Mountains” in Tewa. It is of particular significance to the Navajo Tribe, or Dinéh of the American Southwest. To them it is known as Sisnaajini or “White Shell Mountain”. The peak marks the eastern boundary of the Dinetah, or Navajo homeland. The mountain is considered a living breathing entity. The wetlands (Bureau of Land Management, U.S Fish and Wildlife Service) and the sand dunes (National Park Service) that flank the mountain are revered as critical components of the life force of the mountain.

The Jicarilla Apache call the mountain Nishnojini, “Black Belt” Monster Slayer, Nío nas ga né, directed Jicarilla and Navajo peoples on where to go from the top of the mountain and it is thought that the clouds retain spirits that bring the water. The mountain is a place of medicine power.

The Kaputa (Capote) Ute consider the mountain a holy place and call it Peeroradarath, “the monster’s back”, “great grandmother serpent” or “dragon’s back”; Blanca Peak as the head and the Sangre de Cristo range to the north, the body. Near the mountain was an old lake, Aripit, where Ute ancestors hunted the mastodon and the big buffalo, the Hooche.

….

The Historic Preservation Department of the Navajo Nation recommends designating Sisnaajini as a Traditional Cultural Property to recognize its cultural significance and to maintain its integrity as a critical component of Navajo cosmology and overall well-being of the Navajo people.” (Rio Grande NF, Assessment 12, Areas of Tribal Importance, 2015)

Recreational and Scenic Values

The Blanca Peak Special Interest Area at its highest point rises almost 7,000 feet above the San Luis Valley. The area’s soaring elevation, precipitous alpine ridges, and secluded glacial valleys and lakes draw mountaineers, hikers, campers, and photographers keen on experiencing unforgettable mountain scenery.

In particular, Blanca Peak, Little Bear Peak, and Ellingwood Point draw thousands of mountaineers annually hoping to reach the summits, test their mountaineering abilities in highly challenging circumstances and enjoy viewscapes that can extend to points up to 100 miles away. Little Bear Peak ranks among the most exposed routes to the summit among Colorado’s 54 fourteeners, which enhances the challenge of this primitive recreational pursuit. An estimated 1,000-3,000 climbers attempt Blanca Peak and Ellingwood Point annually, while less than 1,000 pursue Little Bear’s summit (Colorado Fourteeners Initiative, 2015). The Blanca Peak and Ellingwood Point trails from Como Lake were two of only three Fourteener trails in Colorado that received an “A” rating by the Colorado Fourteeners Initiative in 2015. This was due to work completed on these trails in 2011 and 2012.

Boundary, Size, and Access

The proposed Blanca Peak Special Interest Area consists of about 4,300 acres that are adjacent to and outside of the existing Sangre de Cristo Wilderness. The SIA boundary could alternatively be drawn to also incorporate the entirety of the Blanca Peak massif, including that portion within the designated wilderness area. This would not increase protective management to maintain the pristine character of the mountain, but it would better reflect the intact wholeness of the mountain in recognition of its cultural significance and apply a management obligation to the entire cultural area to protect its special character and purpose. The SIA is bounded to the north and northeast by the Pike-San Isabel National Forest, to the south by the private Trinchera Blanca Ranch managed under a conservation easement held by the U.S. Fish and Wildlife Service, and to the west by BLM lands.

A rough four-wheel-drive road (Forest Road #975) provides motorized access to Lake Como in the center of the area. FR 975 is known as one of the roughest and most challenging, if not the most difficult, 4WD roads in Colorado. There are some who value the road for its challenging nature, and prefer to try to drive a vehicle to its end point. However, the tribes have concerns with oil or other automotive fluid spills, littering, and abandoned car parts desecrating the values for which they hold the area sacred. And, many mountaineers and hikers choose to hike the road because it is too rough.

Proposed Management

Specific management direction is proposed to protect Blanca Peak’s unique cultural values, as well as it remarkable recreational and scenic values. These recommendations are based upon desired experiences of visitors wanting to enjoy specific aspects of the SIA (including cultural aspects) that support the stated reasons for the creation of the SIA. These include:

 Make the Blanca Peak SIA administratively unavailable for oil and gas leasing and mineral material sales, and recommend a mineral withdrawal for locatable minerals.

 Management direction must include prohibition on timber harvest and new road construction.

 Restrict motorized and mechanized travel to only the Lake Como access road. Prohibit motorized game retrieval off designated routes. Implement existing travel management designations by installing and enforcing a barrier and signage west of Como Lake to end motorized use at that location.

 Education is recommended for motorized recreationists traveling on the Blanca road to discourage littering, abandonment of broken vehicle parts, and also what type of vehicle and modifications are necessary to safely and responsibly drive on the road. The area should be managed using adaptive management. If monitoring finds more than three examples of oil or other automotive fluid spills, littering, abandoned car parts, or similar left behind each year, additional action will be considered, including permanently closing the road to motor vehicle use.

 Do not allow competitive events on the road or trail, or within the SIA.

 Do not allow communication facilities/infrastructure within this area.

 Monitor the natural soundscape to ensure that noise stays under specified decibel limits (the non-standard motorized vehicles that the road attracts may not be designed to meet sound limits). If necessary, establish specific sound limits to protect the natural soundscape.

 Coordinate closely with the Native American tribes when developing specific management direction that protects and interprets the pristine character of the mountain and determines access to the resources of particular cultural significance.

 Develop an interpretive plan in consultation with the Native American tribes that interprets the area’s special character and unique values.

Information Resources

Topic Data Source Cultural Rio Grande NF Assessment 12, Areas of Tribal Importance, 2015 Recreation Colorado Fourteeners Initiative hiker use estimates, 2015

CHAMA BASIN WATERSHED PROTECTION AREA

Proposed Designated Area Rio Grande National Forest 22,900 acres Conejos Peak Ranger District

General Description

Chama Basin is a large, intact roadless area that encompasses the entirety of the Chama River’s headwaters not already included within the South San Juan Wilderness. The Chama River is the largest source of municipal water supply for the majority of New Mexico’s urban population. Vast tracts of aspen cover much of the basin, and the Rio Chama at its center is a healthy montane riparian forest of willow, cottonwood, and alder.

Chama Basin has been the focus of prior management actions to enhance its value as an intact and undisturbed headwaters watershed. In 2011, the Rio Grande NF completed acquisition of the mineral rights, consolidating surface and mineral estates under federal jurisdiction and thereby assuring compatible management. Chama Basin has previously been evaluated as possessing high potential for oil and gas resources. Federal ownership of the mineral estate allows complete discretion to the Forest Service about future mineral leasing.

Watershed values

The proposed Chama Basin Watershed Protection Area consists primarily of the 21,600-acre Chama Basin Colorado Roadless Area, which is primarily an Upper Tier area. The area is managed for both non- motorized and motorized recreation, and cattle and sheep grazing occurs. The basin is a compact, confined watershed bounded on three sides by high ridges and escarpments, with only a single road providing access to the southern edge of the basin. (USDA Forest Service Colorado Roadless Rule, 2012)

The uppermost headwaters of the East Fork of the Rio Chama are situated in the adjacent, upstream South San Juan Wilderness. The uppermost headwaters of the West Fork arise within the adjacent, upstream Banded Peak Ranch, which is managed compatibly for watershed protection under a conservation easement.

Over 10 miles of streams within Chama Basin have been determined eligible for inclusion with the Wild and Scenic Rivers System. These include both the East Fork and West Fork of the Rio Chama, as well as 5 miles of Archuleta Creek. The streams were categorized under the Scenic classification, even though the entirety of these segments is inaccessible by road. The 4-5 miles of the Rio Chama mainstem should similarly be recognized as eligible for inclusion as a scenic river. (Rio Grande LRMP FEIS, 1996)

Wildlife and Botanical Values

The area sees high use by lynx, a threatened species. Boreal owl and goshawk, two sensitive species, have been documented in the area. Bald eagles use the area in the summer.

The Rio Chama Potential Conservation Area identified by Colorado Natural Heritage Program is entirely contained within the proposed watershed protection area. The Rio Chama PCA is a 191- acre site of High Biodiversity Significance identified for its montane riparian forest. The basin’s broad floodplain has large amounts of alluvium, abandoned river channels, and downed logs that create a very dynamic, active riparian system. Biodiversity elements of specific interest include mountain willow (Salix monticola)/mesic graminoid montane riparian willow carr, and a narrowleaf cottonwood/thinleaf alder (Populus angustifolia/Alnus incana) montane riparian forest. (CHNP Potential Conservation Area Report, 2015)

Boundary, Size, and Access

The proposed Chama Basin Watershed Protection Area is a well-defined and confined watershed. The watershed protection area encompasses 22,900 acres, of which about 21,600 acres is an Upper Tier Colorado Roadless Area. The western rim and eastern rim of the area are the watershed divides. The northern boundary is the national forest boundary or the wilderness boundary, with the uppermost mile or two of the West Fork and East Fork located within adjacent conserved private land (Banded Peak Ranch) or adjacent designated wilderness (South San Juan). The southern boundary is the national forest boundary. Forest Road 121 provides access to the southern, lower reaches of the Rio Chama at the forest boundary. A system of motorized trails (Archuleta Creek and West Fork) and non-motorized trails (Rio Chama and East Fork) provide access to the area’s interior.

Proposed Management

Specific management direction is proposed to ensure primacy of watershed protection as follows:

 The Chama Basin Watershed Protection Area must be found unsuitable for oil and gas leasing and mineral material sales, and made discretionary no lease for watershed protection purposes. The area also needs to be withdrawn from mineral entry.

 Management direction must include prohibition on road construction and limitations on tree removal consistent with Upper Tier management prescribed by the Colorado Roadless Rule, 36 CFR Part 294.43(b), 294.42(b).

 Motorized and mechanized vehicle use can only occur on designated routes that are located and managed to minimize impacts to watershed values. Best management practices are in place on all access routes and monitored regularly to ensure effectiveness.

 Eligible Wild and Scenic Rivers must be managed to preserve their eligibility for designation under the Wild and Scenic Rivers Act. Management direction must include no new roads or expanded motorized access, no water impoundments or diversions, no mineral leasing or extraction, and no new surface disturbing activities. o The classification of the East Fork of the Rio Chama should be changed to Wild to reflect its condition as a primitive watershed inaccessible by motorized access. o The Rio Chama mainstem, from the confluence of the two forks downstream to the national forest boundary, should additionally be identified as an eligible river under the Scenic or Recreational classification.

 Develop an interpretive program for the area that educates visitors on the special character and watershed values of the area.

Information Resources

Topic Data Source Biodiversity CHNP PCA Report, 2015 Roadless area USDA Forest Service Colorado Roadless Rule, 2012 Wild and Scenic Rivers Rio Grande LRMP Final EIS, 1996

SPRUCE HOLE/OSIER/TOLTEC LANDSCAPE CONNECTIVITY ZOOLOGICAL AREA

Proposed Designated Special Interest Area Rio Grande National Forest 39,500 acres Conejos Peak Ranger District

General Description

Restoring and maintaining wildlife habitat connectivity within and beyond the National Forest is vital for allowing wildlife to migrate, and recover wide-ranging carnivore populations. Connectivity is especially important in the face of climate change because it enables species that are already stressed to move more easily through the landscape. The proposed corridor provides crucial connected habitat for large game species including mule deer, elk, pronghorn, and Rocky Mountain bighorn sheep as well as large carnivores such as Canada lynx, mountain lions, and black bears. The Rocky Mountain bighorn sheep is a Species of Conservation Concern (SCC), and the Canada lynx is protected as threatened under the U.S. Endangered Species Act. The proposed corridor connects to a similar proposal made by New Mexico citizens to the Carson National Forest and the Rio Grande del Norte National Monument. Through an “all lands” approach to coordination, the Forest Service and partners have a unique and inspiring opportunity to establish a landscape-scale linkage that can benefit wildlife on into the future.

Wildlife Habitat Connectivity Values

The proposed connectivity zoological area is a key movement path for wide- ranging species between southern Colorado and Northern New Mexico. Natural Heritage New Mexico identified this area as the northern reach of the Northern Taos Plateau Wildlife Movement Focal Area that spans through the RGNF, Carson National Forest, and the Rio Grande del Norte National Monument that is managed by the Bureau of Land Management (Muldavin and McCollough 2016). Mule deer and elk migrate through the area, and Rocky Mountain bighorn sheep make seasonal shifts to summering and wintering A newly released Canada lynx explores his new home in the Rio habitat there. Grande National Forest. © Richard Reading

Protecting remaining intact habitat large enough to allow freedom of movement for these iconic species has never been more important. Habitat loss, deterioration, and fragmentation have caused Colorado’s mule deer population to decline. This is cause for concern, because significant numbers of families, particularly in the local area, rely on the species for food. Disease and habitat loss have put Colorado’s bighorn population in jeopardy. Designation of the corridor as Zoological Area would help maintain and restore ecological conditions necessary for bighorn to persist in the Forest and beyond the plan area.

Canada lynx have used this corridor since they were reintroduced by Colorado Parks and Wildlife in 1999. Having an established population of lynx back in Colorado is a source of pride for all wildlife lovers in the state. Protecting linkages for lynx is incredibly important for their long-term viability, and especially now following the large spruce bark beetle outbreak on the forest. Lynx are stressed by climate change, timber harvesting, roads, and winter recreation. Establishing the corridor will reduce some of these stresses on lynx.

Additional Biodiversity Values

Managing the Spruce Hole/Osier/Toltec Landscape Connectivity Zoological Area to maintain and restore habitat connectivity would benefit an array of at-risk and special interest species along with those identified above. Several RGNF SCCs are likely to occur in the area including boreal owl, peregrine falcon, Brewer’s sparrow, flammulated owl, golden eagle, olive-sided flycatcher, bald eagle, Rio Grande cutthroat trout, Gunnison’s prairie dog, among others, Ripley’s milkvetch, slender cliffbreak, Plumber’s cliff fern, Colorado divide whitlow grass, and many flowered gilia. The area may provide recovery habitat for federally protected species such as Mexican spotted owl, Southwestern willow flycatcher, yellow-billed cuckoo, and New Mexico meadow jumping mouse. Some of the migratory birds that likely use habitats in the area on a seasonal basis include ferruginous hawks (though some are non-migratory), black swifts, sage sparrows, burrowing owls, Cassin’s finches, Grace’s warblers, Gray vireos, juniper titmouse, Lewis’s woodpeckers, loggerhead shrikes, long-billed curlews, mountain plovers, pinyon jays, and Virginia’s warblers.

Three Colorado Natural Heritage Program Potential Conservation Areas (PCAs) overlap with proposed connectivity zoological area. These include the Cascade Creek PCA at Osier and Osier Creek PCA, which were identified for Rio Grande cutthroat trout habitat, and the Rito Hondo Creek PCA, identified for its occurrences of Ripley’s milkvetch.

The proposed connectivity zoological area overlaps the Spruce Hole – Sheep Creek Upper Tier Roadless Area which contains over 3,000 additional acres of ecosystems types that are not well represented in the Forest’s designated protected areas system. Under-represented ecosystems include grasslands and dry mixed conifer forest (The Wilderness Society, 2016).

Boundary, Size, and Access

The Spruce Hole/Osier/Toltec Landscape Connectivity Zoological Area contains 39,500 acres of the Rio Grande National Forest. It is bounded on the north by the Conejos River as well as Highway 17, which also creates the western boundary. For the purposes here, the southern boundary is the Colorado-New Mexico state line where the Rio Grande National Forest meets the Carson National Forest. Of course, this political boundary does not demarcate where wildlife movement stops, and a shared management strategy for maintaining and restoring habitat connectivity between the Forests is encouraged.

Proposed Management

The Spruce Hole/Osier/Toltec Landscape Connectivity Zoological Area is proposed for designation in order to enhance landscape-level habitat connectivity for large game and large carnivores, such as Canada lynx. Specific management direction includes:

 Management actions should be driven by the primary need to ensure continued or enhanced habitat connectivity and viability of the zoological area for wildlife movement.

 Activities currently authorized by the agency in this zoological area shall coexist with wildlife movement, migration and dispersal. Changes to current activities and infrastructure may be required if found incompatible with the area’s wildlife values.

 Where possible, augment wildlife values through purchase from willing sellers, exchange, transfer or donation of additional acreage of crucial wildlife habitat for their migration, movement and dispersal. Acquired lands are to be managed consistent with the corridor’s standards and guidelines.

 Winter, including over-snow vehicle use, and summer recreation activities should conform to best available scientific knowledge for mitigating impacts to at-risk and other sensitive wildlife species.

 Do not authorize new permanent roads within the corridor in order to maintain unfragmented habitat for wildlife migration and dispersal.

 Establish road and motorized trail density standards within the management area to conform to the best scientific recommendations, generally less than one mile per square mile (Lyon 1979; Van Dyke et al. 1986a, b; Fox 1989; Trombulak and Frissell 2000; Reed et al. 1996; Strittholt and DellaSala 2001; Davidson et al. 1996). Ensure that there will be no net increases in densities above a scientific credible threshold. If these densities do not exist today, the Forest Service will develop a strategy to achieve them.

 All temporary roads are removed and the lands and waters on which they were located are restored to natural conditions within one year of the termination of the purpose for which they were established.

 Decommission and reclaim unauthorized routes and unneeded system roads.

 Establish and implement in a timely manner mitigation standards for existing roads and Highway 17 to facilitate movement of wildlife including a reduction in mortality of wildlife from vehicle collisions (modified from BLM 2012: 2-55). Coordinate with CDOT on planning and projects.

 Limit disturbance footprint resulting from vegetation management activities within the corridor spatially and temporally (e.g., establish maximum width and acres of any one ground disturbance, and limit total acreage of ground disturbance at any one time)

 Minimize fencing for livestock and make all fences wildlife friendly. Coordinate with permittees to identify fencing that is not critical for livestock operations; fencing that is not critical for livestock operations and that is impeding wildlife movement is removed. Any new livestock fencing that is installed should be constructed in a manner that will minimize disruption to wildlife movement, taking into consideration seasonal migration and water resources.

 Preclude the granting of new right-of-ways for energy development that would negatively impact wildlife, their habitat and its connectivity.

 Withdraw the corridor from location and entry under the Mining Law, subject to valid existing rights.

 Access to inholdings must be maintained at no greater than current standards, and reduced or avoided entirely if possible.

 The Connectivity Zoological Area must be discretionary no oil and gas leasing, although there is low likelihood of oil and gas occurrence in this location. It should be withdrawn from mineral entry.

Information Resources

Topic or Data Data Source wildlife movement and Muldavin, E. and R. McCollough. 2016. Wildlife Doorways: Supporting Wildlife wildlife connectivity Habitat Connectivity Across Borders in the Upper Rio Grande Watershed. Natural opportunity data Heritage New Mexico and University of New Mexico. March. Center for Native Ecosystems. 2006. Linking Colorado’s Landscapes Species Movement Arrows. https://databasin.org/datasets/16d4904566f7446e99768175af07b1e5. Ecosystem representation The Wilderness Society, 2016. Ecosystem Representation Report. Attached as Appendix 2 to letter submitted by The Wilderness Society et al on September 6, 2016 on the Wilderness evaluation preliminary report. Wildlife, general Forest Service. 2016. List of Species of Conservation Concern for the Rio Grande National Forest. Rocky Mountain Region. August 17. NatureServe Explorer: An online encyclopedia of life [web application]. Version 7.1. NatureServe, Arlington, Virginia. http://explorer.natureserve.org. NatureServe Explorer: An online encyclopedia of life [web application]. Version 7.1. NatureServe, Arlington, Virginia. http://explorer.natureserve.org. U.S. Fish and Wildlife Service. Information for Planning and Conservation (IPaC). https://ecos.fws.gov/ipac/. CNHP Potential Colorado Natural Heritage Program. CNHP Potential Conservation Areas Reports. Conservation Areas http://www.cnhp.colostate.edu/download/gis/pca_reports.asp#c. Colorado human population Svaldi, Aldo. 2015. Colorado’s population jumped by 101,000 in 12 months. Denver Post. June 13: http://www.denverpost.com/2015/12/22/colorados-population- jumped-by-101000-in-12-months-2/. mule deer and elk wildlife Big Game Movement, NM Dept. of Game & Fish movement data Elk Migration Patterns, CO Parks and Wildlife 2014 Mule Deer Migration Patterns, CO Parks and Wildlife 2014 Elk Linkage Modeled Southern, Rockies Ecosystem Project/Center for Native Ecosystems 2009 Colorado Parks and Wildlife. The Story of Colorado’s Mule Deer. https://cpw.state.co.us/Documents/MuleDeer/ColoradosMuleDeerStory.pdf. Rocky Mountain bighorn Bighorn Overall Range, CO Parks and Wildlife 2014 sheep Bighorn Severe Winter Range, CO Parks and Wildlife 2014 Bighorn Summer Concentration Area, CO Parks and Wildlife 2014 pronghorn Pronghorn Overall Range, CO Parks and Wildlife 2014 Lynx Denning and Winter Habitats, SW CO U.S. Forest Service Canada lynx Lynx Habitat Other, SW CO U.S. Forest Service Lynx Potential Habitat, CO Parks and Wildlife 2014 Lynx Linkage Modeled, Southern Rockies Ecosystem Project/Center for Native Ecosystems 2009 mountain lion Mountain Lion Overall Range, CO Parks and Wildlife 2014 black bear Black Bear Fall Concentration, CO Parks and Wildlife 2014 wolf All Species Movement Arrows, Southern Rockies Ecosystem Project peregrine falcon nesting Colorado Natural Heritage Program 2014 Colorado Oil and Gas Conservation Commission 2008 Colorado Parks and Wildlife 2014 Gunnison’s prairie dog Gunnison’s Prairie Dog Overall Range, CO Parks and Wildlife 2014 Brazilian free-tailed bat Overall Range, CO Parks and Wildlife 2014 Rio Grande cutthroat trout Colorado Natural Heritage Program Route density standards Davidson, Diane W., William D. Newmark, Jack W. Sites, Jr., Dennis K. Shiozawa, Eric A. Rickart, Kimball T. Harper, and Robert B. Keiter. 1996. Selecting Wilderness Areas to Conserve Utah’s Biological Diversity. Great Basin Naturalist 56(2):95-118. Forest Service. 2008. Southern Rockies Lynx Management Direction, Final Environmental Impact Statement Volume 1. Fox, R.A. 1989. Mule Deer (Odocoileus hemionus) Home Range and Habitat Use in an Energy-Impacted Area of the North Dakota Badlands. Masters Thesis, University of North Dakota. Grand Forks, ND. Lyon, L. J. 1979. “Habitat Effectiveness for Elk as Influenced by Roads and Cover.” Journal of Forestry, October, 658-660. Stritthold, J.R., and D.A. DellaSala. 2001. Importance of Roadless Areas in Biodiversity Conservation in Forested Ecosystems: A Case Study—Kalmath-Siskiyou Ecoregion, U.S.A. Conservation Biology 15(6):1742-1754. Trumbulak, S.C., and C.A. Frissell. 2000. Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities. Conservation Biology 14(1):18-26. VanDyke, F. G., Brocke, R. H., Shaw, H. G., Ackerman, B. B., Hemker, T. P., and Lindzey, F. G. (1986b). Reactions of Mountain Lions to Logging and Human Activity. Journal of Wildlife Management. 50(1): 95-102. VanDyke, F. G., Brocke, R. H., and Shaw, H. G. (1986a). Use of Road Track Counts as Indices of Mountain Lion Presence. Journal of wildlife Management. 50(1):102-109.

SUMMER COON LA VENTANA GEOLOGIC AREA

Proposed Designated Area Rio Grande National Forest 22,400 acres Divide Ranger District

General Description

The proposed Summer Coon La Ventana Geologic Area offers a unique opportunity to see well- preserved outcrops representing the earliest evidence of the Rio Grande continental rifting. The proposed area incorporates much of an ancient stratovolcano (a composite layered structure built up from sequential outpourings of eruptive materials), a nearly perfect pattern of radial dikes, and the La Ventana Natural Arch eroded into the center of one of the most prominent dikes. The area includes significant cultural, botanical and ecological values in addition to its notable geological importance.

The Summer Coon La Ventana Geologic Area expands the existing 8,441-acre Elephant Rocks Special Interest Area to incorporate the entirety of the Summer Coon volcanic field, particularly the well-developed radial dikes originating from the area’s center. The existing SIA was designated in the prior Forest Plan for a portion of the Summer Coon volcanic features as well as rare botanical features in the form of a Forest Service sensitive species, the rock-loving Neoparrya.

The Natural Arch is a traditional cultural property considered sacred to the Ute and Jicarilla Apache. Extension of the SIA to include the La Ventana Natural Arch expands the represented values to include cultural as well as geologic and ecological values. The expanded boundary encompasses lower elevation 8,880-foot ecosystem types representative of the foothills surrounding the San Luis Valley, with grassland, pinyon-juniper and ponderosa pine woodlands transitioning to higher elevation Douglas-fir and aspen at over 11,000 feet.

Geologic and ecological values

Summer Coon is an eroded Oligocene-aged stratovolcano located in the eastern San Juan Mountains of Colorado, on the western edge of the San Luis Valley. It is noteworthy because it marks the beginning of the Rio Grande rift – about 34 million years ago – when rising magma was threatening to pull the continental plate apart. The volcano is tilted slightly; this probably occurred after eruption as the rift system grew and lifted. The volcano has well developed radial dikes, but no ring dikes. La Ventana is a natural arch eroded into the long, narrow wall of one of the most prominent dikes. The central intrusive complex appears as a group of low hills running north-northwest in the center of the volcano. The hills are surrounded by an approximately circular alluvium-filled valley about two miles in diameter. This volcano is part of a larger volcanic complex in the area that erupted from about 31 million years ago to 22 million years ago and is now represented by a series of calderas.

Erosion has uncovered the former stratovolcanco down to its base, revealing a complete basal section of the 8-10 mile diameter cone. A geology driving tour along Saguache County Road A32 provides an educational introduction to readily accessible and interesting stops. (Noblett and Loeffler, 1987), and could be expanded into an engaging interpretive tour for forest visitors.

The Summer Coon La Ventana Geologic Area includes a portion of the Elephant Rocks Potential Conservation Area identified by Colorado Natural Heritage Program. This PCA is a complex of volcanic boulders, rock outcrops, and shrublands separating the prairie of the valley floor from the San Juan Mountains and contains both rare plant and animal species, which results in its rank of High Biodiversity Significance. Specific biodiversity elements present include a medium- sized population of the rock-loving Neoparrya – an herb that is restricted to south-central Colorado; a rare milkvetch (Astragalus cerussatus) with only 20 known occurrences; and a silky pocket mouse subspecies population found here that is restricted to the San Luis Valley and is rare within its range. (CHNP Potential Conservation Area Report, 2015)

The Eagle Mountain PCA is also located within the proposed Summer Coon La Ventana Geologic Area. The PCA includes the cliffs around Eagle Mountain and Eagle Rock, and is identified as of General Biodiversity Interest because of its nesting habitat for peregrine falcons. (CHNP Potential Conservation Area Report, 2015)

Cultural Values

The Natural Arch is considered sacred to the Jicarilla Apache and Ute people. The Forest Service presently manages it as a traditional cultural property because of significance to the indigenous peoples. The Rio Grande NF’s Assessment of Areas of Tribal Importance describes the arch’s significance in cultural ceremonies and as a rendezvous location. (Rio Grande NF Assessment 12, 2015)

Boundary, Size, and Access

The proposed Summer Coon La Ventana Geologic Area consists of 22,400 acres, which incorporates the entirety of the existing 8,441-acre Elephant Rocks Special Interest Area. The geologic area is contiguous on the east with a portion of BLM’s popular Penitente Canyon Special Recreation Management Area. The geologic area is defined by La Garita Creek on the north, by the national forest boundary on the east and south, and generally by Old Woman Creek or private land along the west. Saguache County road A32 provides access directly to the interior of the area, and Forest Road #659 leads to the La Ventana Natural Arch. The expanded boundary better captures the geologic, ecological, and cultural features than the previous Elephant Rocks Special Interest Area boundary and is more appropriate for conserving this unique landscape.

Proposed Management

Specific management direction is proposed to protect and interpret the area’s scenic character, botanical and geologic features, and cultural and recreational values. These recommendations are based upon desired experiences of visitors wanting to enjoy specific aspects of the Geologic Area (including cultural aspects) that support the stated reasons for the creation of the area. These include:

 The Summer Coon La Ventana Geologic Area must be administratively unavailable for oil and gas leasing and mineral material sales, and a mineral withdrawal needs to be recommended for locatable minerals.

 Management direction must include prohibition on timber harvest and new road construction.

 Motorized and mechanized travel must be restricted to designated routes and motorized game retrieval off designated routes must be prohibited.

 The Forest Service should develop an interpretive program for the area that at a minimum includes and interpretive driving tour that teaches about the area’s unique and special qualities. The Forest Service should consider developing non-motorized interpretive trails as well. Interpretation of cultural values should be done in close cooperation with Native American tribes.

 Prohibit rock climbing on the dike on which the arch is located to protect cultural values.

Information Resources

Topic Data Source Geology Noblett & Loeffler, Summer Coon Volcano Geology, Colorado College, 1987 Cultural Rio Grande NF Assessment 12, Areas of Tribal Importance, 2015 Biodiversity CHNP PCA Reports, 2015

WOLF CREEK PASS LINKAGE LANDSCAPE ZOOLOGICAL AREA

Proposed Designated Area Rio Grande National Forest 22,300 acres Divide Ranger District

General Description

The Wolf Creek Pass Linkage Zoological Area is the most important wildlife linkage zone in the San Juan Mountains. It is situated in the very heart of the San Juan Core Area for lynx, which comprises the core reintroduction area and the most expansive lynx habitat in the Southern Rockies. The Wolf Creek Pass linkage has been frequently utilized by lynx, and presumably may be important for other species such as pine marten, boreal owl, and wolverine in the future.

The proposed Zoological Area includes the most complex management landscape on the Rio Grande National Forest. Much of the area has experienced severe mortality from spruce beetle, and the largest wildfires in the recent history of the San Juan Mountains have occurred in close proximity. The linkage area includes designated wilderness, Colorado Roadless Areas, and the Continental Divide National Scenic Trail, but it also incorporates a permitted ski area, a busy highway corridor, private inholdings, water impoundments, high recreation use both winter and summer, and past and present timber harvests. Moreover, the viability of the linkage area will be tested in the future by rapidly changing habitat conditions. The combination of spruce beetle epidemic, large intense wildfires, and climate change will impose new stresses in this area.

A Zoological Area designation will focus the needed management attention on this crucial landscape for wildlife and landscape connectivity and emphasize the priority of juggling many competing human activities in order to preserve the viability of the linkage. The area was originally identified in the Southern Rockies Lynx Management Direction as a “lynx linkage area,” which are “areas of movement opportunity” and “can be maintained or lost by management activities.” (Forest Service 2008 at Appendix D)

Linkage values

The Forest Service has previously succinctly defined the critical significance to lynx of the Wolf Creek Pass linkage:

Lynx are heavily using the Wolf Creek Pass Lynx Linkage area as a dispersal corridor and the viability of this linkage is important to the recovery of lynx in Colorado. The linkage spans a forested swath over the Continental Divide between large blocks of highly effective subalpine habitat. Lynx denning and established home ranges have been identified to the north and south of the Wolf Creek Pass Lynx Linkage. The linkage is part of the Colorado Division of Wildlife’s “Core Research Area” in the San Juan Mountains, recognized as the largest continuous block of high quality lynx habitat in the state and where the CDOW focused their 10-year lynx monitoring and research efforts. (Village at Wolf Creek FEIS, 2014)

Managers concur that maintaining landscape-level habitat connectivity may be paramount to maintaining a viable population because of the patchy, discontinuous distribution of lynx habitat in the Southern Rockies Ecosystem. For that reason, landscape linkages must be available to allow lynx movements between adjacent mountain ranges. Linkage areas are areas of movement opportunities. They exist on the landscape and can be maintained or lost by management activities or developments. (Village at Wolf Creek FEIS 2014; Southern Rockies Lynx Amendment 2008)

The Wolf Creek Pass Linkage Zoological Area includes significant portions of two Colorado Roadless Areas, both managed as Upper Tier. A portion of the Trout Mountain-Elk Mountain roadless area is located immediately north of Highway 160, and the western half of the Fox Mountain roadless area is incorporated within the southern half of the linkage area.

The Continental Divide National Scenic Trail corridor defines the southern border of the linkage area. The trail corridor is managed to provide high-quality scenic, primitive hiking and equestrian opportunities. (Forest Service Manual 2350, 2009)

Two Potential Conservation Areas identified by the Colorado Natural Heritage Program are located largely within the Wolf Creek Pass Landscape Linkage Special Interest Area boundary. The Haven of the Reflected Moonwort PCA is in the subalpine zone near the Continental Divide. It is ranked as High Biodiversity Significance for its occurrences of the moonwort family. The Pass Creek at South Fork Rio Grande PCA is ranked as a Moderate Biodiversity Significance site owing to an historic Rio Grande cutthroat trout population. (CHNP PCA Reports, 2015)

Boundary, Size, and Access

The proposed Wolf Creek Pass Linkage Zoological Area is bounded on either side of Highway 160 eastern approach to Wolf Creek Pass by major watershed and topographic divides. It includes about 22,300 acres on the Rio Grande National Forest, and there are additional lands on the adjacent San Juan National Forest.

Proposed Management

The Wolf Creek Pass Linkage Zoological Area is proposed for designation in order to ensure its conservation as a landscape-level habitat connectivity for lynx and other wildlife. Specific management direction includes:

 Management actions must be driven by the primary need to ensure continued or enhanced habitat connectivity and viability of the linkage area for wildlife movement.

 The Wolf Creek Pass Linkage Zoological Area must be discretionary no oil and gas leasing, although there is low likelihood of oil and gas occurrence in this location. It should be withdrawn from mineral entry.

 Management direction must include prohibition on road construction and limitations on tree removal for the two roadless areas consistent with Upper Tier management prescribed by the Colorado Roadless Rule, 36 CFR Part 294 Subpart D.

 Do not authorize new permanent roads within the corridor in order to maintain unfragmented habitat for wildlife migration and dispersal.

 Decommission and reclaim unauthorized routes and unneeded system roads.

 Establish and implement in a timely manner mitigation standards for existing roads and Highway 160 to facilitate movement of wildlife including a reduction in mortality of wildlife from vehicle collisions (modified from BLM 2012:2-55). Coordinate with CDOT on planning and projects.

 Winter and summer recreation activities must conform to best available scientific knowledge for mitigating impacts to lynx and other sensitive wildlife species, and, if necessary be limited spatially and/or temporally.

 Changes in operation or permit boundaries of Wolf Creek Ski Area must be designed to avoid new impacts to use of linkage corridor.

 Access to inholdings and new recreation developments must be maintained at no greater than current standards, and reduced or avoided entirely if possible.

 Coordinate with grazing permittees to identify fencing that is not critical for livestock operations. Fencing that is not critical for livestock operations and that is impeding wildlife movement is removed. Any new livestock fencing that is installed should be constructed in a manner that will minimize disruption to wildlife movement, taking into consideration seasonal migration and water resources.

Information Resources

Topic Data Source Lynx Village at Wolf Creek FEIS, 2014 Biodiversity CHNP PCA Report, 2015 Roadless area USDA Forest Service Colorado Roadless Rule, 2012 Wildlife Bureau of Land Management. 2012a [BLM]. Lower Sonoran and Sonoran National crossings Monument Proposed Resource Management Plan and Final Environmental Statement. June 2012. https://www.blm.gov/epl-front- office/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage¤tPag eId=21457. Accessed 04/11/2016. Route density Davidson, Diane W., William D. Newmark, Jack W. Sites, Jr., Dennis K. Shiozawa, Eric A. standards Rickart, Kimball T. Harper, and Robert B. Keiter. 1996. Selecting Wilderness Areas to Conserve Utah’s Biological Diversity. Great Basin Naturalist 56(2):95-118. Forest Service. 2008. Southern Rockies Lynx Management Direction, Final Environmental Impact Statement Volume 1. Fox, R.A. 1989. Mule Deer (Odocoileus hemionus) Home Range and Habitat Use in an Energy-Impacted Area of the North Dakota Badlands. Masters Thesis, University of North Dakota. Grand Forks, ND. Lyon, L. J. 1979. “Habitat Effectiveness for Elk as Influenced by Roads and Cover.” Journal of Forestry, October, 658-660. Stritthold, J.R., and D.A. DellaSala. 2001. Importance of Roadless Areas in Biodiversity Conservation in Forested Ecosystems: A Case Study—Kalmath-Siskiyou Ecoregion, U.S.A. Conservation Biology 15(6):1742-1754. Trumbulak, S.C., and C.A. Frissell. 2000. Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities. Conservation Biology 14(1):18-26. VanDyke, F. G., Brocke, R. H., Shaw, H. G., Ackerman, B. B., Hemker, T. P., and Lindzey, F. G. (1986b). Reactions of Mountain Lions to Logging and Human Activity. Journal of Wildlife Management. 50(1): 95-102. VanDyke, F. G., Brocke, R. H., and Shaw, H. G. (1986a). Use of Road Track Counts as Indices of Mountain Lion Presence. Journal of wildlife Management. 50(1):102-109.

Appendix H Scientific Basis for Protecting Wildlife Corridors in Land Management Planning

Properly designed networks of wildlife corridors represent one of the best strategies to mitigate the negative impacts of habitat fragmentation and help wildlife species adapt to climate change. Strategies that seek to maintain or restore connectivity between protected or otherwise intact natural areas are now considered critical to biodiversity conservation (Hilty et al. 2006, Miller & Hobbs 2002, Taylor et al. 2006). Conservation scientists have now long agreed that “the preponderance of evidence is that corridors almost certainly facilitate travel by many species” (Beier and Noss 1998). Many analytical frameworks for prioritizing specific habitat corridors to preserve landscape connectivity have been formulated (e.g., Bunn et al. 2007, Compton et al. 2007, Carroll et al. 2011, McRae et al. 2008, Walker & Craighead 1997), and this area of conservation science continues to see intense growth. Although the particulars of wildlife response to climate change are largely unknown (Root 2003, Travis 2003, Jarema et al. 2009), establishment of landscape connectivity via corridors is the most frequently cited strategy for combating the impacts of climate change on biodiversity (Heller & Zavaleta 2009).

Designing, designating and protecting wildlife corridors should be a part of Forest Service land planning in order to mitigate the compounding and simultaneous impacts of habitat fragmentation and climate change. The information provided in Appendix 5 addresses the ecological justification for corridor science as an essential component of land management. There are three main areas of justification for structuring land management around corridors and habitat connectivity: maintenance of ecosystem function; preserving wildlife movement patterns and the resource availability these patterns facilitate; and mitigating the effects of climate change on species and ecosystems. The information provided in Appendix 5 represents the best available science, which the 2012 planning rule requires the agency to utilize.1

a. Ecosystem Function and Thresholds of Landscape Connectivity

Planning for corridors and connectivity requires an examination of the physical structure of the landscape as well as the functional response of wildlife and other landscape elements to that structure:

(1) The structural (or physical) component: the spatial arrangement of different types of habitat or other elements in the landscape, and (2) The functional (or behavioral) component: the behavioral response of individuals, species, or ecological processes to the physical structure of the landscape (Crooks and Sanjayan 2006).

Habitat fragmentation leads to a reduction in landscape connectivity by reducing the occurrence or the effectiveness of natural ecosystem processes and preventing wildlife species from moving across the landscape (Crooks and Sanjayan 2006). Biologists are in agreement that habitat fragmentation is one of the greatest threats to the persistence of individual wildlife species and overall biodiversity (Wilcove 1998). Habitat fragmentation consists of two different processes that simultaneously and negatively affect wildlife species: (1) a reduction in the overall habitat available to wildlife species – habitat loss;

1 36 C.F.R. § 219.3 (agency “shall use the best available scientific information to inform the planning process” and “shall document how [that] information was used to inform the assessment”). and (2) the creation of isolated patches of habitat separated from what was once the contiguous landscape (Crooks and Sanjayan 2006).

Habitat loss and fragmentation can occur as a result of a variety of human activities on the landscape. On public lands, industrial energy development, logging, mining, off-road vehicle (ORV) trails (both designated and illegally created), and roads are the land use changes that drive fragmentation. These are associated with a complex of stressors that cause further fragmentation such as the introduction of invasive species; disease transmission and other issues related to the presence of pets; noise, light, and water pollution; change in wildfire regimes; power transmission lines; and others. When the total effect of the “human footprint” from all fragmentation is modeled across land ownerships in the West, it cumulatively covers approximately 48% of the landscape (Leu et al. 2008). This study defined the human footprint as any human development or activity on private or public land (everything from ORV trails to residential and industrial development); and includes direct habitat loss as well as habitat fragmentation and overall degradation. Fahrig (2002) suggested that each species tends to have an “extinction threshold” of minimum habitat necessary, meaning that when available habitat drops below the threshold, the risk of extinction increases. Habitat fragmentation may play an important role in adjusting this threshold level because as fragmentation increases, the amount of habitat necessary for the species to persist also increases. If habitat is connected, even when drastically reduced, there is a much higher probability of population persistence than if the available habitat is reduced and fragmented (Travis 2003).

A reduction in landscape connectivity does not just affect wildlife directly; it can also affect species indirectly through ecological processes that provide beneficial services to wildlife as well as humans (also known as “ecosystem services”) (Kremen 2005, Ricketts et al. 2006). Examples of ecosystem services include water purification, oxygen production, erosion control, and insect pollination of important food crops. There is also a growing consensus in the scientific community that not only is biodiversity dependent on landscape connectivity, but also overall ecosystem health, as measured by biomass production, nutrient cycling, water and nutrient retention, community stability and other measures independent of biodiversity (Lyons et al. 2005).

b. Impacts of Habitat Fragmentation on Wildlife Migration, Movement and Resource Acquisition

When wildlife habitat patches become isolated and individual animals within a species are unable to move across the landscape, wildlife populations are affected by a multitude of harmful processes. According to Hilty et al (2006), there are six main adverse effects that may occur as a result of habitat fragmentation: (1) increased isolation leading to detrimental genetic and demographic effects; (2) changes in species richness or composition; (3) modification of energy flow, nutrient cycling, and hydrological regimes; (4) declines in populations of individual species or their geographic extent across the landscape; (5) edge effect problems that can lead to the introduction of exotic invasive species as well as increases in predation and competition among different wildlife species; and (6) increased human disturbance and associated direct and indirect mortality.

Wildlife population persistence, evolution, and speciation are all driven by genetic factors. As the areas between crucial wildlife habitat patches are converted to human use, fragmenting the landscape, individual wildlife populations become more isolated (Frankham 2006). When wildlife is not able to disperse from natal habitats or migrate throughout the landscape then the entire population may face genetic isolation. Genetic isolation increases the prevalence of negative genetic factors that can lead to a higher extinction risk. These genetic factors include “inbreeding depression, decreased ability to adapt to environmental factors, mutation accumulation, and outbreeding depression.” Id. In contrast, if individual animals within populations are still able to migrate, even with decreased overall habitat, the genetic effects of isolation can be mitigated. Frankham (2006) estimates that “with sufficient migration, a fragmented population will have the same genetic consequences as a single large population of the same total size.” This reflects Travis’s (2003) observation that when habitat is connected, even when reduced overall, there is a higher probability of population persistence.

Changes in vegetation composition, energy flow, nutrient cycling, and microclimates may negatively impact wildlife if they are unable to find vital resources necessary for survival. Food, water, minerals, and other resources that individual animals require are not evenly dispersed throughout the landscape (Hobbs et al. 2008). For example, the most nutritious forage may be in a completely different location from a watering hole. Due to this isolation and inconsistent allocation, wildlife species need the ability to move unhindered throughout the landscape to find resources. Habitat fragmentation restricts wildlife from “matching their distribution to the resources they require to survive and reproduce” and these impacts can drastically affect wildlife; rendering “landscapes effectively unsuitable [for wildlife]” (Hobbs et al. 2008).

Human disturbance that causes and contributes to fragmentation is often associated with roads. Edge effects and human exploitation can influence individual animals and entire populations. According to Clevenger and Wierzchowski (2006), “roads cause changes to wildlife habitat that are more extreme and permanent than other anthropogenic sources of fragmentation.” Edge-sensitive species will have declined nesting, production, and survival rates in highly fragmented locations. Additionally, edge- sensitive species may be exposed to interactions with edgegeneralist species, that can outcompete them for resources, and predators that can now prey on those species more effectively (Fletcher 2005). Fragmentation also allows for biologically diverse areas to be opened up to human activity (Ewers and Didham 2006). An increase in human activity can often have negative impacts on wildlife species. For example, motor vehicles can cause mortality through collision, ORV operators may illegally enter core habitat –further fragmenting the landscape, and legal and illegal hunters may access wildlife species more easily (Ewers and Didham 2006).

c. Landscape Connectivity and Mitigating Wildlife Impacts of Climate Change

It is unequivocal that warming of the earth due to human-induced climate change is rapidly occurring (IPCC 2007). The Intergovernmental Panel on Climate Change and the U.S. Global Change Research Program agree that global climate change will have drastic effects on biodiversity worldwide (IPCC 2007, Karl et al. 2009). Over the last twenty years, conservation biologists have firmly established that climate change may pose a significant threat to the future persistence of some wildlife species; wildlife species already have and will continue to respond to climate change in various ways as well (Hughes et al. 2000, Burns et al. 2003, Travis 2003, Pyke 2004). Climate change will also likely exacerbate stressors that wildlife already face, most notably habitat loss and fragmentation.

Researchers have noticed that some species have started to respond to climate change in significant ways (Root et al. 2002, Pyke 2004). Hughes (2000) and Root et al. (2003) predict that climate change will impact wildlife species in four specific ways: (1) Physiological – the metabolic and developmental rates of some species may be affected; (2) Distributional – species are already changing their distributions and will likely continue to do so even more; (3) Phenological – as the timing of environmental cues change, life cycle events triggered by those cues will also change; and (4) Adaptative – some species with short life cycles and rapid population growth may undergo microevolution in situ. Some wildlife species are already responding to climate change in many of the above ways, as are the plant species essential to support wildlife populations. Researchers have also recorded habitat distribution changes in several species (Hughes 2000; Barnosky et al. 2003, Burns et al. 2003). Range shifts occur dissimilarly throughout different latitudes, and some species may change only the density level within the metes and bounds of their traditional ranges. According to Jarema et al. (2009), beaver (Castor canadensis) habitat ranges in Quebec have not shifted in response to the climate, but the density of beavers within the range has shifted north. Romme and Turner (1991) have also speculated that in the Greater Yellowstone Ecosystem, many species that are alpine zone obligates will likely go extinct because their ranges will shift upward to a point where no more shifting can occur.

Observational studies of phenological changes occurring within multiple species demonstrate some of the best scientific evidence that climate change is already impacting wildlife species (Hughes 2000, Root et al. 2003). Various bird species are migrating from their winter habitats and arriving at their summer habitats earlier in the spring. For example, Inouye et al. (2000) illustrated that the average day of first sighting for the American Robin (Turdus migratorius) in Gothic, Colorado changed from April 14 to March 11 between 1974 and 1999. At the same time that bird species are arriving earlier, the winter snow pack is staying longer at higher elevations adding extra stress to birds who arrive early and are unable to find food (Inouye et al. 2000). Amphibian reproduction, insect peak flights, and flower budding are also taking place earlier (Hughes 2000). If the timing of insect peak flights and flower budding occurs at times when birds are not arriving, a rapid decoupling in the phenological relationship between species may result – compounding stress on species that depend on flowers and insects.

Research indicates that many species are capable of rapid evolution, or microevolution, in response to anthropogenic environmental changes such as climate change. Briggs (2009) presents a thorough examination of microevolution in a range of plant species. Case studies from around the world support that Darwinian evolution in many plant species is rapid and ongoing, and call into question the ability to conserve intact ecosystems or restore degraded ecosystems in this context through existing management frameworks. Microevolution in animal species has been also documented for invertebrates (Umina et al. 2005, Balanya 2006). Evidence for vertebrate animals is sparse to date, but the first case of microevolution in a vertebrate species has recently been documented (Karrell et al, 2011). The tawny owl in Finland has been shown to have shifted its feather coloration over the last decade from white towards brown in response to milder winters and resulting lack of snow cover. It is important to note that this genetic plasticity cannot be expected from all species, particularly organisms with long generation times and limited reproductive potential. For these species, arguably those that are considered the most highly evolved on the planet, adaptation to climate change must be facilitated by management, and this management must be innovative, adaptive, tailored to specific goals, and based on the very best available science.

As Root et al. (2003) state, “if such climatic and ecological changes are now being detected when the globe has warmed by an estimated average of only 0.6°C, many more far-reaching effects on species and ecosystems will probably occur in response to changes in temperature to levels predicted by IPCC, which run as high as 6°C by 2100.” The West is changing rapidly, and land managers must become the leaders in working towards solutions that help wildlife species in the face of climate change, or the Intermountain West may lose the species for which it is known. Although scientists cannot know wildlife will respond to climate change, research supports that habitat ranges of some species will have to shift to avoid extinction, and this highlights the need to manage for a landscape that wildlife can easily traverse in order to adapt to a changing climate (Root et al. 2003, Botkin et al. 2007, Jarema et al. 2009). The measures land managers take to plan for climate change must include strategies that allow wildlife species to adapt to climate change. One particularly useful way for the USFS to help wildlife species adapt is by protecting wildlife corridors because “[l]andscape connectivity will play an increasingly important role in the persistence of many plant and animal populations in the face of global change and resultant shifts and restructuring of species distributions” (Taylor et al. 2006). In fact, in a review of 22 years of scientific literature in which strategies were recommended for managing biodiversity in the face of impacts from climate change, the top recommended strategy was to maintain habitat connectivity (Heller & Zavaleta 2009). As the second largest land manager in the U.S., the USFS must be particularly invested in producing and implementing useful climate change solutions.

Literature Cited

Balanya, J., Oller, J. M., Huey, R. B., Gilchrist, G. W. & Serra, L. Global genetic change tracks global climate warming in Drosophila subobscura. Science 313, 1773–1775 (2006).

Barnosky, A.D., et al. 2003. Mammalian response to global warming on varied temporal scales. Journal of Mammalogy. 84(2): 354-368.

Beier, P. and Noss, R.F. 1998. Do habitat corridors provide connectivity? Conservation Biology. 12(6): 1241-1252.

Beier, P. et al. 2008. Forks in the road: choices in procedures for designing wildland linkages. Conservation Biology 22(4): 836-851.

Botkin, D.B. et al. 2007. Forecasting the effects of global warming on biodiversity. BioScience. 57(3): 227- 235.

Briggs, D. 2009. Plant Microevolution and Conservation in Human-influenced Ecosystems. Cambridge: Cambridge University Press. 618 pp.

Burns, C.E. et al. 2003. Global climate change and mammalian species diversity in U.S. national parks. PNAS 100(20): 11474-11477.

Clevenger, A.P. and Wierzchowski, J. 2006. Maintaining and restoring connectivity in landscapes fragmented by roads. In: Crooks, K.R. and Sanjayan, M., editors. Connectivity Conservation. Cambridge: Cambridge University Press. 502-535.

Crooks, K.R. and Sanjayan, M. 2006. Connectivity conservation: maintaining connections for nature. In: Crooks, K.R. and Sanjayan, M., editors. Connectivity Conservation. Cambridge: Cambridge University Press. p. 1-19.

Ewers, R.M. and Didham, R.K. 2006. Confounding factors in the detection of species responses to habitat fragmentation. Biological Review 81: 117-142.

Fahrig, L. 2002. Effect of habitat fragmentation on the extinction threshold: a synthesis. Ecological Applications. 12(2): 346-353.

Fletcher, Jr., R.J. 2005. Multiple edge effects and their implications in fragmented landscapes. Journal of Animal Ecology 74: 342-352.

Frankham, R. 2006. Genetics and landscape connectivity. In: Crooks, K.R. and Sanjayan, M., editors. Connectivity Conservation. Cambridge: Cambridge University Press. p. 72-96.

Karl, T.R., Melillo, J.M., Peterson, T.C. (eds.). 2009.. Global Climate Change Impacts in the United States. Cambridge University Press, Cambridge.

Karell, P. et al. 2011. Climate change drives microevolution in a wild bird. Nat. Commun. 2:208. Available at http://www.nature.com/ncomms/journal/v2/n2/full/ncomms1213.html%3FWT.ec_id%3DMARKETING% 26WT.mc_id%3DNC1107CE1YR0?message- global=remove&WT.ec_id=MARKETING&WT.mc_id=NC1107CE1YR0.

Haddad, N.M. and Tewksbury, J.J. 2006. Impacts of corridors on populations and communities. In: Crooks, K.R. and Sanjayan, M., editors. Connectivity Conservation. Cambridge: Cambridge University Press. p. 390-415.

Hargrove, W.W. et al. 2004. A practical map-analysis tool for detecting potential dispersal corridors. Landscape Ecology. 20: 361-373.

Hilty J.A., Lidicker W.Z., and Merenlender A.M. (2006) Corridor Ecology: The Science and Practice of Linking Landscapes for Biodiversity Conservation. Washington DC: Island Press.

Hobbs, N.T. et al. 2008. Fragmentation of rangelands: Implications for humans, animals, and landscapes. Global Environmental Change 18: 776-785.

Hughes, L. 2000. Biological consequences of global warming: is the signal already apparent?. Trends in Ecology and Evolution 15(2): 56-61.

Inouye, D.W. et al. 2000. Climate change is affecting altitudinal migrants and hibernating species. PNAS 97(4): 1630-1633.

IPCC. 2007. Climate change 2007: synthesis report. contribution of working groups I, II, III to the fourth assessment report of the intergovernmental panel on climate change. [Core Writing Team, Pachauri, R.K. and Reisinger, A. (eds.)]. IPCC, Geneva, Switzerland.

Jarema, S.I., et al. 2009. Variation in abundance across a species’ range predicts climate change responses in the range interior will exceed those at the edge: a case study with North American beaver. Global Change Biology 15: 508-522.

Kremen, C. 2005. Managing ecosystem services: what do we need to know about their ecology. Ecology Letters 8: 468-479.

Leu, M. et al. 2008. The Human Footprint in the West: A Large-Scale Analysis of Anthropogenic Impacts. Ecological Applications 18:1119–1139.

Lyons, K. G. et al. 2005. Rare species and ecosystem functioning. Conservation Biology 19(4): 1019-1024. Pascual-Hortal, L. and Saura, S. 2006. Comparison and development of new graph-based landscape connectivity indices: towards the prioritization of habitat patches and corridors for conservation. Landscape Ecology 21: 959-967.

Pyke, C. 2004. Habitat loss confounds climate change impacts. Frontiers in Ecology and the Environment 2(4): 178-182.

Ricketts, T.H. et al. 2006. Connectivity and ecosystem services: crop pollination in agricultural landscapes. In: Crooks, K.R. and Sanjayan, M., editors. Connectivity Conservation. Cambridge: Cambridge University Press. p. 256-289.

Romme, W.H. and Turner, M.G. 1991. Implications of global climate change for biogeographic patterns in the Greater Yellowstone Ecosystem. Conservation Biology 5(3): 373-386.

Root, T.L. et al. 2003. Fingerprints of global warming on wild animals and plants. Nature 421:57-60.

Taylor, P.D., et al. 2006. Landscape connectivity: a return to the basics. In: Crooks, K.R. and Sanjayan, M., editors. Connectivity Conservation. Cambridge: Cambridge University Press. p. 29-43.

Travis, J.M.J. 2003. Climate change and habitat destruction: a deadly anthropogenic cocktail. Proceedings of the Royal Society of Biological Sciences. 270: 467-473.

Umina, P. A., Weeks, A. R., Kearney, M. R., McKechnie, S. W. & Hoffmann, A. A rapid shift in a classical clinal pattern in Drosophila reflecting climate change. Science 308, 691–693 (2005).

Wilcove, D.S. et al. 1998. Quantifying threats to imperiled species in the United States. Bioscience 48(8): 607-615.

Appendix I Regulatory Framework for Managing a Forest Transportation System

Road management

To address its unsustainable and deteriorating road system, the Forest Service promulgated the Roads Rule in 2001.1 The rule directs each National Forest to conduct “a science-based roads analysis,” generally referred to as the travel analysis process.2 Based on that analysis, forests must “identify the minimum road system [MRS] needed for safe and efficient travel and for administration, utilization, and protection of National Forest System lands.”3 The Rule defines the MRS as:

the road system determined to be needed [1] to meet resource and other management objectives adopted in the relevant land and resource management plan . . . , [2] to meet applicable statutory and regulatory requirements, [3] to reflect long-term funding expectations, [and 4] to ensure that the identified system minimizes adverse environmental impacts associated with road construction, reconstruction, decommissioning, and maintenance.

Id. Forests also must “identify the roads . . . that are no longer needed to meet forest resource management objectives and that, therefore, should be decommissioned or considered for other uses, such as for trails.”4

While subpart A does not impose a timeline for agency compliance with these mandates, the Forest Service Washington Office, through a series of directive memoranda, ordered forests to complete the initial travel analysis process and produce a travel analysis report (TAR) by the end of fiscal year 2015, or lose maintenance funding for any road not analyzed.5 The memoranda articulate an expectation that forests, through the subpart A process, “maintain an appropriately sized and environmentally sustainable road system that is responsive to ecological, economic, and social concerns.” They clarify that TARs must address all system roads – not just the small percentage of roads maintained for passenger vehicles to which some forests had limited their previous Roads Analysis Process reports or TARs. And they require that TARs include a list of roads likely not needed for future use. Nationwide,

1 36 C.F.R. part 212, subpart A, 66 Fed. Reg. 3206 (Jan. 12, 2001). 2 36 C.F.R. § 212.5(b)(1). Forest Service Manual 7712 and Forest Service Handbook 7709.55, Chapter 20 provide detailed guidance on conducting travel analysis. 3 36 C.F.R. § 212.5(b)(1). 4Id. § 212.5(b)(2). The requirements of subpart A are separate and distinct from those of the 2005 Travel Management Rule, codified at subpart B of 36 C.F.R. part 212, which address off-highway vehicle use and corresponding resource damage pursuant to Executive Orders 11644, 37 Fed. Reg. 2877 (Feb. 9, 1972), and 11989, 42 Fed. Reg. 26,959 (May 25, 1977). 5 Memorandum from Joel Holtrop to Regional Foresters et al. re Travel Management, Implementation of 36 C.F.R., Part 212, Subpart A (Nov. 10, 2010) (Exhibit #1); Memorandum from Leslie Weldon to Regional Foresters et al. re Travel Management, Implementation of 36 C.F.R., Part 212, Subpart A (Mar. 29, 2012) (Exhibit 2); Memorandum from Leslie Weldon to Regional Foresters et al. re Travel Management Implementation (Dec. 17, 2013) (Exhibit 3). TARs are currently undergoing review by the Washington Office to ensure consistency with regulatory requirements and the directive memoranda.6

Once the TARs are finalized, the next step is “to use the travel analysis report to develop proposed actions to identify the MRS” and unneeded roads for decommissioning at a scale of the 6th HUC watershed or larger and undertake appropriate NEPA review.7 “The MRS for the administrative unit is complete when the MRS for each subwatershed has been identified, thus satisfying Subpart A.”8

Land management planning

The 2012 Planning Rule imposes substantive mandates to establish plan components – including standards and guidelines – that maintain or restore healthy aquatic and terrestrial ecosystems, watersheds, and riparian areas, and air, water, and soil quality.9 The components must be designed “to maintain or restore the structure, function, composition, and connectivity” of terrestrial, riparian, and aquatic ecosystems10, must take into account stressors including climate change, and the ability of ecosystems to adapt to change11, and must implement national best management practices for water quality.12 The rule also requires the Forest Service to establish riparian management zones for which plan components “must ensure that no management practices causing detrimental changes in water temperature or chemical composition, blockages of water courses, or deposits of sediment that seriously and adversely affect water conditions or fish habitat shall be permitted.”13 In addition, plans must include plan components for “integrated resource management to provide for ecosystem services and multiple uses,” taking into account “[a]ppropriate placement and sustainable management of infrastructure, such as recreational facilities and transportation and utility corridors.”14 Plan components must ensure social and economic sustainability, including sustainable recreation and access.15 And the Forest Service must “use the best available scientific information” to comply with these substantive mandates.16

Climate change

6 See Memorandum from Leslie Weldon to Regional Foresters re Completion of Travel Management and Next Steps (Sept. 24, 2015) (Exhibit 4). 7 2012 Weldon Memo. For instance, Watershed Restoration Action Plans developed under the Watershed Condition Framework should include essential projects that implement TAR recommendations, and every project at the scale of the 6th HUC watershed or greater that implicates the road system should include in its purpose and need statement identification of the MRS and unneeded roads for decommissioning and implementation of actions identified in the TAR. 8 Id. 9 36 C.F.R. § 219.8(a)(1)-(3); see also id. § 219.9(a) (corresponding substantive requirement to establish plan components that maintain and restore the diversity of plant and animal communities and support the persistence of native species). 10 Id. § 219.8(a)(1) & (a)(3)(i) 11 Id. § 219.8(a)(1)(iv) 12 Id. § 219.8(a)(4). 13 Id. § 219.8(a)(3)(ii)(B). 14 Id. § 219.10(a)(3). 15 Id. § 219.8(b) 16 Id. § 219.3 Executive Order 13,653 provides direction on “Preparing the United States for the Impacts of Climate Change.” The Order recognizes that “[t]he impacts of climate change – including an increase in prolonged periods of excessively high temperatures, more heavy downpours, an increase in wildfires, [and] more severe droughts . . . – are already affecting communities, natural resources, ecosystems, economies, and public health across the Nation,” and that “managing th[o]se risks requires deliberate preparation, close cooperation, and coordinated planning . . . to improve climate preparedness and resilience; help safeguard our economy, infrastructure, environment, and natural resources; and provide for the continuity of . . . agency operations, services, and programs.”17 To that end, the Order requires agencies to take various actions aimed at making “watersheds, natural resources, and ecosystems, and the communities and economies that depend on them, more resilient in the face of a changing climate.”18 For example, “recognizing the many benefits the Nation’s natural infrastructure provides, agencies shall, where possible, focus on program and policy adjustments that promote the dual goals of greater climate resilience and carbon sequestration.”19 Agencies also must develop and implement adaptation plans that “evaluate the most significant climate change related risks to, and vulnerabilities in, agency operations and missions in both the short and long term, and outline actions . . . to manage these risks and vulnerabilities.”20

The Forest Service’s 2014 climate adaptation plan recognizes that the wide range of environmental and societal benefits provided by our national forests “are connected and sustained through the integrity of the ecosystems on these lands.”21 The plan highlights USDA’s 2010-2015 Strategic Plan Goal 2 of “[e]nsur[ing] our national forests . . . are conserved, restored, and made more resilient to climate change, while enhancing our water resources.”22 With respect to transportation infrastructure specifically, the plan recognizes that, “[w]ith increasing heavy rain events, the extensive road system on NFS lands will require increased maintenance and/or modification of infrastructure (e.g. larger culverts or replacement of culverts with bridges).”23 The adaptation plan points to a number of actions to address these risks. For example, the plan highlights the 2012 Planning Rule as a mechanism to ensure that “National Forest System . . . land management planning policy and procedures include consideration of climate change.” Id.24 The final directives to the planning rule echo the importance of designing plan components “to sustain functional ecosystems based on a future viewpoint” and “to adapt to the effects of climate change.”25 The adaptation plan also points to Forest Service Manual

17 Exec. Order 13,653, § 1 (Nov. 1, 2013) 18 Id. § 3. 19 Id. 20 Id. § 5(a) 21 USDA Forest Service 2014. 22 Id. USDA’s updated FY2014-FY2018 Strategic Plan retains Goal 2. 23 Id. 24 Id.See also 36 C.F.R. § 219.8(a)(1)(iv) (ecosystem integrity plan components must take into account stressors including climate change, and the ability of ecosystems to adapt to change); id. § 219.6(b)(3) (forest assessments must “[i]dentify and evaluate existing information relevant to the plan area for . . . the ability of terrestrial and aquatic ecosystems on the plan area to adapt to change”); id. § 219.5(a) (planning framework designed to allow the Forest Service “to adapt to changing conditions, including climate change”); id. § 219.12(a)(5)(vi) (monitoring programs must address “[m]easurable changes on the plan area related to climate change and other stressors”). 25 FSH 1909.12, ch. 20, § .23.11 2020, which provides “Ecological Restoration and Resilience” directives designed “to restore and maintain resilient ecosystems that will have greater capacity to withstand stressors and recover from disturbances, especially those under changing and uncertain environmental conditions, including climate change and extreme weather events.”26

The Council on Environmental Quality (CEQ) also recently reinforced the importance of integrating climate change into land management planning processes in its final guidance on addressing climate change in NEPA reviews. The guidance acknowledges that “[c]limate change is a fundamental environmental issue, and its effects fall squarely within NEPA’s purview”:

Identifying important interactions between a changing climate and the environmental impacts from a proposed action can help Federal agencies and other decision makers identify practicable opportunities to reduce GHG emissions, improve environmental outcomes, and contribute to safeguarding communities and their infrastructure against the effects of extreme weather events and other climate-related impacts.27

The guidance goes on to recognize the increased vulnerability of resources including transportation infrastructure, due to a changing climate, and clarifies that NEPA requires agencies to analyze proposed actions and alternatives in the context of climate change, including the vulnerability of particular resources including transportation infrastructure, and to consider opportunities for climate adaptation and resilience. Id. § III(B).

26 USDA Forest Service 2014 27 Council on Environmental Quality, Final Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in National Environmental Policy Act Reviews, § I, 81 Fed. Reg. 51,866, (Aug. 5, 2016). Attached Exhibits

Exhibit 1: Memorandum from Joel Holtrop to Regional Foresters et al. re Travel Management, Implementation of 36 C.F.R., Part 212, Subpart A (Nov. 10, 2010)

Exhibit 2: Memorandum from Leslie Weldon to Regional Foresters et al. re Travel Management, Implementation of 36 C.F.R., Part 212, Subpart A (Mar. 29, 2012)

Exhibit 3: Memorandum from Leslie Weldon to Regional Foresters et al. re Travel Management Implementation (Dec. 17, 2013)

Exhibit 4: Memorandum from Leslie Weldon to Regional Foresters re Completion of Travel Management and Next Steps (Sept. 24, 2015)

Forest Washington 1400 Independence Avenue, SW Service Office Washington, DC 20250

File Code: 2300/2500/7700 Date: November 10, 2010 Route To:

Subject: Travel Management, Implementation of 36 CFR, Part 212, Subpart A (36 CFR 212.5(b)

To: Regional Foresters, Station Directors, Area Director, IITF Director, Deputy Chiefs and WO Directors

Travel planning is intended to identify opportunities for the forest transportation system to meet current or future management objectives, based on ecological, social, cultural, and economic concerns. As you know, the Forest Service Travel Management Rule, promulgated in 2005, has three parts:  Subpart A – Administration of the Forest Transportation System;  Subpart B – Designation of roads, trails, and areas for motor vehicle use; and  Subpart C – Use by over-snow vehicles.

Over the past 5 years, the Agency has made great strides in completing Subpart B of the Travel Management Rule (rule), which was prioritized in order to stop uncontrolled cross-country motor vehicle use. Approximately sixty-seven percent of National Forest System (NFS) lands are covered by a motor vehicle use map. It is anticipated that 93 percent of NFS lands will be covered by December 31, 2010.

Subpart A of the Travel Management Rule

This letter is to reaffirm agency commitment to completing those sections of Subpart A of the rule which requires each unit of the NFS to:  Identify the minimum road system needed for safe and efficient travel and for the protection, management, and use of NFS lands; and  Identify roads that are no longer needed to meet forest resource management objectives and; therefore, scheduled for decommissioning or considered for other uses (36 CFR 212.5(b)).

By completing the applicable sections of Subpart A, the Agency expects to identify and maintain an appropriately sized and environmentally sustainable road system that is responsive to ecological, economic, and social concerns. Though this process points to a smaller road system than our current one, the national forest road system of the future must provide needed access for recreation and resource management and support watershed restoration and resource protection to sustain healthy ecosystems and ecological connectivity.

America’s Working Forests – Caring Every Day in Every Way Printed on Recycled Paper

Regional Foresters, Station Directors, Area Director, IITF Director, Deputy Chiefs and 2 WO Directors

Process

Identifying the minimum road system and unneeded roads requires a travel analysis process that is dynamic, interdisciplinary, and integrated with all resource areas. With this letter, I am directing the use of the travel analysis process (TAP) described in Forest Service Manual 7712 and Forest Service Handbook (FSH) 7709.55, Chapter 20, to complete the applicable sections of Subpart A. The TAP is a science-based process that will ensure future travel-management decisions are based on the consideration of environmental, social, and economic impacts. All NFS roads, maintenance levels 1-5, must be included in the analysis.

For units that have previously conducted travel analysis or roads analyses (RAPs), the appropriate line officer should review the prior report to: 1) assess the adequacy of the analysis and the relevance of any recommendations to the process for complying with Subpart A; 2) help determine the appropriate scope and scale for any new analysis; and 3) build on previous work. A RAP completed in accordance with publication FS-643, “Roads Analysis: Informing Decisions about Managing the National Forest Transportation System,” will also satisfy the roads analysis requirement of Subpart A.

Although the TAP does not include a National Environmental Policy Act (NEPA) decision, we expect line officers to engage the public in the process, which should involve a broad spectrum of interested and affected citizens, other State and Federal agencies, and tribal governments.

Results from the TAP must be documented in a travel analysis report, which should include:  Information about the analysis and recommendations;  A map displaying the recommended minimum road system;  A list of recommended unneeded roads; and  Further reporting requirements identified in Step 6 of FSH 7709.55, Chapter 20.

Each regional forester must certify that TAP reports for units within their region comply with this direction and are consistent with national policy.

In complying with this direction, units should seek to integrate the steps contained in the Watershed Condition Framework (WCF) with the six TAP steps contained in FSH 7709.55, Chapter 20, to eliminate redundancy and ensure an iterative and adaptive approach for both processes. We expect that the WCF process, and especially the initial watershed condition assessment (Step A) to be completed by March 31, 2011, will provide important information for your work on Subpart A, while the TAP process will likewise provide information for the WCF process. The intent is for each process to inform the other so that they can be integrated and updated with new information or where conditions change. However, the Agency expectation is that each process will move forward: units should not halt one process to wait for the other.

Timing

The travel analysis report must be completed by the end of FY 2015. Beyond FY 2015, no Capital Improvement and Maintenance (CMCM) funds may be expended on NFS roads (maintenance levels 1-5) that have not been included in a TAP or RAP.

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Regional Foresters, Station Directors, Area Director, IITF Director, Deputy Chiefs and 3 WO Directors

Once certified by the regional forester, units are directed to immediately use the TAP reports to inform resource assessments, project and forest plan NEPA decisions to achieve the TAP recommendations.

Leadership

The Washington Office lead for Subpart A is Anne Zimmermann, Director of Watershed, Fish, Wildlife, Air and Rare Plants. Working with her on the Washington Office Steering Team are Jim Bedwell, Director of Recreation, Heritage, and Volunteer Resources, and Richard Sowa, Director of Engineering. I expect regions to create a similar leadership structure to lead this integrated effort.

This work will require significant financial and human resources. Your leadership and commitment to this component of the Travel Management Rule is important. Together, we will move towards an ecologic, economic, and socially sustainable and responsible national road system of the future.

/s/ James M. Pena (for) Joel D. Holtrop JOEL D. HOLTROP Deputy Chief, National Forest System

America’s Working Forests – Caring Every Day in Every Way Printed on Recycled Paper

Forest Washington 1400 Independence Avenue, SW Service Office Washington, DC 20250

File Code: 2300/2500/7700 Date: March 29, 2012 Route To:

Subject: Travel Management, Implementation of 36 CFR, Part 202, Subpart A (36 CFR 212.5(b))

To: Regional Foresters, Station Directors, Area Director, IITF Director, Deputy Chiefs and WO Directors

This letter is to reaffirm agency commitment to completing a travel analysis report for Subpart A of the travel management rule by 2015 and update and clarify Agency guidance. This letter replaces the November 10, 2010, letter on the same topic.

The Agency expects to maintain an appropriately sized and environmentally sustainable road system that is responsive to ecological, economic, and social concerns. The national forest road system of the future must continue to provide needed access for recreation and resource management, as well as support watershed restoration and resource protection to sustain healthy ecosystems.

Forest Service regulations at 36 CFR 212.5(b)(1) require the Forest Service to identify the minimum road system needed for safe and efficient travel and for administration, utilization, and protection of National Forest System (NFS) lands. In determining the minimum road system, the responsible official must incorporate a science-based roads analysis at the appropriate scale. Forest Service regulations at 36 CFR 212.5(b)(2) require the Forest Service to identify NFS roads that are no longer needed to meet forest resource management objectives.

Process

Travel analysis requires a process that is dynamic, interdisciplinary, and integrated with all resource areas. With this letter, I am directing the use of the travel analysis process (TAP) described in Forest Service Manual 7712 and Forest Service Handbook (FSH) 7709.55, Chapter 20. The TAP is a science-based process that will inform future travel management decisions. Travel analysis serves as the basis for developing proposed actions, but does not result in decisions. Therefore, travel analysis does not trigger the National Environmental Policy Act (NEPA). The completion of the TAP is an important first step towards the development of the future minimum road system (MRS). All NFS roads, maintenance levels 1-5, must be included in the analysis.

For units that have previously conducted their travel or roads analysis process (RAP), the appropriate line officer should review the prior report to assess the adequacy and the relevance of their analysis as it complies with Subpart A. This analysis will help determine the appropriate scope and scale for any new analysis and can build on previous work. A RAP completed in accordance with publication FS-643, “Roads Analysis: Informing Decisions about Managing the

America’s Working Forests – Caring Every Day in Every Way Printed on Recycled Paper

Regional Foresters, Station Directors, Area Director, IITF Director, Deputy Chiefs 2 and WO Directors

National Forest Transportation System,” will also satisfy the roads analysis requirement of Subpart A.

Results from the TAP must be documented in a travel analysis report, which shall include:

 A map displaying the roads that can be used to inform the proposed action for identifying the MRS and unneeded roads.  Information about the analysis as it relates to the criteria found in 36 CFR 212.5(b)(1).

Units should seek to integrate the steps contained in the Watershed Condition Framework (WCF) with the six TAP steps contained in FSH 7709.55, Chapter 20, to eliminate redundancy and ensure an iterative and adaptive approach for both processes. We expect the WCF process and the TAP will complement each other. The intent is for each process to inform the other so that they can be integrated and updated with new information or where conditions change. The travel analysis report described above must be completed by the end of FY 2015.

The next step in identification of the MRS is to use the travel analysis report to develop proposed actions to identify the MRS. These proposed actions generally should be developed at the scale of a 6th code subwatershed or larger. Proposed actions and alternatives are subject to environmental analysis under NEPA. Travel analysis should be used to inform the environmental analysis.

The administrative unit must analyze the proposed action and alternatives in terms of whether, per 36 CFR 212.5(b)(1), the resulting road system is needed to:

 Meet resource and other management objectives adopted in the relevant land and resource management plan;  Meet applicable statutory and regulatory requirements;  Reflect long-term funding expectations;  Ensure that the identified system minimizes adverse environmental impacts associated with road construction, reconstruction, decommissioning, and maintenance.

The resulting decision identifies the MRS and unneeded roads for each subwatershed or larger scale. The NEPA analysis for each subwatershed must consider adjacent subwatersheds for connected actions and cumulative effects. The MRS for the administrative unit is complete when the MRS for each subwatershed has been identified, thus satisfying Subpart A. To the extent that the subwatershed NEPA analysis covers specific road decisions, no further NEPA analysis will be needed. To the extent that further smaller-scale, project-specific decisions are needed, more NEPA analysis may be required.

A flowchart displaying the process for identification of the MRS is enclosed with this letter.

Regional Foresters, Station Directors, Area Director, IITF Director, Deputy Chiefs 3 and WO Directors

Timing

Leadership

The Washington Office lead for Subpart A is Anne Zimmermann, Director of Watershed, Fish, Wildlife, Air and Rare Plants. Working with her on the Washington Office Steering Team are Jim Bedwell, Director of Recreation, Heritage, and Volunteer Resources, and Emilee Blount, Director of Engineering. I expect the Regions to continue with the similar leadership structures which have been established.

Your leadership and commitment to this component of the travel management rule is important. Together, we will move towards an ecologic, economic, and socially sustainable and responsible national road system of the future.

/s/ James M. Pena (for): LESLIE A. C. WELDON Deputy Chief, National Forest System

Forest Washington 1400 Independence Avenue, SW Service Office Washington, DC 20250

File Code: 2300/2500/7700 Date: December 17, 2013 Route To:

Subject: Travel Management Implementation

To: Regional Foresters, Station Directors, Area Director, IITF Director, Deputy Chiefs and WO Directors

This letter supplements and reaffirms the direction provided in my 2300 /2500/7700 March 29, 2012, letter regarding the implementation of Subpart A of the Travel Management Rule, and the subsequent September 2012 communication materials.

Continued shared understanding is needed between the Washington Office and the regions regarding the Subpart A travel analysis report (TAR) and supporting map and completion expectations by the September 30, 2015, date.

The March 29, 2012, letter outlined a process for identifying the minimum road system (MRS) and clarified the TAR that must be completed by the end of fiscal year (FY) 2015. Beyond FY 2015, no Capital Improvement and Maintenance (CMCM) funds may be expended on National Forest System (NFS) roads (maintenance levels 1-5) that have not been included in a travel analysis process (TAP) or roads analysis process (RAP).

In line with this, two video teleconferences (VTCs) were held with the Regional Foresters (July 15, 2013, and August 9, 2013) to discuss progress toward completing the TAR and a supporting map by September 30, 2015, to share lessons learned, to clarify expectations for public involvement, and to discuss the final deliverables.

All regions stated they were on track to meet the September 2015 deadline. We were able to reach agreement on what needs to be completed by the deadline. Each forest will produce a TAR , a list of roads “likely not needed for future use” and a map displaying the roads. Forests which have completed their TAR will need to ensure their maps conform to standard.

Enclosed is the map template to use with your completed TAR and the associated steps for producing the map. A forest must complete the necessary analysis, produce a report summarizing this analysis (TAR), a list of roads likely not needed for future use, and synthesize these results in a map that displays roads that are likely needed and likely not needed in the future aligned with the following map example to meet the September 30, 2015 deliverable.

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Regional Foresters, Station Directors, Area Director, IITF Director, Deputy Chiefs and WO Directors

We appreciate the feedback received from the two VTCs and the opportunity to make sure we have a shared understanding of the deliverables. Please contact our WO NFS Director’s Steering Team (Rob Harper, Joe Meade, or Emilee Blount) should you have questions on the process or final deliverables.

/s/ James M. Pena (for) LESLIE A. C. WELDON Deputy Chief, National Forest System

Enclosures

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Logo Department Organization Information Organization Address Information Forest Service Washington Office 1400 Independence Avenue, SW Washington, DC 20250

File Code: 7700 Date: September 24, 2015 Route To:

Subject: Completion of Travel Management and Next Steps

To: Regional Foresters

As a result of the teleconference held August 17, 2015, and the deadline for completing your Travel Analysis Reports (TARs) September 30, 2015, I want to re-emphasize the Chief’s expectations and next steps. Prior to considering the TAR final, review each to ensure the intent has been met and the reports are complete. As required by Subpart A of the Travel Management rule; each unit of the National Forest System must:

 Identify the minimum road system needed for safe and efficient travel and for administration, utilization, and protection of National Forest System lands;

 Identify the roads on lands under Forest Service jurisdiction that are no longer needed to meet forest recreation and resource management objectives and reflect long-term funding expectations; and,

 Decommission or consider other uses of those roads identified as unneeded.

As you are aware, completion of the TAR involves three parts:

1. Travel Analysis Process (TAP), a map displaying all system roads that differentiates between those roads which are likely needed from those roads which are likely not needed;

2. List of each road clearly showing the relationship to your TAP, integrated with your analysis, your rationale; and,

3. Clarification of proposed changes to your system roads.

Once your review is complete, please send the link where your TAR is located to Leslie Boak, Acting National Transportation Program Manager at [email protected] for posting on Forest Service internal Web site at http://fsweb.wo.fed.us/eng/. The Washington Office (WO) travel management leadership team comprised of the Directors for Engineering, Technology and Geospatial Services; Watershed, Fish, Wildlife, Air and Rare Plants; and Recreation, Heritage and Volunteer Resources will monitor your progress and will provide a National WO Review. The TARs are not considered final until both reviews are complete, at which time, the TARs will be available to the public.

If you have any questions, please contact Brian Ferebee, Associate Deputy Chief, National Forest System, at (202) 205-0824, or by email at [email protected].

/s/ Brian Ferebee (for) LESLIE A. C. WELDON Deputy Chief, National Forest System

cc: Glenn P. Casamassa

America’s Working Forests – Caring Every Day in Every Way Printed on Recycled Paper Appendix J

Examples of road plan components from existing National Forest Land Management Plans

Last Updated: August 2016

Topic Forest Example of Road Component LRMP Date Road density San Juan National Road Density Guideline for Water Quality and Watershed Health on SJNF Lands: In 2013 Forest order to protect water quality and watershed function, road densities on SJNF lands should not exceed 2 miles/square mile within any U.S. Geological Survey (USGS) 6th level Hydrologic Unit Code (HUC) watershed. In order to protect major surface source water protection areas for municipalities within USGS 6th level HUC watersheds, road densities on NFS lands should not exceed 1.5 miles/square mile. If new road construction is necessary on NFS lands within an area exceeding this density guideline, management actions should be considered that would result in post-construction road densities that are equal to or less than the pre-construction density.

The following parameters and constraints will be used to calculate road density for water quality and watershed health: 2.13.27a: Roads used to develop road density calculations include those roads on NFS lands only, regardless of road ownership, that are a) open year-long or seasonally to public use and b) closed to public use, but are used for administrative access or are authorized by contract, permit, or other written authorization. Included in these calculations are NFS maintenance level 2–5 roads. Non-motorized and motorized trails and those roads that are closed to all motorized use and/or are in storage are not used for road density calculations. Temporary roads to be used for 5 years or less are not included in these calculations. 2.13.27b: Road densities will be calculated within USGS 6th level HUC watersheds on NFS lands only. 2.13.27c: Municipal watersheds are USGS 6th level HUC watersheds where the surface source water intake exists for an incorporated town, city, or other municipality with a public water supply. The MOU between the USFS Region 2 and the CDPHE states, “Revised Forest Plans will provide direction and desired conditions for municipal supply watersheds/source water areas to protect water quality while allowing for multiple use outputs (per 36 CFR 251.9 and FSM 2542).” 2.13.27d: Data used for density calculations will be based on the best available information at the time of analysis.

Road and Motorized Trail Density Guideline for Ungulate Production Areas, Winter Concentration Areas, Severe Winter Range, and Critical Winter Range on SJNF Lands: The intent of this guideline is to ensure no net loss of existing habitat effectiveness within the areas listed below. In order to maintain wildlife habitat effectiveness of SJNF lands, road and motorized trail densities should be addressed when analyzing and approving management actions that affect motorized routes. Where management actions would result in road and motorized trail densities exceeding 1 mile/square mile on SJNF lands in the areas listed below, actions should be designed to maintain habitat effectiveness on SJNF lands throughout each mapped polygon. Habitat effectiveness for this guideline is considered maintained when road densities within the CPW mapped areas on SJNF lands listed below are less than or equal to 1 mile/square mile. When road densities exceed 1 mile/square mile within the CPW mapped areas on SJNF lands listed below, densities should not be increased without mitigation designed to maintain habitat effectiveness. - Big game production areas (calving or lambing areas) - Elk and deer severe winter range - Elk and deer winter concentration areas - Deer critical winter range The following parameters and constraints will be used to calculate road and motorized trail density for wildlife: 2.13.29a: Roads used to develop route density calculations include roads on NFS lands only, regardless of road ownership, that are a) open year-long or seasonally to public use and b) closed to public use, but are used for administrative access or are authorized by contract, permit, or other written authorization. Included in these calculations are maintenance level 2–5 NFS roads. Also included for this calculation are NFS trails that are designated for motorized use. Roads and motorized trails with design features sufficient to maintain habitat effectiveness (such as seasonal closures that are determined to be sufficient mitigation), as determined by the USFS biologist, should not be used for final density calculations. Non-motorized trails and those roads that are closed to all motorized use and/or are in storage are not used for route density calculations. Temporary roads to be used for 5 years or less are not included in these calculations. 2.13.29b: Data used for density calculations will be based on the best available information at the time of analysis.

2.13.31: Road and Motorized Trail Density Guideline for Deer and Elk General Winter Range on SJNF Lands: Where management actions would result in road and motorized trail densities exceeding 1 mile/square mile and where CPW analysis determines that road and motorized trail densities inhibit the state’s ability to meet population objectives, SJNF management actions should be designed to reduce the impacts of road density on habitat effectiveness throughout each mapped general winter range polygon. This guideline applies to the portions of each mapped general winter range polygon not covered under Guideline 2.13.29. The following parameters and constraints will be used to calculate road and motorized trail density for wildlife: 2.13.31a: Roads used to develop route density calculations include roads on NFS lands only, regardless of road ownership, that are a) open year-long or seasonally to public use and b) closed to public use, but are used for administrative access or are authorized by contract, permit, or other written authorization. Included in these calculations are maintenance level 2–5 NFS roads. Also included for this calculation are NFS trails that are designated for motorized use. Roads and motorized trails with design features sufficient to maintain habitat effectiveness (such as seasonal closures that are determined to be sufficient mitigation), as determined by the USFS biologist, should not be used for final density calculations. Non-motorized trails and those roads that are closed to all motorized use and/or are in storage are not used for route density calculations. Temporary roads to be used for 5 years or less are not included in these calculations. 2.13.31b: Data used for density calculations will be based on the best available information at the time of analysis.

Chequamegon- Goal 3.1 – Capital Infrastructure: Build and maintain safe, efficient, and effective 2004 Nicolet National infrastructure that supports public and administrative uses of National Forest Forest System lands. Retain and progress toward the Forestwide average total road density goal of 3.0 miles per square mile established in 1986. Objective 3.1: Reduce average open and total road density on the Chequamegon- Nicolet National Forests. Use Appendix BB, “Guide for Reducing Open and Total Road Density” and Road Density Map in Map Packet to focus efforts.

Temporary Roads San Juan National Standard 2.13.22: No temporary road shall be constructed . . . prior to the 2013 Forest development of a project-specific plan that defines how the road shall be managed and constructed. The plan must define the road design, who are responsible parties and their roles in construction, maintenance and decommissioning, the funding source, a schedule for construction, maintenance and decommissioning, the method(s) for decommissioning, and post-decommissioning monitoring requirements for determining decommissioning success.”

White Mountain Standard: Temporary roads must be decommissioned upon completion of the 2005 National Forest activity for which they were authorized.

Minimum Road Monongahela Goal, RF02: Provide developed roads to the density and maintenance level needed 2006 System and National Forest to meet resource and use objectives. During watershed or project-level planning: Subpart A a) Update inventory of area transportation system. requirements b) Determine the minimum transportation system necessary to achieve access management objectives. c) Incorporate cost efficiency into construction, reconstruction and maintenance needs. d) Identify roads to decommission, obliterate, replace, or improve that are causing resource damage. e) Integrate needs for off-road parking.

Beaverhead- Goal: The minimum transportation system necessary is identified and managed… 2011 Deerlodge National Forest Decommissioning Coconino National Objective: Naturalize or decommission 200 to 800 miles of unauthorized roads and 2013 and sustainability Forest system roads to create a more cost effective road system and to restore natural resources impacted by roads during the 10 years following plan approval.

Guideline: To maintain an efficient and sustainable road system, unneeded roads should be decommissioned. Factors in prioritizing the naturalization of decommissioned and unauthorized roads should include the following: 1. Watershed Condition - Soils that are receiving, or are expected to receive, damage to the extent that soil productivity is or will be significantly impaired outside of the road prism. - Riparian areas (e.g., springs, wetlands, or stream reaches) that are impaired due to sedimentation or alterations to hydrology related to the road. - Meadows at the TES montane meadows polygon map unit scale that are likely to be or being damaged. - Poorly located, designed, or maintained roads connected to downstream impaired waters, where potential for increased runoff and sedimentation is high. 2. Wildlife, Fish, and Plants - Habitats for threatened, endangered, or sensitive species that are susceptible to roads as barriers or roads as mortality hazards. 3. Social and Cultural Values - Areas of high or very high scenic integrity. - Roads that provide undesirable access to archaeological sites and areas of traditional cultural use by local tribal members. - Areas where user conflict must be resolved or to ensure public safety. - Semiprimitive nonmotorized ROS objectives as set through environmental analysis. - Roads where use levels or road maintenance causes adverse noise effects to wildlife during key periods in their life cycle or to recreational experiences. - Redundant roads. - Roads that are not identified on the motor vehicle use map (MVUM), which are not needed for administrative purposes. - Roads that continue to be used for public access despite motorized restrictions.

Jefferson National Objective 33.01. Analyze transportation system within one watershed per year 2004 Forest through watershed analysis, and identify roads to be decommissioned. (See also Objective 1.02). Objective 33.02. Priorities for decommissioning are roads causing resource damage and roads in areas where the desired condition is to reduce open road density.

Chequamegon- Guideline: Road decommissioning and restoration priorities: 2004 Nicolet National • Resource protection and (or) restoration. Forest • Abandoned roadbeds and unneeded access roads associated with road relocation. • Meeting desired road densities within Wilderness study areas, Management Areas 6A and 6B (semi-primitive non-motorized areas), wild and scenic riverways, Moquah Barrens, and Riley Lake Wildlife Management Area. • Meeting desired road densities within Research Natural Areas, Special Management Areas, and Old Growth and Natural Feature Complexes. • Local roads that connect to arterial or collector roads scheduled for reconstruction. • Working towards desired total road density within areas not listed above and shown as 2.0 mile/square mile open road density on Road Density Map (See Map packet). Connectivity Coconino National Management Approach: 2013 Forest - Consider wildlife and plant habitat needs early in the transportation and development planning process. - Work closely with the Arizona Game and Fish Department, Arizona Wildlife Linkages Working Group, Arizona Department of Transportation, and others to identify linkages and potential barriers to wildlife movement and to mitigate such threats during project design.

Cross-boundary Coconino National Management Approach: 2013 integration Forest - Cooperate with the National Park Service (NPS) to identify Forest Service roads near boundaries with national monuments that should be closed or decommissioned from the system to prevent trespass onto NPS land. Visitor experiences Jefferson National Standard: Road construction is not allowed within Semi-Primitive Motorized or Non- 2004 Forest Motorized areas except during an emergency or as subject to valid existing rights and leases. (See standards under Recreation Opportunity Spectrum.)