THE WILDERNESS SOCIETY, HIGH COUNTRY CONSERVATION ADVOCATES, WESTERN COLORADO CONGRESS, CONSERVATION COLORADO, GREAT OLD BROADS FOR WILDERNESS, SHEEP MOUNTAIN ALLIANCE, ROCKY MOUNTAIN WILD, SAN JUAN CITIZENS ALLIANCE, ROCKY SMITH, RIDGEWAY OURAY COMMUNITY COUNCIL, WESTERN ENVIRONMENTAL LAW CENTER, WEST SLOPE CONSERVATION CENTER

Forest Planning Team GMUG National Forest 2250 Highway 50 Delta, CO 81416

January 22, 2018

Dear GMUG Planning Team,

Please accept these comments on the draft wilderness inventory from The Wilderness Society, High Country Conservation Advocates, Western Colorado Congress, Conservation Colorado, Great Old Broads for Wilderness, Sheep Mountain Alliance, Rocky Mountain Wild, San Juan Citizens Alliance, Rocky Smith, Ridgeway Ouray Community Council, Western Environmental Law Center, and Western Slope Conservation Center. The Grand Mesa-Uncompahgre-Gunnison National Forest (GMUG) posted the draft inventory online1 on January 8, 2018 and set January 22, 2018 as the deadline for submitting comments. We want to thank you for contacting us before you released the draft inventory, and taking the time to answer our questions during this two-week period.

This letter is divided into two sections. The first section discusses the draft wilderness inventory criteria2 that the GMUG used to identify wilderness inventory polygons, and the second section provides feedback on specific polygons. To the degree we were able, we have provided photographs, google earth screen shots, and other pieces of evidence to support our comments.

I. Feedback on the Wilderness Inventory Criteria

A. Size criteria

Page 2 of the draft criteria document describes how the ‘size’ criteria were applied:

Areas to be included in the Inventory must be federal lands and must meet one of the following size criteria:

1. The area contains 5,000 contiguous acres or more.

2. The area contains less than 5,000 contiguous acres, but is of sufficient size as to make practicable its preservation and use in an unimpaired condition, including but not be limited to areas contiguous to an

1 https://www.fs.usda.gov/detail/gmug/landmanagement/planning/?cid=fseprd500301 2 Available at https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd568465.pdf

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existing wilderness, primitive areas, administratively recommended wilderness, or wilderness inventory of other Federal ownership.

3. For areas less than 5,000 acres that are not adjacent to already designated areas, the Responsible Official will need to consider and determine whether such areas could be preserved in an unimpaired condition. (No areas that meet this size criteria are yet included in the inventory; this criteria will apply if such smaller, isolated areas are recommended by the public).

Subsection 3 is unnecessary (it describes a subset of situations under section 2) and it is confusing because it appears inconsistent with the language in section 2. Subsection 2 directs the GMUG to look at areas less than 5000 acres that are of sufficient size to make practicable their preservation and use in an unimpaired condition, including when they are contiguous to existing wilderness or wilderness inventory areas under other Federal ownership, while subsection 3 refers to areas contiguous to existing designated wilderness only.

Recommendation: Delete subsection 3.

In addition, after listening to the informational webinars offered by the GMUG on the wilderness inventory, we got the sense that the GMUG may have not comprehensively applied the adjacency filter. Subsection 2, which echoes the language in FSH 1909.12, chapter 70, section 71.21(2), directs the agency to include polygons that are less than 5,000 acres in size and adjacent to designated wilderness, primitive areas, administratively recommended wilderness, or wilderness inventory of other Federal ownership. Emphasis added. It was our sense from the conversation on the webinar that the GMUG may have only looked at polygons adjacent to designated wilderness and may have not considered polygons adjacent to wilderness inventory areas of other federal units. These include Bureau of Land Management (BLM) lands of wilderness characteristics and wilderness study areas, as well as wilderness inventory areas on adjacent national forests (Rio Grande, White River, Pike-San Isabel, and San Juan).

While we are sure more exist, here is one example where acreage was inappropriately left out of the inventory for failure to look across the boundary. Inventory polygon 61 (Matterhorn) inappropriately excludes Sunshine Mountain on the south side of the North Fork Henson Creek, apparently because it appears to be an isolated fragment less than 5,000 acres in size. However, this portion of the inventory polygon is adjacent to the BLM’s American Flats Wilderness Study Area (WSA), which itself is contiguous with the Uncompahgre Wilderness. The boundary for inventory polygon 61 should align with the Colorado Roadless Area (CRA) boundary and include all lands adjacent to the BLM WSA. An excerpt from the BLM’s Montrose 1:100K surface management quad is attached below that depicts the relationship of these units.

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Additionally, there is an inventory polygon under 5,000 acres that has recently been pending in wilderness legislation introduced in Congress, most recently in the Colorado Wilderness Act of 2015. This is the western portion of Horsefly Creek, which would be part of inventory polygon 18 other than for a transmission line, and is included within the proposed Norwood Canyon wilderness unit on adjacent BLM lands in the legislation. See Exhibit 4 for a map and additional details.

Recommendation: We request that you ensure that the adjacency filter is comprehensively applied so that polygons less than 5,000 acres and adjacent to wilderness inventory units or in pending wilderness legislation under other federal management are included in the wilderness inventory. As a first step, you should check to make sure that CRA acreage is not excluded from the inventory, and if it is you should check to make sure that the exclusion is not due to a failure to apply the adjacency filter appropriately.

B. Substantially noticeable improvements

i. Application of the definition of substantially noticeable improvements is not adequately rigorous.

The hardest part of developing the inventory of lands that may be suitable for wilderness is identifying with rigor, accuracy, and replicability the substantially noticeable improvements. While we like the definition of substantially noticeable improvements proffered on page 4 (“An improvement is substantially noticeable when it creates a noticeable difference in form, line, color, texture and pattern in the surrounding natural landscape at a size, scale, or concentration that contrasts with the surrounding natural landscape. To be substantially noticeable, the improvement or concentration of improvements must be more dominant than the surrounding natural landscape scene.”), we are concerned that the criteria and data sets that the GMUG used to evaluate whether improvements meet the definition are deficient, and inadequate or inappropriately utilized, respectively. The Wilderness Society has developed inventories in several forests using the criteria set forth in the Forest Service Handbook 1909.12, chapter 70, and has found that it is necessary to utilize digital spatial data

3 with sufficient detail and attribution so that substantially noticeable and substantially unnoticeable impacts can be distinguished, and complement digital data with field surveys. We are concerned that the GMUG developed the inventory using digital data only and without sufficient rigor such that the resultant inventory inappropriately excludes qualifying acreage from the inventory.

Below, we describe exactly how the GMUG inventory is deficient, and offer recommendations on how the GMUG might address the deficiencies.

1. Vegetation treatments and timber harvests

The criteria document states that all vegetation treatments beyond the removal of a single tree are considered substantially noticeable and are excluded from the inventory.

If the vegetation treatment involved tree removal beyond single tree removal, it is considered substantially noticeable and has been excluded from the draft inventory.9 Other types of vegetation treatment, i.e., weed treatment, are included in the Inventory.

Footnote 9 states that:

Vegetation treatment activities considered substantially noticeable, and/or are typically associated with harvest activities: Commercial thin, coppice cut, disease control, fill-in or replant trees, fill-in seed or reseed trees, fire line construction, fuel break, group selection cut, improvement cut, insect control, over story removal cut, patch clear-cut, permanent land clearing, piling of fuels (hand or machine), plant trees, pre-commercial thinning for visual, pre-commercial thin, range control vegetation, salvage cut, sanitation cut, seed-tree cuts, Shelterwood establishment cuts, single-tree selection cut, site preparation for natural regeneration (mechanical), site preparation for planting (mechanical), stand clear-cuts, thinning for hazardous fuels reduction, tree encroachment control, tree release and weed, watershed resource non-structural improvements erosion control, wildlife habitat (activities, create corridors, create openings, intermediate cut, mechanical treatment, non-structural improvements, pre- commercial thinning, and regeneration cut).”

Draft Wilderness Inventory Criteria, page 5.

Similarly, the draft criteria documents states that all timber harvest areas are considered substantially noticeable:

All timber harvest areas are considered substantially noticeable for the draft inventory– they are roaded, interwoven with skid trails, persistent stumps, etc. These are excluded from the draft inventory.

Draft Wilderness Inventory Criteria, page 5.

The GMUG helpfully shared the GIS layer that it used for identifying disqualifying vegetation treatment and timber harvest areas. In examining the data layer, we found that it includes a wide variety of project types with completion dates extending as far back as 1900. As far as we can tell, the GMUG did not attempt to discern which vegetation and timber project areas are substantially noticeable and which are not. Instead, the GMUG

4 arbitrarily considered that all projects are substantially noticeable and disqualified affected acres. In fact, based on the criteria document and the data layer, if at any time over the past 118 years the GMUG removed two or more trees as part of a documented project, the project acreage in its entirety was deemed a substantially noticeable feature and was excluded from the inventory. This approach ignores the fact that signs of vegetation management and timber projects diminish over time, and vary considerably by type of cut (for instance, selective thinning projects may not seem substantially noticeable while clearcuts may), ecosystem type, elevation, aspect, soil type, and project date. It is not rational, for instance, to presume that vegetation management and timber projects conducted decades ago are still substantially noticeable without conducting field work and presenting evidence showing that they are.3 The GMUG must provide a rational basis for identifying substantially noticeable vegetation and timber project areas, and cannot simply claim that all project acres over the last 118 years are substantially noticeable.

After reviewing the draft inventory and systematically looking at excluded areas on google earth, we are convinced that the GMUG excluded qualifying acreage in numerous instances across the forest. Here is one example. The inventory excludes about 4,000 acres of Escalante Breaks, the portion of the Inventory Unit 7 (Kelso Mesa) Colorado Roadless Rule Area bounded by FDR 409 (Brushy Ridge Road) on the north and by the rim of North Fork Escalante Creek on the south. The exclusion is apparently owing to past mechanical treatments for wildlife habitat improvements. There are no substantially noticeable impacts on the ground, and there are not open (or even decommissioned roads) in the excluded acreage. See Exhibit 1 for photographs of the excluded acreage showing no substantially noticeable impacts. We provide additional examples in Section II of this letter.

It is instructive to look at how other forests that have recently conducted wilderness inventories navigated this issue. The Flathead National Forest in Montana recently published its final environmental impact statement; its wilderness inventory and evaluation are contained in Appendix 4.4 The Flathead National Forest distinguished between timber harvest and vegetation treatments. It included vegetation treatments in the inventory, and excluded certain categories of timber harvests, and provided a detailed rationale for this approach based on what a person would see on the ground. Id. at Pages 4-6, 4-8 to 4-10. The relevant pages from the Flathead National Forest’s Final Wilderness Inventory and Evaluation Report are attached as Exhibit 2. After applying its rationale, the Flathead National Forest ultimately decided that timber harvests 40-years-old and younger would be excluded from the inventory:

Based on the following factors, the planning team determined that regeneration timber harvest (such as clearcuts and seed tree harvests) and associated road-building activities that were conducted within the last 40 years (since 1974) are substantially noticeable on the Flathead National Forest. This determination was based on factors such as tree height growth, stand productivity, stand densities, time of tree regeneration, topographic features (such as slope), abundance and type of ground vegetation (such as shrub density), and distance from harvested area. There is obvious variability in stand conditions across the Forest, but for the purposes of this inventory process and due to the need to

3 The data layer shows that the GMUG excluded 2,265 project areas totaling 167,769 acres that date back 50 years or more. 4 See Final Environmental Impact Statement for the Forest Plan Flathead National Forest, Volume 4: Appendices and Glossary, December 2017. Pages 4-7 to 4-13. Available at https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd566351.pdf.

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consider all National Forest System lands outside of existing wilderness (1,024,526 acres), the timeframe of 40 years was used as a point of time within which, in general, areas harvested were considered substantially noticeable. However, the planning team reviewed in detail areas that had had regeneration harvests as well as fire to determine whether the fire had ameliorated the effects of the harvesting. The planning team made a case- by-case determination of whether those areas were still considered to be substantially noticeable.

Id. at 4-9.

The Santa Fe National Forest in New Mexico in the last year published its final wilderness inventory criteria.5 It established that other improvements that are substantially noticeable in the area as a whole must be:

1. substantially noticeable according to [the forest’s] definition [which is the same as the GMUG’s definition] 2. widespread in the landscape, reflecting pervasive past human influence 3. visible using aerial imagery at the forest-wide scale (1 inch = 1 mile) or if not visible on aerial imagery, have a pervasive impact on the area when viewed from the ground. This pervasive impact determination will be based on field knowledge and documented in this process.

Id. at 4. Like the Flathead National Forest, the Santa Fe National Forest also distinguished between vegetation management and timber harvest projects, including the former in the inventory.6 It eliminated from the inventory “[c]lear cut forested areas, fuel breaks, and areas of pinyon-juniper chaining that are currently substantially noticeable on the area as a whole” explaining that “[s]ubstantially noticeable means the treatment is more dominant than the surrounding landscape. Edges of the treatment create a noticeable difference in form, line and texture found in the landscape, being dominant, abrupt, strongly defined, vegetation regeneration is minimal.” Id. at 5. The Santa Fe notes that excluded areas are not “solely based on FACTS reporting, but on what can be seen on aerial photography at a 1 inch = 1 mile or 1:63,360 scale. FACTS or other evidence of past activities may be used to locate potential exclusions, but substantially noticeable judgement is based on aerial photo interpretation.” Id. at 5, footnote 8.

Recommendation: The GMUG must develop a reasonable method to identify the vegetation management and timber harvest areas that are substantially noticeable to the area as a whole, and those that are not. Using the revised methodology, the GMUG must correct the wilderness inventory so that improvements that are not substantially noticeable are included in the inventory polygons. The GMUG should examine locations where CRAs have excluded acreage, and, in all cases where the agency is unable to demonstrate the presence of a

5 Inventory and Evaluation Process for Lands that may or may not be Suitable for Inclusion in the National Wilderness Preservation System, Santa Fe National Forest. Final Inventory Criteria. Available at: https://www.fs.usda.gov/detail/santafe/landmanagement/planning/?cid=fseprd530212 6 Id. at 5. The Santa Fe included in the inventory “vegetation treatments such as prescribed fire use and non-commercial fuels reduction treatments that do not produce wood products, areas of sage mowing…[and] [a]reas with legacy (closed) logging roads, fuelwood, or other thinned areas and other timber harvest areas where logging and prior road construction are not substantially noticeable.”

6 substantially noticeable impact or a ML 2-5 road, the GMUG should remove the exclusion and ensure that the entire CRA is included in the final inventory.

2. Improvements related to mineral development.

The GMUG draft wilderness inventory criteria documents states that areas of mining activity (“wells, and mine tailings, adits, and ponds”) are excluded from the inventory. The document states that all wells are considered substantially noticeable:

Wells/well pads, even if plugged and abandoned, are considered substantially noticeable.10 These are excluded from the inventory with a 300-foot buffer.11

Id. at 6.

It does not provide a similar statement related to the removal of mining related improvements.7 The draft criteria document does not explain why all wells are considered substantially noticeable. It is entirely conceivable that some old well pads, long abandoned, plugged or retired, are not. Similarly, while we do not doubt that some improvements related to mining are substantially noticeable, we are equally sure that some are not. The lone adit on a mountainside, for instance, would not be substantially noticeable to the area as a whole. For example, Exhibit 3 provides photographs of mine features that were excluded inappropriately from polygon 51 (Hayden Mountain). The features are substantially unnoticeable to the area as a whole and do not dominate the larger landscape.

The GMUG staff helpfully provided the GIS layer used for mining features, which we examined. The mine data is of mine hole openings (shafts, stopes, holes, pits or adits) and tailing pile features (mine dumps, tailings, waste, overburden, dredge, placer or hydaulic deposits, highwall or processing sites)8 associated with abandoned mineral lands. The mine hole data set includes information on the physical condition and environmental rating of the features. The former ranges from Intact to Not Found, and the latter ranges from Extreme (1 point) to None (5 points). The GMUG contains 2,488 (of a total of 5,567) mine hole features. One hundred and eighty-four have N (not found), 846 F (filled or collapsed), 956 I (intact), 489 P (partially filled or collapsed), and 13 unknown; 2,163 have environmental degradation rating 5 (none), 135 have ratings of 3 or 4, 42 have rating 2, 1 has an extreme rating, and 57 are rated as unknown. Three hundred and nineteen features are located in designated Wilderness on the GMUG. Of these, 108 are rated as Intact, and 34 have an environmental rating of 2 to 4.

The tailings pile data set also includes information on the physical parameters (including dimensions, and whether the vegetation on the feature has regrown to be Dense, Moderate, Sparse, or Barren) and environmental rating of the features ranging from None (5 points) to Extreme (1 point). There are 1,637 (of a total of 3,442) tailings features on the GMUG. One hundred and forty-two have Dense vegetation, 487 have Moderate, 664 have Sparse, 320 have Barren, and 44 are rated unknown; 1,305 have Environmental Rating of none (5 points), 201 slight (4 points), 82 potentially significant (3 points), 26 significant (2 points), and 23

7 Note that footnote 10 is missing from the document. 8 These descriptions are copied from the metadata accompanying the GIS layer.

7 unknown. None are extreme (1 point). The average footprint of tailings pile features within the GMUG is 1,841 square feet. Two hundred and twenty-seven tailings features are located within designated Wilderness with an average footprint of 931 square feet. Of these, 212 have Moderate, Sparse, or Barren vegetation density (i.e., not dense), and 44 have environmental rating 2 - 4 (significant to slight, i.e., not none).

These findings are not unexpected given that the GMUG used an abandoned mineral land dataset. The Colorado high country, within and outside of designated Wilderness, is pockmarked with evidence of historical mining such as small mine openings, pits, and dump piles. The vast majority of these features are minor and not impacting, and not substantially noticeable to the area as a whole. In fact, it is very likely that wilderness inventory polygons that contain these types of features would be identified as having historical value in the wilderness evaluation. See FSH 1909.12, chapter 70, section 72.1(4) (“Evaluate the degree to which the area may contain ecological, geological, or other features of scientific, educational, scenic, or historical value. These values are not required to be present in an area for the area to be recommended for inclusion in the National Wilderness Preservation System, but their presence should be identified and evaluated where they exist. Such features or values may include:… Historic and cultural resource sites…”).

As far as we can tell, the GMUG did not attempt to use the attributes in the dataset to distinguish the substantially noticeable features from the substantially unnoticeable features, and instead excluded all features along with a 300-foot buffer. This included mine holes where the condition of the hole is Not Found.9 As with vegetation management and timber harvest areas, the GMUG must have a rational basis for identifying the improvements related to mineral development that are and are not substantially noticeable to the area as a whole. In addition, in the specific case of mine features, the GMUG made an irrational choice to use a dataset of abandoned mineral lands that mainly includes historic mining features instead of a data set of active mining operations. If the GMUG persists in using the abandoned mineral land data base it must use the attributes to identify the features that might possibly have substantially noticeable features and then check the sites, ideally in the field, but at a minimum through google earth or aerial imagery.

Looking again for lessons from other forests who have recently completed wilderness inventories, the Santa Fe National Forest chose to include sand and gravel pits, permit rock collection areas, small mining claims, historic mining evidence, and other areas of mining activity where impacts are not substantially noticeable, and excluded from the inventory areas of commercial open pit mining that have not undergone reclamation, active mining operations, gas extraction wells, and areas of active mine reclamation. Supra. Page 5.

Recommendation: The GMUG must develop a rational basis for identifying the improvements associated with mineral development that are substantially noticeable to the area as a whole. Using the revised methodology, the GMUG must correct the wilderness inventory so that improvements that are not substantially noticeable are included in the inventory polygons. The GMUG should strive to find and use a data base of active mining operations to do this. If the GMUG persists in using the abandoned mineral land data base, it must use the

9 For instance, some of the features excluded from polygon 51 (Hayden Mountain) have this description.

8 dataset’s attributes to identify the features that might possibly have substantially noticeable features and then check the sites, ideally in the field, but at a minimum through google earth or aerial imagery.

3. Watershed treatment areas - ditches, dams, reservoirs

The draft wilderness inventory criteria document states that ditches, dams, and reservoirs are excluded from the inventory polygons. Clearly large water development features are likely substantially noticeable, but small features, such as small isolated drainage ditches and stock ponds, may not be. We cannot tell from the draft criteria document what data sources the GMUG used to identify features that merit exclusion.

Recommendation: The GMUG should clarify what data sources it used, and whether those sources have the necessary detail to discern substantially noticeable features. If the data is not as fine scaled as required, the GMUG must develop and apply a rational basis for including and excluding water development features.

II. Clarify how the GMUG will correct the wilderness inventory based on changes to criteria document and public comment.

We are concerned that the following paragraph (draft criteria document, page 4) wrongly gives the impression about the fate of wilderness inventory areas in which substantially noticeable improvements were mistakenly included (because of the coarse nature of the GIS data available that impedes the accurate identification through computer mapping of the substantially noticeable improvements).

Not all improvements that are substantially noticeable are eliminated from the draft Inventory due to the assumptions made below. For instance, some features on a landscape may be substantially noticeable but are located outside of an established road buffer. It is important to remember that all of these features will be considered during the next stage of the wilderness process: Evaluation. During the evaluation stage, an area included in the inventory may ultimately be evaluated as possessing very low wilderness characteristics if improvements are considered to be very evident on the landscape. An area included in the inventory may be removed from further contemplation in the evaluation stage altogether, if improvements are considered to be substantially noticeable on the landscape.

The paragraph states that a wilderness inventory area in which substantially noticeable improvements were mistakenly included would either in the evaluation phase 1) be ranked as having low wilderness character, or 2) be eliminated from further contemplation. The more appropriate approach is that the disqualifying portions of wilderness inventory areas would be excluded from the polygons so long as the total polygon acreage continued to exceed 5,000 acres or the area is of sufficient size as to make practicable its preservation and use in an unimpaired condition. It is not appropriate to either eliminate the entire area or say that it has low wilderness character because of the presence of a substantially noticeable improvement that should not have been included in the area in the first place (and would not have been if the GMUG had more discerning computer data or had conducted a field inventory in addition to the GIS mapping exercise).

In addition, the draft criteria document does not explain how the GMUG will correct inappropriate exclusions of qualifying acres in the evaluation stage. Just as the GMUG in the evaluation stage may find substantially noticeable features within inventory polygons, it may also find that acres were inappropriately excluded by the incorrect presumption of the existence of a substantially noticeable feature. The first type of mistake should be

9 corrected as described above, and the second should be corrected by expanding the inventory boundary out to disqualifying features.

Recommendation: Modify the paragraph to clarify how mistaken inclusions of substantially noticeable improvements will be addressed as follows (additions are in bold, deletions in strike-through text):

Not all improvements that are substantially noticeable are eliminated from the draft Inventory due to the assumptions made below and the fact that the GMUG did not field-check the computer-generated maps. For instance, some features on a landscape may be substantially noticeable but are located outside of an established road buffer. In finalizing the wilderness inventory, the GMUG will modify the polygon boundaries in response to public comment and subsequent fieldwork that will occur during the evaluation stage It is important to remember that all of these features will be considered during the next stage of the wilderness process: Evaluation. When we find that substantially noticeable improvements were mistakenly included within inventory areas, we will modify the boundary to exclude the improvements. If the boundary adjustment shrinks the polygon acreage below 5,000 acres, we will re-apply the size criteria described on page 2 of this document. Conversely, when we find that polygon boundaries were drawn to exclude improvements that we subsequently determined were not substantially noticeable, we will expand the boundaries accordingly. During the evaluation stage, an area included in the inventory may ultimately be evaluated as possessing very low wilderness characteristics if improvements are considered to be very evident on the landscape. An area included in the inventory may be removed from further contemplation in the evaluation stage altogether, if improvements are considered to be substantially noticeable on the landscape.

III. Comments on specific inventory polygons

Exhibit 4 details concerns that we have with the current boundaries of specific inventory polygons by national forest. For each polygon, we describe our concern, provide a recommendation to address our concern along with supporting evidence. The supporting evidence is usually in the form of a photograph or google earth screenshot. Our approach was to document the most serious concerns associated with polygons that overlap tracts we or GPLI have prioritized for protection, and then rely on the GMUG to adjust the inventory more generally based on our feedback in Section I of this letter. Please do not assume that if we did not provide a comment on a specific polygon we are satisfied with the inventory boundaries; given the short timeframe, we did not have time to closely review and provide feedback on all polygon boundaries.

Thank you for the opportunity to comment. We would be glad to meet in person or on the phone with the planning team to discuss our comments and possible ways to address the deficiencies discussed above. As always, we appreciate the hard work that you are putting into this plan revision, and your consistent willingness to answer questions and provide clarifications upon request.

With regards,

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Vera Smith Matt Reed Forest Planning and Policy Director Public Lands Director The Wilderness Society High Country Conservation Advocates 1660 Wynkoop Street, Suite 850 PO Box 1066 Denver, CO 80202 Crested Butte, CO 81224 303-650-5942 970-349-7104 [email protected] [email protected]

Steve Allerton Mark Pearson President Executive Director Western Colorado Congress San Juan Citizens Alliance 134 N 6th St 1309 East Third Avenue Grand Junction, CO 81501 PO Box 2461 Durango, CO 81302 970-256-7650 office: 970.259.3583 Ext. 1 [email protected] sanjuancitizens.org

Scott Braden Rocky Smith, Forest Management Analyst Wilderness & Public Lands Advocate 1030 Pearl St. #9 Conservation Colorado Denver, CO 80203 1536 Wynkoop St. #510 303 839-5900 Denver, CO 80202 [email protected] [email protected] 720-530-7473 Jim Stephenson: Public Lands Chairman Ridgway Ouray Community Council Robyn Cascade & Laurie Shannon, Co-Leaders PO Box 272 Northern San Juan Chapter (Ridgway) Ridgway, CO 81432 Great Old Broads for Wilderness 970/626-5594 C/o PO Box 2924 Durango, CO 81302 Shannon Laun 970-385-9577 Staff Attorney [email protected] Western Environmental Law Center 1402 Third Ave. Suite 1022 Karen Tuddenham Seattle, WA 98101 Executive Director Ph: (206) 487-7225 Sheep Mountain Alliance [email protected] PO Box 389 www.westernlaw.org Telluride, CO 81435 970-728-3729 Alex Johnson [email protected] Executive Director Western Slope Conservation Center Alison Gallensky 204 Poplar Ave, Paonia, CO 81428 GIS & IT Director (970) 527-5307 Rocky Mountain Wild [email protected] 1536 Wynkoop St., Suite 900 Denver, CO 80031 (303) 619-0509 [email protected]

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Sherry Schenk Leader Grand Junction Chapter Great Old Broads for Wilderness 379 Ridge View Drive Grand Junction, CO 81507 970-596-8510 [email protected]

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Exhibit 1: Example of Inappropriate Exclusion of Acreage in Inventory Unit 7 (Kelso Mesa)

The draft inventory excludes about 4,000 acres of Escalante Breaks, the portion of the Inventory Unit 7 (Kelso Mesa) Colorado Roadless Rule Area bounded by FDR 409 (Brushy Ridge Road) on the north and by the rim of North Fork Escalante Creek on the south. This is apparently owing to past mechanical treatments for wildlife habitat improvements. There are no substantially noticeable impacts on the ground, and there are no open roads in the excluded tract.

Two photos at the Short Point Cutoff Trailhead provide an overview of the area, indicated as 7-A and 7-B on the Google Map capture below.

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Photo 7-A: Short Point Cutoff Trailhead on Brushy Ridge Road, FDR 409, indicating no mechanized travel is allowed into the Escalante Breaks component of Inventory Unit 7 (Kelso Mesa) that is under discussion here.

Photo 7-B: Overview into the excluded Escalante Breaks component of Inventory Unit 7 (Kelso Mesa) that is under discussion here.

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Exhibit 2: Excerpts from the Flathead National Forest Wilderness Recommendation Process Report Related to Other Improvements.

Excerpted from the bottom of Page 4-6 through 4-10.

Other improvements Other improvements on the Forest were reviewed to determine whether to include or exclude certain areas in the inventory (table 4-1). Guidance on improvements considered can be found in Forest Service Handbook 1909.12 chap. 70 sec. 71.22b.

Table 4-1. Determination of whether areas with certain types of improvements were included or excluded from the Flathead National Forest wilderness area inventory, with guidance from the Forest Service Handbook.

Improvement Type and Guidance Remarks Airstrips were excluded from the inventory because the Airstrips three existing airstrips on the Forest are next to open roads. These are temporary structures and were included in the Heliports inventory, when present. These were included in the inventory. The definition of Vegetation treatments that are not substantially “substantially noticeable” and how the interdisciplinary noticeable. team used the concept in the inventory is presented on pp. 4-14 to 4-15. Timber harvest areas where logging and prior road construction are not substantially noticeable were included in the inventory. Areas where regeneration harvest had taken place within the last 40 years and where significant Timber harvest areas where logging and prior road fire had occurred were reviewed in detail to determine if construction are not substantially noticeable. they should be included in the inventory. The determination for substantially noticeable, and how the interdisciplinary team used the concept in the inventory, is presented on p. 4-6. Permanently installed vertical structures, such as It was determined that these vertical structures have electronic installations including cell towers and minimal impact, including their maintenance and access television, radio, and telephone repeaters, provided requirements; therefore, areas with vertical structures were their impact, as well as their maintenance and included in the inventory. access needs, are minimal.

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Improvement Type and Guidance Remarks Few areas of historical mining activity exist on the Flathead Areas of historical mining where impacts are not National Forest; therefore, these areas were included in the substantially noticeable. inventory. Areas of mining activity are minimal on the Flathead Areas of mining activity where impacts are not National Forest; therefore, these areas were included in the substantially noticeable. inventory. Range improvement areas with minor structural improvements (for example, fences or water Few areas that have range improvements exist on the troughs) and non-structural improvements (chaining, Flathead National Forest; therefore, these areas were burning, spraying, potholing, and so forth) that are included in the inventory. not substantially noticeable. Areas with dispersed camping sites and outfitter camps Recreational improvements, such as occupancy were included in the inventory as they are temporary and spots or minor hunting or outfitting camps. As a easily removed. general rule, do not include developed sites. Areas with minor, easily removable recreation Areas with developed recreation sites were excluded from developments may be included. the inventory. Note: trails are not considered a recreational improvement. Whether these are included or excluded is dependent on Ground-return telephone lines, electric lines, and the type of phone or power line. Most power lines are in power lines if a right-of-way has not been cleared. main road corridors, which were not included in the Exclude power lines with cleared right-of-ways, wilderness inventory areas. Small buried water pipelines, and other permanently installed linear transmission lines were included in the wilderness right-of-way structures. inventory. Watershed treatment areas (contouring, diking, channeling) that are not substantially noticeable or where the wilderness characteristics can be Few areas of watershed treatment exist on the Flathead maintained or restored through appropriate National Forest; therefore, these areas were included in the management actions. Areas may include minor inventory. watershed treatments that have been accomplished manually, such as small hand-constructed gully plugs. Lands adjacent to development or activities that impact opportunities for solitude. The fact that a Areas adjacent to development or activities were included non-wilderness activity or use can be seen or heard in the inventory. from within any portion of an area shall not, of itself, preclude inclusion in the inventory. Areas with structures, dwellings, and other relics of past Structures, dwellings, and other relics of past occupation that are considered part of the historical and occupation that are considered part of the historical cultural landscape of the area were included in the and cultural landscape of the area. inventory.

Areas Included in the Inventory The areas listed in table 4-2 are areas the planning team identified and included in the inventory and carried forward for further evaluation. For step 2, the wilderness evaluation, the interdisciplinary team took a more detailed look at these inventoried areas to determine how well they meet wilderness characteristics, using a set of criteria based on the Wilderness Act of 1964.

Table 4-2. Wilderness Inventory Areas (Names and Acreage)

Area Acres Beaver Lake 3,542 Bob North** 88,041 Canyon 18,814

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Area Acres Coal 67,184 Cold Creek 674

Crane Porcupine2 5,338 Demers 6,959 Elk Creek 7,739 Essex 23,061 Fatty Creek 4,963 Glacier Creek 2,590 Hungry Horse Reservoir East* 37,152 Hungry Horse Reservoir West* 178,536 Jim Creek 1,509 Le Beau 6,340 Lindbergh Lake 1,019 Meadow Lake 1,033 North Fork Cold Creek 445 Piper Creek 590 Puzzle 24,110 Sky West 6,266 Swan Face South* 52,958 Tuchuck 34,189 Whale 69,597 Woodward Creek 2,198 TOTAL 644,847 3 * Previously part of the Bear-Marshall-Scapegoat-Swan-Hungry Horse area. ** The Bob North area was revised on August 19, 2014, to exclude Silvertip Cabin, a reduction of 52 acres.

Determining substantially noticeable The term “substantially noticeable,” as it relates to wilderness evaluations, is not defined in the Forest Service Handbook’s sections on wilderness evaluation (Forest Service Handbook 1909.12 chaps. 70, 71.22b). The planning team’s vegetation, and scenery specialists developed a process to determine “substantially noticeable” in regards to timber harvest and associated roads. The process focused on what a viewer would likely observe when viewing harvest areas and associated roads from the background, midground, and foreground of an area. This process assisted in determining whether or not vegetation treatments, timber harvest, and prior road construction are substantially noticeable and, consequently, whether or not an area should be included or excluded from the wilderness evaluation inventory.

2 When reviewing the wilderness inventory process, the planning team identified this new area that was over 5,000 acres. 3 Because the Bear-Marshall-Scapegoat-Swan-Hungry Horse area in the draft wilderness inventory was very large (352,165 acres), the planning team felt that to adequately evaluate the land for wilderness character, it was necessary to separate this area into smaller parts. The Bear-Marshall-Scapegoat-Swan-Hungry Horse area was divided along the geographic area boundary lines, except for splitting the Swan Face area from the Hungry Horse Reservoir (to make the Hungry Horse Reservoir West polygon), which followed the 1986 forest plan’s recommended wilderness line for a short distance.

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For the purpose of this wilderness evaluation process, vegetation treatments and timber harvest are considered different activities.

Vegetation treatments These include only prescribed fire use and non-commercial fuel reduction treatments that do not produce wood products. These types of treatments generally have not created substantially noticeable effects on the Flathead National Forest landscape. For these reasons, the planning team included vegetation treatment areas in the wilderness evaluation inventory.

Timber harvest activities Based on the following factors, the planning team determined that regeneration timber harvest (such as clearcuts and seed tree harvests) and associated road-building activities that were conducted within the last 40 years (since 1974) are substantially noticeable on the Flathead National Forest. This determination was based on factors such as tree height growth, stand productivity, stand densities, time of tree regeneration, topographic features (such as slope), abundance and type of ground vegetation (such as shrub density), and distance from harvested area. There is obvious variability in stand conditions across the Forest, but for the purposes of this inventory process and due to the need to consider all National Forest System lands outside of existing wilderness (1,024,526 acres), the timeframe of 40 years was used as a point of time within which, in general, areas harvested were considered substantially noticeable. However, the planning team reviewed in detail areas that had had regeneration harvests as well as fire to determine whether the fire had ameliorated the effects of the harvesting. The planning team made a case- by-case determination of whether those areas were still considered to be substantially noticeable. If they were determined not to be substantially noticeable, they were included in the wilderness inventory. If they were determined to be still substantially noticeable, they were excluded from the inventory.

Tree growth rates (height growth), especially in young, immature tree stands, depend upon site productivity. Average stand height growth was estimated across all sites on lands suitable for timber production. On the better growing sites of the Flathead National Forest, the average stand height increases by about 11 inches per year during the first 40 years of growth. On the poorest sites, average stand height may increase on average about 6 inches per year. Therefore, on the Flathead National Forest, a 40-year- old stand would generally have a height range of 20 to 37 feet, depending on site productivity.

What a viewer is likely to see Boundaries of past regeneration harvest units on the Flathead National Forest are typically geometric in shape, with straight lines that contrast with unharvested areas. When viewed from the background (4 or more miles away), harvested areas are typically very distinct, with the line of delineation between harvested areas and unharvested areas substantially noticeable from the background view.

Roads within and surrounding harvested areas are particularly visible during the first few decades after harvest until young trees have gained sufficient height to block views of the roads. In areas with steep terrain, the steep slopes increase the visibility of prominent cut-and-fill slopes and require longer time periods before trees are tall enough to block continuous views of the roads.

After four decades, trees should generally be high enough (20 to 37 feet) to reduce the line of delineation between harvested and unharvested areas as well as to intermittently break up views of road cuts and fills.

In the midground view (0.5 to 4 miles from viewer), evidence of past regeneration harvested units are similar to background views except that the viewer may not have a continuous line of sight as when viewing from the background view. The line of delineation between harvested and unharvested areas, as well as road cuts, may be interrupted due to terrain and vegetation.

18

In the foreground view (0 to 0.5 mile from viewer), stumps are generally still evident within four decades after harvest, particularly in drier areas, because decomposition is relatively slow under the dry and cold conditions of the Flathead National Forest. After four decades, stumps have decomposed or ground covers (shrubs) sufficiently block the visibility of the stumps. Road cuts may be long lasting and evident to the foreground viewer for longer than 40 years. The delineation between harvested and unharvested areas diminishes as young trees grow and reduce views within the harvested area.

Wildfire may soften edges created by the delineation between harvested and unharvested areas and skyline corridors; it may also burn stumps, standing trees, and logging residue such as branches and boles and thus reduce the visual effect of harvesting. However, it may also expose more roads associated with the harvested area. When reviewing harvested areas where fire occurred, the planning team utilized the web tool Google Earth to view areas post-fire and consulted with district staff knowledgeable about the areas.

After considering tree height growth, stand productivity, stand densities, time of tree regeneration, topographic features, and abundance and type of ground vegetation at different viewing distances, areas of past harvest were generally found to be substantially noticeable, on average, for at least 40 years from time of harvest. The high-contrast edges created by the harvest, associated road cuts, and evidence of mechanical harvest (such as visible stumps or skyline corridors) within these areas were the most prominent features affecting the substantially noticeable determination. As mentioned before, the effects of fire were also taken into account, and a determination was made on a case-by-case basis to determine whether an area harvested within the last 40 years was no longer substantially noticeable due to fire in the harvest area.

19

Exhibit 3: Examples of mine features in Senator Beck basin that are not substantially noticeable on the GMUG yet excluded from polygon 51 (Hayden Mountain) in the draft inventory.

Image 1: A google earth screenshot showing the upper Senator Beck basin. The mine is not visible because it is hidden by the undulating landscape. It sits on the far edge of the basin. The only way to see it is to hike right up to it. There is one historic standing structure left. The photographs below depict scenes at the yellow pins on this image.

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Photograph 1: This photograph shows old tailings piles. These features are not more dominant than the surrounding natural landscape scene and therefore are substantially unnoticeable.

Photograph 2: This photograph, which looks south, shows the one standing structure in the area, referenced above. In the background is Trico Peak. These features are not more dominant than the surrounding natural landscape scene and therefore are substantially unnoticeable. The structure adds historic character.

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Exhibit 4: Comments on Specific Wilderness Inventory Polygons

Gunnison NF

Wilderness Comments on Polygon Boundary Recommendation to Correct Description of Supporting References to Overlapping Inventory Issue Evidence Supporting Evidence proposed Polygon conservation Number area1

62 Draft Inventory boundaries appear to Include these areas within the Google Earth Screenshot 62-A, B Cataract be accurate, with the exception of Inventory. Wilderness the exclusion of areas around two historic mine holes in the far western part of the polygon.

143 Draft Inventory boundaries appear to Cochetopa be accurate. Creek Wilderness

165 The Draft Inventory arbitrarily Include these areas within the Google Earth Screenshots 165-A, B Cochetopa excludes historic timber and mining Inventory. Hills Linkage activities that are not substantially Area noticeable. For example, on the western side of polygon 165, in the vicinity of Mill Creek and Razor Creek, several historic cuts totaling over 100 acres are excluded. See 165-A for one of these examples, an 18-acre cut that was completed in 1900, almost 120 years ago, and that is within upper tier roadless! This indiscriminate exclusion pattern is

1 A draft conservation proposal was shared by signatories of this letter with the GMUG planning staff in November 2017. repeated across this special landscape.

Also excluded are historic mine sites that are not substantially noticeable, such as the site identified in 165-B.

165 The northeastern corner of this Include these areas within the Google Earth Screenshots 165-C Lake Branch polygon does not include all available Inventory. Wilderness qualifying acres. Over 100 acres of Wilderness-quality, upper tier roadless forest are excluded because of timber projects dating to 1925 and 1950. Immediately to the east, the Inventory excludes a timber project from 1908. See 165-C. None of these are substantially noticeable.

140 The polygon excludes from the draft Include this area within the Google Earth Screenshot 140-A Sawtooth Inventory a single-tree selection Inventory. Wilderness harvest that was completed in 1960. This arbitrarily eliminates a 74-acre area that should be included.

165 Draft Inventory boundaries appear to West Baldy be accurate. Wilderness

Areas Identified for Conservation by Signatories on Gunnison Public Lands Initiative (GPLI)2

146 Draft Inventory boundaries appear to East Cement be accurate. Wilderness

2 https://www.gunnisonpubliclands.org/ 151 Draft Inventory boundaries appear to Fossil Ridge be accurate. Wilderness Addition: Crystal Creek

163 Draft Inventory boundaries appear to Fossil Ridge be accurate. Wilderness Addition: Lottis Creek

138 Draft Inventory boundaries appear to Maroon Bells be accurate. Wilderness Addition: Deer Creek

155 The northern quarter of polygon 155 Include these areas within the Google Earth screenshots, 155-A, B Matchless does not include all available qualifying Inventory. which show that impacts Wilderness acres. The inventory excludes from from these timber GPLI’s recommended Matchless projects are not Wilderness approximately 58 acres in substantially noticeable. three tracts that were part of a 1992 timber sale. Signs of the management activities are hard to see and certainly are not more dominant than the surrounding landscape scene.

Immediately to the north, within the Matchless SMA, the Draft Inventory excludes a patchwork of hundreds of acres of wilderness-quality lands related to past timber activities. Most if not all of these are not substantially noticeable. For example, one area excluded from the Inventory is a 10- acre disease control project completed in 1983. See 155-B. Within that project area are several very small openings in the canopy, but they are certainly not “more dominant than the surrounding natural landscape.”

91 Draft Inventory boundaries appear to Raggeds be accurate. Wilderness Addition: Munsey Creek- Erickson Spring

124 The GPLI Poverty Gulch Wilderness Include these areas within the Google Earth screenshot 124-A Raggeds area, within polygon 124, has a circular Inventory. Wilderness area excluded from it in the Draft Addition: Inventory. This area is approximately Poverty Gulch 600 feet in diameter, and is identified as a mine hole and tailings. We are familiar with this specific area, and any signs of historic mining activities at that specific area are not more dominant than the surrounding landscape scene.

147 The Inventory excludes areas around Include these areas within the Google Earth screenshot 147-A Star Peak two historic mine holes on the summit Inventory. Wilderness of Carbonate Hill. Neither are substantially noticeable. See 147-A.

65 The Inventory removes approximately Include these areas within the Google Earth screenshot 65-A Uncompahgre 130 acres of wilderness-quality land Inventory. Wilderness from the southeastern portion of the Addition: polygon, attributable to the presence Failes of the Thompson Ditch No. 2 and to Creek/Soldier two historic timber projects. Creek

The timber projects were completed in 1900, and total 130 acres. These 118- year old improvements are not substantially noticeable.

65 Draft Inventory boundaries appear to Uncompahgre be accurate. Wilderness Addition: Little Cimarron

58 The GMUG’s inventory of Polygon Include these areas within the Google Earth screenshots 58-A, B, C, D Uncompahgre 58/Turret Ridge is particularly Inventory. Wilderness troubling. The draft inventory excludes Addition: hundreds of acres, much of it within Turret Ridge upper tier roadless lands, based on past timber projects. This arbitrarily excludes some of the most outstanding wilderness-quality lands in an iconic and rugged part of the forest.

The three areas removed from the inventory on the southwest side of the polygon represent approximately 29 acres that were cut in 1966. These acres are identified as upper tier roadless. They are not substantially noticeable. See 58-A.

In the extreme southeast part of the polygon, approximately 69 areas that have been removed from the draft inventory are labeled as “Plant Trees” from 1983. These 35-year old plantings are not substantially noticeable. See 58-B.

Directly to the north is another tree planting that was completed in 1983 that is excluded from the Inventory, totaling 22 acres. See 58-C.

This pattern of excluding wilderness- quality lands because of exceedingly old timber cuts and vegetation treatments extends along the eastern flank of Turret Ridge all the way to its northern terminus. Dates for these treatments are from 1958, 1960, 1962, 1966, 1968, and 1983, and the majority of the excluded acres are within upper tier roadless area. To illustrate one particularly arbitrary exclusion, the Inventory excludes a 140-acre project that was completed in 1966. See 58-D. It is within upper tier roadless lands, and in no way is substantially noticeable within this wild and forested landscape.

82 Draft Inventory boundaries appear to West Elk be accurate. Wilderness Addition: Beckwiths

109, 117 The inventory excludes hundreds of Include these areas within the Google Earth screenshots 117-A, B West Elk acres from polygon 117, including Inventory. Wilderness lands identified as upper tier roadless. In the southeastern portion of the Addition: polygon, between Squirrel Creek and Castle Mill Creek, the Inventory excludes over 200 acres because of historical timber cuts and vegetation treatments. These projects date to 1965, 1966, 1967, and 1972. We are intimately familiar with this particular landscape. It is heavily- forested, and to the extent that there are small openings within the excluded areas, they appear natural, and certainly are not substantially noticeable.

64 The Draft Inventory excludes Include these areas within the Google Earth screen shots 64-A, B, C West Elk numerous historical, mine-related sites Inventory. Wilderness from polygon 64, including five areas Addition: Coal within the proposed Coal Mountain Mountain addition to the West Elk Wilderness.

Five of the exclusions are for solitary mine hole openings, while one also is associated with a tailings pile. All five are deep in the backcountry, and in no way are substantially noticeable.

110 Draft Inventory boundaries appear to West Elk be accurate. Wilderness Addition: Beaver

83 The Draft Inventory excludes several Include these areas within the Google Earth screenshots 83-A, B West Elk historical cuts and tree plantings along Inventory. Wilderness the eastern and northern parts of Addition: polygon 83. Dillon Mesa

On the eastern side of the proposed Dillon Mesa Wilderness area, alongside Road 723, the Inventory excludes almost 100 acres because of cuts completed in 1920. A subpart of this excluded area also saw sanitation cut that occurred in 1966. This part of the polygon is a rolling terrain of mixed forest and sagebrush, and nothing in the excluded area is substantially noticeable. See 83-A.

Moving further north along the polygon to its terminus, the Draft Inventory arbitrarily excludes hundreds of acres of historic tree plantings and timber cuts. These appear to be related to several projects occurring between 1958 and 1977. Much of the vegetation changes from these projects are invisible from the air. Other areas appear as small openings from the air, but are not substantially noticeable and are not “more dominant than the surrounding natural landscape scene.” While this part of the forest has witnessed concentrated timber projects in the past, the most recent one is still over 40 years old. See 83-B. 98 The Draft Inventory arbitrarily excludes Include these areas within the Google earth screenshots 98-A, B West Elk numerous small timber and vegetation Inventory. Wilderness projects from polygon 98 and the East Addition: East Elk Wilderness proposal area. These Elk Creek range in project diversity from a 1985, 3.47-acre clear cut on the margins of the forest (See 98-A), to a 69-acre tree planting completed in 1972 (See 98-B). This is a wild and rugged landscape, with numerous natural openings in the forest. None of the excluded areas appear to be substantially noticeable.

110 The Draft Inventory excludes 410 Include these areas within the Google earth screenshots 110-A, B West Elk acres, or 5%, from the proposed Inventory. Wilderness Steuben Wilderness addition. As with Addition: most of the excluded areas on Steuben Wilderness-quality lands in the southern West Elk Mountains, the Draft Inventory excludes many of these areas because of historic timber projects.

For example, almost in the middle of polygon 10/Steuben Creek, the Inventory excludes a 41-acre cut that occurred in 1920. See 110-A. In the extreme southeast corner of the polygon, the Inventory excludes a 16- acre cut from 1920 (See 110-B). Neither of these 98-year old projects is substantially noticeable.

64 The Draft Inventory excludes a solitary Include these areas within the Google earth screenshots 64-D, E, F West Elk mine hole near the northern end of Inventory. Wilderness polygon 64, and within the proposed Addition: Curecanti Wilderness addition. See 64- Curecanti D. The historic feature is not substantially noticeable.

The Inventory also excludes hundreds of acres on the west side of Curecanti Creek, and within upper tier roadless lands, because of historic timber projects. These include a 35-acre clearcut completed in 1960 (see 64-E), as well as connected network of old tree plantings from the early 1980s (see 64-F). None of the improvements associated with these exclusions are substantially noticeable.

64 The Draft Inventory unjustifiably Include these areas within the Google Earth screenshots 64-G, H West Elk excludes many acres from the Inventory. Wilderness Mendicant area due to a variety of Addition: reason. Mendicant

Deep in the backcountry, in some of the wildest lands on the Gunnison National Forest north of Bald Mountain, the GMUG has excluded an area around an historic mine hole. It is in no way substantially noticeable. See 64-G.

The Draft Inventory also excludes several hundred acres due to historic timber projects, most notably on the western flanks of Mendicant Ridge. Most of these date to the mid-1960s, and the past 50 years have obliterated any substantially noticeable signs of these improvements. See 64-H.

78 Draft Inventory boundaries appear to West Elk be accurate. Wilderness Addition: Soap Creek

GPLI Areas (Special Management Areas)

150 The Inventory removes Include these areas within the Google Earth 150-A, B American Flag acreage from the southwest side of the Inventory. screenshots show that polygon. This appears to be related to impacts from this timber two timber cuts, neither of sale are not substantially which appear to be substantially noticeable. noticeable to the landscape as a whole. The logging, identified by the agency as establishment and preparatory cuts, were completed in 1988 and 1995

82 The Inventory removes significant Include these areas within the Google Earth Screenshot 82-A Beckwiths acreage on eastern part of the Inventory. polygon. A portion of that appears to be from a timber group selection cut from 1981 of 122 acres.

70 There are a few circular areas carved Include these areas within the Google Earth Screenshots 70-A, B, C Clear Fork out within the polygon of which seem Inventory. to be development-related exclusions, although they do not appear significantly noticeable as shown in image 70 - A, B and C.

169, 170 The far southern part of polygon 169 Include these areas within the Google Earth Screenshot 169-A East Gunnison has significant acreage removed from Inventory. Divide due to timber projects dating to 1914.

146 We are perplexed with the Draft Include this area within the Google Earth Screenshot 146-A Granite Basin Inventory’s removal of an area within Inventory. the center of the polygon. It does not appear to be timber or mining related, and there are no signs of substantially noticeable improvements there.

71 The Draft Inventory excludes several Include these areas within the Google Earth Screenshot 71-A Lamborn wildlife habitat treatments, none of Inventory. which are substantially noticeable. See 71-A.

Uncompahgre NF (Plateau Region)

Wilderness Comments on Polygon Boundary Recommendation to Description of Supporting References to Overlapping Inventory Correct Issue Evidence Supporting proposed Polygon Evidence conservation Number area

7 The inventory excludes about 4,000 The wilderness inventory See Exhibit 1 See Exhibit 1 Kelso Mesa acres of Escalante Breaks, the portion unit should be aligned with Wilderness of the Inventory Unit 7 (Kelso Mesa) the Colorado Roadless Rule Colorado Roadless Rule Area bounded Area boundary along FDR by FDR 409 (Brushy Ridge Road) on the 409 (Brushy Ridge Road). north and by the rim of North Fork Escalante Creek on the south. This is apparently owing to past mechanical treatments for wildlife habitat improvements. There are no substantially noticeable impacts on the ground or open roads.

18 The western end of Inventory Unit 18 It would be beneficial to Map of San Miguel Proposed #18-A Horsefly (Horsefly Creek) is separated from the the legislative process, and Wilderness Area Creek rest of Horsefly Creek by a large for the GMUG’s transmission line that spans the canyon engagement in review of from rim to rim. The smaller separated that legislation, to ensure piece is less than 5,000 acres and is not the wilderness inventory identified for wilderness inventory. for Unit 18 addresses this However, it is adjacent to a proposed section of Horsefly Creek, wilderness unit on adjacent BLM lands, which considered which is not a WSA and may not collectively with adjacent otherwise show up as an adjacent unit. BLM lands makes for a unique and intriguing However, this western segment of canyon unit along one of Horsefly Creek is a major portion of an Colorado's very rare area on BLM lands, Norwood Canyon undammed major rivers (also called San Miguel River), proposed (the San Miguel). for wilderness designation in the

Colorado Wilderness Act of 2015, H.R. 3336, introduced by Rep. Diana DeGette and considered in the last Congress. It will likely again be proposed in legislation for wilderness designation later in 2018. Uncompahgre NF (Mountain Region)

51 GMUG #51 does not extend south of Extend the boundary of Gate closure (locked) at north #51-A -#51-X Hayden McIntyre Gulch; coalition proposal #51 south to include Spirit access to Greyhound Rd. Used by Mountain extends to Black Bear Rd/Trico Peak Gulch and Senator Beck owner of mining claim only. (#51- with appropriate road buffer. Desire to Basin to within a A) include Spirit Gulch, Ptarmigan Lake Basin, and Senator Beck Basin for their reasonable buffer of Black Photographs: opportunities for solitude and primitive Bear Rd Elk cows and calves. lower recreation. These areas provide valuable wildlife habitat and corridor reaches of Greyhound Rd . The (especially elk.) GMUG inventory entire landscape from Black Bear Rd to Campbird Rd is active elk includes 6,527 acres whereas citizen proposal is 10,226 acres – a difference habitat/production area. Hwy of 3,699 acres. The basins that were 550 in the left background shows the proximity of elk habitat to excluded, extending northeast from Trio Peak to Richmond pass, are large road. (#51-B) expansive basins that see little View south across section of recreational use (foot/ski traffic only) Greyhound Mine (mine is and opportunities for solitude are very excluded from citizen proposal) high. While evidence of past mining toward the landscape that exists, in the larger context of the warrants inclusion in the landscape, most of the mining wilderness inventory: wildlife remnants are largely unnoticeable and habitat/corridor; scenic value; are fading away. These basins hold primitive recreation; solitude. significant snow often well into mid- Note: the trail that crosses the July. slope is designated as Greyhound Rd on the GMUG map, but is no longer used as a road. (#51-C)

Evidence that Greyhound Rd is actually a trail, so GMUG should not exclude this area based upon GIS maps that indicate a road (#51-D)

Humans walking on trail (Greyhound Rd on GMUG map) to emphasize that this road is no longer a road. Though mine should be excluded, the terrain above the mine at higher elevation and the entire landscape south of mine into Spirit Gulch warrants inclusion in Inventory. (#51-E)

Spirit Gulch warrants inclusion: opportunities for solitude, elk habitat, scenic value (#51-F)

Trail (not road) between Spirit and McIntyre Gulches. Note view of Red Mtn #1 and Brown Mtn on horizon. Spectacular scenery. (#51-G)

View west across lower Spirit Gulch. Scenic value. Trail (not road) in foreground. (#51-H)

View of mine activity at base of Spirit Gulch just inside our proposed boundary. Argue that such mine activity is not “more dominant than the surrounding landscape. (Though we could easily exclude this site if needed.) Note the other tailing pile even less noticeable center right. (#51- I)

Spirit Gulch boasts some of the finest wildflowers In the valley ( GOV has more closeups if you need!) Elk habitat. (#51-J)

View into Spirit Gulch from SW in late November. Note trail (old road) on far slope. Does not dominate landscape. (#51-K)

Looking north from Ptarmigan Basin into upper Commodore Gulch and beyond toward lower Spirit Gulch. Note Greyhound Mine in distance (center right.) Most significant to note: the Greyhound Rd (which is actually a trail) on the south facing slope is not substantially noticeable per the GMUG’s definition. Greyhound Gulch is excluded from our proposal but all terrain in foreground and higher elevations warrants inclusion in the GMUG inventory (as proposed by our coalition. (#51- L)

(Not sure we need this one?) View up Commodore Gulch. Commodore Gulch and surrounding higher elevations (above and to south of Barstow Mine) warrant inclusion. Barstow Mine is just out of picture lower right. (#51-M)

View near treeline in Ptarmigan Basin looking into upper basin (Lake not visible). (#51-N)

View from low in the basin looking up. Only a small trail (path) exists from Red Mtn Pass road into upper basin. (#51-0)

View of upper Ptarmigan Basin (Lake not in view) (#51-P)

View of mining implements that remain at Ptarmigan Lake. (#51- Q)

View of Senator Beck Basin (Google Earth) from Trico Peak to the mine (note the mine is tucked away in the far corner of basin and takes little away from the landscape). (#51-R)

Location of mine area which is largely tucked into a corner of the landscape. (#51-S)

Remaining standing structure in Senator Beck basin. (#51-T)

View from treeline into upper basin. Mining area cannot be seen. (#51-U)

View from upper basin down. Looking across at Reds (#51-V)

Looking northeeast from Trico Peak across Senator Beck Basin to Hayden Mtn (farthest along ridge) (#51-W)

Aerial of Spirit Gulch Area (#51-X)

44 Too many exclusions (based on mining Ground-truth to verify Aerial Photo from Google Earth 44-A Hope Lake GIS layer.) The vast majority of the which of these features are of area at ~1in=1mi (Sheep buffered features (looks like “Swiss actually substantially Mountain) SIA Cheese”) are not noticeable from an noticeable on the ground, aerial view (at a scale of ~1 in=1mi). with the caveat that in We are interested in helping to provide many cases historical further ground-truthing once we are mining features can be able to get out on the ground in these included in wilderness areas. Even in the cases where there is areas (such as the soil discoloration due to an adit or Collegiate Peaks and the other mining infrastructure, this often Weiminuche) and are blends into the surrounding scenery. considered historical assets. Indeed, there appears to even be a buffered feature next to Hope Lake with nothing at the center of it.

In addition, this area forms a key part of the recommended San Juan Mountains Wilderness and should eventually align with those boundaries, including smaller carveout for watershed protection area in Waterfall Canyon, and none in Swamp Canyon.

This area is part of the proposed San Juan Mountains Wilderness Act (SJMWA).

46 Same issue with too many mining Ground-truth to verify Aerial Photo from Google Earth 46-A North Side of exclusions. which of these features are of area at ~1in=1mi Ophir Valley actually substantially and upper noticeable on the ground, Bridal Veil with the caveat that in many cases historical Basin and mining features can be Bear Creek included in wilderness areas (such as the Collegiate Peaks and the Weiminuche).

37 This area is part of the proposed Please note that areas like Lizard Head SJMWA. this that are part of the Wilderness very well-vetted SJMWA. Addition: Black Face

19 A-J: Clearcut patches performed in the A-J: Ground-truthing to Google Earth images. 19 – A. – M. Lizard Head early 1990s are entirely excluded within gain better insight into the Wilderness the area. Although aerial imagery does character of each patch, 19 – A. – M. Addition: East indicate vestigial effects of timber rather than excluding areas 1 inch: 1 mile scale. Beaver Creek treatment, we have reason to believe collectively. that several of these patches have developed thick understory, which might make exclusion unnecessary.

K: Southern indentation, with timber treatment overlay ID #0204054701041016000, should not be K-L: Reconsider aerial excluded. On the opposite side of the imagery and revise road, there is visible scoring of the boundaries to initial landscape from a sanitation treatment recommendations. in 1953. But on the side within the Better define criteria for recommended wilderness area, the timber treatments effects of treatment are inconspicuous considered “substantially and there is uniformity between noticeable,” as there are adjacent vegetation/timber. clear discrepancies among L: Similar issue with northeastern treatments. exclusion area, which was also the

result of a 1954 sanitation treatment (timber treatment overlay ID # Treatment timelines should 0204054701041014000). There is no be reevaluated. evidence of any dominant landscape features that would be classified as “substantially noticeable.”

M: In the northeastern section, adjacent to the area cited above (O), there is no documentation of historical timber treatment. Additionally, there is

no evidence of other exclusionary features (mineral development, M: Explanation for watershed treatments etc.) Without exclusion. additional information justifying this decision, we don’t see a reason why this section should be excluded.

40 Past mining sites should not lead to Recheck the mining Google Earth 39-40-A Lizard Head buffered exclusions in this relatively exclusion in this area, and Wilderness 1 in<1 mi small area. This area is part of the that boundaries match Addition: San proposed SJMWA. proposed wilderness Bernardo boundaries. (North)

39 Past mining sites should not lead to Recheck the mining Google Earth 39-40-A Lizard Head buffered exclusions in this relatively exclusion in this area, and Wilderness 1 in<1 mi small area. This area is part of the that boundaries match Addition: San proposed SJMWA. proposed wilderness Bernardo boundaries. (South)

26 Past mining sites should not be Make sure that three 26-A Lizard Head excluded. mining “spots” are not left Wilderness Addition: This area is part of the proposed out. They are not visible Silver Pick SJMWA. from air. Basin

36 This area is part of the proposed Make sure boundaries Lizard Head SJMWA. match current Wilderness recommended wilderness Addition: boundaries Sunshine

15 A & B: The areas in the southeast A-D: Google Earth images. 15 A.B.C.D. Lone Cone SIA corner and eastern edge of the Lone Reconsider aerial imagery 15 A.B.C.D. Cone SIA, with overlaid timber and revise boundaries to treatment ID #s 0204054701061008000 1 inch: 1 mile scale. & 0204056101021004000 respectively, initial recommendations. were excluded on the basis of 65-year- Better define criteria for old single tree selection cut treatments. timber treatments However, there are no visual indicia of considered “substantially such treatments, and the respective noticeable,” as there are forest is indistinguishable from its clear discrepancies among surroundings. treatments.

C: Similar issue with 16-acre cutout (timber treatment overlay ID # 0204056101031002000).

D: Eastern indentation (timber treatment overlay ID #0204054701071010000) not justified. There was tree planting 57 years ago. If anything, the area looks more natural than if it was left unplanted. In conclusion, the effects of tree planting are not substantially noticeable. 35 Past mining sites should not be Make sure boundaries Sneffels excluded. match current Wilderness recommended wilderness Addition: Last This area is part of the proposed boundaries Dollar/Sheep SJMWA. Creek (Last Dollar)

45/38 Past mining sites should not be Make sure boundaries Google Earth 45-38-A Sneffels excluded. Also, the 300-foot buffering match current Wilderness of a road into eastern side of this recommended wilderness 1 in=1 mi. Addition: Last polygon (between 45 and 38). boundaries. Reduce Dollar/Sheep buffering on this road. Creek (Liberty This area is part of the proposed Reevaluate mining Bell) SJMWA. exclusions.

50 This area is a long Sneffels standing proposal for Wilderness congressional action Addition: for a designated Whitehouse Wilderness Area. These are wild lands that Mountain have not seen any (East and mining activity and the West) existing claims are unnoticeable.

52 The Draft Inventory excludes several Uncompahgre old mining-related features that may Wilderness not be substantially noticeable. Addition: Baldy

54 The Draft Inventory arbitrarily excludes Uncompahgre several old mining-related features that Wilderness may not be substantially noticeable. Addition: Bear Creek 67, 69 The Draft Inventory arbitrarily excludes Uncompahgre several old mining-related features that Wilderness may not be substantially noticeable. Addition: Crystal

61 Inventory polygon 61 (Matterhorn) The boundary should align #61A, B, C Uncompahgre inappropriately excludes Sunshine with the Colorado Roadless Wilderness Mountain on the south side of the Area boundary and include Addition: North Fork Henson Creek apparently all lands adjacent to the Matterhorn because it appears to be an isolated BLM WSA. #61-A depicts fragment less than 5,000 acres. the relationship of these However, this portion of the inventory units. polygon is adjacent to the BLM’s American Flats Wilderness Study Area, which itself is contiguous with the Uncompahgre Wilderness.

Grand Mesa National Forest

Wilderness Comments on Polygon Boundary Recommendation Description of References to Overlapping proposed conservation Inventory to Correct Issue Supporting Supporting area Polygon Evidence Evidence Number

Not The Draft Inventory does not include Include this Proposed Attachment Hightower Linkage Area identified 3,630-acres of inventoried roadless landscape in the Hightower entitled with a lands at Hightower Mountain, which Draft Inventory. Linkage Area Hightower polygon borders the White River National Narrative Linkage Area number on Forest. Its two units are separated by a the private inholding, and both units are contiguous with the Reno Mountain Roadless Area on the White River interactive National Forest. While it is less than story map 5,000 acres in size, it is contiguous to roadless lands on an adjacent forest, and must be included in the Draft Inventory.

Gunnison National Forest Screenshots

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Uncompahgre National Forest Photos and Screenshots

Figure 44-A: Hope Lake (Sheep Mountain) SIA

Figure 46-A: North Side of Ophir Valley and upper Bridal Veil Basin and Bear Creek

Figure 19. A-M. East Beaver Creek

Figure 39-40-A San Bernardo North and South:

Figure 26-A Silver Pick Basin:

Figure 15. A-D. Lone Cone

Figure 45-38-A:Last Dollar/Sheep Creek (Liberty Bell)

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#61-B: Photo shows view of American Flats WSA and Sunshine Mountain from the south, with Uncompahgre and Wetterhorn Peaks visible just beyond the unit to the north.

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Hightower Linkage Area

Proposed Linkage Area Grand Mesa National Forest Grand Valley Ranger District 3,630 acres (Hightower East – 830 acres; Hightower West – 2,800 acres)

General Description

The Hightower Linkage Area, located on Grand Mesa, consists of two separate parts of the Hightower Roadless Area, approximately 17 miles east of Collbran. Its two units are separated by a private inholding, and both units are contiguous with the Reno Mountain Roadless Area on the White River National Forest. Hightower is within the Northern-Central Highlands and Rocky Mountain Eco-Section (M33IH) with elevations ranging from 8,000’ to 9,700’.

This is not a large area, but it provides important connectivity in a chain of adjacent and nearly adjacent roadless areas stretching from the Grand and Battlement Mesas in the west all the way across the Crystal River and toward the main stem of the Rockies in the east. Hightower also sits along an important north-south corridor that connects the Colorado River Valley with the North Fork River Valley and the extensive wildlands south of there.

Hightower Mountain at 9,555 feet and Reno Mountain at 9,741 feet are highpoints on the ridge that forms the northern boundary of this area and forms the western end of the Plateau Valley, north of the Grand Mesa. Hightower Creek in the Colorado River system has its headwaters in this area. Aspen forests predominate in this area with sagebrush steppes and gamble-oak at the lower elevations and small areas of spruce-fir near Hightower Mountain.

Manageability

The boundaries for this area are well defined by roads, trails and the National Forest boundary. There are two separate pieces of this Linkage Area, separated by an “L” shaped piece of private land. Nonetheless, both pieces are adjacent and contiguous with the Reno Mountain Roadless Area on the White River National Forest.

There have been oil and gas leases located within this roadless area over the years. However, no oil and gas drilling has occurred within the roadless area. If the area remains open and available to leasing in the future, it can be protected by an NSO stipulation and minerals can be accessed under the area using directional drilling technologies.

We recommend against further road development and/or reconstruction in this area in order to maintain and protect wildlife and habitat. Further, eliminating and reclaiming existing non- system roads and trails within the area would increase wildlife values and aid in keeping big game species on public lands as opposed to private lands where often they are not welcome. We recommend the area be designated as a Linkage Area, closed to mineral leasing and sales, and timber production, and managed to protect and enhance existing habitat, backcountry recreation opportunities, and clean water.

Information Resources

Item Data Source

Roadlessness Colorado Roadless Rule at 36 CFR xx Forest Service inventory pursuant to FSH 1909.12,chapter 70, section 71 Naturalness; Outstanding Opportunities Forest Service inventory pursuant to FSH for Solitude or Unconfined Primitive 1909.12,chapter 70, section 72 Recreation USDA Forest Service, R2, Profiles of Colorado Roadless Areas 2008 GMUG Roadless Inventory & Evaluation for Potential Wilderness Areas, 2005 Supplemental Values Connectivity SREP Wildlands Network 2003, USDA Forest Service Southern Rockies Lynx Amendment, 2008 Aplet et al, Indicators of Wildness 2000, Belote et al, Identifying Corridors among Large Protected Areas in the United States, 2016 Boreal Toad Overall Range Colorado Parks and Wildlife Species Activity Mapping 2017 Elk Production Area Colorado Parks and Wildlife Species Activity Mapping 2017 Elk Winter Concentration Area Colorado Parks and Wildlife Species Activity Mapping 2017 Lynx Potential Habitat Colorado Parks and Wildlife Species Activity Mapping 2017 Moose Concentration Area Colorado Parks and Wildlife Species Activity Mapping 2017 Moose Priority Habitat Colorado Parks and Wildlife Species Activity Mapping 2017