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Lands with Wilderness Characteristics: Badito Cone Contiguous Units

Badito Cone over Badito Cone South unit, Royal Gorge Field Office Photo: John Sztukowski

The intent of this report is to present objective data to illustrate that the area in question qualifies as Lands with Wilderness Characteristics (LWC), in accordance with Bureau of Land Management (BLM) Manuals 6310 and 6320. The information presented in this report meets the minimum standards for review of new information per Manual 6310, and accordingly BLM must review this information and make its findings and documentation of the review process available to the public as soon as practicable.

Lands with Wilderness Characteristics: Badito Cone Contiguous Units

BLM Royal Gorge Field Office, District BLM Unit Identifiers: COF-020-001 (Badito Cone), COF-020-002 (North Hondo), COF-020-003 (Chitwood Gulch), COF-020-087 (Badito Cone North)

Submitted by:

Wild Connections 2168 Pheasant Place, Springs, CO 80909 [email protected]; (719) 686 - 5905

Prepared by:

John Sztukowski, Wildlands Inventory Coordinator, Wild Connections [email protected]; (817) 939 - 4239

Report Date:

March 2015

Table of Contents Map of Badito Cones Contiguous Units LWC ...... 3 Overview ...... 4 Discussion of Wilderness Characteristics including Boundary Delineations...... 6 I. The Badito Cone Contiguous Units proposed LWC meets the minimum size criteria for roadless lands...... 6 II. The Badito Cone Contiguous Units proposed LWC is primarily affected by the forces of nature...... 10 III. The Badito Cone Contiguous Units proposed LWC provides outstanding opportunities for solitude and primitive recreation...... 13 IV. The Badito Cone Contiguous Units proposed LWC has supplemental values that would enhance the wilderness experience and should be recognized and protected...... 14 Summary Conclusion ...... 16 Badito Cone Contiguous Units Proposed LWC Waypoints ...... 18

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Map of Badito Cones Contiguous Units LWC

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Overview

The Badito Cone Contiguous Units proposed Lands with Wilderness Characteristics (LWC) is comprised of BLM lands contiguous with the Greenhorn Mountain Wilderness and/or Forest Service (USFS) Roadless Recommended Wilderness around the geological feature, Badito Cone. The proposed LWC is made up of four units that comprise approximately 7,600 acres, wrapping around the predominantly to the south, but to the southeast and southwest as well. The nearest town is Walsenburg, CO, located about 20 miles to the southeast. All units are located in Huerfano County. The Badito Cone area supports a diversity of vegetation, primarily consisting of pinyon-juniper woodlands in the rugged rocky uplands with ponderosa pine mixing in at higher elevations. Cottonwoods and willows can be observed in the gulches that drain the unit. The terrain is predominantly steep and rocky, made up of canyons, cliffs, and rock outcroppings. The proposed LWC ranges from elevations of approximately 6,400 feet at its southernmost point to about 8,400 feet near the units’ boundaries approaching the USFS Recommended Wilderness to the east. Prairie grasslands can be found in the lower foothills to the south and east. The Badito Cone Contiguous Units proposed LWC is largely bordered by private property. Road 438 represents the only major access point to any of the units, splitting the two largest units to the southwest, bordering both as the road makes its way to Badito Cone and Forest Service land. County Road 616 borders the southern portion of the largest of these units for a short distance. The remainder of these and all units can otherwise only be accessed by foot via contiguous USFS land.

The four Badito Cone Contiguous Units will be referenced geographically, beginning in the northwest, moving counterclockwise around the Wet Mountains. The northwestern unit, Arroyo Hondo, is approximately 530 acres, and does not offer public access. The BLM inventoried this unit as COF-020- 002 (North Hondo) and found the unit to have wilderness characteristics. Below this unit is Badito Cone West, approximately 950 acres, and has a southern boundary of USFS Road 438. The BLM inventoried this unit as COF-020-087 (Badito Cone North) and also found it to have wilderness characteristics.

The Badito Cone South unit is by far the largest of these areas, comprising over 5,800 acres. Its northern boundary primarily consists of USFS recommended wilderness, with USFS Road 438 the northern boundary to the northwest. The BLM inventoried this unit as COF-020-001 (Badito Cone) and found wilderness characteristics on 4,866.2 acres, but not on 923.5 acres, identified as COF-020- 001-A (delineated by the yellow line in the above map), the northwestern portion of this area adjacent to USFS Road 438. The BLM did not find wilderness characteristics in this area due to grazing features and access, evidence of old mining, and evidence of timber harvesting. While this subunit does have man-made features, they are largely unnoticeable and do not affect the natural integrity or the apparent naturalness of the unit overall (BLM Manual 6310, p 6-7), particularly when taking into account for the larger 5,800 acre BLM contiguous area, not to mention the greater wilderness corridor this can create with the USFS Greenhorn Mountain Wilderness and Roadless Recommended Wilderness to the north. Furthermore some of the features found within this unit can be considered historical.

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The final unit making up the Badito Cone Contiguous Units proposed LWC is Creek, the northeastern most of these units, and comprises about 330 acres. The BLM inventoried this unit as COF-020-003 (Chitwood Gulch) and found it to have wilderness characteristics. The roads leading to this unit are inaccessible to the public. This unit mostly aligns with a Colorado Natural Heritage Program (CNHP) Potential Conservation Area (PCA), identified for moderate biodiversity significance.

The Badito Cone Contiguous Units proposed LWC has high habitat and range values for many wildlife species, including Canadian lynx, swift fox, Rocky Mountain bighorn sheep, black bear, elk, mule deer, white-tailed deer, pronghorn, mountain lion, black-tailed prairie-dog and Gunnison’s prairie-dog. Critical and valued bird species identified in this area include the Mexican spotted owl and scaled quail, both identified as priority birds by Partnership in Flight. The threatened fish species, the greenback cutthroat trout can be found in the Apache Creek unit.

Opportunities for solitude and primitive recreation are abundant in the proposed Badito Cone Contiguous Units LWC. The steep rocky terrain, mid-elevation forests, vegetated gulches, and grassland prairies provide extensive opportunity for solitude in the forms of isolation, remoteness, lack of visitation and vegetative and topographic screening. Primitive recreation is also available in all seasons, including hunting, fishing, backpacking, hiking, wildlife viewing, bird watching, and photography. BLM's Manual 6310 states that the boundary delineation for a LWC unit "is generally based on the presence of Wilderness Inventory Roads" but can also be based on property lines between different types of land ownership or on developed rights of way (Manual 6310, p 4). These were the parameters Wild Connections used to define the boundaries of the Badito Cone Contiguous Units proposed LWC. Only after the true boundaries of the contiguous roadless unit are identified can an objective and thorough assessment of that unit's wilderness characteristics be made. In the spring of 2013, Wild Connections produced a preliminary boundary delineation for this unit based on the size and contiguity requirements stated in Manual 6310 (p 6). In 2014, Wild Connections' mapping teams visited the Badito Cone Contiguous Units proposed LWC to conduct in- depth, on-the-ground inventories of these units. Our goal was to assess this area for wilderness characteristics, based on BLM's Manual 6310, and report our findings to the BLM's Royal Gorge Field Office in efforts to identify potential wilderness areas to expand "wildlands" corridors in . Additionally we have reviewed the 2013 BLM RGFO inventory and boundaries and have made assessments and adjustments based on our in-depth field inventories.

Wild Connections’ report offers new in-depth data and information, including photo, narrative, and geo-referenced data, supporting the Badito Cone Contiguous Units proposed LWC. The boundary delineations and narratives describing the wilderness characteristics found within this unit are detailed below. Waypoints (many with photos) are referenced throughout this report; the photos with geo-data, time and date stamp, description, and page number can be found at the end of the report, akin to the one shown below.

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Badito Cone (30) - NNE Topographic and vegetative screening make for excellent opportunities for solitude in these units (p. 13)

Discussion of Wilderness Characteristics including Boundary Delineations

I. The Badito Cone Contiguous Units proposed LWC meets the minimum size criteria for roadless lands.

The Badito Cone Contiguous Units proposed LWC comprises approximately 7,600 contiguous roadless acres. While only one of these units, Badito Cone South, surpasses the minimum size criteria of 5,000 acres for a potential LWC (BLM’s Manual 6310, p 5), all of the units meet the size requirements for wilderness characteristics as “they are contiguous with lands which have been formally determined to have wilderness or wilderness potential values, or any Federal lands managed for the protection of wilderness characteristics” (BLM’s Manual 6310, p 5). USFS’ contiguous Greenhorn Mountain designated Wilderness and surrounding Roadless Recommended Wilderness meet these qualifications.

With regard to route determination, BLM Manual 6310 states that a "way" maintained solely by the passage of vehicles does not constitute a "road" for purposes of inventorying wilderness characteristics. A "way" that is used on a continuous and regular basis still does not constitute a road. Additionally, a vehicle route that was constructed by mechanical means, but is no longer being maintained by mechanical methods is also not a road. By comparison, a Wilderness Inventory Road (WIR) is a vehicle road that has "been improved and maintained by mechanical means to ensure relatively regular and continuous use" (Manual 6310, p 11). Wild Connections' inventory of this area 6

assesses routes that are or are not considered WIRs based on the above definitions from Manual 6310. Routes that did meet the criteria for WIRs were removed from the unit as cherrystems.

For the Badito Cone Contiguous Units proposed LWC, much of the BLM’s assessment of the LWC boundaries and characteristics appear to be largely accurate. The only difference in Wild Connections’ inventories of these units is in regard to the wilderness characteristics in BLM subunit COF-020-001-A, the western portion of Wild Connections’ Badito Cone South unit. The boundary delineations of this unit will be discussed below in this unit, with other wilderness characteristics to follow in the proceeding sections. The four units that make up the proposed LWC will be discussed geographically counterclockwise, beginning with the northwest contiguous unit, Arroyo Hondo.

The Arroyo Hondo unit (COF-020-002) is bordered by USFS Roadless Recommended Wilderness to the east. The remainder of the unit is insulated by private property. There is no public access to this unit. Waypoint 1 views the unit from the east, at the end of public access on County Road 622. The BLM inventoried this unit as North Hondo and did not find any Wilderness Inventory Roads. The BLM inventoried one way in this unit, a very short route (approximately 650 feet) that enters the unit at Waypoint 2. In BLM’s report for this area, they state that this way was created for range use that is no longer in use, with no recent use observed. The route was not created by mechanical means, not maintained, improved, nor regular and continuous, and will remain within the unit as a way. Wild Connections supports BLM’s claims for this unit.

The Badito Cone West unit (COF-020-087), just to the south of the Arroyo Hondo unit, is also bordered by USFS Roadless Recommended Wilderness to the east. Private property borders the unit to the north and west, with USFS Road 438 making up the southern boundary, separating it from the BLM Badito Cone South unit. USFS Road 438 becomes the unit boundary at Waypoint 8, traversing about 1.4 miles east to the Forest Service boundary at Waypoint 13. Waypoint 12 views this route with a USFS 438 carsonite road sign that designates this route for high clearance vehicles. This route was constructed by mechanical means, shows indications of improvements and regular and continuous use, and thus will be removed from the unit as a Wilderness Inventory Road (WIR).

A short distance onto USFS 438 from the western pubic entrance, a former route heads north into the unit at Waypoint 10. This route shows heavy revegetation and is washed out by a gulch a short distance along the route, as evidenced in Waypoint 11. This route was not constructed by mechanical means, is not maintained, and is not regular and continuous. It will remain within the unit as a way.

The Badito Cone South unit (COF-020-001) shares USFS Road 438 as a unit boundary with the Badito Cone West unit, to the north. The USFS 438 boundary begins further east for this unit, at Waypoint 3. This also represents the western portion of BLM’s inventoried unit, COF-020-001-A, for which the BLM did not find wilderness characteristics. There are a few routes that enter the unit to the south from USFS Road 438 in the northwest corner of this unit. Waypoint 4 views the westernmost of these routes. As seen in the photopoint, this route was not constructed by mechanical means, shows no indications of improvement or maintenance, and does not appear regular or continuous. It appears as a social trail that is mostly revegetated and will remain within the unit as a way. This route heads south for less than one-half mile to Waypoint 5 where it meets a locked gate and fence line at the private property boundary. The BLM inventoried this route as well as (CO-020-001-i), for ATV 7

recreational use, and also concluded it to be a way. Note there are no BLM signs on the ground designating use or restrictions for this route.

About one-tenth mile east of this route along USFS Road 438 is another social trail that heads south into the unit at Waypoint 6. This trail is even more faint and revegetated, disappearing a short distance into the unit at Waypoint 7. As evidenced in the above photopoints, this route was not created by mechanical means, shows no indications of improvement, maintenance, or regular and continuous use, and thus will remain within the unit as a way. The BLM did not inventory this route. Similarly to the last route, there are no BLM signs delineating designations or restrictions for this route.

The BLM inventoried one more route in this area (CO-020-001-d), again as ATV recreation/hunting use, however this route was difficult to find on the ground. Wild Connections’ inventory did find the BLM inventoried campsite at Waypoint 9, just off USFS Road 438, however a route was not observed on the ground past this. Regardless, Wild Connections concurs with BLM’s assessment that this route will remain within the unit as a way.

Given that these routes in the northwest of this unit were not constructed by mechanical means and show much revegetation, they are not visible throughout most of the unit, cannot be distinguished nearby, and thus do not impact the overall naturalness of this unit or even this portion of the unit. Furthermore Wild Connections recommends that the BLM make known their plans for these routes, installing proper signage on the ground.

The only other public access into this unit is from the north via USFS land at Waypoint 17. This route, BLM 6274, represents the eastern boundary for BLM’s inventoried subunit, CO-020-001-A. The USFS/BLM boundary is denoted by a barbed wire fence on the ground that stretches east and west along the border. There are no signs on the ground denoting the change in public land or designations/restrictions for the route’s use into BLM land. As evidenced in the above photopoint, this route shows considerable revegetation; the BLM stated in their report that BLM 6274 receives light use. This is even more apparent a little further south on the route at Waypoint 18, looking up the completely revegetated route through the grasslands to Badito Cone. The BLM reports that this route was initially bladed, although that was only evidenced along parts of the route. Regardless, Wild Connections agrees with BLM’s assessment that this route has not shown improvement or maintenance by mechanical means and should remain within the unit as a way. The BLM stated that this route gets regular and continuous use, however that was not observed on the ground, as indicated in the photopoints.

BLM 6274 comes to a “junction” further south at Waypoint 20, however neither of these routes are discernible on the ground, as they are completely revegetated, as evidenced in the photopoint. BLM 6274 ends a short distance south at private property at Waypoint 22, complete with a barbed wire fence line, locked gate, and No Trespassing sign. The route picks back up south of the private property, continuing southeast, ending into private property again at Waypoint 32. This route is not accessible to the public from the south via State Highway 69 due to private property.

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The route that heads west from the above referenced revegetated junction (Waypoint 20 - right), leads to a former prospecting site at Waypoint 25, however there is no evidence of recent excavation, only a historic 73 year old military tractor. A short spur route off this mining route was observed at Waypoint 23, and leads south the private property. As evidenced in the photopoints, these are primitive routes that may have initially been bladed by mechanical means, however show no signs of improvement, maintenance, or regular and continuous use, and will remain within the unit as ways.

Badito Cone (20) - SSE This concludes the boundary and route Revegetated junction at BLM route 6274 delineation for BLM’s subunit CO-020-001-A. (p. 8,9) Naturalness and additional wilderness characteristics will be identified in the following sections for this subunit.

Everything to the east of BLM 6274 aligns with BLM’s inventoried unit, CO-020-001 (Badito Cone), in which they did find wilderness characteristics. Note that Wild Connections is proposing CO-020-001 and CO-020-001-A as one contiguous roadless area. The BLM uses BLM 6274 as the boundary between these two, however as their report indicates, this route does not meet WIR stipulations and should remain within the unit as a way, not having to be designated a boundary.

Just east of BLM 6274 is another route that traverses from USFS land, essentially making a loop with BLM 6274. This route stems from BLM 6274 in the Badito Cone unit at Waypoint 21. The route splits at Waypoint 28, and reconnects a short distance before the BLM/USFS boundary to the north, however the latter junction was not observed on the ground. Waypoint 29 views the western of these two routes, atop a north-south ridgeline. This route enters the BLM/USFS boundary at Waypoint 31, indicated by the fence line viewed west. As evidenced in all of these photopoints, both of these routes were most likely constructed by mechanical means via blading, however they show no signs of improvement, maintenance, or regular and continuous use. Wild Connections agrees with BLM’s assessment for these routes (CO-020-001-j) that they should remain within the unit as ways. The only evidence of these routes are the linear features through the forest when observed on the route on the ground, however are difficult to see otherwise due to the steep topography and dense vegetation in this section of the unit.

The BLM inventoried more routes in this unit, Badito Cone South, however they are inaccessible to the public. Waypoint 33 views the route to the uranium prospecting site from State Highway 69, however it is gated and locked with a private property sign posted as there is a private property buffer before BLM land is met on this route. The BLM inventoried this route (BLM 6275 and CO-020- 001-m) to enter the BLM at Waypoint 34, traversing northerly for approximately two miles, reaching 9

the uranium mine at Waypoint 35, just south of the BLM/USFS boundary. The BLM concluded that this route was initially bladed, however is not maintained (for at least the last 10 years), improved, or regular and continuous. The BLM stated that the route is washed out near the southern entrance and shows no recent use. Wild Connections agrees that this route should remain within the unit as a way. Furthermore, this route does not affect the natural integrity of the unit as it is not visible to the average visitor.

State Highway 69 borders the southernmost boundary of the Badito Cone South unit for a short distance at Waypoint 36 for about one-quarter mile, however there are no public access points on the ground and no BLM signs for entering or leaving public lands.

The BLM also inventoried a few short routes in the northeast Badito Cone South unit, however these are also inaccessible to the public. Waypoint 37 views this section of the unit from the junction of County Road 650 and 651 to the east. This is the route that would lead to the BLM inventoried routes, however a road sign on CR 650 states “No Public Land Access,” as this road leads to a series of subdivisions cradled next to the public land. The BLM inventoried these routes, initially purposed for range management, to have historic motorized use, but current use of only foot and horse. They were not constructed by mechanical means and will remain within the unit as ways.

The northeasterly of the four contiguous Badito Cone Contiguous Units proposed LWC, Apache Creek unit (COF-020-003), would also be accessed via County Road 650, however as previously stated, there is no public land access from this road. Waypoint 38 views this unit from the southeast via County Road 650. The BLM did inventory one route into this unit, a two-track starting in the southeast corner of the unit, which has seen no recent motorized activity, only foot and horse, and is rarely used. This route was not constructed by mechanical means and will remain within the unit as a way.

II. The Badito Cone Contiguous Units proposed LWC is primarily affected by the forces of nature.

The Badito Cone Contiguous Units proposed LWC is primarily affected by the forces of nature, with human impacts considerably unnoticeable within the unit. Motorized public access to any of the units is limited to one public access point in the west via USFS Road 438. Other routes found within the unit showed a lack of motorized use and an overall apparent lack of regular use, with the forces of nature reclaiming many of the former roads. None of the routes have BLM signage that designates or restricts motorized use, which may help to corral any illegal motorized activity in the area. Other human impacts that were observed in the proposed LWC were minor and will be detailed at the end of this section.

The proposed LWC offers a mixture of vegetation types, due to the topographic variety found within these units. Pinyon-juniper woodlands dominate much of the steep and rocky terrain within the units, as seen in Waypoint 14, viewing the Badito Cone West unit, and Waypoint 16, which views the Badito Cone South unit. The underbrush consists primarily of cacti, rabbit brush, sagebrush, native grasses, and wildflowers. Ponderosa pine mixes in at the higher elevations, and cottonwoods and willows can be observed in the gulches that drain the units. Waypoint 36 illustrates the prairie

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grasslands found in the lower elevation foothills. This photo was taken at State Highway 69 at the southernmost point, and approximate lowest elevation, of any of the units. Much of Wild Connections’ inventory of the Badito Cone Contiguous Units proposed LWC revealed untrammeled naturalness, however there were some minor human impacts observed as well. The minor human impacts found within the unit primarily consist of former roads, fence lines, indications of rangeland management, and prospecting sites with historic equipment. See the above section for detailed analyses on roads and routes within Badito Cone Contiguous Units. The only road found within the unit, USFS Road 438 is removed as a WIR and splits the Badito Cone West and Badito Cone South units, becoming a boundary road for both. Former routes that are being reclaimed by nature, routes that do not meet BLM Manual 6310’s definitions for roads, were left in the unit as ways.

Wild Connections was not able to access the Arroyo Hondo unit and will default to the BLM’s naturalness assessment of this area. The BLM found a few minor human impacts: a two track route to access an old stock tank no longer in use, an abandoned two track in the unit most likely initially purposed for prospecting, and other indications of former range and mining activity in the area. Nevertheless, the BLM concluded that as a result of the inventory concluded, “the North Hondo unit generally appears to have been affected primarily by the forces of nature.”

The Badito Cone West unit also appears to be primarily affected by the forces of nature. With the exception of a short revegetated route into the interior from the southwest via USFS Road 438, no other human impacts were observed. The BLM stated in their report for this area (CO-020-087) that this unit also had range improvements in the forms of fences, gates, springs, stock tanks, and corrals, however these were not observed in Wild Connections’ inventory and the BLM did not provide waypoints or photos of these impacts. Regardless, the BLM also stated that cattle grazing has diminished considerably due to the recent drought conditions and that the activity is mostly concentrated along the southern boundary, USFS Road 438. Furthermore, the BLM concluded that this unit generally appears to have been affected primarily by the forces of nature and that the unit appears to have apparent naturalness due to the rough, rugged topography and minimal human impact. Waypoint 14 exemplifies this, viewing the untrammeled naturalness of the Badito Cone West unit looking down from USFS land just above the unit’s eastern boundary.

The unit to the south, Badito Cone South, and more specifically the western portion of the unit identified by BLM as CO-020-001-A, was not found to have wilderness characteristics according to BLM’s report. The BLM state that this is due to grazing features (developed springs, corrals, fence lines, and cattle guards), evidence of mining (constructed routes, tailing piles, and an old track dozer), and timber harvest (firewood gathering and cut logs). While a few minor human impacts were observed in this subunit, the majority of the impacts identified by the BLM were not observed on the ground. There were no indications of rangeland management in this unit, other than the boundary fences at USFS land and private property. Furthermore the BLM failed to provide any evidence, waypoints or photos, of any grazing features in this subunit.

The only evidence of mining in the CO-020-001-A subunit is a former prospecting pit just off of BLM route 6274 at Waypoint 25. However this has not seen use in years and the most prominent impact is the 1942 Army M2 Medium tractor, which should be considered historical, actually adding value to this (sub)unit. Another piece of machinery, most likely a towing winch, was observed just south of the

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tractor along the spur route to the pit at Waypoint 24. This may be considered historical as well, but regardless is small, low to ground, and not noticeable unless the viewer is right on top of it. The BLM provided no other evidence of mining in this subunit. Similarly, the BLM did not provide evidence, waypoints or photos, for the timber harvest human impacts claimed by the BLM for this subunit. There may be some old downed trees along the routes, however these are substantially unnoticeable, particularly given how heavily wooded the subunit is. The only other noticeable human impacts within the subunit are the old routes in the western portion of the unit, BLM’s boundary route BLM 6274, and the short prospecting routes stemming from BLM 6274. However as evidenced in the above section, these routes are heavily revegetated and unnoticeable throughout much of the unit, as they are not even discernible nearby. In addition to the revegetation of the routes, which the BLM also confirms all as ways in this subunit, the linear features (along with the prospecting pit and historic mining equipment) are substantially unnoticeable throughout the unit due to the steep rocky topography and heavily wooded pinyon-juniper forest. Nothing but untrammeled naturalness was observed from the northern boundary Road USFS 438, and similarly from BLM’s eastern boundary route BLM 6274 looking into the interior of BLM subunit CO-020-001-A. Badito Cone (7) - ENE Waypoint 7, right, views Badito Cone over Unmarked route ends shortly into unit interior; the untrammeled naturalness of BLM’s View of Badito Cone over Badito Cone South unit subunit CO-020-001-A from the subunit’s (p. 8,12) western interior.

As evidenced in the above section, and according to BLM’s report for CO-020-001, BLM 6274 is not a WIR and can remain within the unit as a way. Therefore BLM 6274 should not be a boundary, combining CO-020-001-A and CO-020-001 into one continuous roadless area of over 5,800 acres. Waypoint 26 views this route from above nearby, capturing the naturalness features of CO-020-001 to the east. Furthermore the human impacts that the BLM confines to a 900 acre subunit should be reassessed for this greater 5,800 contiguous roadless area.

The BLM found wilderness characteristics on the contiguous land, CO-020-001, despite similar human impacts found: range activity improvements (fences, gates, springs, stock tanks, and corrals), an old uranium prospecting mine, and old routes. The only rangeland improvements in this area observed by Wild Connections’ inventory is a small earthen dam located just east of BLM 6274 at Waypoint 19. Note that much of the historic and former range activity that the BLM cites in their report is in the northeast section of the unit, inaccessible to the public.

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The BLM documents the old uranium prospecting mine and remnants with photos and descriptions in their report, stating that the route leading up to it has not been maintained for at least 10 years and is washed out, rendering it inaccessible to full-size vehicles, in addition to being inaccessible to the public. Waypoint 16 views down on this section of the unit from near the BLM/USFS northern boundary, however again given the steep topography and dense vegetation of the unit, no human impacts are discernible. The only other noticeable human impacts found in this unit are the old routes: CO-020-001-j to the east of BLM 6275, the washed out route to the uranium prospecting mine, and the former range access routes that no long receive motorized use in the northeast corner. These routes show heavy revegetation and are not visible throughout much of the unit. Wild Connections agrees with BLM’s report that “this unit appears to have apparent naturalness due to the rough, rugged topography and minimal human imprint compared to the overall size of the unit.” As documented above, Wild Connections pas provided evidence that this unit should be extended to include the approximately 900 acre contiguous BLM land to the west, BLM inventoried subunit CO-020-001-A, which posses comparable naturalness and wilderness characteristics.

The Apache Creek unit to the northeast also has minor human impacts, however they do not affect the overall naturalness characteristics. Similar to the Arroyo Hondo unit, the Apache Creek unit is inaccessible to the public and Wild Connections will defer to the BLM’s assessment of the unit. The BLM found minor human impacts in the forms of an old two-track route and former range activity in the area, however no recent motorized activity was observed and BLM determined that the two-track is not open to the public and rarely used. Wild Connections agrees with BLM’s assessment that these minor human impacts do not affect the naturalness of the area and that the unit generally appears to have been affected primarily by the forces of nature.

While there are a few minor human impacts spread throughout the Badito Cone Contiguous Units proposed LWC, these are examples of “human-made features” that are considered substantially unnoticeable and thus do not hinder wilderness characteristics (BLM Manual 6310, p 6). Furthermore what was found and inventoried in these units do not affect the natural integrity or the apparent naturalness of the units overall (BLM Manual 6310, p 6-7).

III. The Badito Cone Contiguous Units proposed LWC provides outstanding opportunities for solitude and primitive recreation.

The Badito Cone Contiguous Units proposed LWC offers many opportunities for solitude and primitive and unconfined recreation. There are vast opportunities for solitude given the topographic variety, dense vegetation, the few public entry points, and lack of trails (motorized and non- motorized). The rugged wooded hills, canyons, and cliffs provide excellent screening from unnatural sights and sounds. Waypoint 30, viewing east over a canyon in the northern Badito Cone South unit, shows an excellent example of the topographic and vegetative screening available for solitude in these units. The gulches, cutting through rocky canyon terrain also provide outstanding opportunity for solitude. Furthermore, the observed lack of visitation and overall use in these units provide outstanding opportunities for respite and remoteness just about anywhere in the proposed LWC. 13

Consisting of over 7,600 acres of contiguous unroaded wilderness land, the proposed LWC offers a multitude of primitive and unconfined recreational opportunities as well. There are outstanding opportunities for hiking, backpacking, camping, rock climbing, hunting, wildlife viewing, bird watching, horseback riding, and photography. There are excellent opportunities for hunting within this unit; high value animal species and habitat are documented in the section below. There are also outstanding opportunities for fishing in the Apache Creek unit. The BLM’s report for COF-020-001 (Badito Cone) sums up the recreational experience very well for these units: “The unit is contiguous with the USFS recommended wilderness area and roadless area, a dominant impression of an observer is that it is a part of a great expanse of wild country... The opportunities for primitive recreation becomes outstanding due to the lack of primitive routes in the area, the large expanses of land it encompasses, and the varied terrain that offers many types of recreational uses.”

IV. The Badito Cone Contiguous Units proposed LWC has supplemental values that would enhance the wilderness experience and should be recognized and protected.

Wild Connections’ inventory of the Badito Cone Contiguous Units proposed LWC supports the existence of numerous supplemental values that contribute to the overall experience of visiting this area and provide additional evidence that this unit's unique qualities should be recognized and protected. The majority of these values support the area’s regional ecological importance and rich biodiversity. The supplemental values presented below are not intended to be exhaustive, rather a summarization of some of the widely known significant values for which basic data was available to complement our on-the-ground inventory. These four units are all contiguous with the greater USFS Greenhorn Mountain Wilderness and/or Roadless Recommended Wilderness, a vast corridor of connectivity for flora and fauna. 23,087 acres comprise the rugged forested Greenhorn Mountain Wilderness, not accounting for the contiguous Recommended Wilderness and greater Pike-San Isabel national Forest. The Badito Cone Contiguous Units can extend this connectivity core 7,600 acres to the southeastern, southern, and southwestern lower elevation foothills and grasslands, critical habitat for many species.

The Badito Cone Contiguous Units have extraordinary biological values. The proposed LWC supports high precision occurrences of the globally and state vulnerable plant species, Rocky Mountain bladderpod (Lesquerella calcicola). About half of the Apache Creek unit aligns with the Colorado Natural Heritage Program’s (CNHP) Potential Conservation Area (PCA) of South Apache Creek, a greater area of nearly 5,300 acres recognized for moderate biodiversity significance (B4). The biodiversity significance is attributed to the extant occurrences of the threatened fish species, the greenback cutthroat trout (Oncorhynchus clarkii stomias) in the Apache Creek watershed, and a historical occurrence of the globally vulnerable Mexican spotted owl (Strix occidentalis lucida). The Mexican spotted owl is also a Colorado Parks and Wildlife (CPW) threatened species, a US Wildlife Conservation and

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Restoration Program’s (WCRP) Comprehensive Wildlife Conservation Strategy (CWCS) Species of Most Concern, and Partnership in Flight Priority Bird. Other significant and valued bird species have been identified in the area. In addition to the Mexican spotted owl, the proposed LWC supports overall range for the scaled quail (Callipepla squamata), also a Partnership in Flight Priority Bird. RMW also identifies wild turkey (Meleagris gallopavo) overall range and production area for these units.

High habitat and range values for many other wildlife species have also been identified in the Badito Cone Contiguous Units proposed LWC. Rocky Mountain Wild’s (RMW) Assessment of Biological Impact (ABI) documented the following mammals and associated values within the unit: Canadian lynx (Lynx canadensis) potential habitat; swift fox overall range (Vulpes velox); Rocky Mountain bighorn sheep (Ovis canadensis Canadensis) overall range, winter range; black bear (Ursus americanus) overall range; elk (Cervus Canadensis) overall range, summer range, winter range, severe winter range; mule deer (Odocoileus hemionus) overall range, summer range, winter range, severe winter range; white-tailed deer (Odocoileus virginianus) overall range; pronghorn (Antilocapra americana) overall range, winter range, linkage area; mountain lion (Puma concolor) overall range; Brazilian free tailed bat (Tadarida brasiliensis) overall range; Gunnison’s prairie-dog (Cynomys gunnisoni) overall range; black-tailed prairie-dog (Cynomys ludovicianus) overall range; Aberts squirrel (Sciurus aberti) overall range. A few of these species garner additional recognition. The most notable animal species affiliated with the proposed LWC is the Canadian lynx, which is listed as a threatened species by the US Fish and Wildlife Service (FWS), an endangered species by the CPW, and a species of most concern by WCRP’s CWCS. The swift fox is listed as a threatened species by CPW as well as Colorado BLM sensitive. The black-tailed prairie-dog is a species of concern for CPW, Colorado BLM sensitive, and WCRP’s CWCS species of most concern. Gunnison’s prairie-dog is also listed as a species of most concern by WCRP’s CWCS and Colorado BLM sensitive. The Brazilian free tailed bat is a Colorado state ranked critically imperiled species.

There are exceptional scenic views from within the proposed LWC, given the many high vantage points found throughout the unit. The Sangre de Cristo Mountains are viewable to the west and southwest, for example in Waypoint 27 in the Badito Cone South unit (BLM’s subunit CO-020-001-A). The Blanca Massif is a pronounced feature of the in this region, easily identifiable on a clear day. Similarly, the are normally visible to the south, also prominent features in the region as a large eastern outlier of the Culebra Range, a sub-range of the Sangre de Cristo Mountains in southern Colorado, visible from the Front Range.

Badito Cone itself is also a significant feature (Waypoint 18): the predominant cone at the southern end of the Wet Mountains was a historical geographical reference for native peoples, explorers, and settlers.

The 7,600 acre proposed wilderness is noteworthy for its disparate geological features. These units represent the southern end of the Wet Mountains, as they descend from mountains into foothills and then into the prairie grasslands. Many different geological layers are captured from the Badito Cone peak, extending from USFS down into BLM land. All of the Badito Cone Contiguous Units capture this

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transformation. The majority of the southern Wet Mountains are from the Early Proterozoic Age, the oldest rocks in the area, made up primarily of felsic and mafic gneiss. This is captured along the highest elevation edges of the Badito Cone Contiguous Units. Descending south and west is a thin layer of Permian-Pennsylvanian conglomerate and sandstone, followed by a larger band of Cretaceous-Jurassic sandstone and mudstone that wrap around the southern end of the Wet Mountains. There are large deposits of deep red sandstone in some of the canyons, particularly in the Badito Cone West unit and Badito Cone South unit. Waypoint 15, right, illustrates this in the latter unit from above on USFS land at the base of Badito Cone.

Much of the lower elevation areas, predominantly in the Badito Cone South unit, are from the Cretaceous Period, consisting of shale and limestone. Badito Cone itself represents the most recent geology in the area, from the Tertiary Age, as it once produced volcanic activity, hence the cone shape. Plutonic rock can be found Badito Cone (15) - SSW extending south from Badito Cone into the View of deep red sandstone canyon in the Badito Cone West unit, but mostly down Badito Cone South unit (p. 16) into the Badito Cone South unit. BLM 6274 appears to descend right down the primary volcanic flow line. The above geological data was obtained from the United States Geological Survey's (USGS) Mineral Resources on-line spatial data, selected for Colorado's geology.

Summary Conclusion

Based on Wild Connections' extensive on-the-ground and aerial inventories, the Badito Cone Contiguous Units proposed LWC qualifies as Land with Wilderness Characteristics (LWC) in accordance with BLM's Manual 6310. These four units are contiguous to USFS wilderness and/or recommended wilderness, comprising over 7,600 contiguous roadless acres. Given the size of the unit, lack of significant human impacts, disparate topography, diverse ecosystems, and abundant wildlife, the Badito Cone Contiguous Units proposed LWC offers outstanding wilderness characteristics - including apparent naturalness and outstanding opportunities for solitude and primitive and unconfined recreation.

The boundaries and wilderness characteristics identified by the BLM generally align with Wild Connection’s inventory. However BLM inventoried subunit CO-020-001-A should be considered to have wilderness characteristics and be a part of the greater Badito Cone South unit. The BLM reported that BLM 6274, their boundary between the two, is not a WIR and can remain within the unit as a 16

way. Therefore this should be one greater unit, comprising over 5,800 acres of contiguous roadless BLM land that wraps around the USFS portion of the southern Wet Mountains. The reported impacts in BLM subunit CO-020-001-A unit, the revegetated routes, old prospecting site, and historic equipment minor and human impacts and furthermore are largely unnoticed on the ground due to the steep topography and dense vegetation. CO-020-001-A should be included in the overall proposed LWC since it is contiguous with BLM’s unit COF-020-001, since this subunit does possess wilderness characteristics, and since the human-made features are substantially unnoticeable and do not affect the natural integrity of the unit, particularly when assessed with the 5,800 contiguous roadless acre area in sum.

While much of the proposed LWC consists of untrammeled wilderness, human impacts were found. As documented, former roads, fences, gates, signs, and a historical mining equipment were observed within the unit. Earthen dams and other rangeland management practices were also observed within the proposed LWC. Nevertheless these are minor human impacts, consistent with BLM Manual 6310, as the natural integrity and the apparent naturalness of the proposed LWC units in total are not compromised. The BLM recognized these impacts to be minimal in all units, except for CO-020-001-A.

Wild Connections’ inventory has documented the necessary boundaries as well as the wilderness characteristics within the unit. This overview provides new information, including narrative, photo, and geo data, and supporting maps, documenting that the approximately 7,600 acre Badito Cone Contiguous Units proposed LWC meets wilderness criteria. This area possesses Lands with Wilderness Characteristic status and its wilderness values should be protected and preserved. It is imperative that the BLM recognize and protect these values in their land management decisions, so that these unique and abundant wilderness qualities are sustained.

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Badito Cone Contiguous Units Proposed LWC Waypoints

The following photographs correspond with the numbered Waypoints on the above Badito Cone Contiguous Units map and may be referred to in the report narrative describing the wilderness characteristics. The direction of view (16 point Cardinal) is indicated in the bolded caption. Below this is a short description of the photo, with the referenced page number(s) in parenthesis.

The photos are also watermarked with the direction (degrees and cardinal) in the top right, date and time in the bottom right, elevation in the bottom center, and the latitude and longitude in the bottom left.

Badito Cone (1) - NW Badito Cone (4) - NNE View of NW unit, Arroyo Hondo, from CR 622; Revegetated unmarked route into NW Badito Cone No public access (p.7) South unit from USFS 438 boundary road (p. 7)

Badito Cone (5) - S Badito Cone (6) - SE End of unmarked route at private property Faint unmarked route into NW Badito Cone South (p. 7) unit from USFS 438 boundary road (p. 8)

Badito Cone (7) - ENE Badito Cone (9) - E Unmarked route ends shortly into unit interior; Excellent opportunity for camping in Badito Cone View of Badito Cone over Badito Cone South unit South unit; view of Badito Cone over interior unit (p. 8,12) (p. 8)

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Badito Cone (10) - NNE Badito Cone (11) - NE Junction for unmarked revegetated route into SW Unmarked route revegetated and washed out in a Badito Cone West unit (p. 7) gulch shortly along route (p. 7)

Badito Cone (12) - N Badito Cone (13) - NW Badito Cone West and South units’ boundary road USFS 438 boundary road at BLM/USFS boundary USFS 438 at carsonite sign (p. 7) (p. 7)

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Badito Cone (14) - NNW Badito Cone (15) - SSW View of steep rocky terrain with a pinyon-juniper View of deep red sandstone canyon in the woodland in the Badito Cone West unit Badito Cone South unit (p. 10,11) (p. 16)

Badito Cone (16) - ESE Badito Cone (17) - ESE Dense pinyon-juniper landscape common across all BLM 6274 route into Badito Cone South unit units; viewing Badito Cone South unit (p. 10,13) from USFS land to the north (p. 8)

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Badito Cone (18) - NNW Badito Cone (19) - E View of Badito Cone over interior Badito Cone Small earthen dam off BLM route 6274 in the South unit on BLM route 6274 Badito Cone South unit (p. 8,15) (p. 12)

Badito Cone (20) - SSE Badito Cone (21) - SE Revegetated junction at BLM route 6274 BLM route 6274 junction for loop route (p. 8,9) CO-020-001-j, which heads north to USFS land (p. 9)

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Badito Cone (22) - SSE Badito Cone (23) - SW BLM route 6274 at private property fence line Mining route junction off BLM route 6274 with locked gate and no trespassing sign (p. 9) (p. 8)

Badito Cone (24) - NNE Badito Cone (25) - WNW Old towing winch south of prospecting pit Historic 1942 Army M2 Medium tractor in front (p. 12) of old prospecting pit (p. 9,11)

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Badito Cone (26) - ENE Badito Cone (27) - WSW View of BLM route 6274 through heavily wooded View of Sangre de Cristo Mountain range from pinyon-juniper rolling landscape Badito Cone South unit (BLM CO-020-001-A subunit) (p. 12) (p. 15)

Badito Cone (28) - N Badito Cone (29) - SSW Junction at CO-020-001-j in Badito Cone South unit Route CO-020-001-j shows no indications of (p. 9) recent use (p. 9)

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Badito Cone (30) - NNE Badito Cone (31) - W Topographic and vegetative screening make for View BLM/USFS boundary fence line for the excellent opportunities for solitude in these units Badito Cone South unit (p. 13) (p. 9)

Badito Cone (33) - NW Badito Cone (36) - WNW No public access to uranium prospecting route in View of Badito Cone over Badito Cone South unit Badito Cone South unit (p. 9) at boundary road State Highway 69 (p. 10)

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Badito Cone (37) - WSW Badito Cone (38) - NNW View of Badito Cone South NE unit from CR 650 View of Apache Creek unit from CR 650; and CR 651 junction; no public access No public access (p. 10) (p. 10)

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