United States Department of the Interior Bureau of Land Management

Buffalo Horn Land Exchange

DOI-BLM-CO-N05-2017-0009

Scoping Comments

April 2017

U.S. Department of the Interior Bureau of Land Management Northwest District White River Field Office 220 East Market St Meeker, CO 81641 SCOPING PROCESS The BLM uses a scoping process (40 CFR 1500-1508) to identify potential significant issues in preparation for impact analysis. The principal goals of scoping are to identify issues, concerns, and potential impacts that require detailed analysis. Scoping is both an internal and external process. Internal scoping was initiated when the project was presented to the White River Field Office (WRFO) interdisciplinary team on 1/10/11. External scoping was initiated when the public was formally notified of the proposed land exchange through a Notice of Exchange Proposal (NOEP) which was published in the Rio Blanco Herald Times on 12/8/16, 12/15/16, 12/29/16, 1/5/17, 1/12/17, 1/19/17 and in the Craig Daily Press on 12/9/16, 12/16/16, 12/23/16, and 12/30/16. The BLM also issued a press release soliciting scoping comments from the public on 12/8/16 and presented an overview of the exchange to the Northwest Resource Advisory Council. The BLM sent letters directly to potentially affected individuals and organizations (including livestock grazing permittees, oil and gas lessees and operators, rights-of-way holders, special recreation permit holders, and adjacent landowners) and elected officials (Senator Bennet, Senator Gardner, Representative Tipton, Moffat County Commissioners, and Rio Blanco County Commissioners) to inform them of the scoping period. A public meeting was held on 1/5/17 at the Meeker Public Library to discuss the proposal.

COMMENTERS The BLM received scoping comments from the following individuals, businesses, non- governmental entities, and other public agencies:

Albert and Mary Krueger Dale Haskins Pattie Terp Andrew Rice Davon Smith Rick Dodds Augustus Energy Partners II, LLC Dean Gent Rick Tingle Billy Tingle Douglas Pfau Rockies Express Pipeline LLC Bobby Gutierrez Earl Stout Sierra Nelson Boyd Richardson Edward O'Malley Steve and Kim Jordan Bradley Bauer Freddy Sanchez Steve LaBau Bradley Benton Gary Davies Strawberry Creek Outfitters Brandon Sanders Gloria Jones Sullivan Bros Outfitting Brennan Jensen Greg Hanberg The Wilderness Society Brett Bauer Hawk and Shelley Greenway Toby Garcia Candace Collins Jason Powell Todd Lewis Charles Slack Jimmy Jackson Tom Alley Chris White Joe Gutierrez Unknown Individual Clay Springer Kristi Wilson Vannoy Ranch LLC Parks and Wildlife Leslie Sorensen W. Ray Barnes Colorado Wild Public Lands Melanie McKee White River Conservation District Conservation Colorado Michael Munch William Loftus

DOI-BLM-CO-N05-2017-0009-EA_Scoping Comments 1 ISSUES The BLM identified the following issues and questions from the scoping comments submitted by the public which will be addressed in the environmental assessment. (The public will have the opportunity to review and comment on the preliminary environmental assessment in the fall of 2017.)

Land Exchange Process

 Is it appropriate for private landowners to benefit from a trade involving public lands?

 Why does the BLM consider isolated Federal parcels difficult to manage?

 Will the BLM consider non-monetary values (such as recreational experiences and wildlife habitat) when evaluating the values of the parcels included in the exchange?

 Does the exchange proposal include a conservation easement to protect wildlife habitat on the Federal parcels that may become private property?

 Will the appraisals be made available for public review before the exchange is finalized?

 Has the BLM been able to contact all potential affected interests (mineral estate owners and lessees)? Lands and Realty

 How would the exchange affect the Vannoy Ranch’s use of a road across public land to access other portions of their private property?

 How would adjacent landowners be affected by existing fences that follow topographic features (such as ridgelines) rather than property boundaries? (See also Livestock Grazing)

 How would the exchange affect land status within Rio Blanco and Moffat counties?

 Would the BLM consider selling the isolated parcels (either to Buffalo Horn or other adjacent landowners) rather than including them in the exchange?

 Will the BLM honor all the terms, conditions, and access rights granted by existing pipeline easements and document the existence of the easements on the BLM’s Master Title Plat and Historical Index? Recreation

 Would disposal of the Federal parcels to Buffalo Horn facilitate the ranch being able to retain elk on private property?

 Would disposal of the Federal parcels to Buffalo Horn result in crowding public land hunters into a small area?

DOI-BLM-CO-N05-2017-0009-EA_Scoping Comments 2  Do the exchange parcels provide unique big game hunting opportunities within Game Management Units 11 and 211 (including opportunities for back-country hunting)?

 Would the exchange result in an increase in trespass hunting on private land southeast of parcel B?

 Is this area proposed to be included as part of the Wagon Wheel OHV Trail System? Wilderness Study Areas

 Would additional public access to the Windy Gulch and Black Mountain Wilderness Study Areas affect the naturalness and solitude of these areas?

 Would the acquisition of parcel B result in the expansion of either the Windy Gulch or Black Mountain WSAs? Access and Transportation

 How would the exchange affect access (by foot, bike, horse, and motorized vehicles) to public lands? Wildlife

 Do the exchange parcels provide unique or important habitat for wildlife (such as elk migration corridors)? Lands with Wilderness Characteristics

 How would the exchange affect inventory and management of lands with wilderness characteristics? Surface and Ground Water Quality

 How would the exchange affect distribution of water available for livestock and wildlife on public and private lands? Geology and Minerals

 How would the exchange affect the Master Surface Use Agreement between Augustus Energy Partners II, LLC regarding surface operations needed to develop leased Federal minerals?

 What affect would the exchange have on future leasing of fluid minerals (oil and gas)?

 How would the exchange affect reclamation requirements for mineral development (both abandoned wells and current/future development)? Livestock Grazing

 How would the exchange affect management of BLM grazing allotments?

DOI-BLM-CO-N05-2017-0009-EA_Scoping Comments 3  How would adjacent landowners be affected by existing fences that follow topographic features (such as ridgelines) rather than property boundaries? (See also Lands and Realty) Socioeconomics

 How would the property values of adjacent landowners be affected by the exchange?

 How would an increase in public access affect private hunting leases?

 What economic impacts associated with hunting and other recreation might be expected from the exchange?

DOI-BLM-CO-N05-2017-0009-EA_Scoping Comments 4

Appendix A – Copies of Scoping Comment Letters

(Note: Mailing addresses, email addresses, and phone numbers have been redacted.)

Heather

I am concerned about the proposed land exchange F-8. This land sets close behind my house and it splits about equal half on my side of the fence and half on Buffalo Horn side. The fence was put on the ridge from my field all the way back to the top of the ridge in the back (about 4 miles or so), not following the property lines because of the terrain being difficult to navigate. I am wondering how this will take place, will Buffalo Horn fence this, if so who will survey this parcel, as of now there are no markers on any of the corners, either side of the fence. There are two deep draws that the fence will have to cross making this task very difficult with a dozer disturbing a lot of area causing erosion that will drain down to my field. The only road access I have to check my fence that separates Buffalo Horn and me goes through this f-8 parcel so how will I be able to check and repair my fence, if I have to have a dozer build me a road around this who will pay for it, not only that but maintaining the road on the side of the hill with erosion being a problem instead of staying on the ridge where the road will last with almost no maintenance. I have been involved with the working of this place for 40 years, the fences and roads are in and look the same now as they did then. I don't think I should have to pay for any of this because Buffalo Horn is the one wanting this not me. Buffalo Horn will have very limited use of the land on my side of the fence because of the two draws they will have to cross with no other access. There are multiple places on the thousands of acres of land that Buffalo Horn borders the B L M where there is not a third party involved.

Thanks Roy Vannoy Vannoy Ranch LLC

2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Proposed Buffalo Horn Land Exchange

WRFO_BHLEX, BLM_CO

Proposed Buffalo Horn Land Exchange 1 message

Joy Boyd Tue, Jan 17, 2017 at 5:34 AM To: [email protected]

My name is Chris White, from West Virginia. I have been hunting in Mountain Area of Colorado for nine years now. I think this land exchange would not benefit the public but would benefit the Buffalo Horn Ranch. I have notices the ranch controlling the elk so that they remain on the ranch, so with more land joining their land now would make it easier for them to do that. I do not agree with this land exchange. I have spent a lot of money with the State of Colorado.

Concerned Non-Resident Hunter,

Chris White

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ac6bb841f0a0c&siml=159ac6bb841f0a0c 1/1

2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo horn land exchange

WRFO_BHLEX, BLM_CO

Buffalo horn land exchange 1 message

Brett Bauer Fri, Jan 20, 2017 at 11:42 PM To: [email protected]

I was very disappointed to hear about the possible land exchange with buffalo horn! I am very much opposed to this deal! First and foremost without my personal interest and bias, the BLM mission is to sustain the health, diversity, and productivity of America's public lands for the use and enjoyment of present and future generations. Simply put This land exchange does not meet that mission! The land would be more difficult if not impossible to access than it currently is! And for this reason alone you should not exchange land!

On a personal note I hunt this land every archery season. It is difficult country to access, and once in you must bring all of your water with you as any close water is private! I have to continuously check GPS in order to obey and respect the private land around me! On more than one occasion I have witnessed buffalo horn driving the elk off of public land back onto private! Very troubling to me as that ranch has thousands and thousands of acres yet they still have to illegally push elk out of the less than 1 square mile I hunt! I actually caught them in the act and exchanged a conversation with the owner Steve who was blowing his cow call like a dying cat while carrying a semiautomatic rifle and not wearing any orange! He said he shouldn't have to where orange on his property! Angry from him ruining my day of hunting I told him he wasn't on his land! To make matters worse the year before I ran into his main lion guide who said he was coming to help track a bear that was shot by a client! That's great except he had dogs with him!!!!!!!! More illegal activity! In short if I've witnessed that much in the last 3 years of hunting weekends only during archery, I can't imagine what else goes on the remainder of the year on the thousands of acres buffalo horn ranch ?!?

Please don't allow this man the priveledge to own any of our public lands!!!!!! Sincerely, Brett Bauer from Georgetown Colorado

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159bfc382da3d0f9&siml=159bfc382da3d0f9 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn Land Exchange Comment - Bradley Bauer

WRFO_BHLEX, BLM_CO

Buffalo Horn Land Exchange Comment ­ Bradley Bauer 1 message

Bradley Bauer Sat, Jan 21, 2017 at 7:54 PM To: "[email protected]"

To Whom It May Concern,

In respect to the Buffalo Horn Land Exchange, I am advocating that the Bureau of Land Management (BLM) not exchange public lands that are contiguous with existing public lands. While I am most concerned with two parcels, I remain adamantly opposed to the prospect of exchanging any public land adjacent to existing public lands. I acknowledge the fact that the BLM is attempting to create easier access to existing public lands; however, one must consider whether or not this is a worthwhile sacrifice of our current public land assets. Considering the value of this prime recreational ground and animal habitat, it is difficult to comprehend why we would consider exchanging such lands in a time when public access in general is on the decline.

From a recreational and primarily hunting perspective, parcels F­5 and E­2 consist of approximately 1,000 acres of prime animal habitat currently accessible inside an over­the­counter (OTC) Game Management Unit for elk hunting. These parcels of land consist of a healthy mixture of native grasses, sage brush, serviceberry, mountain mahogany, pinyon pine, juniper, ponderosa pine, Douglas fir, aspens, and water. Within this abundant habitat exists a healthy population of elk, deer, bear, coyote, cougar, sage grouse, and several other species of mammals, birds, and reptiles. Due to the steep and rugged topography, confined location, and difficult access, parcel F­ 5 is basically an extension of the Windy Gulch WSA. It is in effect non­motorized to the public. While only 240 acres in size, parcel F­5 is both a prime animal habitat and OTC hunting ground. OTC elk habitat of this quality is scarce and very often inaccessible due to private land obstruction. This unique combination of wildlife and habitat characteristics makes this parcel a prime hunting area for those who are motivated to access such country. This land should most certainly not be dismissed as “difficult to access,” as stated in the Scoping of the Proposed Buffalo Horn Land Exchange.

That being said, during the January 5th open house there was heavy emphasis placed upon the increased access to the WSA provided through this land exchange. In particular, the presenter explained how the proposed exchange would create easier access from the southwest boundary of the Windy Gulch WSA, essentially connecting the Windy Gulch and Black Mountain WSAs. After I clarified that there was additional access from the northwest along the Gray Hills ridgeline, she commented that someone would have to be “pretty motivated” to access that country from the northwest along the Gray Hills. She was very accurate with her assessment of my comment. Not only would one have to be motivated, but he or she would have to possess the physical and mental fortitude, as well as the discipline to navigate and hunt that country with the potential of harvesting and packing out an animal. This is a special place to hunt because there are few prepared and willing to hunt this country. For those who are, OTC hunting ground like this in Northwest CO is rare. https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159c4190f98b33d2&siml=159c4190f98b33d2 1/3 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn Land Exchange Comment - Bradley Bauer

Those familiar with the topography within the public-private boundaries between parcels F-5 and E-2 and the Buffalo Horn Ranch understand why the Gray Hills ridgeline is so valuable to hunting elk. Public hunting pressure originates from the south and west, thus pushing elk high into the upper reaches of the Gray Hills. Water is scarce in this country, with the majority of it located on private land. In addition to human pressure, the elk migrate over the Gray Hills and into the Strawberry drainage to access water. There is no water within the boundaries of the Windy Gulch WSA and there are only a few springs located on surrounding BLM land, all of which are near motorized vehicle access roads. Parcel F-5 possesses multiple options for water, as well as quality bedding, feeding, and rutting ground for elk and other animals. Due to the steep topography along the Gray Hills ridgeline, the elk essentially push over the top into lower grounds in response to human pressure and weather patterns. Outside of parcel F-5, the vast majority of these grounds are private (currently held by the Buffalo Horn Ranch). This unique combination of man and nature creates a refuge for elk to exist while their basic needs are met, but still on public land. Parcels F-5 and E-2 are two of a very few areas in NW CO that reward motivated, OTC public land hunters with a quality, low pressure elk hunt. If the BLM were to exchange these parcels of land, the Gray Hills ridgeline would become the new boundary and exclude the public land, do-it-yourself hunter, from access to any game species below the ridge to the northwest.

Considering the value of these public lands, why would we exchange such a remote piece of public land so rich in wildlife and recreational resources for land that is motorized and/or easily accessible? Moreover, regardless of whether or not the exchange happens, the Buffalo Horn Ranch will simply use it as they always have, which is for grazing and hunting. If the exchange comes to fruition, the Buffalo Horn Ranch would essentially gain more of what it already has, while the public would lose something of which they have very little.

In summary, I reflect upon the conversations among local citizens on January 5th at the open house. Outfitters, ranchers, landowners, concerned citizens, and BLM officers discussed the different land parcels involved in the exchange. One of the topics of conversation surrounded the determination of land value as the parcels involved have been set based upon monetary value. As I listened I heard the obvious characteristics usually associated with land value (such as agriculture, natural resources, outfitting, and access), but I was hesitant to discuss the value of this prime ground to hunters like me and for obvious reasons. But as we talked, it became more obvious that this would be an important conversation to have, as the BLM officers appeared empathetic to our concerns. So after discussing some of the characteristics that make these parcels important to me, it became very clear that a monetary value cannot be placed on many of the public land parcels involved in this exchange. This land, in fact, is truly priceless.

I ask that you consider my combination of both fact and opinion during your decision-making process. If it any time you would like clarification, please feel free to contact me. I am more than willing to discuss my thoughts with those involved.

Sincerely,

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159c4190f98b33d2&siml=159c4190f98b33d2 2/3 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn Land Exchange Comment - Bradley Bauer Bradley Bauer

Meeker, CO

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159c4190f98b33d2&siml=159c4190f98b33d2 3/3 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Response to Buffalo Horn Land Exchange

WRFO_BHLEX, BLM_CO

Response to Buffalo Horn Land Exchange 1 message

Casey Sullivan Sat, Jan 21, 2017 at 7:27 PM To: [email protected]

Attached is a letter in regards to the Buffalo Horn land exchange.

Thank you for your consideration,

Casey Sullivan Sullivan Bros. Outfitting

Visit us at: www.sullivanbrosoutfitting.com

blm land exchange.pdf 30K

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159c40110dfd32e5&siml=159c40110dfd32e5 1/1 Sullivan Bros. Outfitting

Grand Junction, Colorado 81506 January 19, 2017

Bureau of Land Management White River Field Office/Land Exchange Comments 220 East Market Street Meeker, Colorado 81641

RE: Proposed Buffalo Horn Land Exchange

This letter is intended to express issues/concerns regarding the BLM land exchange with Buffalo Horn Ranch. My brothers and I operate Sullivan Bros. Outfitting and have three concerns AGAINST the land exchange nearing leased hunting grounds used during the big game archery and rifle seasons.

1.) The increase of public access encroaching on private hunting leases, thus diminishing the quality of hunting in the area. 2.) The possibility of this area becoming part of the Wagon Wheel Trail system again hindering and negatively impacting the quality of hunting in the area. 3.) Increase in illegal trespass hunting on private land leases Southeast of parcel B.

Sullivan Bros. Outfitting has prided itself on offering quality hunts to a number of hunters looking to avoid overly populated areas to hunt. Our thoughts are that this land swap could negatively impact business and the quality of hunting in this area and is of significant concern to ourselves and our business.

Sincerely,

Casey, Joe, and Bradley Sullivan 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn Land Exchange Comment

WRFO_BHLEX, BLM_CO

Buffalo Horn Land Exchange Comment 1 message

Brennan Jensen Sun, Jan 22, 2017 at 8:32 PM To: [email protected]

Dear BLM,

I am a 15 year old outdoorsman living in Meeker, Colorado. I am writing this letter because I believe the BLM should not trade parcel F-5 to the Buffalo Horn Ranch. This hunting area is a high quality experience for elk hunting. I killed my first bull elk with a muzzleloader in parcel F-5. We actually hunted many bulls that morning before calling my bull in to close range. It was a rewarding experience because I had to put forth so much effort into this hunt. I had to drive a four wheeler 17 miles and then carry a backpack another 3 miles with all of the necessities required to hunt for 3 days in the mountains. I had to pack 15 lbs. of water because Windy Gulch WSA does not have any water. Once we set up camp, we did not have to worry about seeing other hunters because this spot is so remote. It is also extremely beautiful. This was an experience that many hunters and kids will not have if we make this trade. The value of this land is much more than the other land we would get just for increased access. I believe we should do our best to keep remote hunting places for the true outdoorsmen and save my honey hole, which is maybe no longer my honey hole because I had to write this letter.

Thank you,

Brennan Jensen

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159c96186872fb8f&siml=159c96186872fb8f 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn Ranch Land Exchange

WRFO_BHLEX, BLM_CO

Buffalo Horn Ranch Land Exchange 1 message

Todd > Sun, Jan 22, 2017 at 7:01 PM To: "[email protected]"

To Whom It May Concern,

Before trading parcels of continuous public land in order to create greater access to surrounding public land, I ask that you consider the recreational value of parcels F-5 and E-2, among other public land parcels included in the proposed Buffalo Horn Land Exchange. These are quality hunting grounds located within an over-the-counter hunting elk game management unit. Parcel F-5 is difficult to access, and therefore helps to preserve a quality hunting opportunity for hunters motivated to pursue a backcountry hunting experience along the Gray Hills and in the Windy Gulch WSA. Parcel F-5, due to its topographical location and position adjacent to private land, is essentially part of the Windy Gulch WSA. Parcel E-2 offers some of the same characteristics as F-5, but with easier access. If we were to lose these parcels (and others similar in nature), we would continue to limit hunting experiences for motivated hunters interested in getting away from motorized traffic and human pressure. Considering the challenges involved with public access to quality hunting grounds, I cannot comprehend why we would consider trading these parcels. Please do not include these parcels in the Buffalo Horn Land Exchange, as this would limit public access to quality hunting while increasing the private landowner’s monopoly on such experiences.

Thank you,

Todd Lewis Meeker, CO

Sent from my iPhone

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159c90e76f737fb6&siml=159c90e76f737fb6 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo horn land transfer

WRFO_BHLEX, BLM_CO

Buffalo horn land transfer 1 message

Andy Rice Sun, Jan 22, 2017 at 3:38 PM To: [email protected]

Dear Heather,

Thank you for your efforts in putting the presentation regarding the buffalo horn land swap together. Your maps and information were clear and understandable. I felt like a valued Share holder, which I appreciate.

All things considered, I support the transfer. I believe that adding consolidated wildlife habitat absolutely justifies giving up the several small pieces already under BLM management.

I must tell you that I have serious concerns regarding the possible increase in easy access to Windy Gulch WSA. I regularly use Windy Gulch for hunting and hiking. I enjoy Windy Gulch because the deer and elk population is largely undisturbed, which makes for excellent wildlife viewing opportunities. I attribute the lack of wildlife disturbance in Windy Gulch to the current lack of motor vehicle access.

Wildlife is my passion. I spend 100% of my free time, looking for, watching, photographing, and hunting elk, deer, and bear in NW Colorado, and I do these activities exclusively on BLM lands. I choose to travel by foot, rather than atv, when engaging in these activities. I do this because so few people walk anymore and I enjoy the solitude I find in nature, and because wildlife viewing opportunities increase when a person travels quietly.

There are too few BLM parcels where people in my position can go, assured that a tough hike will not prove unproductive, because of atv traffic. WSA's, like Windy Gulch, are some of the only places left in NW Colorado where foot hikers can travel more than a mile or two between atv trails.

There is a road on the buffalo horn parcel bordering the Windy Gulch WSA, which would allow top-down access to Windy Gulch, if atv's were allowed to use it. In my opinion, that type of access would increase use by for-profit antler hunting, and "road hunting" during rifle big game hunting seasons. I'm afraid that if this increased access is allowed, the sanctuary qualities of Windy Gulch would be lost.

I implore you, should the transfer occur, to consider the fact that the parcel butts up against non-vehicular access areas, and extend that protection to the new parcel. Please designate parcel "b" as a walk in area.

Thank you for taking the time to read my request, I hope that I have successfully conveyed the importance this issue carries for me. Sincerely,

Andrew Rice.

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159c855573546373&siml=159c855573546373 1/2 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo horn land transfer

Sent from my iPhone

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159c855573546373&siml=159c855573546373 2/2 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo horn-BLM land exchange

WRFO_BHLEX, BLM_CO

Buffalo horn­BLM land exchange 1 message

brandon sanders Sun, Jan 22, 2017 at 10:31 PM To: [email protected]

To whom it may concern:

I am writing in response to the proposed land exchange by the BLM with the Buffalo Horn Ranch in Rio Blanco and Moffat County. I oppose exchanging the E2 parcel which is currently BLM land. I have been hunting this parcel specifically every year, multip[le times a year, for the past seven years. In my experience these draws are the most productive lands in the whole area for elk hunting. Most of the time the elk will come and bed in these draws and rarely cross the road that runs along the top of the ridge. If E2 was exchanged the public would lose out big time. The elk would end up hanging in those draws with no pressure to cause them to leave. I have spent many hours on these ridges and much time harvesting elk out of these public land draws. I have also spent time with family and friends in the summer time up in the area for the views. I understand the main road up on top would stay public even if the exchange went through but it would change the whole dynamics of the area. Most people would not choose to travel all the way back there for recreation to be surrounded by private land. I do not see any land that the public would get that would outweigh the cost of giving up this parcel. It was my understanding that the area in E2 was one of the driving factors for the CPW to purchase the land for the Colorow State Wildlife Area in order to make better access to those ridges for recreation. So giving that away would undo a lot of what CPW did. Once again I think it would be a mistake for the BLM to exchange the E2 area that is heavily used by the public.

It makes sense to give up the isolated pieces of BLM that the public can't access (D4, F8, F2, etc.). If I had to choose between the public getting A3, A5, or B, I would definitely choose B. Parcel B would open up a lot more land for hiking, hunting that are currently difficult to get to for the public. But I would want to keep it a walk in area only. If there are roads put in there that the public can access than the elk and deer will be pressured out of the entire area to private lands. A-5 would be better than A3 as far as hunting goes for the public due to the terrain and types of cover.

Once again my main concern is exchanging the E2 parcel. If the rest of the exchanges do or don't go through they will not impact the area as much as as the public losing the E2 parcel. Thank you for your time and seeking the Public's input on this matter.

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159c9ce8cc05d373&siml=159c9ce8cc05d373 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - (no subject)

WRFO_BHLEX, BLM_CO

(no subject) 1 message

Benton, Bradley < Mon, Jan 23, 2017 at 8:43 PM To: "[email protected]"

To Whom it May Concern,

I am writing in regards to the proposed land swap with Buffalo Horn Ranch. I do not agree that this should take place and I also believe it is not in the best interest of the public.

Thanks,

Bradley Benton Salesman Helena Chemical Company

Holly Grove, Ar. 72069 Cell Office

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ce92b8cefa618&siml=159ce92b8cefa618 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn Land Exchange Comments

WRFO_BHLEX, BLM_CO

Buffalo Horn Land Exchange Comments 1 message

White River Conservation District Mon, Jan 23, 2017 at 11:43 AM To: [email protected]

Good morning,

Please see the attached comments regarding the Buffalo Horn Land Exchange submitted by the White River Conservation District.

Thank you,

Chris Colflesh District Manager

Meeker, CO 81641

Buffalo Horn Land Exchange Comments.pdf 357K

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159cca4fffe0ab56&siml=159cca4fffe0ab56 1/1

Promoting the wise use of all natural resources

January 23, 2017

Bureau of Land Management White River Field Office 220 East Market Street Meeker, CO 81641

Re: Proposed Buffalo Horn Land Exchange

To Whom it may concern,

After reviewing the proposed Buffalo Horn Land Exchange Proposal, the White River Conservation District would like to submit the following comments.

The White River Conservation District in cooperation with the Douglas Creek Conservation District and Rio Blanco County developed the Land and Natural Resources Plan and Policies for Rio Blanco County (Plan). The Plan was developed to ensure that the socioeconomic wellbeing, the culture and customs of the constituents, and natural resource health are considered in federal decisions. The BLM is required to consider this Plan under NEPA and FLPMA. The Land Use Planning and Legal Framework can be found on page 3 in Section 2 of the Plan. A copy of the plan can be found on our website at www.whiterivercd.com.

The proposed exchange will provide for a net gain of approximately 2,000 +/- acres in Federal Land within Rio Blanco County. The Land and Natural Resources Plan and Policies for Rio Blanco County states in Section 4.1: County History, Custom, and Culture, Policy Statement 1, “Support no net gain of federal lands.” A solution that could address this issue is to not exchange properties, however sell to Buffalo Horn the isolated parcels of BLM located within Rio Blanco County that are land locked by Buffalo Horn private property. A secondary solution that could address this issue is to exchange parcels equal in acreage that provide for no net gains of federal lands in Rio Blanco County.

Additionally, the proposed land exchange includes a parcel labeled as “B” located in between the Black Mountain and Windy Gulch WSA’s. The District has concern that this parcel, if the exchange takes place will be included into the WSA’s, or be designated as Lands with Wilderness Characteristics (LWC). We do understand that a local field office cannot designate land into a WSA, it takes Congressional action, however local field offices do have the authority to designate LWC’s. A solution to this issue could be urge Congress to release the Black Mountain and Windy Gulch WSA’s from consideration as they do not fit the criteria as wilderness. Both WSA’s contain roads as shown on BLM maps. The Land and Natural Resources Plan and Policies for Rio Blanco County states in Section 4.10: Special Designation Areas (Wilderness Areas, Wilderness Study Areas, Lands with Wilderness Characteristics ACECs), and Scenic Byways/Viewshed, Policy Statement number 4 states, “Remove or release all WSAs from consideration that contain non-wilderness characteristics, such as roads or active oil/gas wells.”

– Meeker, CO 81641 – Phone

Promoting the wise use of all natural resources

Thank you for the opportunity to provide comment.

Sincerely,

Neil J Brennan, President White River Conservation District

– Meeker, CO 81641 – Phone

2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Fwd: Land exchange with Buffalo Horn Ranch-Meeker Colorado

WRFO_BHLEX, BLM_CO

Fwd: Land exchange with Buffalo Horn Ranch­Meeker Colorado 1 message

Candace Collins Mon, Jan 23, 2017 at 8:57 PM To: [email protected]

------Forwarded message ------From: "Candace Collins" Date: Jan 23, 2017 9:53 PM Subject: Land exchange with Buffalo Horn Ranch-Meeker Colorado To: Cc:

Your trade with Buffalo Horn Ranch is only beneficial to one side and that is NOT the public.

What good comes from this land trade for the public? Its my understanding that that ranch owner already owns a substantial amount of ground, so what is the benefit to the public from this land swap?!

No good comes from a governmental agency and a wealthy land owner crawling into bed together.

Rethink your decision. Do what is right for many, not few.

Sincerely, Candace Collins

Sent from my Verizon Wireless 4G LTE DROID

Your trade with Buffalo Horn Ranch is only beneficial to one side and that is NOT the public.

What good comes from this land trade for the public? Its my understanding that that ranch owner already owns a substantial amount of ground, so what is the benefit to the public from this land swap?!

No good comes from a governmental agency and a wealthy land owner crawling into bed together.

Rethink your decision. Do what is right for many, not few.

Sincerely, Candace Collins

Sent from my Verizon Wireless 4G LTE DROID

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ce9ef473d6e1f&siml=159ce9ef473d6e1f 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Ranch

WRFO_BHLEX, BLM_CO

Buffalo Ranch 1 message

Gary Davies Mon, Jan 23, 2017 at 10:22 PM To: [email protected]

To whom it concern,

It is not in the publics best interest for the Bureau of Land Management and the Buffalo Horn to make this land exchange.

Sincerely, Gary Davies

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ceed835f81d6c&siml=159ceed835f81d6c 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn Land Exchange

WRFO_BHLEX, BLM_CO

Buffalo Horn Land Exchange 1 message

Rick Dodds Mon, Jan 23, 2017 at 8:05 PM To: [email protected]

I do not feel it is in the publics best interest for the Blm to exchange land/land swap with the Buffalo Horn Ranch.

The only winners in this event would be the Buffalo Horn Ranch. Pristine land would be lost and this will give more control to a ranch that already owns most of the north Strawberry Creek area anyway. This is not good for the public in any way or form.

Rick Dodds

Meeker, CO 81641

Sent from my iPhone

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WRFO_BHLEX, BLM_CO

BLM Buffalo Horn Land Exchange Scoping comments 1 message

Blue Heron Forge < Mon, Jan 23, 2017 at 2:06 PM To: [email protected] Cc: Hawk and Shelley , , Doris and Chuck Downey

Dear BLM/ WRFO,

This is a set of scoping Comments asking the BLM to address several issues and to extend scoping period to a time when the public can inspect the lands in question in accessible non-winter conditions.

Thank you,

Franz C. Froelicher jr

Colorado Wild Public Lands

Basalt CO 81621

Dear BLM.docx 32K

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159cd28aee1bfc7f&siml=159cd28aee1bfc7f 1/1 BLM WRFO,

Land Exchange Comments,

220 East Market St.

Meeker, CO. 816411

From; Colorado Wild Public Lands, , Basalt CO.81621

Dear BLM,

Thank you for hosting the evening presentation of the Buffalo Horn Land Exchange. We are impressed with the amount work that has taken place between 2008 and the present, 2017. As a public lands advocates with nearly a decade experience specifically in proponent Driven Land Exchanges we would like to submit the following scoping comments regarding both the process and then the specific details of this exchange that we believe are good or are areas of concern.

Public lands have support of Governor Hickenlooper and all of the state’s recreational industries that support this multi-billion dollar economy. The first State Public lands Day will be celebrated in May and the comments for keeping public lands public are demonstrated on that web site; https://outdoorindustry.org/article/colorados-public-lands-day-bill-recognizes-the-value-of-the- outdoors/. We respectfully submit this link to show the importance of public lands to Coloradoans.

We were pleasantly surprised that both your agency and you personally have recognized the importance of lesser known and traveled public places. The tendency has been to write –off these areas with the often abused phrases that accompany almost all proponent driven land exchanges, moving them forward past reasonable objections. These are the same phrases that tender public land as “ …of little or no public use” along with the phrase ” has little or no public access” and the conclusion therefore the lands are “of little public value”. These are the three relevant topics that are which key in determining if an exchange is truly in the interest of the Public. Solution: describe to the public and define ‘value for value’ for each element of the exchange. Specify and include economic and intrinsic parameters for each parcel before the exchange presentation starts. Help the public understand these values and parameters for each habitat type.

Please include the DPW and public interest agencies such as Outdoor Alliance and Colorado Wild Public Lands in these early discussions. There should be a panel of professionals that the governor might appoint to advocate for the public interest. This is important as the BLM is charged to remain neutral in its assessment, valuations and presentations and decisions according to the GAO report GAO-09-611. Without a non- government publics advocate presence, it is difficult to both remain neutral and also carry the executive determination in the Public’s best interest. The report sites pressure on staff to get exchanges completed more rapidly especially when the nongovernment party if paying 50 % or more of the process a costs as you mentioned was the case in this exchange. There needs to be many more inputs, checks and balances than exists in the present process and it needs to be public.

We commend you on your presentation but noticed there were no alternative proposals on the table for public review; we believe that should be part of the process.

Appraisal methods;

As you carefully stated at the presentation, in many cases it is those less used places that are the gold of public lands and waters. However, systemically the appraisal methods used have incorporated little or no value for short term or long term economic recreational uses, habitat values, and wildlife considerations that are key economic drivers in Colorado. Solution; Again The public or a public review board needs to see the balance ledger on these issues for each parcel before or at the time of presentation, but well before any proposal finishes the scoping phase. That should include an appraiser who has much experience in land exchanges of all types. The same lengthy GAO report establishes that appraisals need updating every three years and that qualified appraisers often unavailable.

Appraisal values:

In this case any minimally appraised agriculture value ignores these economic drivers. Without an enhanced economic value for habitat under federal protection, selling or trading these isolated parcels would not be in the public interest. Solution; add appraisal values in coordination with the DPW and specialized appraisers to demonstrate the missing valuations. Show the public how these values are reached. The appraisal system of land exchange is flawed and has been called out by the GOA, also in that report. There can be discrepancies in the tens of millions without resolution. Appraisal systems for habitat and wild life values need to be included as part of the overall economic values for the public interest to be fair.

Easements analyses of protections pros and cons/ measuring public benefit;

Public lands under federal protection still need a value for that federally protected habitat; they are worth something- vs private ownership which could be good or bad depending on a) if there is an easement, b) if the easement language is legally sufficient to protect the habitat its suppose to protect , c) If there is no easement to protect habitat… delineate a potential cost to habitat condition, loss of wild life and overall economic repercussions to and recreational industries. d) Will it be developed? If there is an easement and it does protect habitat and enhance wildlife, who are the beneficiaries? Does the public loose or gain? Does the overall land acquisition create a ’refuge effect’ such that winter vegetation gets clobbered before winter and thus leave wildlife in a compromised state. Will the owner allow some public or not. If so what is that worth and who benefits? What is the public benefit?

At the micro input level- solution; for example at habitat modeling indices for many species can give a value for each habitat component and its collective impact on the total species needs for sustainability.. Easements need to be reviewed by a public advocate if not posted for review on your web site.

Who pays for the trade?

Full disclosure of all participating relationships is required for any exchanges where third party facilitators are acting, but is missing in cases where it appears to be a negotiation between a lone land owner and the BLM only. This is of public interest so we know that there are no other beneficiaries affecting the negotiation and as a matter of transparency.

A huge injustice to the public in many land exchanges is how a private owner can increase the value of his or her estate with the exchange then place an easement on the land which is paid for in the form of a tax break. The valuation for that easement is typically for the whole parcel not just the lands exchanged. That can happen as part of the trade or years after the land is traded without public scrutiny. This should be a required disclosure on any contract signed for the public. If the Public already owns accessible land before the trade, it’s protected under federal rules and there’s no reason to trade it away. The owner can receive a calculated and large tax credit in the millions of dollars. That might work in some circles but one can’t ignore that the owner has acquired public lands which were protected from development under BLM/ Federal regulations, and is now asking that since they are private lands – with newly granted development potential-you the public can to pay for not developing the same lands.

In essence this is having the public pay to give away their own lands and never set foot on them again.

Solution: Full disclosure should be mandatory for easements. They need to written into or out of any agreement the owner makes in the exchange and that needs careful review by a public advocate with the appropriate easement /appraisal experience.

What are the economic gains and losses, as it relates to hunting and non-hunting recreation in the area? The public needs to see a value placed on each and every recreational use as well as the intrinsic value of the activity. Solution; illustrate these values so they can be publically reviewed or there is no public interest that can be discerned. Appoint a public board for all land exchanges to review values so they can inform the public. No closed door meetings, transparency is key! This is not a job for the State Land Board as it needs a different level of scrutiny with the public estate held in the highest regard. Again the recreation industry is a huge economic driver in Colorado and appraisal values need to consider this against all other scenarios.

Scoping process;

You mentioned the process started in 2008 stopped, then restarted in 2011, then went forward for two more years until 2013 with the “final exchange plan”. This seems like plenty of time to have had a public review of parcel values and comparisons yet we are just hearing about this in the last two months with a very short window to evaluate the properties and their economic gains/ losses. Again without knowing these specifics how is the public interest reviewed or served? Public scoping needs to be added to inspect sites in accessible non-winter conditions.

The Exchange outreach materials also need to incorporate a spread sheet of the sum of values mentioned above, along with a presentation from the DPW perspective and an involved public advocate. While the BLM worked under its guidelines in a neutral position there is a need for a report column with current uses estimated for each parcel. For example; D-3 and F-5 have access labeled as “difficult” .We request that as a matter of all land exchanges the access factors should be very clear, such as; this is accessible on foot , horse , bike, other… and then distances to the nearest edge of each parcel in question from any road. This allows the public a better window for input without biasing the scoping reports with words such as “difficult”. Current uses should be next to the access description for analysis.

BLM outreach and contact to Public before and during the scoping period;

The BLM spoke at the meeting about public involvement being “low”. Our meeting attendees asked if the BLM had contacted the DPW for a list of hunter users and likewise for other recreational user groups for those areas but it had not been done before the scoping. Solution; The scoping period needs public input and needs to be extended until July 2018 so all user groups can be contacted and there is a spring / summer window for first hand inspection of these parcels. IF the users are not identified and contacted then how would they know to send input? The outreach material was good but currently the contact base is too narrow to determine public use and interest. In this age of media it is not too difficult and should be required to make these contacts.

Who is notified is critical to reasonable and significant public input. We ask that scoping period be substantially extended in order for the contacts to be made. Public access during scoping;

The lands in question should be accessible to the public for personal site visits for three seasons before the scoping phase. The Scoping Phase needs to be extended until these minimum criteria are met. How would the public interest be preserved and how would the public know about these lands without time to see them. Solution; Again there is a need to extend the scoping phase to visit these parcels.

A-5 parcel

The A-5 parcel appears to be a major part of the exchange, 1921 acres or close to 50% of the total exchange. It has no restrictions to protect habitat, and has no plan that we noticed to rehabilitate the land for any specific wild life species. We think this is not in the public interest if a major part of the exchange does not include agreements for land reclamation, grouse habitat rehabilitation, and a plan for specific funding those costs. We can agree that it has potential! But what happens to mineral development leases and the many abandoned wells? These need to be addressed in the exchange document.

E-2 Parcel and F-5 Parcel

The E-2 parcel and F-5 parcel we were told have very good big game hunting in the fall and are one of the few places that hold water for the wildlife. In this value to value exchange scenario where are these valuable hunting areas replaced? Where are the water concerns? Losing these areas without similar replacement and benefit is not in the public interest. Solution; same as A-5.

A-3

The A-3 parcel is part of a much larger public area and we cannot discern if there is a sage grouse population that would be served here without increased protections/restrictions. Without DPW input and land condition report it is not possible to see the benefit. If the land is poor condition for sage grouse, deer, antelope o and elk, what habitat rehabilitation plans would you put in place if any and how is that protected? Solution; reporting, clarity of values, economic and wildlife habitat analysis for public to see, DPW presentation, increased scoping.

B parcel.

The B parcel needs explanation and should also require the DPW explain why this is a high priority and why it is critical to the overall picture. We cannot visit this parcel before scoping concludes and have no way to evaluate it seriously. Its wildlife values and public interest may not balance well against the lands going off the Federal register. While it was mentioned as high priority at the meeting, there are no notes in the scoping proposal handout ‘note column’ that explain how valuable this is to DPW or wildlife and what calculations were used to arrive with the finding.

Need for Parcel Consolidation defined, General;

Areas that are completely surrounded with absolutely no access still have public value under the protections afforded public lands vs private. Finding ‘value for value’ requires that at least the same protections will exist for exchanged habitat. Thus an easement or at least a written agreement needs to be held, otherwise there is no specific public or wildlife value in place.

Consolidation for management vs consolidation for trespass violations

The isolated “F- D and C-2” parcels need to be given values for their current land use and potential habitat value with protections. These need to be separated in the proposal for scrutiny. Often there is only one smaller area that gets repeated attention for trespass issues and that initiates the large sweeping public land estate changes proposed by private land holders as a solution to an isolated problem. This is not in the public interest. Solution: Fencing and posting can easily solve most issues for trespass.

Consolidation values defined for each parcel.

For each parcel to be “consolidated” specify issue and pros and cons of privatizing.

It may be land locked and hold no access but will it be protected as private land or will it be lost habitat to wildlife? Will it be grazed past recovery or built on? Without easements in place nothing is guaranteed about those parcels.

Access;

- Refuse to use the term’ little or no access’ it either has access or it doesn’t.

--If it has accesses delineate where and for what uses and give it a dollar value for those uses and for habitat.

- If it has no access at all then delineate the cost of management values for comparison i.e. if it’s currently grazed under federal management and rules and no one else but the adjacent land manager has access, then management is one phone call and one or two visits a year to access the parcel condition at very little cost. It can be managed under federal rules that protect valuable or critical wildlife habitat easily. When a parcel becomes private there is a potential loss of habitat thus loss of wildlife at the whims of an owner. The future use needs to be clarified to the public and written into the final agreement.

In closing please accept the above scoping comments. We agree that many hard to get to places are the ones that an uncle tells a nephew about or a place where a parent takes his/her son or daughter to know and regard as a treasure. Some or many of these areas are relatively undiscovered and will be for future generations, but is up to the governing agencies and land stewards looking out for the public estate and valuing those places not to trade or sell them based on errors in processing or a current snapshot of use patterns or economic values that have been systematically excluded from appraisals. There needs to be tenure plan for future use to guide these decisions according to the Government Accountability reports.

Some public lands of course are treasures throughout such as many river and canyon stretches of the White, Yampa, Green and Colorado. But many are smaller and take some effort to get to. Those places are increasingly rare. These lands and values should not be diminished as they have great value to many!

Sincerely

Francis Froelicher

For Colorado Wild Public Lands 501-c-3, Basalt Co. 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Re: BLM Buffalo Horn Land Exchange Scoping comments

WRFO_BHLEX, BLM_CO

Re: BLM Buffalo Horn Land Exchange Scoping comments 1 message

Hawk and Shelley > Mon, Jan 23, 2017 at 4:54 PM To: Blue Heron Forge Cc: [email protected], Annie Rickenbaugh , Jean Perry , Doris and Chuck Downey

Please see the attached document concerning the Buffalo Horn Land Exchange

On Mon, Jan 23, 2017 at 2:06 PM, Blue Heron Forge wrote:

Dear BLM/ WRFO,

This is a set of scoping Comments asking the BLM to address several issues and to extend scoping period to a time when the public can inspect the lands in question in accessible non-winter conditions.

Thank you,

Franz C. Froelicher jr

Colorado Wild Public Lands

PO box 590

Basalt CO 81621

970 963 1735 h

Buffalohornexchangecomment-hawkgreenway.doc 30K

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159cdc24528f6ce9&siml=159cdc24528f6ce9 1/1 Hawk Greenway Aspen Colorado 81612

BLM WRFO, Land Exchange Comments, 220 East Market St. Meeker, CO. 816411 From; Colorado Wild Public Lands, , Basalt CO.81621

Dear BLM,

I would like to comment on the Buffalo Horn Land Exchange.

1. Parcel A5 is encumbered by roar right of way easements and/or is subject to privately leased mineral extraction agreements. Will these be extinguished prior to the exchange or will the federal government accept parcels so encumbered? I am not sure the existing, abandoned wells have been adequately cleaned up, would be subject to re-opening with improved drilling technology (fracking?), or what. What public purpose is there in accepting pre-drilled industrial lands in need of management, particularly if they are subject to such encumbrances? 2. Parcel F5 is wonderfully illustrative of the access issue which so well defined at the public presentation. Namely, that it has ACCESS. According to at least one local user, it is the only wildlife accessible water source in the entire adjacent windy gulch wilderness study area, and as such is an incredibly valuable, integral part of that public landscape. The definition of access, particularly in Western Colorado where hunting is such a huge part of the public tradition, is telling. Many hunters use non-motorized means of access, whether it is on foot or horseback. As should be obvious, many hunters are very motivated to get beyond the crowds, and many game animals are only reliably found distant from roads, jeeps, and four wheelers. By allowing the definition of ACCESS to include foot and horse traffic, and given it’s water, any justification for trading away the parcel A5 as of no or little value to the public evaporates. This parcel should not be a part of the exchange. 3. Parcel E- 2. Because this parcel is adjacent to, and a part of a very large block of public lands which the Colorado Department of Parks and Wildlife have just completed a large lands purchase, fundamentally changing public access and uses, long after the land exchange was contemplated, it should NOT be included in this land exchange. 4. Parcel G. This was cited at the public lands meeting as a very high quality sage grouse habitat, without public access as it is landlocked. While the sage grouse narrowly avoided federal listing, it is still an important species. The BLM has the option of encumbering trade lands with restrictive easements, allowing the land to enter into the exchange while protecting the wildlife habitat. Such an easement could be held by a third party, such as the Nature Conservancy, or the Colorado Cattleman’s Association. Without such protections the parcel should stay in federal ownership. 5. Appraisals. The proposed land exchange appraisals should be made public before the exchange is finalized with an adequate timeline for public review. 6. The lands going to the private party from the public estate would become subject to development pressures unknown for the federal lands, creating value simply by dint of their new status as private property. Any proffered conservation easement to protect wildlife habitat, sage grouse or elk and deer, should be placed on the properties prior to the transfer taking place to avoid the issue of windfall profits be taken. For example, under federal ownership parcel G has wonderful sagegrouse habitat, subject to little more than grazing pressure. Upon exchange it is subject to any number of development scenarios. The BLM conclude that management of a 40 acre isolated tract is more difficult, yet desire the habitat to be protected. If they hold an easement on the property, it is protected at little cost to the public. If they desire the new owner to donate an easement on the parcel, it COULD become a tax donation, costing the public the value of the donated development rights. In essence, the public would be paying to have their lands taken away from them. Require an easement protecting the habitat, and the “Quid Pro Quo” rule would ensure that no inadvertent tax benefit transferred with the property. It is essential to the potential tax deductibility/ windfall profits problem that the language and timing of held easement rights surrounding any land transfer be very carefully handled. 7. Timing and publication of the comment period. Is this exchange, after so many years, now on a “fast track”? What is the purpose of holding the comment period, and public house, over the holidays and in midwinter? Please extend the comment period, and post notifications, on the parcels involved, through at least ONE full hunting season. Colorado’s economy depends in great part upon out of state hunters, American citizens who OWN these lands in question, and to contemplate giving them away without actually getting comments from them is just not right. Use the CPW databases to identify and contact hunters who use the area. Post signs and or interview them on the ground. Legal notices in local papers may meet a legal definition of “Public Notice” but I assure you that out of state hunters will not be reading the legal notices from afar.

Thank you for the opportunity to comment. I look forward to following this proposal through its next stages.

Sincerely, Hawk Greenway 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn Land Exchange

WRFO_BHLEX, BLM_CO

Buffalo Horn Land Exchange 1 message

Toby Garcia Mon, Jan 23, 2017 at 7:19 PM To: "[email protected]"

I am writing against the the land exchange that Buffalo Horn wants to complete. It is a far better deal for the ranch than for the public and that ranch already controls most everything out that way! Please do not allow the land exchange to go through as it is proposed at this time. Thanks Toby Garcia Meeker CO

Sent from my iPhone

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WRFO_BHLEX, BLM_CO

buffalo horn land exchange 1 message

Joe Gutierrez Mon, Jan 23, 2017 at 10:37 PM To: [email protected]

To whom it may concern , I do not believe the land exchange is in the best interest of the public for several reasons . One is the accesses to the wilderness study areas will defeat the whole purpose of having them in the first place . By building a road and parking area will increase noise traffic and more area that will need to be patrolled by a already understaffed BLM , Sheriff and Parks and Wildlife personnel . The increased amount of people looking for shed antlers will disrupt the elk and deer in the spring when they are having their young . The summer UTV and other off road vehicles will need to be closely monitored so that they are not using undesignated areas and ruining the pristine land that has been set aside to be protected . And durning the fall big game seasons the increased traffic will spoil what was once a great back country hunt . On both large parcels the buffalo horn will still have access to the areas to graze and run their big game outfitting operation so essentially they lose nothing . If the exchange does go thru they will control the ridge tops , main water sources and key access points that the public now has the opportunity to use . In my mind it is a win win situation for the buffalo horn and once again the public suffers at the hands of a big money corporation . Thank you for your time and hopefully this whole deal will never occur and we can keep one of our valuable pristine areas for future generations to enjoy

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159cefb2214f3c35&siml=159cefb2214f3c35 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Fwd: public land exchange comments

WRFO_BHLEX, BLM_CO

Fwd: public land exchange comments 1 message

Sauls, Heather Mon, Jan 23, 2017 at 3:22 PM To: Buffalo Horn LEX AR Email

------Heather Sauls Planning & Environmental Coordinator BLM White River Field Office 970-878-3855 [email protected] ------

------Forwarded message ------From: Greg Hanberg Date: Mon, Jan 23, 2017 at 3:20 PM Subject: public land exchange comments To: "[email protected]"

please see attached for comments

Greg Hanberg RT(R) BAS Director of Radiology

Meeker Colorado 81641

This email and any files transmitted with it are intended solely for the use of the individuals or entities to which they are addressed and are not to be disclosed to any other party. If you have received this email in error please return it to the sender, and delete any copies thereof. Thank you for your cooperation.

In response the Buffalo horn land exchange.docx 15K

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159cd6cf28c8f915&siml=159cd6cf28c8f915 1/1 In response the Buffalo horn land exchange;

Being a Hunting/outdoor recreation/public land enthusiast, I am opposed to the Exchange of public land with the Buffalo horn Ranch. I have hunted and camped and accessed the particular properties of E-2 and F-5 many times and have enjoyed the beauty and sanctuary that those properties provide. In my accessing of those two particular properties it does not surprise me that the Buffalo horn ranch is wanting the control those particular pieces. What I have found is that in hunting those properties is that each of those properties have parts that the elk desire, ie Food habitat and Water. Those two particular properties lie adjacent to the buffalo horn and are prime migration elk areas. They also hold elk in there year round. I have accessed them through the scenery gulch in each different season of the year. In early spring the elk calve there and hold there because of the abundance of food and water. As well as the habitat that it has. In the summer they will remain there are many local elk that stay there year round and are available to hunt and watch in august through December for the late Cow seasons. By exchanging the property of E-2 you the public is losing a prime piece of area that hold elk year round and provide access the where the elk migrate from. I have spent many days watching the elk access the fields and flats in the bottom of the valley, and watched them move up the valley floor and up into the cover that is on the public land. I have watched them move up to the road that will be the proposed boundaries and stop there and bed below the rather than access the other side of the road because of the traffic that the small 2 track road gets during the hunting seasons. There are many people who access and hunt this area. During hunting season is not unreasonable to see 10-15 different hunting parties in the particular areas that are being discussed per day. By losing these particular pieces Prime wildlife habitat are being lost to the public, and are being given to a large ranch that is securing up public lands that are not in the best interest of the public.

In regards to the Property C-1 I am also opposed to the land exchange of this property. With the location this is another prime elk habitat that holds elk throughout the year. It has all the key components that Wildlife need. IE Food Water Cover. It is also one of the Prime migration Routes.

That is a large amount of elk that migrate onto the ColoWyo property and through the C-1 area. The elk and deer been observed to move out of these areas once there is some sort of pressure. They then move on into the buffalo horn property. Once in the buffalo horn they will then seek cover and move up into the public land. In particular E-2 as well as many other places. Without the disruption and pressure that is seen in C-1 the elk tend to stay there until moved. This is another key migration area that if given to the buffalo horn there will be a loss of public land that is not in the interest of the public.

The Property A-5 and A-3 in my opinion are two properties that are not worth the loss of the other properties.

I am adamantly opposed to the trading of public lands to large landowners. In a dollar for dollar trade I feel that the buffalo Horn is Taking advantage of the Public land Holders by Obtaining land that will increase their property and land that is prime habitat that the public land holder could and does benefit from. I feel that this any of these land exchanges is a disservice to the public and hope that this will stop and not go through. 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn Land Exchange

WRFO_BHLEX, BLM_CO

Buffalo Horn Land Exchange 1 message

Jimmy Jackson Mon, Jan 23, 2017 at 7:55 PM Reply-To: Jimmy Jackson > To: "[email protected]" To whom it may concern, Our pristine wilderness is one of the last things that our future generations will have to enjoy without atv's and trucks destroying the land. I believe it is in the best intrest for all that this land exchange does not proceed. Thank you, Jimmy Jackson

A.J CONSTRUCTION INC.

GLENWOOD SPRINGS CO. 81602

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ce667163cac29&siml=159ce667163cac29 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - TWS et al Scoping Comments on Buffalo Horn Land Exchange

WRFO_BHLEX, BLM_CO

TWS et al Scoping Comments on Buffalo Horn Land Exchange 1 message

Soren Jespersen Mon, Jan 23, 2017 at 9:36 PM To: "[email protected]" Cc: "[email protected]"

Thank you for the opportunity to comment on the proposed Buffalo Horn Land Exchange. Please let me know if you have any questions.

Thanks,

Soren Jespersen

Planning and Policy Representative

The W ilderness Society | Craig, Colorado

Office: | cell:

www.wilderness.org

Facebook: www.facebook.com/TheWildernessSociety

Twitter: twitter.com/Wilderness

WRFO Buffalo Horn Land Exchange - TWS et al scoping comments 012317_final.pdf 344K

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January 23, 2017

Submitted electronically via: [email protected]

Heather Sauls, Planning and Environmental Coordinator BLM White River Field Office 220 E. Market St. Meeker, CO 81641

Re: Buffalo Horn Land Exchange (DOI-BLM-CO-N050-2017-0009-EA)

Dear Ms. Sauls,

Thank you for the opportunity to provide comments on scoping for the Environmental Assessment for the proposed Buffalo Horn Land Exchange in Moffat and Rio Blanco Counties in Northwest Colorado. These comments are submitted on behalf of The Wilderness Society and Conservation Colorado. Our organizations are generally supportive of public land exchanges that result in enhanced public benefits, are of equal value, and which increase the manageability of public lands, as allowed for under the Federal Land Policy and Management Act (FLPMA). Because such land exchanges have the potential to impact numerous natural and recreational resources, it is important that BLM take a cautious and slow approach, while examining at all potential exchange configurations, before finalizing any such exchange. BLM must fully document all resources present on all potentially conveyed parcels—not only mineral and wildlife resources, but also wilderness-quality lands and recreational resources. Our scoping comments below detail our concerns and recommendations on those issues.

I. BLM must inventory, analyze, and avoid or mitigate impacts to lands with wilderness characteristics.

a. BLM must address lands with wilderness characteristics as part of this project.

Lands with wilderness characteristics are one of the resources of the public lands that must be inventoried under the Federal Land Policy and Management Act (FLPMA). 43 U.S.C. § 1711(a); see also Ore. Natural Desert Ass’n v. BLM, 625 F.3d 1092, 1122 (9th Cir. 2008) (holding that “wilderness characteristics are among the ‘resource and other values’ of the public lands to be inventoried under § 1711”). FLPMA allows for public land exchanges that, among other requirements, serve the public interest. Federal regulations include the “[p]protection of…wilderness and aesthetic values” as an “important objective” that shall be considered when determining whether or not a public interest will be served by a proposed land exchange. 40 C.F.R. §2200.0-6. Instruction Memorandum 2011-154 directs BLM to consider lands with wilderness characteristics in land use plans and when analyzing projects under NEPA. The IM promulgates current agency policy for considering the wilderness characteristics on public lands as part of its multiple-use mandate in developing and revising land use plans and when making subsequent project level decisions, consistent with FLPMA. The IM directs BLM to “conduct and

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maintain inventories regarding the presence or absence of wilderness characteristics, and to consider identified lands with wilderness characteristics in land use plans and when analyzing projects under [NEPA].” This requirement is reaffirmed by IM CO-2016-023, which directs: “The authorized officer will consider potential adverse impacts to lands with wilderness characteristics through the NEPA process for a proposed project.” IM CO-2016-023 at Attachment 1-6.

BLM Manual 6310 requires BLM to consider whether to update or conduct a wilderness characteristics inventory when a project that may impact wilderness characteristics is undergoing NEPA analysis, when the public identifies wilderness characteristics as an issue in a NEPA process, and/or when the public submits new information concerning resource conditions. BLM Manual 6310 at .06(A). Appropriately, the draft proposed action discusses lands with wilderness characteristics and application of the minimum tool concept in those areas. Draft Proposed Action at 18.

When conducting NEPA analysis, BLM is required to ensure an updated inventory of lands with wilderness characteristics is available and relied upon for areas potentially impacted by the proposed action. NEPA requires BLM to analyze baseline conditions when undertaking environmental analysis. 40 C.F.R. § 1502.15 requires agencies to “describe the environment of the areas to be affected or created by the alternatives under consideration.” In Half Moon Bay Fisherman’s Marketing Ass’n v. Carlucci, 857 F.2d 505, 510 (9th Cir. 1988), the Ninth Circuit states that “without establishing . . . baseline conditions . . . there is simply no way to determine what effect [an action] will have on the environment, and consequently, no way to comply with NEPA.” As described above, lands with wilderness characteristics are one of the resources of the public lands that must be inventoried under FLPMA. Therefore, BLM must have accurate LWC inventory information available to establish baseline conditions required for NEPA analysis.

IM CO-2016-023 affirms that accurate inventory information is critical to the NEPA process:

Inventory updates are often performed when a land use plan is being revised, and they can also be updated at any other time to ensure that the baseline information is current and relevant. This is especially important when using this information to perform an analysis for the National Environmental Policy Act (NEPA).

IM CO-2016-023 at Attachment 1-1 (emphasis added).

As detailed elsewhere in these comments, the proposed exchange includes lands that have been identified by BLM as lands with wilderness characteristics, federal lands that are likely to qualify as lands with wilderness characteristics but have yet to be inventoried by BLM, and private lands that are likely to meet the criteria as lands with wilderness characteristics if they are transferred into federal ownership (see details on specific parcels below). BLM must address lands with wilderness characteristics in the NEPA analysis for this project.

b. BLM has not conducted updated lands with wilderness characteristics inventories for all of the parcels included in the proposed land exchange.

As stated above, BLM must analyze impacts to lands with wilderness characteristics in the Buffalo Horn Land Exchange EA in order to comply with FLPMA, NEPA, IM 2011-154, BLM Manuals 6310 and 2200 and IM CO-2016-023. However, BLM has not conducted lands with wilderness characteristics inventories on any of the parcels proposed for federal acquisition in this exchange, nor for the Parcel F-5, which is

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proposed for disposal but which likely qualifies as lands with wilderness characteristics as defined by Manual 6310. We appreciate the commitment BLM makes in the Buffalo Horn Land Exchange – Feasibility Analysis (“Feasibility Report”) to survey Parcel B and a portion of Parcel A-5 for the presence of lands with wilderness characteristics. BLM must also inventory Parcel F-5 because of its contiguity with lands already managed as a Wilderness Study Area.

IM CO-2016-023 includes a flowchart to help BLM determine whether LWC inventory is up to date when evaluating projects. IM CO-2016-023 at Attachment 1-2. The first step in the flowchart queries whether the project has the potential to impact wilderness characteristics. In this case, the answer is yes because the proposal would not only dispose of lands already identified by BLM as lands with wilderness characteristics, but would also result in the acquisition of lands which likely qualify as lands with wilderness characteristics because of their contiguity with federal lands already identified as containing or managed to protect wilderness characteristics. The next step in the flowchart queries whether BLM has inventoried the area consistent with Manual 6310. In this case, the answer is no for Parcel F-5 and for all of the private parcels proposed for acquisition in the exchange. The flowchart directs BLM to update the inventory in this case.

c. BLM must not dispose of inventoried lands with wilderness characteristics

The proposed exchange includes two parcels that are either already inventoried as lands with wilderness characteristics by BLM or which are likely to qualify as lands with wilderness characteristics after an inventory is conducted in compliance with Manual 6310. Parcel C-1 contains approximately 340 acres of the Danforth Hills lands with wilderness characteristics unit as identified by the BLM Little Snake Field Office1. Parcel F-5 is contiguous with the Windy Gulch Wilderness Study Area and as such likely qualifies as lands with wilderness characteristics as per Manual 6310. These parcels, and any others that are determined to qualify as lands with wilderness characteristics, must be excluded from the proposed exchange.

d. BLM must minimize and mitigate impacts to LWC.

The proposed land exchange includes two parcels for disposal that qualify or likely qualify as lands with wilderness characteristics. The proposal also includes several parcels for acquisition that likely qualify as lands with wilderness characteristics. Including these parcels in the exchange—either for disposal or acquisition—would result in impacts to these resources either immediately (as they are disposed of) or as management for the newly acquired lands is established. BLM should comply with the full mitigation hierarchy in evaluating this project, summarized as avoid, minimize and compensate. BLM has new mitigation guidance that directs the agency on incorporating the mitigation hierarchy into project reviews and approvals. BLM must utilize this new guidance, set forth in MS-1794 and H-1794-1, to consider mitigation in advance of anticipated public land uses and apply mitigation to address impacts to resources from public land uses.

BLM’s Mitigation Handbook requires BLM to consider the full mitigation hierarchy as defined by the CEQ regulations at 40 C.F.R. § 1508.20. H-1794-1 at 1.1.A.1. In accordance with the mitigation hierarchy, and

1 BLM inventory for the Danforth Hills LWC, posted online at: https://www.blm.gov/style/medialib/blm/co/field_offices/little_snake_field/recreation/lwc/unit_42.Par.68710.Fil e.dat/LWC_Polygon_042_Inventory_Package.pdf

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described above, BLM should first and foremost seek to avoid impacts to lands with wilderness characteristics to the full extent practicable, including by evaluating a proposal that avoids disposal of such resources, or one that ensures that an equitable acreage of wilderness resources are acquired and managed as part of the land exchange.

BLM should seek to minimize impacts to LWC and WSAs by proposing management for acquired lands that does not result in increased impacts to the naturalness or outstanding opportunities for solitude in either of the contiguous WSAs or in the contiguous Danforth Hills or North Colorow LWCs.

II. BLM should consider management for recreation and/or lands with wilderness characteristics in any acquired parcels

The Feasibility Report states that all of the proposed parcels in the exchange “appears to be in the public interest”, primarily because of the benefits provided by increased public access to the Black Mountain and Windy Gulch WSAs. The report cites the acquisition of Parcel B as “the heart of the exchange” and states that the acquisition of this parcel “would provide improved public access to the Black Mountain and Windy Gulch WSAs” (Feasibility Report p.3). While we support improving the access to these important wilderness-quality lands, BLM must ensure that the acquired lands are managed in such a way that this improved access doesn’t diminish or harm the wilderness resources for which the WSAs were created in the first place.

The Feasibility Report states that “non-Federal lands acquired in the exchange would be managed similarly to adjacent BLM lands”. Yet, on the very same page, BLM states that even if lands acquired in Parcel B are found to meet the criteria for LWC because of their contiguity with a Wilderness Study Area lands or lands with wilderness characteristics, “it is unlikely the BLM would manage [them] for wilderness characteristics due to the private mineral estate” (Feasibility Report p.3). This ignores the fact that less than half of Parcel B is non-Federal mineral estate. It also fails to consider the fact that a significant portion of Parcel A-5 may also qualify as lands with wilderness characteristics because of its contiguity with the lands identified by BLM as the Colorow Mountain LWC. BLM must not prematurely foreclose on options to manage acquired lands to protect their wilderness characteristics, especially considering that lands which have already been identified as LWC are being proposed for disposal in this exchange. Because of the stated public benefits of this exchange to improve recreational access to wilderness-quality public lands, BLM must also consider management for the acquired lands that would emphasize the recreational component of these lands, such as Special Recreation Management Area or similar, while considering management to limit impacts to recreational uses from mineral development or other uses of the acquired lands. In addition, BLM should ensure that any funds acquired as part of equalization payments are used exclusively to mitigate the impacts of increased access to these wilderness-quality lands.

III. BLM should endeavor to determine ownership of private minerals which underlie parcels to be acquired into federal ownership

Manual 2200 clearly states that “[c]areful analysis is critical when contemplating the acquisition of land with outstanding mineral interests and/or rights, particularly when such lands are being considered for acquisition for their surface resource attributes” and that “a mineral report on the non-Federal lands” should be required “whenever some or all of the mineral estate would not be acquired”. (Manual 2200- 1 at G.2.a). In this case, the Feasibility Report simply states that “all parcels have a high potential for oil

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and gas occurrence”—no further detail is provided about each parcels potential for fluid mineral development. Further, BLM has publically stated their reluctance to determine who owns those private minerals underlying roughly 840 acres of Parcel B. Determining the ownership of the minerals under Parcel B must be completed as part of the market evaluation and feasibility studies for this exchange. It is feasible that the make-up of that ownership (i.e. is it one owner or several?) does influence the value of those mineral resources and/or their likelihood of ever being developed. BLM’s analysis of the mineral estate under the proposed exchange parcels does not yet meet the requirement in Manual 2200 that a “careful analysis” of mineral resources is “critical” when contemplating acquiring lands for their surface attributes, as is being done here.

IV. Comments on specific parcels listed for inclusion in the proposed exchange

a. BLM lands to be exchanged to private

Parcel C-1 – Approximately 340 acres of C-1 are within the Danforth Hills LWC as identified by the BLM Little Snake Field Office. These lands were found to contain the wilderness characteristics of apparent naturalness, outstanding opportunities for solitude, and outstanding opportunities for primitive and unconfined recreation, including hiking, horseback riding, and wildlife-viewing. As discussed elsewhere in these comments, BLM must seek to avoid disposing of identified lands with wilderness characteristics.

Parcel E-2 – BLM states in the Feasibility Report that this parcel has no motorized access except along the ridge-top route that would act as its western boundary. However, BLM’s own route inventory conducted as part of the Travel and Transportation Management Amendment to the Rock Springs RMP shows two routes that enter the proposed disposal parcel and head into the unit from the west—a route in the north portion of the unit identified by the BLM as route segments 5435 and 6393, and a route in the southern portion of the disposal parcel identified by route segment IDs 5519 and 432, also known as BLM Route 1710. These route segments were identified by BLM as having current public access. BLM must include the loss of this existing public access in its inventories and appraisals for this parcel.

Parcel F-5 – BLM fails to mention in the Feasibility Study that this parcel is contiguous with the Windy Gulch WSA and likely qualifies as lands with wilderness characteristics. The boundary between this parcel and the WSA is an administrative boundary only, and is not based on any existing on-the-ground linear feature. Disposal of this parcel will result in the loss to the public of up to 240 acres of qualifying lands with wilderness characteristics. As discussed elsewhere in this document, BLM must avoid disposal of wilderness-quality lands. If BLM does include this parcel in the exchange, it must ensure that wilderness quality lands are acquired that are commensurate with the lands lost in Parcel F-5, which in this case would mean acquiring at least 240 acres of unleased wilderness contiguous lands that meet the criteria for lands with wilderness characteristics as defined by Manual 6310. Such lands could be potentially be found in lands owned by Buffalo Horn Ranch in upper Smith Gulch and Jordan Draw contiguous with the northwest portions of the Windy Gulch WSA.

b. Private lands to be acquired by BLM

Parcel B – Parcel B is described by BLM as “the heart of the exchange”. Because BLM bases its public benefit assessments on the supposition that acquiring Parcel B will provide new and secure public access to the Black Mountain and Windy Gulch Wilderness Study Areas, it is crucial that this parcel, or similar, be included in the exchange. However, BLM must complete more vigorous assessments of the

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resources present in this parcel in order to understand its value and liabilities. First, BLM is unclear who owns the mineral rights beneath nearly half of the parcel (838 acres) and BLM has publically stated that they have no intention of determining who does own these sub-surface rights. This parcel also likely contains numerous sub-parcels, upwards of 600 acres according to our estimation, which meet the criteria as lands with wilderness characteristics as per Manual 6310. This parcel contains at least one underground pipeline ROW and numerous developed stock ponds and water impoundments, some of which may or may not be functioning assets for the grazing permittee in this parcel.

Parcel A-3 – It is unclear why this parcel is being included in the proposed exchange. The parcel is isolated from the other parcels in the exchange and provides no benefits for public access or recreation. While this parcel does contain priority habitat for greater sage-grouse, this fact alone is insufficient to warrant its inclusion in this exchange for which the public benefit is stated as improved access to wilderness-quality lands. BLM should consider removing this parcel from the proposal and instead seek to add similar acreage and value to the exchange by including other Buffalo Horn Ranch-owned parcels adjacent with the Windy Gulch WSA in upper Smith Gulch and Jordan Draw. Adding such lands, or an easement to the road that passes through them, would increase public benefits by enhancing access to the northwest portions of the WSA as well as allowing for more efficient motorized access to the popular hunting areas along the Gray Hills via Smith Gulch.

Parcel A-5 – BLM should consider splitting Parcel A-5 into two individual parcels for the purposes of evaluation—lands to the west of the Indian Valley Truck Trail and lands to the east. Buffalo Horn Ranch- owned lands proposed for Federal acquisition that are west of the Indian Valley Truck Trail should be considered less publically beneficial than lands to the east of the truck trail, as these lands provide no increased public access to wilderness-quality lands. Lands to the east are contiguous with the Colorow Mountain LWC as identified by BLM. In addition, the lands to the west of the Indian Valley Truck Trail are almost entirely leased and held-by-production of oil and gas resources, while lands to the east are almost entirely unleased To the east, Colorow Mountain LWC is currently being managed as a Tier 1 LWC in the context of oil and gas development as ascribed in the Oil and Gas Amendment to the White River RMP, which results in this area being managed as NSO for oil and gas development without exception, modification or waiver. Any portions of A-5 that are determined to be contiguous with the Colorow Mountain LWC should also be considered for management to protect those wilderness characteristics, such as through NSO and other stipulations. BLM should consider interchanging the portion of Parcel A-5 that is west of the Indian Valley Truck Trail for lands which enhance the public interest of access to wilderness-quality lands, such as lands owned by Buffalo Horn Ranch either northwest of the Windy Gulch WSA in Smith Gulch or contiguous with the Colorow Mountain LWC in Teds Gulch or Deep Channel Creek along the Moffat and Rio Blanco County line.

Thank you for considering these scoping comments on the proposed Buffalo Horn Lands Exchange. Please contact us with any questions or to discuss these comments in more detail.

Sincerely,

Soren Jespersen, Planning and Policy Representative The Wilderness Society

Craig, CO 81625

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Luke Schafer, West Slope Advocacy Director Conservation Colorado

Craig, CO 81625

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2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Land exchange Buffalo Ranch

WRFO_BHLEX, BLM_CO

Land exchange Buffalo Ranch 1 message

Gloria Jones Mon, Jan 23, 2017 at 6:52 PM To: "[email protected]"

This proposal is a win, win situation for Buffalo Ranch and a LOSE, LOSE situation for public and wildlife. The gains for the land exchange are against the best interest of the wildlife. It appears to let Buffalo Ranch control over more BLM property for their hunters. The wildlife areas need to take priority over any land exchange. It is not the people's obligation to make more money for Buffalo Ranch.

Sent via the Samsung Galaxy S®6 active, an AT&T 4G LTE smartphone

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WRFO_BHLEX, BLM_CO

Fwd: Buffalo Horn Land Exchange 1 message

Sauls, Heather Mon, Jan 23, 2017 at 2:10 PM To: Buffalo Horn LEX AR Email

------Heather Sauls Planning & Environmental Coordinator BLM White River Field Office 970-878-3855 [email protected] ------

------Forwarded message ------From: Georgia Kofoed Date: Mon, Jan 23, 2017 at 1:16 PM Subject: Buffalo Horn Land Exchange To: Heather Sauls

Heather-

I hope you had a good weekend and that today isn’t bringing too much Monday with it!

Attached is the comment letter which Augustus has put together. I am sending it to you first to be sure the form is in line with what is expected.

Also, I will be emailing it to the email address in the BLM proposal. Is that Kent Walter’s email or is that a generic Buffalo Horn Exchange email?

Thanks!

Georgia G. Kofoed

V.P. Land

Augustus Energy Partners II, LLC

Denver, CO 80202 

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BHR Land Exchange AEP Comment Ltr 1-23-2017.pdf 5385K

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2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Proposed Buffalo Horn Land Exchange

WRFO_BHLEX, BLM_CO

Proposed Buffalo Horn Land Exchange 1 message

Albert and Mary Krueger Mon, Jan 23, 2017 at 6:15 PM To: "[email protected]" , Kent Walter

As per your letter dated December 8, 2016

Thank you very much

Mary and Albert Krueger

land swap BLM with Buffalo Horn Ranch.docx 125K

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General considerations:

Albert and Mary K. Krueger as operators of the family owned Villa Ranch and Mary K. Krueger Outfitting are in opposition to the proposed land swap. A land swap of this magnitude is not at all in the best interest of the public at large and especially those who engage in hunting big game, deer and elk on BLM lands.

The proposed land swap is not a fair trade since the land proposed to be acquired by Buffalo Horn is by far more valuable than the land offered to the public.

The property values of landowners adjacent to the public lands affected by the proposed land exchange may be significant diminished.

Parcel B:

The proposal of trading parcel B to the public will alter the current characteristics of the Black Mountain and Windy Gulch Wilderness Study Areas located to the west of Villa Ranch.

BLM officials have stated that an important motive for the acquisition of parcel B is improved access of the public to the BLM lands. Currently all of the public lands surrounding parcel B are can be accessed by the public, either by motorized vehicles from the west and the north or on foot and horseback. Big game outfitters are an additional resource to facilite access on foot or by horseback. None of the public lands surrounding parcel B are landlocked by private properties.

With a potential end of the WSA (Wilderness Study Area) sometime in the future, modern off road motorized vehicles will increase motorized traffic to the area and change the wilderness characteristics of the area forever.

The area around parcel B with current private ownership of parcel B creates a prime elk habitat and an elk sanctuary, a critical aspect for the health of the elk herd in the area. The elk herd enjoys and thrives with using the area as a prime calving ground.

The current constellation of parcel B in private ownership and the two WSA have created a unique parcel of land very much appreciated by a certain segment of the hunting public. Over the years, we have met hunters who have accessed the area by public access and they really appreciate the existence of a remote, more difficult to access BLM land. They have emphasized that this area caters to their choice of seeking remoteness and solitude as a very special experience of hunting public lands. Hunting guests with licensed outfitters like Mary Krueger, very much have voiced a high level of satisfaction with the current constellation of land ownership and do not want to see a change.

Parcel F-8

Mary and Albert Krueger have agreed to lease land from the Vannoy family for cattle grazing. The Rawlson and Vanoy Ranch is very much affected by the proposed privatization of parcel F-8. Under the exchange proposal about 40 permitted acres of the F-8 parcel of land fenced and exclusively used for more than 100 years as part of the Vanoy Ranch would be appropriated to the Buffalo Horn Ranch LLC. Considering the size of the parcel removed in relationship the privately held property, this proposal would mean an economic hardship, let alone the cost involved to re-locate fences and roads.

Albert and Mary Krueger 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn Land Swap

WRFO_BHLEX, BLM_CO

Buffalo Horn Land Swap 1 message

Steve LaBau Mon, Jan 23, 2017 at 10:29 PM To: "[email protected]"

I have never held a Colorado hunting license, but have gone with my son and a group of dads to hunt the area around Buffalo Horn Ranch for elk, my son has harvested elk 5 of the six years we have been hunting this area, way to Colorado land managers, because we are not nearly that successful here in Idaho. My opinion is that most of the swap would be a good deal and clean things up a bit, but two parcels are particularly troubling. The first is c-1 which borders and cuts off a migration route but more troubling is E-2, which further limits access to the area that includes the Douglases. A better deal for the public would be to secure access to the trailhead that begins where the public trail and road cut from Buffalo Horn merge. Until 3 years ago this access was available, getting there now is tough. It did get busier up there when the Colrow access point deal was made. However, access to that area is extremely challenging now. The bull he took this year was over 5 miles back in and that really has been the case that we are going deeper and deeper into that area to find bulls. Buffalo Horn has been quite successful at running those elk off the public and keeping them on their land. Thanks for asking for and accepting our feedback. I have 6 points for mule deer now and should be drawing in that area in the next couple of years..

Steve LaBau

Eagle, Idaho 83616

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WRFO_BHLEX, BLM_CO

land exchange 1 message

Melanie Mckee Mon, Jan 23, 2017 at 8:52 PM Reply-To: To: "[email protected]"

I do not agree with the land exchange between Buffalo Horn and the BLM. This would be a bad situation for the owners of adjacent properties. They just want to bottleneck the whole valley and it is unacceptable!

Melanie Mckee Sent from Yahoo Mail on Android

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WRFO_BHLEX, BLM_CO

Buffalo Horn Land Exchange 1 message

Michael Munch Mon, Jan 23, 2017 at 9:11 PM To: [email protected]

To Whom It May Concern

I would like to take this opportunity to voice my opinion that I believe the Buffalo Horn Land Exchange is not in the best interest of the public. Part of the reason that I love the Meeker area is the vastness of public lands where you can escape the rigors of everyday life. I do not see how adding a parking lot and more roads would benefit the public. Part of the mystique of the wilderness areas is that it is difficult to access some of these areas. There is no better feeling than exercising and working to get to see some of the beauty this Land has to offer. I believe instead we should be promoting the fact that people need to live healthier life styles so that they too are able to hike to witness these beautiful places. It will never be the same to be able to drive to a location to see it. It looses a part of its beauty by being so accessible. Please consider my opinions when making this decision. I know many that feel the same but may not be aware of what this entails.

Thank you

Michael Munch.

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WRFO_BHLEX, BLM_CO

Buffalo Horn Ranch 1 message

[email protected] Mon, Jan 23, 2017 at 8:45 PM To: "[email protected]"

To whom it may concern-

I am a Rio Blanco County Native and still come home to spend time in Rio Blanco County frequently. I am writing to express my disapproval of the land exchange between the BLM and the Buffalo Horn Ranch. I do not believe this exchange is beneficial to the public (me). I believe that it only serves the interest of the Buffalo Horn Ranch. I do not believe that the land being exchanged is of equal quality even though it is of equal size.

If you have any questions about my position please feel free to contact me.

Thank you,

Sierra

Sierra R. Nelson, M.S. Administrative Assistant Utah Wool Growers

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ce94b5006987d&siml=159ce94b5006987d 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn Ranch land exchange

WRFO_BHLEX, BLM_CO

Buffalo Horn Ranch land exchange 1 message

Edward O'Malley Mon, Jan 23, 2017 at 2:30 PM To: [email protected]

To land exchange,

My family and i have been hunting in Colorado for many years, when i heard about the land exchange between the BLM and Buffalo Horn Ranch i was very happy and also concerned about the area concerning Smith Gulch. I am glad i can hunt in this area , my concerns are it becoming an ATV access area. I really enjoy remote hike in areas my family also enjoy the hike in to remote areas while hunting, it seems to me that remote areas are becoming far and few between. my major concern is the pristine environment will be destroyed if this area becomes an ATV area, i feel ATV's destroy the areas they travel and cause serious erosion issues. while i am out hiking and hunting my experiences when ATV's are in the area they scare game out of the area. I hope the BLM will take this into consideration in keeping the Smith Gulch area a walk in area.

sincerely,

Edward O'Malley

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159cd3cd7e299aae&siml=159cd3cd7e299aae 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Fw: Buffalo ranch land exchange

WRFO_BHLEX, BLM_CO

Fw: Buffalo ranch land exchange 1 message

Douglas Pfau Mon, Jan 23, 2017 at 9:11 PM To: "[email protected]"

Please do not do the land exchange. It is not in the best interest of the public. Thanks, Doug Pfau Colorado resident

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------Forwarded message ------From: To: "[email protected]" Cc: Bcc: Date: Tue, 24 Jan 2017 04:06:57 +0000 Subject: Buffalo ranch land exchange Please do not do the exchange. It is not in the best interest of the public. Thank You. Doug Pfau

noname.eml 7K

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ceac0a9242212&siml=159ceac0a9242212 3/3 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo horn ranch

WRFO_BHLEX, BLM_CO

Buffalo horn ranch 1 message

Jason Powell Mon, Jan 23, 2017 at 9:03 PM To: [email protected]

I don't think it's in the best interest of the public to do a land exchange with the buffalo horn ranch. Thank you.

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159cea9efbcd0e0c&siml=159cea9efbcd0e0c 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - This is by far more beneficial to the buffalo ranch then to the public this is not except able for them to benefit fr…

WRFO_BHLEX, BLM_CO

This is by far more beneficial to the buffalo ranch then to the public this is not except able for them to benefit from this as they have everything already. 1 message

Boyd Richardson Mon, Jan 23, 2017 at 7:09 PM To: [email protected]

Sent from my iPhone

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ce3c4060ff3f0&siml=159ce3c4060ff3f0 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Land Swap with Buffalo Horn Ranch

WRFO_BHLEX, BLM_CO

Land Swap with Buffalo Horn Ranch 1 message

Davon Smith Mon, Jan 23, 2017 at 6:32 PM To: "[email protected]"

To whom,

I Dissapprove of the land exchange between Buffalo Horn and the Proposed BLM land. From the Life and Times of Grizzly Gutierrez

In my opinion this exchange is by far more in the best interest of the Buffalo Horn then it is for the public . One of the large parcels of land is right between 2 wildlife study areas that would make the areas more accessible to the public but would still be accessible to the buffalo horn which is a win win situation for Buffalo Hornas well as the other large parcel .

The meeting I went to it was said that if the exchange went thru then they would build a road and parking lot right in the middle of the 2 wildlife study areas . By doing so it would completely ruin the whole concept and intentions of the wildlife study area .

As of now the area is only accessible to the public by foot or horseback and by opening it up would only mean easier access to destroy the pristine area that has been set aside for wildlife to flourish with the least amount of human interaction .

The land that the Buffalo Horn will gain I feel are key traffic areas that will limit the public into BLM land that is open to the public already , again a win win situation for Buffalo Horn.

Again I disapprove of the land exchange with Buffalo Horn Ranch

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ce1a5e4abcc00&siml=159ce1a5e4abcc00 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Fwd: Buffalo Horn land exchange comment letter

WRFO_BHLEX, BLM_CO

Fwd: Buffalo Horn land exchange comment letter 1 message

Sauls, Heather Mon, Jan 23, 2017 at 8:40 AM To: Buffalo Horn LEX AR Email

------Heather Sauls Planning & Environmental Coordinator BLM White River Field Office 970-878-3855 [email protected] ------

------Forwarded message ------From: Walter, Kent Date: Fri, Jan 20, 2017 at 8:51 AM Subject: Fwd: Buffalo Horn land exchange comment letter To: Heather Sauls , Stacey Burke , Lauren Brown

FYI.

Kent E. Walter, PLS Field Manager White River Field Office 220 East Market Street Meeker, Colorado 81641

F (970) 878-3805

"Once we lose our sense of humor, we have lost." KEW

------Forwarded message ------From: Smithers - DNR, Brett Date: Thu, Jan 19, 2017 at 9:56 AM Subject: Buffalo Horn land exchange comment letter To: Kent Walter

Kent:

See attached comment letter, and let me know if you have any questions.

Hope all is well.

Brett

--

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159cbfd10e33ab0d&siml=159cbfd10e33ab0d 1/2 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Fwd: Buffalo Horn land exchange comment letter

Brett Smithers Land Use Specialist, Northwest Region , Meeker, CO 81641

| www.cpw.state.co.us

Buffalo Horn Land Exchange comment letter.pdf 216K

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159cbfd10e33ab0d&siml=159cbfd10e33ab0d 2/2

2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn land exchange

WRFO_BHLEX, BLM_CO

Buffalo Horn land exchange 1 message

Leslie Sorensen Mon, Jan 23, 2017 at 7:29 PM To: "[email protected]"

Please do not proceed with the land exchange with Buffalo Horn Ranch. This is not in the best interests of the public.

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ce4ee88de4c53&siml=159ce4ee88de4c53 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Land transfer

WRFO_BHLEX, BLM_CO

Land transfer 1 message

Clay Springer Mon, Jan 23, 2017 at 8:50 PM To: [email protected]

I do not think the land exchange with buffalo horn ranch is in the best interest of the public

Clay Springer

Sent from my iPad

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ce9875ceb2024&siml=159ce9875ceb2024 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo horn land extange

WRFO_BHLEX, BLM_CO

Buffalo horn land extange 1 message

EARL STOUT Mon, Jan 23, 2017 at 7:41 PM To: [email protected]

The looks of this deal to me the benefits to the public out weighs the negatives. There's a lot of land locked b l m in the ranch and the access to the public east side of Moffat County road 57 is almost nonexistent anyway. So in my opinion go for it its a good deal for both buffalo horn ranch and the public.

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ce5a0a7baf49e&siml=159ce5a0a7baf49e 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Land exchange price creek

WRFO_BHLEX, BLM_CO

Land exchange price creek 1 message

Strawberry Creek Outfitters Mon, Jan 23, 2017 at 8:50 PM To: [email protected]

This land exchange is only for the good of buffalo horn ranch,not the public.I am very familiar with the large parcel of land they will end up with if this deal were to go threw and it has tanks and price creek runs threw it.It is never a good idea to give up property with a great WATER source to end up with several small tracks that will not do the public any good.Second it's in a migrations route for elk and has been for years,they just want to control everything up strawberry creek to there benefit.Third the small area you all want to gain control to build parking to access wilderness study area would make easy access doesn't that defeat the purpose of the a Wilderness Study Area.Long and Short is this deal is only good for one person Buffalo Horn Ranch not the PUBLIC!

Sent from my iPad

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ce98fbbbacadf&siml=159ce98fbbbacadf 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Land exchange

WRFO_BHLEX, BLM_CO

Land exchange 1 message

Pattie Terp Mon, Jan 23, 2017 at 6:31 PM To: [email protected]

It is in my opinion that the land exchange with Buffalo Horn Ranch is not in the best interest of the public or the wildlife study areas. It will only benefit Buffalo Horn Ranch.

Pattie Terp

Meeker CO 81641

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ce198fbdccca9&siml=159ce198fbdccca9 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Fwd: LOUISIANA PURCHASRE RANCH RESPONSE

WRFO_BHLEX, BLM_CO

Fwd: LOUISIANA PURCHASRE RANCH RESPONSE 1 message

Sauls, Heather Mon, Jan 23, 2017 at 11:55 AM To: Buffalo Horn LEX AR Email

------Heather Sauls Planning & Environmental Coordinator BLM White River Field Office 970-878-3855 [email protected] ------

------Forwarded message ------From: RICK > Date: Mon, Jan 23, 2017 at 11:40 AM Subject: LOUISIANA PURCHASRE RANCH RESPONSE To: [email protected]

HELLO HEATHER,

ATTACHED IS OUR RESPONSE TO THE BUFFALO HORN LAND EXCHANGE PROPOSAL. PLEASE GIVE ME A CALL WHEN YOU RECEIVE IT.

THANKS,

RICK TINGLE

LOUISIANA PURCHASE RANCH

MEEKER, CO 81641

WWW.SHOOTELK.COM

LPR W920170123_12370089.pdf 39K https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ccaecdcb7cff3&siml=159ccaecdcb7cff3 1/2

2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn Ranch land exchange

WRFO_BHLEX, BLM_CO

Buffalo Horn Ranch land exchange 1 message

Billy Tingle Mon, Jan 23, 2017 at 7:59 PM To: [email protected], [email protected]

I am opposed to the land transfer proposed between Buffalo Horn Ranch and the BLM. I believe this exchange is to the detriment of the wilderness study areas involved. The only benefit of the transaction appears to be to the private land owner, Buffalo Horn Ranch.

This land-swap is not in the best interest of the general public and should not be allowed to proceed.

Thank you for registering my opposition to this proposal.

Billy Tingle, CEO Oakdale Community Hospital

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ce6a3dcf4adf8&siml=159ce6a3dcf4adf8 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - New Multimedia Message

WRFO_BHLEX, BLM_CO

New Multimedia Message 1 message

19709423200 Mon, Jan 23, 2017 at 9:11 PM Reply-To: 19709423200 > To: [email protected]

Message: Not the best interest of the public

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ceabc2e5c892c&siml=159ceabc2e5c892c 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn Land Exchange

WRFO_BHLEX, BLM_CO

Buffalo Horn Land Exchange 1 message

Kristi Wilson Mon, Jan 23, 2017 at 8:05 PM To: "[email protected]"

I do not support the Buffalo Horn Land Exchange. The parcels that the Buffalo Horn will acquire will negatively impact public land hunting in the Meeker area. The ground that will be acquired by the BLM is not as high quality of hunting areas as will be lost. Area E2 is a "hot spot" for elk and deer. If the Buffalo Horn gains this ground, it will become even easier for them to keep the elk herded onto their private, something that they already excel at. Track C1 is on the edge of a major migration route. Loosing this tract will be detrimental to hunting in this area. Many of these areas (C1, D3, and F5) are hard to access. This is something that makes them great hunting. It does require more efforts by hunters, but that is a big part of what makes them good hunting areas. The ground that will be gained in Smith Gulch, while a good area, is not ideal. It is surrounded by wilderness study. Better access is bad for hunting and because of the restrictions of the wilderness study regulations, habitat developments will be restricted to only the new area. In conclusion, the land that will be lost is better than the land that will be gained. This exchange is not in the best interests of public land recreation.

Sincerely Kristi Wilson

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159ce7014a673260&siml=159ce7014a673260 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Buffalo Horn land swap not in public's best interest

WRFO_BHLEX, BLM_CO

Buffalo Horn land swap not in public's best interest 1 message

Bobby Gutierrez Tue, Jan 24, 2017 at 4:12 PM To: [email protected]

vote against land swap

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159d6058802204f4&siml=159d6058802204f4 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Fwd: Buffalo Horn Land Exchange

WRFO_BHLEX, BLM_CO

Fwd: Buffalo Horn Land Exchange 1 message

Sauls, Heather Tue, Jan 24, 2017 at 7:17 AM To: Buffalo Horn LEX AR Email

------Heather Sauls Planning & Environmental Coordinator BLM White River Field Office 970-878-3855 [email protected] ------

------Forwarded message ------From: Steve-Kim Jordan Date: Mon, Jan 23, 2017 at 8:27 PM Subject: Buffalo Horn Land Exchange To: [email protected]

Dear Heather Sauls, We are writing to oppose this land exchange. We feel it favors Buffalo Horn more than it does the public. We are Wisconsin hunters that enjoy hunting in this area. Sincerely, Steve and Kim Jordan

New London, WI 54961

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159d0d6b0f6e07fd&siml=159d0d6b0f6e07fd 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Re: Land exchange

WRFO_BHLEX, BLM_CO

Re: Land exchange 1 message

Info, BLM_CO Tue, Jan 24, 2017 at 7:30 AM To: Theresa Sanchez Cc: [email protected]

I've forwarded your concerns to the proper email

BLM seeks public comment on proposed land exchange in Rio Blanco and Moffat counties

Body

MEEKER, Colo. – The Bureau of Land Management is seeking public comment on a proposed land exchange in Rio Blanco and Moffat counties that could consolidate public lands and increase public access.

Under the proposed Buffalo Horn Land Exchange, the BLM would acquire three parcels totaling 4,036 acres in exchange for 16 isolated parcels of BLM lands totaling 3,806 acres.

Maps and details about the potential land exchange are available at http://bit.ly/2gIDcCt.

“The BLM will only go forward with a land exchange if it is in the public’s interest,” said BLM White River Field Manager Kent Walter. “To help us make that determination, we need to hear from the public about this proposal.”

Before the BLM begins the environmental assessment of this exchange, it wants to hear any issues or concerns the public believes should be addressed in the EA. The BLM will hold a public open house meeting on Jan. 5, 2017, at the Meeker Public Library, 490 Main St., from 4 to 7 p.m. to provide information and accept written comment.

The BLM will accept public comments through Jan. 23, 2017. Comments may be submitted by email to [email protected] or by mail to BLM WRFO, Land Exchange Comments, 220 East Market St., Meeker, CO 81641.

Before including your address, phone number, e-mail address, or other personal identifying information in your comment, you should be aware that your entire comment—including your personal identifying information—may be made publicly available at any time. While you can ask us in your comment to withhold your personal identifying information from public review, we cannot guarantee that we will be able to do so.

On Mon, Jan 23, 2017 at 1:47 PM, Theresa Sanchez wrote: January 23, 2017

Freddy Sanchez

Stormville, NY 12582

Dear Land Exchange:

I am writing to inquire about the land exchange between Buffalo Horn Ranch and the BLM. More specifically I would like to know about the Smith Gulch area. I have been hunting in Colorado with my brother in law for approximately 10 years. We enjoy to hunt on foot and hope the BLM will keep this area a walking only area. We feel that 4- wheelers/ATVs push the game out and ruin the beautiful terrain.

I would appreciate if you can keep me informed about this land exchange.

Thank you,

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159d0e3ad871dbb8&siml=159d0e3ad871dbb8 1/2 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Re: Land exchange Freddy Sanchez

-- BLM-COSO-Information Access Center 2850 Youngfield St Lakewood Co 80215 303-239-3600

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159d0e3ad871dbb8&siml=159d0e3ad871dbb8 2/2 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Fwd: Land exchange

WRFO_BHLEX, BLM_CO

Fwd: Land exchange 1 message

Info, BLM_CO Tue, Jan 24, 2017 at 7:31 AM To: [email protected]

------Forwarded message ------From: Theresa Sanchez Date: Mon, Jan 23, 2017 at 1:47 PM Subject: Land exchange To: [email protected]

January 23, 2017

Freddy Sanchez 106 Gold Road Stormville, NY 12582

Dear Land Exchange:

I am writing to inquire about the land exchange between Buffalo Horn Ranch and the BLM. More specifically I would like to know about the Smith Gulch area. I have been hunting in Colorado with my brother in law for approximately 10 years. We enjoy to hunt on foot and hope the BLM will keep this area a walking only area. We feel that 4-wheelers/ATVs push the game out and ruin the beautiful terrain.

I would appreciate if you can keep me informed about this land exchange.

Thank you,

Freddy Sanchez

-- BLM-COSO-Information Access Center 2850 Youngfield St Lakewood Co 80215 303-239-3600

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159d0e3d5e7dc9e5&siml=159d0e3d5e7dc9e5 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - this exchange is NOT in the publics best interest! do not proceed with it.From Tom Alley,, POB 329 Meeker, …

WRFO_BHLEX, BLM_CO

this exchange is NOT in the publics best interest! do not proceed with it.From Tom Alley ,, , CO 81641 1 message

Tom Alley Wed, Jan 25, 2017 at 9:21 AM To: [email protected]

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159d66e864d9e869&siml=159d66e864d9e869 1/1

2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Re: Proposed Buffalo Horn Land Exchange

WRFO_BHLEX, BLM_CO

Re: Proposed Buffalo Horn Land Exchange 1 message

Albert and Mary Krueger Sun, Jan 29, 2017 at 11:52 AM To: "[email protected]" , Kent Walter

Ladies and gentlemen,

I just noticed that I did not attach the final version of my letter to the BLM. If, possible, please replace the file with the correct file and still consider the letter being submitted on January 23, 2016. If this cannot be done, please add the current letter as the final addendum to my original letter.

Sincerely

Albert Krueger and Mary Krueger

From: Albert and Mary Krueger Sent: Monday, January 23, 2017 6:15 PM To: [email protected]; Kent Walter Subject: Proposed Buffalo Horn Land Exchange

As per your letter dated December 8, 2016

Thank you very much

Mary and Albert Krueger

Final BLM Land Swap Buffalo Horn.docx 126K

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159eb93e649ce909&siml=159eb93e649ce909 1/1 To the BLMC concerning the proposed land swap BLM with Buffalo Horn Properties LLC (Buffalo Horn).

General considerations:

Albert and Mary K. Krueger, as operators of the family-owned Villa Ranch and Mary K. Krueger Outfitting, oppose the proposed land swap. A land swap of this magnitude is not at all in the best interest of the public at large and would have a detrimental effect on those who engage in hunting big game, deer and elk on BLM lands.

The proposed land swap is not a fair trade because the land proposed to be acquired by Buffalo Horn is far more valuable than the land offered to the public in exchange.

The property values of landowners adjacent to the public lands affected by the proposed land exchange may be significantly diminished.

Parcel B:

The proposal to trade parcel B to the public for multiple parcels owned by the United States, would alter the current characteristics of the Black Mountain and Windy Gulch Wilderness Study Areas located to the west of Villa Ranch.

BLM officials have stated that an important motive for the acquisition of parcel B is improved public access of to BLM lands. Currently all of the public lands surrounding parcel B can already be accessed by the public, either by motorized vehicles from the west and the north, or on foot and horseback. Big game outfitters are an additional resource to facilitate access on foot or by horseback. None of the public lands surrounding parcel B are landlocked by private properties.

With a potential end of the WSA (Wilderness Study Area) sometime in the future, modern off-road motorized vehicles will increase motorized traffic to the area and change the wilderness characteristics of the area forever. Parcel B being open for the public would greatly facilitate just that.

The area surrounding the current privately-owned parcel B is a prime elk habitat and elk sanctuary, which is vital for the health of the elk herd in the area. The herd thrives on using the area as a prime calving ground.

The current constellation of private ownership of parcel B in combination with the two WSA’s has created a unique parcel of land which is sought after and highly valued by the more adventurous hunting public. Over the years, we have encountered many hunters who have entered the area by public access and gained an immense appreciation for the remote BLM land and the exciting challenge it provides. They have emphasized that this area caters to their choice of seeking remoteness and solitude as a very special experience of hunting public lands. Hunting guests with licensed outfitters like Mary Krueger, have voiced a high level of satisfaction with the current constellation of land ownership and do not want to see a change.

Parcel F-8

Mary and Albert Krueger have an agreement to lease land from the Vannoy family for cattle grazing. The Rawlinson /Vannoy Ranch is severely impacted by the proposed privatization of parcel F-8. Under the exchange proposal about 40 permitted acres of the F-8 parcel of land, fenced and exclusively used for more than 100 years as part of the Vannoy Ranch, would be appropriated to Buffalo Horn. This would mean diminishing the value of the Vannoy Ranch. It also would mean an economic hardship, in the cost involved to relocate fences and roads alone.

Thank you for this opportunity to be heard. Should you have any questions regarding our comments, please contact us.

Albert and Mary Krueger Villa Ranch

Meeker, CO 81641 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Fwd: Buffalo Horn Land exchange

WRFO_BHLEX, BLM_CO

Fwd: Buffalo Horn Land exchange 1 message

Sauls, Heather Tue, Jan 31, 2017 at 9:01 AM To: Buffalo Horn LEX AR Email

------Heather Sauls Planning & Environmental Coordinator BLM White River Field Office 970-878-3855 [email protected] ------

------Forwarded message ------From: Loftus, William Date: Tue, Jan 31, 2017 at 8:09 AM Subject: Buffalo Horn Land exchange To: "[email protected]"

Heather,

I became aware of the proposed Buffalo Horn Land Exchange today. I’d like to state that I am opposed to the privatization of the land parcels C1 and C2 on the attached map. My sons and I have accessed the C1 property from Pine Tree Gulch STL. The C1 parcel is a high value elk hunting area that is available to the public. Loss of access to this property would further reduce the opportunities available to hunters of modest incomes in Colorado. I am also opposed to the privatization of the C2 properties. This parcel is also a quality elk property. Access is across private land but the adjacent landowners gave my young sons permission during the extended youth elk season. These two parcels of land have great value to sportsman and should not be privatized.

Thanks,

Bill Loftus

Broomfield, Colorado

2016.01.13_Final_Exchange_Proposal.pdf 4000K

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=159f54289086024a&siml=159f54289086024a 1/1 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Proposed Buffalo Horn Land Exchange 2200 (LLCON05000) COC76595 - Comments of Rockies Express Pi…

WRFO_BHLEX, BLM_CO

Proposed Buffalo Horn Land Exchange 2200 (LLCON05000) COC76595 ­ Comments of Rockies Express Pipeline LLC 1 message

Shawn Welch < > Fri, Feb 10, 2017 at 4:09 PM To: "[email protected]" Cc: Evan Randall >,

Jeffrey Williams

Dear Mr. Walter,

Attached please find a copy of Rockies Express Pipeline LLC’s Comments regarding the captioned proposed land exchange, which are also being sent to you by certified mail.

If you have any questions regarding these comments, or trouble with delivery, please contact me at the number below.

Sincerely,

Shawn Welch

Shaw n T. W elch Partner Holland & Hart LLP

Salt Lake City, UT 84101 Phone Fax

CONFIDENTIALITY NOTICE: This message is confidential and may be privileged. If you believe that this email has been sent to you in error, please reply to the sender that you received the message in error; then please delete this e-mail. Thank you.

2017-02-10 Kent E. Walter USDOI re Land Exchange.pdf 3504K

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=15a2a4dca1e27c25&siml=15a2a4dca1e27c25 1/1

Attachments to Comments of Rockies Express Pipeline LLC dated February 10, 2017

Proposed BLM Buffalo Horn Land Exchange - 2200 (LLCON05000) COC76595 Rio Blanco County, Colorado REX Att. 1 REX Att. 2 REX Att. 3 REX Att. 4 REX Att. 5 REX Att. 6 REX Att. 7 REX Att. 8 REX Att. 9 REX Att. 10 REX Att. 11 REX Att. 12 REX Att. 13 REX Att. 14 REX Att. 15 REX Att. 16 REX Att. 17 REX Att. 18 REX Att. 19 REX Att. 20 REX Att. 21 REX Att. 22 REX Att. 23 REX Att. 24 REX Att. 25 REX Att. 26 REX Att. 27 2/27/2017 DEPARTMENT OF THE INTERIOR Mail - Proposed Buffalo Horn Land Exchange

WRFO_BHLEX, BLM_CO

Proposed Buffalo Horn Land Exchange 1 message

Charles C Slack < > Wed, Feb 15, 2017 at 8:46 AM To: [email protected]

Hello,

I have reviewed the documentation and maps associated with the proposed Buffalo Horn Land Exchange. I am an avid hunter in the effected region and I have to recommend against such an exchange. Please feel free to call and discuss the reasoning behind my recommendation ( ).

Kind Regards…Charles Slack

https://mail.google.com/mail/b/190/u/0/?ui=2&ik=3fcfcc5bfb&view=pt&cat=Scoping%20comments&search=cat&th=15a427473e844ed3&siml=15a427473e844ed3 1/1