Continental Divide National Scenic Trail and the Colorado Trail Reroute Lujan to La Garita Wilderness

Home , Cochetopa Dome, Colorado Trail, Continental Divide Trail, La Garita Mountains, La Garita Wilderness

Environmental Assessment Continental Divide National Scenic Trail and the Colorado Trail Reroute Lujan to La Garita Wilderness

Saguache Ranger District, Rio Grande National Forest and Gunnison Ranger District, Grand Mesa, Uncompahgre and Gunnison National Forests Saguache and Gunnison Counties, Colorado May, 2013

"The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA's TARGET Center at (202) 720- 2600 (voice and TDD). To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence Avenue, S.W., Washington, DC 20250-9410, or call (800) 795-3272 (voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and employer.”

Further Information: For more information regarding this project please contact Niccole Mortenson at [email protected] or 406-329-3163.

TABLE OF CONTENTS

Table of Contents iii Figures and Tables v Chapter 1. Purpose and Need and Proposed Action 1 Document Structure 1 Background 1 Purpose and Need for Action 5 Proposed Action 6 Laws, Regulation and Policy 8 Forest Plan Direction 12 Decision Framework 15 Public Involvement 16 Issues 16 Chapter 2. Alternatives including the Proposed Action 19 Alternatives Considered in Detail 19 Alternatives Considered but Eliminated from Detailed Study 29 Comparison of Alternatives 32 Chapter 3. Affected Environment and Environmental Consequences 35 Cumulative Actions Considered in the Analysis 35 Trail Setting 36 Trail Use & Access 55 User Experience & Trail Effects 62 Wildlife-Threatened or Endangered Species 66 Wildlife-Sensitive Species & Management Indicator Species 83 Migratory Birds 115 Plants-Threatened, Endangered or Sensitive Species 121 Watershed Conditions 129 Road/Transportation System 132 Livestock Grazing and Spread of Noxious Weeds 134 Chapter 4. Consultation and Coordination 139 References Cited or Reviewed 141 Trail Analysis 141 Wildlife 145

iii

Plants 155 Heritage 160 Range 162 Scenery 163 Appendix A. Design Parameters Excerpt (Pgs 1-6) 165 Appendix B. Recommended Seed Mix 173 Appendix C. Response to Comments 175

FIGURES AND TABLES

Figure 1-1. Vicinity Map of Project. 4 Figure 1-2. Existing Route, Proposed Reroute and Access Points, CDNST Lujan to La Garita 7 Table 1-1. Proposed Action Trail Segment Descriptions. 8 Table 2-1. Key Features of Alternative 1. 19 Figure 2-1. Alternative 1 20 Figure 2-3. Alternative 2. 24 Table 2-3. Key Features of Alternative 3. 25 Figure 2-3. Alternative 3. 26 Table 2-4. Key Features of Alternative 4. 27 Figure 2-4. Alternative 4. 28 Table 2-5. Comparison of Alternatives 32 Table 3-1. Description of the Existing Trail Segments (source Tom Lorang Jones). 37 Figure 3-1a. Scenic Integrity Objectives Both Forests (roads not shown for RGNF) 41 Figure 3-1b. Existing Alignment Foreground Viewshed 43 Figure 3-2. Proposed Alignment Roadless 44 Figure 3-3. GoogleEarth (aerial) Image of Trail Routes 48 Figure 3-4. One Half Mile Buffer either Side of Trail 49 Figure 3-5. Spring near Monchego Park 52 Figure 3-6. Stock Pond 53 Figure 3-7. North Pass Topographic Map 55 Figure 3-8. North Pass Aerial Photo 56 Figure 3-9. North Pass Aerial Photo close-up for where the existing trail crosses SH 114. The existing trail follows the road labeled in white “CR31CC” 56 Table 3-2. Brief Summary of Designed Use and Trail Class Features 59 Figure 3-10. Lynx LAUs and Linkage Area 69 Figure 3-11. The utilization distribution for current lynx habitat in Colorado, with Forest Service administrative boundaries and I-70 as a reference. The CDNST Reroute Project vicinity is added for reference. Map is from Figure 7 in Theobald (2011). 72 Table 3-3. Proposed Trail Length within Lynx Suitable Habitat 73 Figure 3-12. Characterization of mapped lynx habitat associated with the CDNST Reroute Project. 74 Table 3-4. Suitable Lynx Habitat, Cochetopa Hills/North Pass Linkage Area 75 Table 3-5. Acres and Percentage of Lynx Habitat Affected by Proposed Trail

Construction 77 Figure 3-14. North Pass Area Aerial View 79 Figure 3-6. Average Snow Depth, Cochetopa Pass SNOTEL site 81 Table 3-7. Dominant Vegetation within 0.25 mile of Proposed Trail and Trailheads 84 Table 3-8. Determination and Conservation Measures Summary 102 Table 3-9. Elk Seasonal Use Areas and Project Activities within DAUs 112 Table 3-10. Mule Deer Seasonal Use Areas and Project Activities within DAU D-26. 113 Table 3-12. Priority habitats and species of the Southern Rocky Mountains province and their relationship to assessment for the CDNST Reroute Project. 118 Table 3-13. BCR Focal Species and Breeding Periods 120 Table 3-14. Species included in further analysis. 122 Figure 3-15. Road System 133 Figure 3-16. Decommission Segment 134 Table 3-15. Grazing allotments and permittees in the analysis area. 135

CHAPTER 1. PURPOSE AND NEED AND PROPOSED ACTION Document Structure The Forest Service has prepared this Environmental Assessment (EA) in compliance with the National Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations. This EA discloses the direct, indirect, and cumulative environmental impacts that would result from the proposed action and alternatives. The document is organized into the following parts: • Chapter 1-This chapter includes information on the history of the project proposal, the purpose of and need for the project and the agency’s proposal for achieving that purpose and need. This section also details how the Forest Service informed the public of the proposal and how the public responded. • Chapter 2-This chapter provides a more detailed description of the agency’s proposed action as well as alternative methods for achieving the stated purpose. These alternatives were developed based on issues raised during scoping. • Chapter 3-This chapter describes the affected environment and effects of implementing the proposed action and other alternatives. This analysis is organized by resource element, as suggested by issues identified in scoping. Within each section, the affected environment is described first, followed by the effects of the No Action Alternative that provides a baseline for evaluation and comparison of the other alternatives that follow. • Chapter 4-This chapter provides a list of preparers and agencies consulted during the development of the environmental assessment. • Appendices-The appendices provide more detailed information to support the analyses presented in the environmental assessment. Additional documentation, including more detailed analyses of project-area resources, may be found in the project planning record.

Background

Continental Divide National Scenic Trail In 1968, Congress enacted the National Trails System Act (The Act) (P.L. 90-543) which established a nationwide trail system. The Act (16 U.S.C. 1242) describes that National Scenic Trails “will be extended trails so located as to provide for maximum outdoor recreation potential and for the conservation and enjoyment of the nationally significant scenic, historic, natural, or cultural qualities of the areas through which such trails may pass.” The Act also specifically directed the study of a Continental Divide National Scenic Trail (CDNST). A study of possible trail routes along the Continental Divide was initiated in 1969 and completed in 1976. The 1976 Study Report describes the purposes of the CDNST: The primary purpose of this trail is to provide a continuous, appealing trail route, designed for the hiker and horseman, but compatible with other land uses....One of the primary purposes for establishing the CDNST would be to provide hiking and horseback access to those lands where man's impact on the environment has not been adverse to a substantial degree and where the environment

1 remains relatively unaltered. Therefore, the protection of the land resource must remain a paramount consideration in establishing and managing the trail. There must be sufficient environmental controls to assure that the values for which the trail is established are not jeopardized...The basic goal of the trail is to provide the hiker and rider an entree to the diverse country along the Continental Divide in a manner, which will assure a high quality recreation experience while maintaining a constant respect for the natural environment... The Continental Divide Trail would be a simple facility for foot and horseback use in keeping with the National Scenic Trail concept as seen in the Appalachian and Pacific Crest Trails. In 1977, a Legislative Final Environmental Statement (FES) describing the routes was completed and filed with the Council on Environmental Quality. Using the information from the Study Report and FES, Congress enacted the National Parks and Recreation Act of 1978 (P.L. 95-625, 92 Stat. 3467) which established the CDNST (16 U.S.C.1244) and amended The Act (P.L. 90-543). The amendment established and designated the CDNST “a trail of approximately thirty-one hundred miles, extending from the Montana-Canada border to the New Mexico- Mexico border, following the approximate route depicted on the map, identified as 'Proposed Continental Divide National Scenic Trail' in the Department of the Interior Continental Divide Trail study report dated March l977...Notwithstanding the provisions of section 7(c), the use of motorized vehicles on roads which will be designated segments of the Continental Divide National Scenic Trail shall be permitted in accordance with regulations prescribed by the appropriate Secretary….” (16 U.S.C. 1244). The basic goal of the CDNST is to provide hikers and horseback riders an opportunity to experience the diverse country along the Continental Divide in a manner that will assure a high quality recreation experience while maintaining a constant respect for the natural environment. The Chief of the Forest Service adopted the 1976 CDNST Study Report and 1977 CDNST Final Environmental Statement on August 5, 1981 (46 FR 39867) pursuant to the National Trails System Act (16 U.S.C. 1244(b)). Further, The Act requires the Secretary of Agriculture to prepare a comprehensive plan for the management and use of the CDNST (16 U.S.C. 1244(f)). The Forest Service goal in 1981 for the CDNST Comprehensive Plan was to provide a uniform trail management program reflecting the purposes of the CDNST while providing for use and protection of the natural and cultural resources along the CDNST. The Chief of the Forest Service approved the Comprehensive Plan for the CDNST in 1985. In 1997, the Deputy Chief of the Forest Service issued a memo to Regional Foresters stating that “…as the CDNST is further developed, it is expected that the trail will eventually be relocated off of roads for its entire length.” The memo further stated that “It is the intent of the Forest Service that the CDNST will be for non-motorized recreation. As new trail segments of the CDNST are constructed to link existing non-motorized segments together, and to reroute the CDNST off of primitive roads or other routes where motorized travel is allowed, motorized use should not be allowed or considered. Allowing motorized use on these newly constructed trail segments would substantially interfere with the nature and purpose of the CDNST.” In 2003, the Rocky Mountain Deputy Regional Forester issued a memo emphasizing the importance of working toward a high-quality non-motorized route for the CDNST in the Rocky Mountain Region by the trail’s 30th anniversary in 2008. The 1985 CDNST Comprehensive Plan Amendment, published in the Federal Register on October 5, 2009 (74 FR 51116), set forth direction to guide the development and management of the CDNST. The 2009 CDNST Comprehensive Plan herein provides consistency with the decision made in that amendment, and replaces the 1985 CDNST Comprehensive Plan. The

2 amended Comprehensive Plan and FSM 2353.42 describe the nature and purposes of the CDNST: “The nature and purposes of the CDNST are to provide for high-quality scenic, primitive hiking and horseback riding opportunities and to conserve natural, historic, and cultural resources along the CDNST corridor.” Numerous CDNST trail segments are still open to motorized recreational uses including the existing section considered in this analysis. This EA addresses the effects of a proposed reroute of a segment of the CDNST in south central Colorado. This segment is currently in close proximity to the Continental Divide in Saguache County on the Rio Grande (RGNF) and Grand Mesa, Uncompahgre, Gunnison National Forests (GMUG). In 2006, a location for the non-motorized trail was identified, flagged and mapped using GPS. Initially the entire segment from Windy Point to Lujan to the La Garita Wilderness was being considered for this project. However, the project interdisciplinary team found that issues and opportunities were substantially different for these two segments. Hence, this EA and the Decision it supports focuses only on the segment from Lujan to the La Garita Wilderness as shown in the vicinity map (Figure 1-1) below. Other related efforts continue to occur. The Chief of the Forest Service has, to date, not officially designated 2400 miles of the CDNST including this segment in accordance with 16 U.S.C. 1246 (a) and (b). Therefore, this project could be considered either a relocation of a proposed route or location of a proposed segment until such time as a route is published in the Federal Register. There are no Unit Plans as defined in FSM 2353.44b(2) or The 2009 CDNST Comprehensive Plan in existence for any of the 3100 miles of the CDNST. Unit Plans would most appropriately occur during a land and resource management plan revision as it will affect other management activities for the entire length of the CDNST on that Unit (a unit is interpreted as Forest).

3 Figure 1-1. Vicinity Map of Project.

4 The Colorado Trail In this area the CDNST is coincident with The Colorado Trail (CT). Both designations have compatible goals and objectives for managing a non-motorized trail. CT developed along a similar timeline as the CDNST. In 1973, the then Regional Forester of the United States Forest Service (USFS) Rocky Mountain Region and Merrill Haskins had the idea of the “Rocky Mountain Trail” as a Bi-Centennial project between Denver and Durango to be completed in 1976. In 1976, a cooperative agreement was signed between the USFS and Colorado Mountain Trails Foundation for building the trail. In 1980, the USFS Issued “Environmental Assessment and Route Directive regarding the Colorado Trail” concept. In 1987, The Colorado Trail Foundation (CTF) was established to complete the trail and the trail segments were finally linked. In 1988, the USFS and The Colorado Trail Foundation (CTF) signed a Master Agreement for partnership of the trail and the trail was dedicated. In 1998, a cabin was purchased to be used for environmental education near Lake City, Colorado. And finally, in 2005, USFS and CTF signed a Memorandum of Understanding for continued cooperation. CTF is a 501(c)(3) nonprofit corporation funded mostly by private sector individuals and companies. Their mission is to keep CT in good condition by maintaining and improving it with the help of volunteers. They recruit and train volunteers, provide leadership, organize CT work crews, supply and support the crews, and manage the Adopt-A-Trail program to accomplish annual maintenance on the entire trail. They continue to work in cooperation with public agencies. The mission of CTF is to provide and maintain, through voluntary and public involvement, and in cooperation with the USFS and Bureau of Land Management, a linear, non-motorized, sustainable, recreation trail between Denver and Durango, Colorado. This trail will provide multi- day, inspirational, and educational values keyed to the diverse, high mountain, natural environment. To preserve the sense of community associated with the unique, high altitude experience achieved by participation in trail activities. The vision of CTF is: • Support environmental education, to be a place for healing and self-renewal, and facilitate an appreciation for the value of natural systems. • Support multiple use, non-motorized, family recreation in a wide variety of unpopulated ecosystems. • Maintain a cooperative effort that involves volunteers and promotes a sense of public ownership. CTF is generally supportive of this proposed route realignment because the new route will be single-track and non-motorized. However, they do not support an alternative that prohibits the use of bicycles.

Purpose and Need for Action The GMUG and RGNF have determined a need to reroute and re-designate uses on a portion of the CDNST/CT consistent with The Act, The 2009 CDNST Comprehensive Plan and to comply with agency policy by: • Establishing a trail with the location, character and use-designation consistent with the purpose and intent of the CDNST/CT; and • Providing trailhead facilities to accommodate safe public access to the trail from State Highway 114, as well as safe crossing of State Highway 114 by trail users. This portion of the CDNST/CT currently consists of segments of various roads and trails which connect to convey the traveler from Lujan to the La Garita Wilderness. Current trail alignment is

5 on the GMUG. Trail tread varies from single track to full-size vehicle roads. Designated uses include hiker/horse trails all the way to full-sized passenger vehicles. Many segments are located well below the continental divide, and have little or no resemblance to a true “continental divide scenic trail.” The desired condition is a trail that is compatible with the nature and purposes of the Act that provides “for high-quality scenic, primitive hiking and horseback riding opportunities and to conserve natural, historic, and cultural resources along the CDNST corridor” (FSM 2353.42)

Proposed Action The GMUG and RGNF Proposed Action consists of the following: • Construct and manage 31.2 miles of trail from Lujan Pass to the Skyline Trail (#465) in the La Garita Mountains, in accordance with standards prescribed by Forest Service Handbook (FSM) 2309.18, Trails Management Handbook. • Construct one 0.9 mile spur trail from Luder’s Campground to the CDNST/CT. This segment of trail follows an old logging road northwest of the campground. • Allowable uses on the trails would include horse and foot travel only. • Construct a trailhead and parking area on the south side of Highway 114 on North Pass. The parking area would be approximately ¼ acre in size and a single vaulted CXT toilet would be installed at the parking area. • Construct a trailhead and parking area in the meadow near the entrance to Luder’s Campground. This trailhead would be constructed to a standard to facilitate horse and horse trailer use. • Decommission approximately 2 miles of non-motorized trail on the GMUG. The remaining segments of the current CDNST/CT follow roads which will remain in place. The actual work of constructing the trail would be done using hand tools, and possibly horses to haul materials, tools, etc. to remote work locations. However, appropriate motorized equipment may also be used for the construction, if available. Construction could be done in a variety of different ways such as with Forest Service crews, volunteers, or by contract, although it is most likely to be done with volunteer groups. The length of time that it will take to construct the trail will depend on how this work would be done, but would likely be completed within two years. A season of operation for construction activities has not been identified other than snow-free season. The only new facilities proposed are a parking area and trailhead at the top of North Pass on Highway 114 and a parking area/trailhead for horse trailer parking at Luder’s Campground. There is a CXT toilet planned for the trailhead at North Pass. This alternative is consistent with the design of Trail Class 2 for Pack and Saddle with a tread width of 24” and clearing limits of 6 feet (three feet on each side of the trail). See Appendix A for design specifications. Alternatives to the Proposed Action including alternatives that allow mechanized use and less facility development are found in Chapter 2.

6 Figure 1-2. Existing Route, Proposed Reroute and Access Points, CDNST Lujan to La Garita

7 Table 1-1. Proposed Action Trail Segment Descriptions.

Segment ID Skyline Trail 1-Skyline 2- 3-Luder’s 3A-Luder’s 4-Luder’s to 5-Highway # 7465 Trail to Cochetopa Spur Spur North Pass 114 to Cochetopa to Luder’s Alternative Lujan Pass Spur Trail

Miles 1.2 22.3 2.5 0.9 1.1 2.5 2.6

From La Garita Skyline Trail Old CDNST Luder’s Spur Luder’s Spur Highway Wilderness Cochetopa 114 Pass (NN114)

To Beginning Old Luder’s Spur Luder’s CDNST North Pass Lujan Pass 2006 Re- Cochetopa Trail Campground (Highway route Pass 114) (NN114)

Trail Status Current New New Existing Trail New New New CDNST Construction Construction Bed Construction Construction Construction

Trail Use Horse and Horse and Horse and Horse and Horse and Horse and Horse and Foot Travel Foot Travel Foot Travel Foot Travel Foot Travel Foot Travel Foot Travel Only Only Only Only Only Only Only

Unit GMUG GMUG RGNF RGNF RGNF RGNF RGNF (Gunnison (Gunnison (Saguache (Saguache (Saguache (Saguache District) District ) 16.3 District) District) District) District); miles; RGNF GMUG (Saguache (Gunnison District) 6 District) miles

Construction Maintenance All New All New Improve All New All New All New Needs Only Construction, Construction, existing trail, Construction, Construction, Construction No existing No existing water bars, No existing No existing trail. trail etc. trail trail

Laws, Regulation and Policy The following laws, regulations and policy direct the management of the CDNST and decisions to be made.

Laws National Trails System Act (16 U.S.C. 1241 (note), 1241-1249) established a National Trails System containing National Scenic Trails and connecting and side trails for the purpose of providing recreation opportunities. The act addresses trail development and administration and encourages the use of volunteers in the Forest Service’s trail program. The act also authorizes agreements to carry out its purposes. National Parks and Recreation Act of 1978 (P.L. 95-625, 92 Stat. 3467) established and designated the CDNST (16 U.S.C.1244) and amended National Trails System Act of 1968. National Forest Roads and Trails Act (16 U.S.C. 532-538) recognizes construction and maintenance of an adequate system of roads and trails within and near the National Forests are essential to meeting the increasing demands for timber, recreation, and other uses. The act

8 establishes procedures related to rights-of-way, easements, construction, record-keeping, and agreements. Surface Transportation Assistance Act of 1978, as amended (23 U.S.C. 101a, 201- 204) establishes criteria for forest highways, defines NFS roads and NFS trails, and authorizes funding for construction and maintenance of NFS roads and NFS trails. Architectural Barriers Act of 1968, as amended (42 U.S.C. 4151 et seq) requires that all facilities designed, constructed, altered, or leased by a federal agency be accessible to persons with disabilities. This Act will apply to approval of new facilities such as restrooms at trailheads as it relates to this decision.

Executive Orders Executive Order 13195, “Trails for America” directs federal agencies to the extent permitted by law and where practicable--and in cooperation with Tribes, States, local governments, and interested citizen groups--protect, connect, promote, and assist trails of all types throughout the United States. This will be accomplished as it relates to this decision by: • Providing trail opportunities with minimum adverse impacts and maximum benefits for natural, cultural, and community resources; • Protecting the trail corridors associated with national scenic trail to the degrees necessary to ensure that the values for which the CDNST was established remain intact; • Coordinating maps and data for the components of the national trails system to ensure that these trails are connected into a national system and that they benefit from appropriate national programs; • Fostering volunteer programs and opportunities to engage volunteers in all aspects of trail planning, development, maintenance, management, and education as outlined in 16 U.S.C. 1250; and • Providing and promoting a wide variety of trail opportunities and experiences for people of all ages and abilities

Regulations The principal regulations for administration of trails and trailheads are: Travel Management (36 CFR Part 212, Subparts A, B, and C). Subpart A establishes requirements for administration of the forest transportation system, including roads, trails, and airfields, and contains provisions for acquisition of rights-of-way. Subpart B describes the requirements for designating roads, trails, and areas for motor vehicle use and for identifying designated roads, trails, and areas on a motor vehicle use map (MVUM). Architectural Barriers Act Accessibility Standards (41 CFR Part 102-76, Subpart C). These guidelines, which were issued by the Architectural and Transportation Barriers Compliance Board (Access Board) in 2004, apply to buildings and facilities subject to the Architectural Barriers Act and were adopted on November 8, 2005, by the General Services Administration (GSA) as accessibility standards to be used by federal agencies operating under the authority of GSA. These standards will apply to approval of new facilities such as restrooms at trailheads as it relates to this decision.

9 Other Authorities The 2009 Continental Divide National Scenic Trail Comprehensive Plan has been adopted as policy (Forest Service Manual (FSM) 2353) included below.

Policy FSM 2309.18 Plan and develop trails based on decisions documented in the applicable land management plan. See FSM 2330.12 for related direction on authorities governing accessibility of recreation programs, sites, and facilities

FSM 2380.3 It is Forest Service policy to: (2).Employ a systematic, interdisciplinary approach to scenery management to ensure the integrated use of the natural and social sciences and environmental design. (3) Ensure scenery is treated equally with other resources. (4) Apply scenery management principles routinely in all National Forest System activities.

FSM 2353.03 Manage NFS trails to achieve the Trail Management Objectives identified for each trail (FSM 2353.12). Provide a variety of trail opportunities, settings, and modes of travel consistent with the applicable land management plan. Establish outstanding and qualified trails or trail networks as components of the National Trails System. Emphasize long-term cost effectiveness and need when developing or rehabilitating trails. Provide a trail system that is environmentally, socially, and financially sustainable. FSM 2353.28(2) Motor vehicle use on National Scenic and National Historic Trails must be consistent with the National Trails System Act (16 U.S.C. 1244 and 1246(c)).

FSM 2353.31 (1) The National Trails System (16 U.S.C. 1242(a)) includes: National Scenic Trails. These extended trails are located so as to provide for maximum outdoor recreation potential and for conservation and enjoyment of the nationally significant scenic, historic, natural, or cultural qualities of the areas through which these trails pass (16 U.S.C. 1242(a)(2). Connecting and Side Trails. These trails are components of National Recreation, National Scenic, and National Historic Trails (16 U.S.C. 1245). Connecting and side trails provide access to and alternate routes for National Recreation, National Scenic, and National Historic Trails. (2) Ensure that management of each trail in the National Trails System addresses the nature and purposes of the trail and is consistent with the applicable land management plan (16 U.S.C. 1246(a)(2)). (3) TMOs for a National Recreation, National Scenic, or National Historic Trail should reflect the nature and purposes for which the trail was established.

10 FSM 2353.32 Establish connecting and side trails where appropriate (16 U.S.C. 1245). Connecting and side trails complement CDNST by providing additional public access or additional recreational opportunities. Manage connecting and side trails in accordance with the direction for the CDNST. FSM 2353.42 Administer trail corridors to be compatible with the nature and purposes of the corresponding CDNST. The nature and purposes of the CDNST are to provide for high-quality scenic, primitive hiking and horseback riding opportunities and to conserve natural, historic, and cultural resources along the corridor. FSM 2353.43c A segment of a CDNST corridor may be relocated to preserve the nature and purposes for which the trail was established and to promote sound multiple-use management. Relocation requires the consent of the agency with jurisdiction over the underlying land. Publish notice of the relocation in the Federal Register. Substantial relocations require an act of Congress (16 U.S.C. 1246(b)). FSM 2353.44a(3) Except as provided in the applicable enabling legislation, do not designate a CDNST for motor vehicle use. (16 U.S.C. 1246; 36 CFR 212.51).

FSM 2353.44b (1) The land management plan for an administrative unit through which the CDNST passes must provide for the nature and purposes of the CDNST (FSM 2353.42) and, in accordance with the programmatic requirements of the National Trails System Act, as amended (16 U.S.C. 1244(f)), and the CDNST Comprehensive Plan, as amended, must: (a)….Establish a management area for the CDNST that is broad enough to protect natural, scenic, historic, and cultural features (FSH 1909.12); (b) Prescribe desired conditions, objectives, standards, and guidelines for the CDNST; and (c) Establish a monitoring program to evaluate the condition of the CDNST in the management area. (2)(c) Establish the Trail Class, Managed Uses, Designed Use, and Design Parameters for the segments of the CDNST that traverse that unit and identify uses that are prohibited on the segments of the CDNST that traverse that unit (FSH 2309.18).(d) Provide for development, construction, signing, and maintenance of the segments of the CDNST that traverse that unit. (e) Identify and preserve significant natural, historical, and cultural resources along the sections of the CDNST corridor that traverse that unit. (f). Consistent with the provisions of the applicable land management plan and the nature and purposes of the CDNST (FSM 2353.42), establish carrying capacity for the segments of the CDNST that traverse that unit (FSM 2353.44b, para. 1). The Limits of Acceptable Change or a similar system may be used for this purpose. (g) Establish monitoring programs to evaluate the site-specific conditions of the CDNST. (3) Monitor implementation of a CDNST unit plan by establishing a program to evaluate and report on the overall condition of the segment of the CDNST that traverses that unit. To the extent practicable, utilize information collected through land management planning and site- specific monitoring programs. (7) Use the Scenery Management System (FSM 2382.1; Landscape Aesthetics: A Handbook for Scenery Management, Agricultural Handbook 701, 1995, http://www.fs.fed.us/cdt) in developing CDNST unit plans and managing scenery along the CDNST. The one-half mile foreground viewed from either side of the CDNST travel route must be a primary consideration in delineating the boundary of a CDNST management area (para. 2b). The CDNST is a concern level 1 route (Landscape Aesthetics, page 4-8), with a scenic integrity objective of high or very high, depending on the trail segment (Landscape Aesthetics, page 2-4).

11 (8) Manage the CDNST to provide high-quality scenic, primitive hiking and pack and saddle stock opportunities. Backpacking, nature walking, day hiking, horseback riding, nature photography, mountain climbing, cross-country skiing, and snowshoeing are compatible with the nature and purposes of the CDNST (FSM 2353.42). Use the Recreation Opportunity Spectrum (ROS) and the ROS Users Guide in delineating and integrating recreation opportunities in CDNST unit plans and managing the CDNST (FSM 2311.1). Where possible, locate the CDNST in primitive and semi-primitive non-motorized ROS classes, provided that the CDNST may have to traverse intermittently through more developed ROS classes to provide for continuous travel between the Montana-Canada and New-Mexico-Mexico borders. Locate a CDNST segment on a road only where it is primitive and offers recreational opportunities comparable to those provided by a trail with a Designed Use of Pack and Saddle Stock, provided that the CDNST may have to be located on or across designated routes because of the inability to locate the trail elsewhere (FSM 2353.44b, para. 11). (9) Generally, segments of the CDNST should fall into Trail Class 2 or 3 and have a Designed Use of Pack and Saddle Stock (FSH 2309.18). However, a CDNST segment may fall into Trail Class 1, 2, or 3 and have a Designed Use of Hiker/Pedestrian where a substantial safety or resource concern exists or the direction for the management area provides only for hiker/pedestrian use. Where a CDNST segment has a Designed Use of Hiker/Pedestrian, consider establishing side trails to accommodate pack and saddle stock needs (16 U.S.C. 1245). If the interval between natural water sources is excessive, consider developing and protecting water sources for hikers and pack and saddle stock use. (10) Bicycle use may be allowed on the CDNST (16 U.S.C. 1246(c)), using the appropriate trail design standards, if the use is consistent with the applicable CDNST unit plan and will not substantially interfere with the nature and purposes of the CDNST (FSM 2353.42). (11) Motor vehicle use by the general public is prohibited on the CDNST, unless that use is consistent with the applicable CDNST unit plan and: (d) Is on a motor vehicle route that crosses the CDNST, as long as that use will not substantially interfere with the nature and purposes of the CDNST (FSM 2353.42); (e) Is designated in accordance with 36 CFR Part 212, Subpart B, and: (1) The designated vehicle class and width were allowed on that segment of the CDNST prior to November 10, 1978, and the use will not substantially interfere with the nature and purposes of the CDNST (FSM 2353.42) or (2) The designated segment was constructed as a road prior to November 10, 1978; or

Forest Plan Direction A summary of Forest Plan management areas affected by the alternatives considered in this analysis area include:

GMUG 2A-Semi-primitive motorized recreation opportunities in a natural appearing environment. (Applies to portions of Alternatives 2, 3, 4 and 5.) 4B-Wildlife habitat for one or more management indicator species. Semi-primitive non-motorized, semi-primitive motorized and roaded natural recreation opportunities will be provided. (Applies to a portion of Alternative 1.) 5A-Big game winter range in non-forested areas. Semi-primitive non-motorized, semi- primitive motorized and roaded natural recreation opportunities will be provided. Motorized

12 recreation on roads managed to prevent stress on big game during primary big game use season. (Applies to a portion of Alternative1.) 5B- Big game winter range in forested areas. Semi-primitive non-motorized, semi- primitive motorized and roaded natural recreation opportunities will be provided. Applies to a portion of Alternative 1.) 6B-Livestock grazing. Semi-primitive non-motorized, semi-primitive motorized and roaded natural recreation opportunities will be provided. 7A-Wood fiber production and utilization on slopes <40%. Semi-primitive non- motorized, semi-primitive motorized and roaded natural recreation opportunities will be provided. (Applies to a portion of all alternatives.) Trail System Management general direction GMUG Forest Plan at III-82 to III-83: 01. Maintain all trails for foot and horse travel unless specifically closed to either or both class of user. 02. Maintain all trails to the following minimum requirements: a. Structure (bridges, corduroy, etc.) are structurally safe and sound for specified class of user. b. Maintain drainage structures to prevent unacceptable resource damage, and c. Remove hazards from the trail to allow safe passage of specified class of users. A safety hazard is a physical condition of ta trail which may cause injury, is unusual or unexpected, and not readily identifiable by the trail user. It is not a condition which is easily identifiable and normally encountered for the type or location of the trail involved.… 03. Provide a full range of trail opportunities in coordination with other Federal, State and municipal jurisdictions and private industries both on and off NFS lands. General direction regarding the CDNST, Forest Plan III-82 to III-83, 04. Apply Interim Management for the CDNST corridor to identified alternative routes utilizing both existing trails and roads and non-existing routes which may be used as connecting travel segments. Interim management will establish visual quality objectives for the foreground and middle ground areas within the corridor. Standards & Guidelines: a. The CDNST corridor is that area which encompasses the foreground and middle ground of the seen-area as viewed from the alternative travel routes identified in the CDNST Comprehensive Plan. Interim management which protects the recreation opportunities will be applied until such time that a specific trail reroute is formally designated as part of the CDNST system. b. All travel route alternatives with the CDNST corridor will have a Visual Management System sensitivity Level I classification until a specific trail route is formally designated. Foreground and middle ground areas within the corridor will meet the highest visual quality objective available within the existing visual condition class constraints and the visual quality objective of the management area. 05. Do not mark existing travel routes as being a part of the CDNST system until they have been formally designated.

13 06. Upon formal designation of a travel route segment as a part of the CDNST system, manage the segment to emphasize foot travel, provide for horse use where safe to do so, and the continuation of motorized use where presently permitted and considered appropriate in the management direction for the overall management area. Give consideration to the needs of the long-distance traveler.” Applicable Standards & Guidelines: a. The formally designated CDNST travelway will have sensitivity Level I Classification. Foreground and middle ground areas as seen from the trail, will meet the highest visual quality objective within the existing visual quality objective of the specific management area. c. All other prescribed direction, standards and guidelines for the specific management area through which the (CDNST) passes apply.

RGNF 5.11-General Forest and Rangelands. The intent of this Prescription is to allow a variety of management options, such as livestock grazing, wildlife habitat, dispersed recreation, exploration and/or development of minerals and energy resources, and timber harvest. Management emphasis is on a balance of resource uses. Users expect to see other people and evidence of human activities. Facilities supporting the various resource uses are common. Motorized transportation is common. Visitors can expect to see managed but natural-appearing stands of trees. Recently cut areas will show tree stumps, slash, skid trails, and soil disturbance. Appropriate settings are offered that are suitable for a broad range of recreation opportunities. Recreation facilities are improved based on user demand. The ROS class is Modified Roaded. Game retrieval is authorized using ATVs. (Applies to portions of alternatives 2, 3, 4 and 5.) 5.13-Forest Production. The intent of this Prescription is to allow a full range of activities, with an emphasis on the production of commercial wood products. Numerous open roads offer commercial access and roaded recreational opportunities, while restricted roads offer non- motorized-recreation opportunities. Users expect to see other people and evidence of human activities. Facilities supporting the various resource uses are common. Motorized transportation is common. Forest visitors can expect to see managed stands of trees in a natural or near- natural forest setting. Stands will have evidence of management, including tree stumps, slash, skid trails, and soil disturbance. Game retrieval is authorized using ATVs. (Applies to portions of all alternatives.) 5.41-Deer and Elk Winter Range. These areas are managed to supply adequate amounts of quality forage, cover, and solitude for deer, elk, and other species while on winter range. In winter, manage human activities so that deer and elk can effectively use the area. Motorized travel, including snowmobiles, is restricted to designated roads and trails, except for ATV biggame retrieval. Users expect to see other people and evidence of human activities. Facilities supporting the various resource uses are common. The ROS class is Roaded Modified. (Applies to portions of alternatives 2, 3 and 4.) 6.6-Grassland Resource Production. These areas are managed to produce forage for livestock. Users expect to see other people and evidence of human activities. Facilities supporting the various resource uses are common The ROS class is Modified Roaded. Game retrieval is authorized using ATVs. (Applies to portions of alternatives 2, 3, 4 and 5.)

14 RGNF Forest Plan at Chapter 3, page 33, 4. Congressionally designated National Historic, Scenic, or Recreation Trails and CT will receive higher priority than other trails for reconstruction, operation, and maintenance. Decision Framework

Authorities The following delegation of authorities is pertinent to the decision to be made on this segment of the CDNST. Regional Foresters is responsible for: • Approving the location of these trails within the applicable corridor and signing notices for the Federal Register of availability of maps and descriptions of the location of these trails (16 U.S.C. 1246(a)(2) and (b)). For trails that traverse multiple regions, the lead regional forester has this responsibility. • Approving non-substantial relocations of National Scenic and National Historic Trails, publishing required notices in the Federal Register, and referring recommendations for substantial relocations to the Chief (16 U.S.C. 1246(b)). For trails that traverse multiple regions, the lead regional forester has this responsibility. (FSM 2353.04g(3)(2 & 6)) • Establishing connecting and side trails as components of National Recreation, National Scenic, or National Historic Trails, as appropriate, under Section 6 of the National Trails System Act. (FSM 2353.04g(4)) Forest Supervisors are responsible for: • Deciding if bicycle use will be allowed on the CDNST (FSM 2353.44b, para. 10). • Deciding if motor vehicle use will be allowed on the CDNST (FSM 2353.44b, para. 11). (This applies only to Alternative 1). • Encouraging the use of volunteers and volunteer organizations in planning, developing, maintaining, and managing the CDNST (16 U.S.C. 1250). (FSM 2353.04i(13)(b, c, f)) District Rangers are responsible for approving Trail Management Objectives (FSM 2353.12), unless that responsibility has been reserved by the Forest Supervisor. (FSM 2353.04j)

Decision The Regional Forester of the Rocky Mountain Region has delegated the authority for making this decision to the GMUG and RGNF Forest Supervisors. The GMUG and RGNF Forest Supervisors will jointly decide whether or not to: • Approve relocation of each of the segments of new CDNST/CT proposed; • Prescribe one design standard/specification (Trail Class) for this segment of the CDNST/CT and Luder’s Spur; • Designate type of use for each trail segment; • Approve facilities to establish at trailheads and at which specific locations. The Forest Supervisors must determine consistency with Law, Regulation, Policy and Forest Plans. The analysis supporting this decision was conducted by a joint Interdisciplinary team comprised of members from both Forests. No cooperating agencies were identified.

15 Public Involvement Scoping for public concern and comment for these facilities was initially done in 2010. Scoping consisted of adding this project to the Schedule of Proposed Actions published through PALS in July of 2010, and sending a scoping letter and map to an extended list of potentially affected/interested parties, agencies and elected representatives. The Scoping letter and map, as well as the mail lists to whom they were sent are in the record. The comment period was from August 13, 2010 (the date of the scoping letter), to September 17, 2010. It should be noted that this was NOT the 30 day Notice and Comment period required under 36 CFR 215, and that another comment period was offered upon completion of this EA. Letters and emails were received from 19 parties, including individuals, organizations, and the Colorado Division of Wildlife (now Colorado Parks and Wildlife). These responses are in the record, and were used directly to identify issues below. In addition to the project specific scoping discussed above, the analysis process that supported the Gunnison Basin Federal Lands Travel Management decision of 2010 provided an opportunity for comment on the Continental Divide Trail. Comments received are recorded in Appendix XX of the Final Environmental Impact Statement, Gunnison Basin Federal Lands Travel Management, April 2010, at pages XX-24 to XX-30. These comments were reviewed and considered as part to this EA, and are incorporated by reference. In summary, comments argued the question of whether the CDNST should be used for motorized use, or not, and advanced positions supported by “intended purposes for the use of the CDNST.” All of these comments were also considered in the development of issues and alternatives. A pre-decisional version of this EA was circulated in October 20 through December 17, 2012 for the official comment period. Approximately 57 letters were sent out which included local media; EA was posted to the web; and legal notices were printed in the local newspapers and newspapers of record. Approximately 890 comments were received from across the United States and Canada during the comment period and approximately 28 were received after the comment period closed. Several local trail groups commented, as well as, counties, individual users, and national groups such as the Continental Divide Trail Coalition, The Colorado Trail Foundation, American Hiking Society and the International Mountain Biking Association. Comments have been summarized and included along with responses in Appendix C.

Issues As a product of scoping and interdisciplinary discussions, the following issues have been identified as either unresolved conflicts requiring alternative analysis to come to decision or potential resource impacts which should be addressed to come to an informed decision. These form the basis for the formulation of alternatives (Chapter 2), and for the environmental impacts analysis (Chapter 3). Text in parenthesis (…) describes where this is considered. • Compare user experience of this segment of trail to the existing route. (Chapter 3). • Address intent and purpose of the CDNST system. (Chapter 1- Background; Laws, Regulation and Policy) • Address impacts on scenery. (Chapter 3) • Trail use and construction may have impacts on wildlife such as direct habitat loss, fragmentation of habitat, and changing animal distributions. (Chapter 3, administrative file)

16 • Trail use and construction may spread noxious weeds. (Chapter 2, Conservation Measures, Chapter 3) • Trail use and construction may impact connecting corridors for lynx and other wildlife. (Chapter 3, administrative file) • Trail use and construction may impact cultural sites. (Chapter 3, administrative file) • Trail use and construction may impact access for elderly and handicapped. (Appendix C) • Trail construction may increase access for hunting in areas not now accessed by trail. (Chapter 3) • Describe effects of new trail location on trail maintenance cost if trees across the trail are not maintained in a timely manner. (Chapter 3) • Trail use and construction may have impacts on grazing management, gates left open, etc. (Chapter 2, Conservation Measures, Chapter 3) • Consider an alternative(s) that allows more ready-access to water. (Chapter 2, Alternatives Considered but Eliminated from Detailed Study) • Address user access to water along trail. needs to be routed so users have access to water (Chapter 3) • Consider an alternative that includes mountain bike use of the trail. (Alternatives 1, 3 & 5) • Consider an alternative that includes no motorized use of the trail. (Alternatives 2-5) • Consider an alternative that includes no motorized or mechanized use of the trail. (Alternatives 2 & 4) • Consider an alternative that includes trailhead facilities that accommodate only non- motorized or non-mechanized use. (Alternative 4) In addition to the issues above, the following resource concerns were identified by the interdisciplinary team requiring analysis in the EA to provide the “hard look” environmental analysis required to make an informed decision. • Trail use and construction may have impacts on soils. (Chapter 3) • Trail use and construction may have impacts on water quality. (Chapter 3) • Trail use and construction may have impacts on Threatened or Endangered or sensitive wildlife species in addition to lynx. Chapter 3, project file) • Trail use and construction may have impacts on Threatened or Endangered plants. Chapter 3, administrative file) • Trail use and construction may have impacts on Road/Transportation System. (Chapter 3) • Trail use and construction may have impacts on Roadless Area resources/values. (Chapter 3)

17 (Intentionally left blank)

18 CHAPTER 2. ALTERNATIVES INCLUDING THE PROPOSED ACTION

This chapter describes and compares the alternatives considered.

Alternatives Considered in Detail Five alternatives were considered in detail for this environmental analysis, as a result of the scoping process. The alternatives presented below represent a range of reasonable alternatives, given the purpose and need and Key Issues for the proposed action. The No Action and three action Alternatives are described and analyzed in detail as follows: • Alternative 1 - No Action • Alternative 2 - (Proposed Action) Hiker/Horse Trail with Facilities • Alternative 3 - Mechanized Trail Use without Facilities • Alternative 4 - (Minimal Development) Hiker/Horse trail without Facilities • Alternative 5 – Non-motorized Trail with Facilities (Preferred Alternative)

Alternative 1 – No Action The Council for Environmental Quality (CEQ) regulations for implementing the National Environmental Policy Act (NEPA) requires that a no action alternative be developed as a benchmark from which the agency can evaluate the proposed action. Under Alternative 1, the CDNST/CT would remain on the current location with no changes to allowable modes of travel. The key features of the No Action Alternative are summarized below in Table 2-1. Table 2-1. Key Features of Alternative 1.

Key Feature Description

New Trail Construction 0 Miles

New Horse and Hike Trail 0 Miles

New Mechanized Trail 0 Miles

CXT Toilets Installed 0

Number of Parking Areas/Trailheads Constructed 0

Area Disturbed by New Parking Areas/Trailheads 0 Acre

Miles of Non-motorized Trail Decommissioned 0 Miles

Miles of CDNST Located on Motorized Roads and 27.0 Miles Trails

19 Figure 2-1. Alternative 1

20 Design Features Applicable to All Action Alternatives The following design features will be included as part of any action alternative to minimize and prevent additional impacts. Use of these conservation measures has been included in effects analysis in Chapter 3.

Protection of Visual Resources A ½ mile buffer (corridor) on either side of the trail will be established according to the Scenery Management System (FSM 2382.1) to protect foreground view of trail. This buffer requires special visual design elements be considered when implementing other projects near the CDNST to avoid creating additional road or other motorized crossings on the trail, creating routes perpendicular to the trail or creating unnatural appearing conditions. Protecting visual resources to this degree is compatible with existing Forest Plan management areas, areas within those management areas with Scenic Integrity Objective levels of high, moderate and low, and allows for continued forest management.

Protection of Wildlife • Placement of the new trail would avoid areas of accumulated down wood that could structurally support lynx denning. Lynx denning habitat characteristics are described in the Southern Rockies Lynx Management Direction, Record of Decision (USDA Forest Service 2008, see Glossary section). • Where practicable, the trail location will avoid areas of multi-storied stands where a dense understory provides snowshoe hare habitat. • In coordination with Colorado Department of Transportation (CDOT) traffic signs would be posted in the vicinity of North Pass and the North Pass trailhead to warn of wildlife crossing and reduce vehicle speeds. • Project activities such as trail and trailhead construction would occur during the period that avoids the need for snowplowing to access sites for project implementation. • Project personnel will be informed to report any individual lynx noted during the duration of project activities. Any sightings or encounters with lynx should be reported to the Forest Service. • Project personnel will be informed to report any TES species noted during the duration of project activities. Any sightings or encounters with TES species should be reported to Forest Wildlife Biologist, RGNF or District Wildlife Biologist, GMUG, Gunnison Ranger District.

Protection of Cultural Resources All persons associated with operations under this decision must be informed that any objects or sites of cultural, paleontological, or scientific value such as historic or prehistoric resources, graves or grave markers, human remains, ruins, cabins, rock art, fossils, or artifacts shall not be damaged, destroyed, removed, moved, or disturbed. If in connection with operations under this decision any of the above resources are encountered workers shall immediately suspend all activities in the immediate vicinity of the discovery that might further disturb such materials and notify the Forest Service authorized officer of the findings. The discovery must be protected until notified in writing to proceed by the authorized officer (36 CFR 800.110 & 112, 43 CFR 10.4).

21 Protection of Watershed • Use Forest Service Region 2 Watershed Conservation Practices Handbook (FSH 2509.25) in the development of the proposed trail alignment, design elements and during construction to aid in maintaining existing watershed condition. • Use FSH 2509.18 and FSH 2509.25 in the development of the proposed trail to be consistent with the direction contained in the Forest Service National Best Management Practices for Water Quality Management on National Forest System Lands (Volume 1: National Core BMP Technical Guide, April 2012) publication.

Protection of Range Resources

Gates • Any fences on the RGNF that require breaching to allow user passage will be modified with properly constructed walk-around structures in addition to gates to minimize the occurrence of gates being left open by hikers. • All gates will require proper signage to inform the public to close the gate. • The UTM coordinates of all gate locations will be given to the RGNF range specialist for entry into the Forest Service database of record. Maintenance of gates and walk-around structures will be listed as protected improvements and monitored.

Noxious Weeds • All equipment/tools used in the project area will be washed and free of noxious plant seed prior to entering the project area. Contractors will be required to certify that their equipment has been properly cleaned prior to entering the project area.

Reseeding • In heavily disturbed sites where there are larger areas of disturbance, such as parking areas and toilet installation areas, reseeding is recommended. • All reseeding should be done using a Forest Service approved seed mix. It is recommended that approved seed mixtures from either the Saguache Ranger District or the Gunnison Ranger District be utilized for any needed reseeding. The recommended seed mixture from the RGNF reclamation prescriptions (1998) are attached (see Appendix B). The seed may be broad-cast applied. However, the soil surfaces need to be firm enough to prevent erosion, but loose enough to allow the seed sprouts to penetrate the soil. The seeding should be done by the end of the growing season in which the disturbance takes place. Fall seeding, on snow, is often the best time to seed in the elevations of the project area. • Natural materials should be used for erosion and sediment control. Cut brush and or aspen should be used to construct silt and sediment control structures. Engelmann spruce and Douglas-fir should not be used due to the increased risk of bark beetle infestation.

Alternative 2 (Proposed Action) Hiker/Horse Trail with Facilities Under Alternative 2 approximately 31.2 miles of new trail construction would occur from the Skyline Trail (#465) in the La Garita Mountains to Lujan Pass with the purpose of re-routing the CDNST and CT from the current location. One spur trail of 0.9 miles would be constructed to

22 connect the CDNST and Colorado Trail to Luder’s Campground. Allowable uses on this trail would include horseback riding and hiking. Motorized and mechanized use would not be permitted. A parking area would be constructed at the top of North Pass (Hwy 114) on the south side of the road which would be approximately 1/4 acre in size. A single CXT vaulted toilet would be installed at the parking area on North Pass. A trailhead and parking area up to ¼ acre in size would be constructed at Luder’s Campground. Approximately 2.0 miles of non- motorized trail on the GMUG NF would be decommissioned following construction of the new trail. See the “Proposed Action” section of this EA for a description of individual segments of trail. This alternative is consistent with the design of Trail Class 2 Pack and Saddle or Trail Class 2 with a tread width of 24” and clearing limits of 6 feet (three feet on each side of the trail). See Appendix A for design specifications. Table 2-3. Key Features of Alternative 2

Key Feature Description

New Trail Construction 32.1 Miles

New Horse and Hike Trail 32.1 Miles

New Mechanized Trail 0 Miles

CXT Toilets Installed 1

Number of Parking Areas/Trailheads 2

Area Disturbed by New Parking Areas/Trailheads < ½ Acre

Miles of Non-motorized Trail Decommissioned 2.0 Miles

Miles of CDNST Located on Motorized Roads and 0 Miles Trails

23 Figure 2-3. Alternative 2.

24 Alternative 3 - Mechanized Trail Use without Facilities Under Alternative 3 approximately 31.2 miles of new trail construction would occur from the Skyline Trail (#465) in the La Garita Mountains to Lujan Pass with the purpose of re-routing the CDNST and CT from the current location. One spur trail of 0.9 miles would be constructed to connect the CDNST and Colorado Trail to Luder’s Campground. Allowable uses on this trail would include horseback riding, hiking and mountain biking (mechanized use). Motorized use would not be permitted. Approximately 2.0 miles of non-motorized trail on the GMUG NF would be decommissioned following construction of the new trail. Because terrain is not expected to be an issue in terms of grade, this alternative is consistent with the design of Trail Class 3 for Hiker/Pedestrian, Trail Class 2 Pack and Saddle or Trail Class 2 or 3 for Bicycle with a tread width of 24” and clearing limits of 6 feet (three feet on each side of the trail). See Appendix A for design specifications. Table 2-3. Key Features of Alternative 3.

Key Feature Description

New Trail Construction 32.1 Miles

New Horse and Hike Trail 32.1 Miles

New Mechanized Trail 32.1 Miles

CXT Toilets Installed 0

Number of Parking Areas/Trailheads 0

Area Disturbed by New Parking Areas/Trailheads 0 Acres

Miles of Non-motorized Trail Decommissioned 2.0 Miles

Miles of CDNST Located on Motorized Roads and 0 Miles Trails

25 Figure 2-3. Alternative 3.

26 Alternative 4 - (Minimal Development) Hiker/Horse Trail without Facilities Under Alternative 4 approximately 31.2 miles of new trail construction would occur from the Skyline Trail (#465) in the La Garita Mountains to Lujan Pass with the purpose of re-routing the CDNST and CT from the current location. Allowable uses on this trail would include horseback riding and hiking. Motorized and mechanized use would not be permitted. Approximately 2.0 miles of non-motorized trail on the GMUG NF would be decommissioned following construction of the new trail. Because this alternative minimizes allowable uses, this alternative is consistent with the design of Trail Class 3 for Hiker/Pedestrian or Trail Class 2 for Pack and Saddle or with a tread width of 24” and clearing limits of 6 feet (three feet on each side of the trail). See Appendix A for design specifications. Table 2-4. Key Features of Alternative 4.

Key Feature Description

New Trail Construction 31.2 Miles

New Horse and Hike Trail 31.2 Miles

New Mechanized Trail 0 Miles

CXT Toilets Installed 0

Number of Parking Areas/Trailheads 0

Area Disturbed by New Parking Areas/Trailheads 0 Acres

Miles of Non-motorized Trail Decommissioned 2.0 Miles

Miles of CDNST Located on Motorized Roads and 0 Miles Trails

27 Figure 2-4. Alternative 4.

28 Alternative 5-Non-motorized Trail with Facilities (Preferred Alternative) It was always the intent of the GMUG and RGNF to include facilities such as trailheads and toilets in Alternative 3 above, but this did not happen in the pre-decisional EA. In order to avoid changing alternatives that went out for public review, this alternative was added based on comments received that pointed out the oversight. Under Alternative 5 approximately 31.2 miles of new trail construction would occur from the Skyline Trail (#465) in the La Garita Mountains to Lujan Pass with the purpose of re-routing the CDNST and CT from the current location. One spur trail of 0.9 miles would be constructed to connect the CDNST and Colorado Trail to Luder’s Campground. Allowable uses on this trail would include biking, horseback riding and hiking. Motorized use would not be permitted. A parking area would be constructed at the top of North Pass (Hwy 114) on the south side of the road which would be approximately ¼ acre in size. A single CXT vaulted toilet would be installed at the parking area on North Pass. A trailhead and parking area up to ¼ acre in size would be constructed at Luder’s Campground. Approximately 2.0 miles of non-motorized trail on the GMUG NF would be decommissioned following construction of the new trail. Please refer to Figure 2-2 which has all the same features as this alternative. Because terrain is not expected to be an issue in terms of grade, this alternative is consistent with the design of Trail Class 3 for Hiker/Pedestrian, Trail Class 2 for Pack and Saddle or Trail Class 2 or 3 for Bicycle with a tread width of 24” and clearing limits of 6 feet (three feet on each side of the trail). See Appendix A for design specifications. See the “Proposed Action” section of this EA in Table 1-1 for a description of individual segments of trail. Table 2.5 Key Features of Alternative 5

Key Feature Description

New Trail Construction 32.1 Miles

New non-motorized (Hiker/Horse/Bike)Trail 32.1 Miles

CXT Toilets Installed 1

Number of Parking Areas/Trailheads 2

Area Disturbed by New Parking Areas/Trailheads < ½ Acre

Miles of Non-motorized Trail Decommissioned 2.0 Miles

Miles of CDNST Located on Motorized Roads and 0 Miles Trails

Alternatives Considered but Eliminated from Detailed Study Alternatives, or aspects of alternatives, which were considered but eliminated from further detailed analysis include:

29 Construct a parking area on the south side of the Old Cochetopa Pass Road (NN14) and include the installation of interpretative signs. This alternative was dropped because these facilities would not be needed given the anticipated levels of use. Construct a highway underpass on Highway 114. This alternative was dropped because it would have been too expensive. Three options were considered in the field for the location of the trail crossing of Hwy 114. This analysis is documented in the file for this project. Two locations were considered and not brought forward for consideration as alternatives. Option 2 was brought forward and is part of the proposed action.

Reroute Option1 (Continental Divide Trail Society) The following routes were considered but eliminated from detailed consideration in this EA: • USGS North Pass Quadrangle. Between Lujan and North Pass, contour west of hill 10989. This already appears to be your plan; if practicable, we would recommend that the Trail remain no higher than 10600 feet of elevation here. From North Pass to Luders Spur, try to avoid the tops of hills 10998 and 10684 unless they offer notable vistas. From Luders Spur to Cochetopa Pass, contour as practicable, particularly east of hill 10422. South of Cochetopa Pass, contour west of the Continental Divide, through the saddle east of hill 10165, in order to provide more convenient access to Los Creek (see comments on access to water). Trail design requirements will dictate the actual location of the trail. The proposed route has been considered for the gentlest grades possible while staying as near to the divide as practicable. Reroute to Los Creek is addressed in next section. • USGS Cochetopa Park Quadrangle. Ascend gradually on the east side of the Divide. Trail design requirements will dictate the actual location of the trail. The proposed route has been considered for the gentlest grades possible while staying as near to the divide as practicable,

Develop trail so there is access to water at the following locations The following access routes to water were considered but eliminated from detailed consideration in this EA: • Southbound hikers, in most seasons, will be able to obtain water from Razor Creek, an estimated 7.1 miles north of Lujan Pass. This area is approximately 5 miles north of the northern end of the proposed trail segment and is therefore outside the area of analysis. • There is a small stream flow in Lujan Creek, a half mile west of Lujan Pass where hikers can get water. There is an evident need for the new segment to be routed so users have access to water at one or more locations along the way. The closest portion of the trail to this water source is the very northern end of this segment where it crosses NFSR 785 on the GMUG. Closer to the proposed alignment at this same

30 road/trail juncture is to go east on to the RGNF and get water from Spanish Creek. Because both of these water sources are at a road junction with the trail with easy, less than ½ mile access in either direction they are not being considered for additional analysis or reroute. • Let us assume that water of reasonable quality can be expected, with confidence, to be found at Monchego Park. An alignment to Monchego Park should be a last resort. Hikers would be displeased by the elevation changes that would be necessitated in order to access Monchego Park. Following the ridgeline, through the openings depicted on the topographic maps, would be a more scenic and enjoyable way to proceed along the CDNST. We request reconsideration of the proposal to descend to Monchego Park (900 foot elevation loss) and ascend a similar amount to return to the Continental Divide. West of Saguache Park Road (787), the proposed route may minimize potential conflict with motorized users traveling on the mapped jeep trail; it might nevertheless be worthwhile to remain closer to contour if the blue spots on the map represent likely sources of decent water or if the open terrain offers greater scenic opportunities than would be the case for the wooded ridgeline of the Divide. There is no proposal in front of GMUG to consider a route to Monchego Park from the proposed CDNST. It is merely noted as a possible water source in the vicinity of the proposed CDNST in the efforts of disclosure. • Luder's Campground. The EA provides little information regarding the water here. The USGS map shows the creek to be ephemeral. Information on the Forest website cautions "NO POTABLE WATER" ... "No drinking water for humans." Luder’s campground is an existing facility that would serve primarily as either an entry or exit point which may or may not receive camping use from trail users particularly hikers due to its distance from the CDNST. There is no reliable water in this creek. • Los Creek is the best accessible water source between Lujan Pass and Cochetopa Creek. Los Creek "though small should prove to be a dependable water source. To access Los Creek, realign the route south of Cochetopa Pass through the notch to the east of hill 10165 and intersect the Jakes-Los jeep trail; from this point, we estimate that water would be found no more than 0.5 mile down the jeep trail, with an elevation loss of 300 feet or less. Because this option includes using the existing transportation system which includes motorized use, that is accessible from the proposed trail route on the Divide, realigning the trail onto the Jeep trail is not being considered in this analysis due to the inconsistency with The Act. • If the proposed alignment along the Divide were retained, a spur to Los Creek would be more convenient that the Luder's Spur. Assuming that the Trail is realigned to bypass Monchego Park, the distance between Los Creek and Cochetopa Creek (at the southern end of the reroute) is approximately 19 miles. Creating a trail in this area is not as consistent with The Act as keeping it on the Divide and would further be difficult to manage because of the proximity to existing roads and other ongoing management activities.

Reroute Options 2 & 3 (Van Der Linden) • An existing pack trail could be used along Nutras Creek to connect to County Road 14dd. Another option would be to construct a new trail of less than 1 mile exiting the CDNST at the same point but connecting to an existing jeep trail which leads to the corrals near Chavez creek. Both of these routes would allow bikes to exit the CDNST

31 just prior to entering the wilderness area and provide a more scenic and challenging Colorado Trail reroute to Los Pinos Pass via Big Meadow and Willow Park. We agree that these segments warrant consideration for future loop options in the context of a larger transportation system. Because some of these options include the existing transportation system which includes motorized use, they are not being considered in this analysis due to the inconsistency with The Act.

Comparison of Alternatives Table 2-5 briefly compares the alternatives considered in detail. Detailed analysis of the resource areas affected is included in Chapter 3. Table 2-5. Comparison of Alternatives

Resource Alternative 1 (No Alternative 2 Alternative 3 Alternative 4 Alternative 5 Action) (Proposed (Preferred Action) Alternative)

Trail Setting Elevation/Topogr Elevation/Topography-trail along Continental Divide aphy-trail in lower elevation Vegetation/Views-view of La Garitas, Sangre de Cristos, San Luis Valley form predominately wooded trail; more opportunity for solitude Vegetation/Views -view of Roadless-non-motorized trail segment; more impacts from adding additional trail Continental Divide from roads and Water- limited availability of water; several reliable sources ½ to ¾ mile from trail motorized trails; approximately 1/3 of trail in open environments; limited opportunity for solitude

Roadless-non- motorized trail segment

Water-close to trail at several locations

Trail Use and Mode of Travel Mode of Travel Mode of Travel Mode of Travel Mode of Travel Access Designation- Designation- Designation- Designation- Designation- variety of hiker/horse hiker/horse/bikes hiker/horse hiker/horse/bikes motorized and non-motorized Access to the Access to the Access to the Access to the uses and routes Trail including Trail including Trail including Trail including parking-Trailhead parking-limited parking-limited parking-Trailhead Access to the along HWY 114 unsafe parking unsafe parking along HWY 114 Trail including and at Luder’s along HWY 114 along HWY 114 and at Luder’s parking-limited Campground Campground unsafe parking Trail Use-low Trail Use-low along HWY 114 Trail Use-low levels of use levels of use Trail Use-low levels of use consistent with consistent with levels of use Trail Use-low to consistent with ROS includes ROS includes consistent with very low levels of ROS includes hikers/horses/bike hikers/horses; ROS includes hikers, mountain hikers/horses; s; winter use not winter use not hikers/horses/bike

32 Resource Alternative 1 (No Alternative 2 Alternative 3 Alternative 4 Alternative 5 Action) (Proposed (Preferred Action) Alternative)

bikers, horseback winter use not encouraged due to encouraged due to s; winter use not riders, motorcycles encouraged due to wildlife conflicts; wildlife conflicts; encouraged due to and other wildlife conflicts; outfitters-no outfitters-no wildlife conflicts; motorized travel outfitters-no change from change from outfitters-no where applicable; change from existing condition; existing condition; change from light to non- existing condition; hunting additional hunting additional existing condition; existent winter hunting additional non-motorized non-motorized hunting additional use; outfitters- non-motorized hunting access hunting access non-motorized some local ranch hunting access although may although may hunting access use and CDNST although may conflict with other conflict with other although may through hiker conflict with other recreational use recreational use conflict with other supplying; hunting recreational users recreational use common with dispersed camps

User Experience & User experience More desirable More desirable More desirable More desirable Trail Effects not ideal. hiker/horse trail hiker/horse/bike hiker/horse trail hiker/horse/’bike Motorized mixed- experience, trail experience, experience, trail experience, use conflicts. conflicts may occur conflicts may occur conflicts may occur conflicts may occur Social and between users between users between users between users physical impacts although expected although expected although expected although expected continue to occr. to be minimized to be minimized to be minimized to be minimized through proper trail through proper trail through proper trail through proper trail design; resource design; resource design; resource design; resource impacts will occur impacts will occur impacts will occur impacts will occur on soils, water, on soils, water, on soils, water, on soils, water, vegetation and vegetation and vegetation and vegetation and wildlife, but are wildlife, but are wildlife, but are wildlife, but are expected to be expected to be expected to be expected to be minimal minimal minimal minimal

Wildlife- Canada lynx-No Canada lynx-may affect not likely to adversely affect. Threatened and impact Endangered Wolverine and Gunnison sage-grouse not likely to jeopardize. Species Wolverine and Gunnison sage- grouse not likely to jeopardize.

Wildlife-Sensitive Sensitive Sensitive Species and Management Species-No Indicator Species impact any species • No impact for American peregrine falcon, spotted bat, or Townsend’s big- (MIS) eared bat MIS-No impact any • May adversely impact individuals, but not likely to result in a loss of viability species in planning area, nor cause a trend toward federal listing for boreal owl, flammulated owl, northern goshawk, olive-sided flycatcher, American marten, pygmy shrew, Rocky mountain bighorn sheep, or wolverine.

MIS

Impacts are expected; however magnitude of potential impacts is negligible in comparison to forest-level habitat distribution and availability.

33 Resource Alternative 1 (No Alternative 2 Alternative 3 Alternative 4 Alternative 5 Action) (Proposed (Preferred Action) Alternative)

Migratory Birds No impact Habitats impacted:

• Aspen <1 ac • High elevation riparian-no impact • Mixed conifer <11 acres • Spruce fir < 8 acres

Plants Endangered-None Endangered-None present present Sensitive Sensitive • Park milkvetch-not found cannot assess • Park • Narrowleaf moonwort and Colrado tansy-aster May adversely impact milkvetc individuals, but not likely to result in a loss of viability in planning area, nor h-not cause a trend toward federal listing found • Peculiar moonwort-no impact cannot assess • Narrowle af moonwo rt and Peculiar moonwo rt-no impact • Colrado tansy- aster-no impact

Cultural No adverse effects No adverse effects

Watershed Some erosion from Some continued erosion from roads resulting in increased sediment in creeks roads resulting in increased Approximately 11 acres of exposed soils. Little additional erosion potential affect to sediment in creeks watershed. Somewhat beneficial effect of adding trailheads in Alternatives 2 and 5 by reducing improper human waste disposal. Somewhat beneficial effect of closing 2 miles of trail.

Road/Transportati Road system would not change on System

Livestock Grazing Continued concern Conservation measures would minimize impacts to livestock management and spread Use with noxious of noxious weeds from construction activities weeds in any disturbed areas.

34 CHAPTER 3. AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

This section discusses the physical, biological, social and economic environments of the affected project area and the potential changes to those environments which could result from implementation of the alternatives. Cumulative Actions Considered in the Analysis Cumulative effects of past present or reasonably foreseeable future actions taking place near enough to the area affected by this project need to be considered. Each resource section of Chapter bounds its analysis area and identifies which of the following actions may have cumulative effects in terms of that resource. The relevant past, present, and foreseeable future activities for consideration in cumulative effects analysis for this specific Analysis Area include: (a) livestock grazing in the area, (b) wildlife, (c) timber harvesting/thinning and wood gathering, (d) recreation, (e) private land development, (f) roads and trails, (g) fire suppression and use, (h) mining, and (i) insect and disease. Each of these is briefly discussed below: Livestock Grazing Livestock grazing has occurred in this area since the late 1800s and continues today. Portions of the trail reroute are currently being used as stock trails as was evidenced by use; this would continue. Wildlife Wildlife ungulate numbers (primarily elk, deer, and bighorn sheep) and rodent populations have fluctuated in the past and would probably continue to do so in the future. When wildlife numbers are high, there could be impacts on palatable Sensitive plants, if they occur in the analysis area. The Colorado Division of Parks and Wildlife monitors and manages wildlife with the goal of keeping big game numbers within their stated objectives. Timber Harvesting/Thinning and Wood Gathering There has been some past timber cutting and wood gathering in the analysis area (mostly commercial harvesting of Engelmann spruce and lodgepole pine outside Wilderness). There are 24 stands of lodgepole pine within 6 feet of the trail (1800 ac), 5 stands of spruce (984 acres) and 7 stands of aspen (650 acres). The other stands within 6 feet of the trail are grass covertype. There are current and future plans for commercial timber harvest and firewood gathering activities. Recreation There is a network of roads and trails in the analysis area which facilitates a variety of recreation access and use. This area has been historically lightly used for mostly dispersed recreation use (driving for pleasure, hiking, camping, etc.) with peak use probably during the fall hunting seasons. Private Land Development

35 Private land exists inside the analysis area and it is mostly associated with patented mining claims. While mining this adds to the historical context of the area, development is minimal and there are no current or foreseeable plans for notable changes in these lands. Roads and Trails There is an infrastructure network of roads and trails in the analysis area. This infrastructure has been in place for many decades, although recent Travel Management Decisions have reduced open road density in this area. Fire Suppression and Use In the past, there has been widespread fire suppression activity, especially at the lower elevations and particularly in the last 50 years or so. However, much of the analysis area is either subalpine or alpine habitat where there has been limited, if any, fire suppression. Currently and in the foreseeable future, there are limited plans for use of prescribed fire at these higher elevations. Mining Mining considers leasable (oil and gas), saleable (sand and gravel), and locatable (hard-rock) minerals. Past mining activities have been primarily locatable mineral activity. Currently, and in the foreseeable future, there are no known plans to appreciably expand this activity in the analysis area. Insect and Disease Insect and disease outbreaks are increasing in the analysis area. Currently, there is a large spruce beetle epidemic causing high mortality in Engelmann spruce forests. We are also starting to see mountain pine beetle in the lodgepole pine along the divide. Cultural Resources The loss of archaeological resources has happened in the past and will happen in the future. The cumulative effect is that over time fewer archaeological resources will be available to learn about past human lifeways, to study changes in human behavior through time, and to interpret the past to the public. Heritage resource inventory, recording, evaluating and archiving basic information about each site for future reference serves to partially mitigate potential cumulative effects to heritage resources. In conjunction with the proposed project, previous logging activities, recreation activities such as hunting, and livestock grazing have the potential to cause ground disturbance and lead to cumulative, long term, irreversible adverse effects to heritage resources. However, because the archaeological site potential appears very low within the analysis, the potential for negative cumulative effects is also low.

Trail Setting

Existing Condition Table 3-1 describes the existing segment of the CDNST as a series of connected existing roads, trails, and two track routes, off of the true Continental Divide to take advantage of existing travel ways, but resulting in a route that is inconsistent with the intended character of the CDNST. Transitions from one route type to another ( e.g., from full sized gravel road to two track, and back, or single track to full sized gravel road, see photographs in Appendix A) are

36 confusing to the user, are poorly marked, and present a challenge to even follow the current alignment of the trail. Table 3-1. Description of the Existing Trail Segments (source Tom Lorang Jones).

Existing Trail Description Segment

From near the end Beginning at Lujan: ...”follow Forest Road 785 as it turns left (south) of Segment 29: away from a spur road that continues straight ahead. At mile 33.7 (10,150), the road crosses over the west side of Lujan Creek, which

may be dry for the first mile or so. The La Garita Mountains loom in the near distance just west of south You will reach Colorado Highway 114 at mile 35.0 (9,720). Turn right (west) and continue along the highway to mile 35.3 where you‘ll find a large pullout on the other (south) side of the road.”

Beginning Segment ….”Pass through a gate in the fence at the southwest end of the 30: pullout on Colorado Highway 114. Follow a clear trail to the south past carsonite posts into the Lujan Cree drainage. The trail soon turns

right (west) at mile 0.3 to parallel the edge of the trees. A tread soon develops a short distance south( left) of the line of posts and crosses Pine Creek at mile 0.6. Don’t follow this across the stream! Just before the near edge of Pine creek, turn left (south) and spot more posts leading upstream along the east side of the water. A faint tread soon develops along this route.” Lupine, wild geraniums, and other bursts of floral fecundity adorn the sides of the trail. Potentilla, rabbitbrush, and willow add color to this arid section of the trail. As an obscure roadbed materializes under the CDT, stay in the drainage along the left side of the streambed until the road crosses over to the right (west) side of the stream at mile 1.8 (9,675). In 0.1 mile, get into the exit lane, take an off-ramp from the stream to the right, and follow it through a 100-yard U-turn that ends up pointing north. The CDT follows a clear logging road (Forest Route 878.1C) out of the drainage and curves back to the south (left) at mile 2.7 (9,940). The road ends in 1.0 mile as a clear single-track continues to the south via a stout, 0.3 – mile climb. This ends at a gate at mile 3.9 (10,260). At mile 4.1, turn left (southeast) off the single-track onto another roadbed (Forest Route 876, unmarked). This descends gradually to the south to a gate at mile 6.4 and reaches Cochetopa Pass Road at mile 6.8. Turn right (west), descend through two switchbacks, and turn left (southeast) onto a jeep road at mile 7.3 (9,630) “ The CDT bend to the right (south, then west) as it climbs gradually to a small stand of trees and a gate at mile 8.1 (9,810). This begins a slight descent into the Los Creek drainage on an idyllic country lane. Stay on the right fork of the main road at mile 8.2 and reach Los Creek at mile 8.6. Follow the road along the creek 0.8 mile to a small pond (9,555) where it forks again. Follow the left fork above Los Creek to the west and climb to mile 9.9 (9,705) on Forest Route 787.2A where

37 Existing Trail Description Segment you will have your first views of the great expanse of Cochetopa Park.” Descend into the park and passes through a gate at mile 11.6. In another 50 yards, stay on Forest Route 787.2a by turning right at a fork. You will reach the well- maintained Saguache Park Road at mile 11.9 (9,352). Turn left (south) and continue to a cattle guard in a wooded saddle at mile 12.8 (9,510). From here the road curves west (right), then south, and reaches the intersection with Forest Route 787.2D, a spur road on the right (southwest ) at mile 13.3 (9,525)”

Beginning Segment Go….”southeast on Forest Route 787.2D. Just after 0.1 mile, leave 31: this road to follow a fainter one to the left (southwest). The CDT soon passes a majestic Ponderosa pine and begins a good climb to mile

0.6. After passing through some trees, the trail breaks out again into sprawling Cochetopa Park and meanders along its southern edge. You will cross Quemado Creek drainage, which is usually dry, at mile 2.1 (9,775) .. A side road branches of to the left (south) to follow this drainage upstream. Avoid this, stay to the right and follow the faint road’s curve 0.2 mile northwest to Forest Route 787.2D which is more clear. Turn left (west), cross the Quemado Creek drainage, and begin a gradual climb. The trail tops out at mile 2.9 (9,960)…… Pass through a gat and descend into the dry Van Tassel Gulch . Cross to the west side to the gulch at mile 3.4 (9,830) and continue 0.1 mile to a road. Turn left (south) and climb steadily through a winsome aspen forest that explodes with color and light in September. Top out in a clearing at mile 5.1 (10,410).” Descend along the road in a slow curve to the right (west, then north) to mile 6.3 where it exits the trees and turns sharply to the left (southwest). Continue 0.3 mile to where several jeep roads converge near a pond. Follow the one farthest left (south) along the edge of the pond and then descend steeply as the road curves to the right (west). At the bottom of this brief descent, look for a very faint trail breaking off to the left (southwest) at mile 6.7 (9,720). If you miss this and end up at the road’s end in a grassy cul-de-sac, walk southeast and pick up the single-track trail where the flat valley bottom meets the steeper hillsides. The single-track soon turns into a jeep road. Where it appears to fork at mile 8.5, take the clearer track that bears left (southeast) behind some spruce trees. In 0.2 mile, the CDT climbs steeply to a bench, beginning a series of climbs and descents above the valley floor. At mile 9.8 (9,945) ne last steep descent takes you to a ford of Cochetopa Creek.… Pickup the trail on the other side.” Continue south to mile 10.4 where the trail crosses Nutras Creek and enters the La Garita Wilderness……”

Source: Excerpt from descriptions of Segments 29, 30 and 31 in the 2002 Updated 2nd Edition (now out of print) of Colorado’s Continental Divide Trail, The Official Guide, by Tom

38 Existing Trail Description Segment Lorang Jones. The book breaks the trail into segments. These do not correspond to maps prepared for this document. Mileages referred to are specific to each segment. Elevations are shown in parentheses.

The CDNST through Colorado traverses some of the most beautiful high elevation mountain scenery in America. Elevations of 13,000 feet and above are not uncommon. For many segments in Colorado the trail is in alpine environments above timber line. Conversely, this segment of trail between Lujan and La Garita, is mostly below 10,500 feet in elevation in forested environments or in lower elevation mountain grassland. The existing trail which takes advantage of a set of connected existing routes (including some full-sized motorized segments, some ATV trails, and some motorized single track) which are well off the Continental Divide is not consistent with the character or objectives intended for the CDNST or CT. Nor is it compatible with the users’ experience of most other segments of the CDNST/CT. The lack of expansive views does not minimize this segment’s importance as a link in the continuous trail system.

Elevation/Topography The existing trail follows drainages and relatively low country. Elevations begin at 10,500 at Lujan, but quickly move down to 10,000, go as low as 9,400 well below treeline through its middle section, then back up to 10,500 feet at La Garita boundary. The existing trail is on northwest side of the Continental Divide off of the divide by as much as 3 miles and on roads,below tree line much of the time.

Vegetation Please refer to the botany reports in the project file for detailed descriptions of the vegetation along the routes. As much as one-third of the length of the existing route is in open, treeless environments, predominantly mountain grassland, below tree line. Tree line in this area is the result of moisture conditions and elevation. Along the proposed route, there are 24 stands (1800 acres) of lodgepole pine within 6 feet of the trail, 5 stands (984 acres) of spruce and 7 stands (650 acres) of aspen. The other “stands” within 6 feet of the trail are grass covertype.

Remoteness/ RecreationOpportunity Spectrum (ROS) The recreation Opportunity Spectrum (ROS) for the existing and proposed route is primarily in “roaded natural” settings with the exception of where the proposed route would occur in management areas 5.11, 5.41, 6.6 on the RGNF which are “roaded modified.” Most of the length of the existing trail is located in “roaded natural” settings which just happen to include the roadless portion. Segments at lower elevations are on the developed end of this ROS class, with the trail actually following existing roads, and passing within sight of dwellings and developed private land. While much of this area does feel “remote”, in that it is a long way from towns and there is not much visitor use, it does not feel primitive or semi-primitive. Roads and development present the appearance and feel of private ranch land type of landscapes.

Visual Resources In a natural setting, visual character attributes are natural elements. Scenic integrity is the degree from which the landscape character deviates from a natural, natural-appearing landscape in line, form, color and texture of the landscape due to human-caused activities.

39 Natural and natural-appearing landscapes have the greatest scenic integrity and are the most valued. As manmade incongruities are added to the landscape the scenic integrity will be altered or decline. Scenic integrity objectives (SIO) are considered very high when the landscape character is intact (“preservation”), high when landscape appears unaltered (“retention”) where deviations present repeat form, line, color, texture and pattern, moderate when the landscape appears slightly altered (“partial retention”), or low when the landscape appears moderately altered (“modified”) as would be the case with management areas 5.11, 5.41 and 6.56 on the RGNF. In areas with high SIO, resource managers strive to perpetuate or create desired scenic environments generally through vegetative screening; these occur along light duty to paved roads, campgrounds and other unroaded areas (in this case areas unmanaged for timber harvest) in the project vicinity. Landscape character encompasses the patterns of topography, vegetation, land use, and aquatic resources which can also be described as the existing landscape attributes. Visual absorption is the ability of the landscape to still appear natural even though human disturbances or alterations are occurring within it. Scenic values increase as terrain allows people to have longer views.

40 Figure 3-1a. Scenic Integrity Objectives Both Forests (roads not shown for RGNF)

41 Landscape visibility (also called visual sensitivity) is the context of viewers, duration of the view and the degree of discernible detail, and the number of visitors to the area. Greater scrutiny of the landscape character and scenic integrity occurs when elements are viewed close-up and for longer periods of time and when landscapes are viewed from aerial views or nearly perpendicular angles in steep terrain. Landscape visibility includes three parts: 1) travelways and uses areas which includes views of the trail or away from the trail, 2) concern levels and 3) distance zones. Visual resource impacts of a trail such at the CDNST can be considered from the perspective of 1) the trail viewed from other places, such as State Highway 114, and 2) views from the trail as seen by users of the trail.

Views of the Trail The existing trail is visible from Highway 114 as it leaves the highway and proceeds southwest as a single track leading through and across an open grassland and stream bottom. It is not easily noticed by drivers on the state highway, and could be mistaken for a cow path. Coming from the north, the trail coincides with, and is, the developed gravel road coming from Lujan Pass. In all instances where the trail can be seen from forest roads (that is where is does not actually coincide with a forest road) the trail is consistent with the visual quality objectives for the general forest, and is congruent in the context of the general forest setting.

Views from the Trail Landscape viewing is subdivided into distance zones. For the visual analysis these distance zone and their related concern levels are defined as: • Immediate foreground: 0 feet to 300 feet (concern level 1)- this area receives the highest scrutiny • Foreground: 300 feet to one-half mile (concern level 1) – this area individual forms dominate (for example individual trees) and other sensory messages are received (for example birds singing) • Middleground: one-half mile to 4 miles (concern level 2-in this area form, texture, and color remain dominant; human activities (such as timber harvest) may cause contrasting features if there are vantage points • Background: 4 miles and greater (concern level 3)- in this area texture disappeared, color is flattened and the landscape appears more simplified As noted above, as much as one-third of the distance of the existing route is in open treeless environments. This affords the user with extensive views of the surrounding country. Predominant views, where vegetation is open enough to allow views from the existing trail, look up from a range of low elevations down to 9,400 feet, at the continental divide in the foreground to middleground to the southeast, as tree covered hills, and then across extended mountain grasslands in the foreground to middle ground to the northwest towards Cochetopa and or Razor Dome in the background. Scenic Integrity Objectives (high, moderate and low) for the area seen from the current trail are consistent with roaded natural settings, and are met by the current trail alignment at all distance zones.

42 Figure 3-1b. Existing Alignment Foreground Viewshed

43 Roadless Character Neither the 2001 Roadless Area Conservation Rule (RACR) nor the 2012 Colorado Roadless Rule (CRR) prohibited trail construction. The proposed trail passes through the center of the Monchego Inventoried Roadless Area (IRA). See Figure 3-2 below. Monchego IRA has had on-going management since it was inventoried in 1979 which had compromised its character. CRR removed Monchego IRA from roadless status, as such; there is no effect on roadless values of the proposed trail passing through this area. The Cochetopa Colorado Roadless Area (CRA), formerly known as North Fork IRA, contains both the most southerly portion of the existing route and the proposed route (Figure 3-2). From IRA designation to CRA designation, areas that contained constructed roads and timber harvest areas were removed and boundaries were adjusted to follow terrain and natural features where possible. This CRA includes “Upper Tier” acres which are more stringent in the activities allowed. The existing route would not be decommissioned in this area. None of the other facilities contemplated, other than the new trail itself, are within or near inventoried roadless areas. Figure 3-2. Proposed Alignment Roadless

44 Roadless characteristics are discussed below as they relate to Cochetopa CRA High quality or undisturbed soil, water, and air. These three key resources are the foundation upon which other resource values and outputs depend. This CRA is within a 10-mile radius of a mandatory Class I airshed as designated by Congress and listed in the Clean Air Act (LaGarita Wilderness). Sources of public drinking water. Maintaining these areas in a relatively undisturbed condition saves downstream communities millions of dollars in water filtration costs. Careful management of these watersheds is crucial in maintaining the flow and affordability of clean water to a growing population. This CRA is within a state-defined source water assessment area (municipal water supply)). Diversity of plant and animal communities. Roadless areas are more likely than roaded areas to support greater ecosystem health, including the diversity of native and desired nonnative plant and animal communities due to the absence of disturbances caused by roads and accompanying activities. Roadless areas also conserve native biodiversity by serving as a bulwark against the spread of nonnative invasive species. Existing vegetation in this area includes forested stands mixed with aspen, lodgepole pine, limber pine, bristlecone pine, and Engelmann spruce. Riparian habitat extends along Cochetopa Creek. Large meadows occur near the Continental Divide. This area provides summer habitat for big game species (black bear, mule deer, elk, and moose) Habitat for threatened, endangered, proposed, candidate, and sensitive species and for those species dependent on large, undisturbed areas of land. Roadless areas function as biological strongholds and refuges for many species. Of the nation’s specie currently listed as threatened, endangered, or proposed for listing under the Endangered Species Act, approximately 25% of animal species and 13% of plant species are likely to have habitat within roadless areas on NFS lands. Roadless areas support a diversity of aquatic habitats and communities, providing or affecting habitat for more than 280 threatened, endangered, proposed, and sensitive species. More than 65% of all Forest Service sensitive species are directly or indirectly affected by inventoried roadless areas. Primitive, Semi-Primitive Non-Motorized, and Semi-Primitive Motorized classes of dispersed recreation. Roadless areas often provide outstanding dispersed recreation opportunities such as hiking, camping, picnicking, wildlife viewing, hunting, fishing, cross- country skiing, and canoeing. While they may have many Wilderness-like attributes, unlike Wilderness the use of mountain bikes, and other mechanized means of travel is often allowed. These areas can also take pressure off heavily used wilderness areas by providing solitude and quiet, and dispersed recreation opportunities. Due to the terrain of the canyon, the area provides opportunities for remoteness and solitude. The portion outside the canyon, however, is on a bench adjacent to the RGNF where the lands are roaded and experience heavy motorized use Reference landscapes. The body of knowledge about the effects of management activities over long periods of time and on large landscapes is very limited. Reference landscapes of relatively undisturbed areas serve as a barometer to measure the effects of development on other parts of the landscape. The La Garita Wilderness is a reference landscape adjacent to the Cochetopa CRA which also has “Upper Tier” acres that may be affected by existing trail or proposed trail alignments. Natural appearing landscapes with high scenic quality. High quality scenery, especially scenery with natural-appearing landscapes, is primary reason that people choose to recreate. In

45 addition, quality scenery contributes directly to real estate values in nearby communities and residential areas. Traditional cultural properties and sacred sites. Traditional cultural properties are places, sites, structures, art, or objects that have played an important role in the cultural history of a group. Sacred sites are places that have special religious significance to a group. Traditional cultural properties and sacred sites may be eligible for protection under the National Historic Preservation Act. No traditional cultural properties or sacred sites have been identified in the vicinity of either the existing trail or the proposed trail alignments in Cochetopa CRA. Other locally identified unique characteristics. Roadless areas may offer other locally identified unique characteristics and values. Examples include uncommon geological formations, which are valued for their scientific and scenic qualities, or unique wetland complexes. Unique social cultural or historical characteristics may also depend on the roadless character of the landscape. No locally identified unique characteristics have been identified in the vicinity of either the existing trail or the proposed trail alignments in the Cochetopa CRA.

Water (for Drinking along trail) One of the concerns raised by the public in response to scoping was that there is very little water in this area. The existing trail crosses several live streams providing opportunity to treat and refill water containers. The existing trail (actually mostly road) meets Lujan Creek just about a mile southwest of Lujan Pass and stays pretty close to a water source for about 3 miles. After leaving Lujan Creek and Pine Creek, there is no water for another 4 miles or so. As the existing trail gets closer to Cochetopa Creek, water is available (seasonally) every few miles, although it seems most people consider Cochetopa Creek the first significant water since Lujan and Pine Creeks.

Environmental Consequences Alternative 1 There would be no change to the existing trail setting with the selection of the No Action Alternative.

Environmental Consequences All Action Alternatives The following analysis applies to the action alternatives.

Elevation/Topography The proposed trail essentially courses the Continental Divide, with a good bit of climbing and descending with the terrain of the divide. Elevations range from 10,500 feet to just over 11,000 feet in the Cochetopa Hills, but for the most part range from 10,500 to 10,800 over the course of the 31 miles. The proposed trail places the alignment at consistently higher elevation than the existing trail. One consequence of this is that the trail has more ascending and descending in short segments than does the existing alignment. There would be trail grade climbs and ascents in some locations as opposed to road grade inclines on the existing roads/trail alignment. Commenters (hiker group) would like to see a grade alignment that avoids pointless ups and downs. The easiest way to accommodate this is to go to a Class 2 or higher trail that is designed for either bikes or Class 3 trail designed for hikers, horses or bikes because these trail classes restrict maximum grade to 10-12%. Trail Classes 2 or 3 for these uses are consistent with Forest Service policy for the CDNST.

46 Vegetation Over the length of the new trail, 90 to 95 percent of the proposed trail alignment passes through forested environments of mixed aspen and conifer. It should be noted that much of the current trail is not under tree cover, and hence is not subject to the hazard and cost associated with the ongoing insect and disease situation in Colorado mountain forests. Mortality of conifer in this area from mountain pine beetle, or spruce beetle, is light. However, this epidemic had reached this area in 2012. Location of the new trail through predominantly forest cover brings with it the risk of many of the conifers along the route becoming hazard trees to users, and expensive in terms of construction and maintenance of an open trail in the future. It is not possible to predict the exact timing although the likelihood is high of this happening.

Remoteness/Recreation Opportunity Spectrum (ROS) The proposed new trail location would offer substantially greater sense of remoteness than the existing route due to the distance from roads and motorized recreation. See the segment by segment description of the existing trail above and of the proposed trail in Table 1-1. On many segments of the new trail the hiker will still have a strong sense of remoteness from sights, sounds or indications of human development despite road crossings and active management. At many points along the new alignment the user is miles from any road or development consistent with the development of a semi-primitive non-motorized trail in a roaded natural or roaded modified environment within management prescriptions of the area.

Visual Resources For any action alternative selected the following mitigation will also apply: A ½ mile buffer on either side of the trail will be established according to the Scenery Management System (FSM 2382.1) to protect foreground view of trail. This buffer requires special visual design elements be considered when implementing other projects near the CDNST to avoid creating additional road or other motorized crossings on the trail, creating routes perpendicular to the trail or creating unnatural appearing conditions. Protecting visual resources to this degree is compatible with existing Forest Plan management areas.

Views of the Trail Under all action alternatives, construction of a new trail and facilities will have a very minor short term effect on visual resources, in terms of views of the trail. With the exception of where it actually crosses points of access, the trail will not be seen from any travelled route, and will be consistent with the visual quality objectives for the area affected. Parking and sanitary facilities to be constructed under Alternatives 2 and 5 but not under Alternatives 3 or 4, and short segments of the trail in all alternatives, will be visible in the immediate foreground and can create more contrast than will be acceptable in areas designated for retention or partial retention. However, the trail is actually part of the expected image of the public being served (USDA Forest Service 1995). With this in mind, the new trail and its construction activity will be seen, as is expected when a trail is added, as a feature or facility to the landscape. The construction activity is a short term effect. The class of trail proposed (materials, and design standard) when complete is intended to reflect a viewing platform that blends into the landscape and will not detract from the scenic experience. As a result, the proposed CDNST route will be compatible within areas managed for high SIOs. The proposed trail alignment will be seen from Highway 114 where it immediately crosses and departs from the highway itself, not in its current location, but nearer the true North Pass. Also,

47 under all action alternatives, in the longer term, Highway 114 on the east side of and approaching North Pass is a public travel way from which some evidence of the trail might be seen. The hill, across which the trail alignment is proposed, faces the highway and is a lodgepole pine forest with area of young growth. The trail construction may result in creation of a linear cut in the tree canopy which could catch the eye of a passer-by, altering the line and form of the forest. Visual quality objectives of foreground from the highway are retention (high SIO) and would still be met. Figure 3-3. GoogleEarth (aerial) Image of Trail Routes

48 Figure 3-4. One Half Mile Buffer either Side of Trail

49 Views from the Trail The existing section of CDNST which shares use with roads is eliminated as system trail under all action alternatives. SIOs (for the proposed alignment range from high to moderate with areas that are nearest to roads, campgrounds and areas unmanaged for timber harvest having the highest visual integrity. In terms of effects on views from the trail in its new location, located predominantly on the actual ridge of the Continental Divide, views, where not obscured by forest vegetation, are in every direction, and extend in many more instances to middle ground and background. These views include the snow-capped peaks of the La Garitas to the southwest in the middle distance, the Sangre de Cristo Mountains in the background across the San Luis Valley to the east, and Cochetopa Dome to the northwest. Note: this view of the La Garitas is of their northeast exposure. This exposure holds snow the longest, offering the “snow-capped mountain” appearance well into the summer and into the hiking season. The location and views from the new trail location are a substantial improvement over the existing trail locations in terms the experience of the user. The scenic quality of what is seen from the new location is much more consistent with the objectives for the CDNST and for back country experience in general. Distant views of mountains as seen from remote locations will be the predominant experience for most of the length of the new trail location. The proposed new trail location does pass through potential future timber sale areas. The types of activities that are occurring and may occur in this area include: • Commercial Timber harvesting using clear-cutting, selection harvest, salvage treatments for insect and disease control, and pre-commercial thinning primarily for insect and disease control; • Mechanical treatment of low vegetation including roller chopping and hydro-ax. These activities are consistent with the Forest Plans, and are appropriate for this area of the National Forest given the current management direction. From the trail, at locations indicated, the user will see clear evidence of previous and current timber harvesting activity from both the existing trail and the new location. These activities are not currently planned at this time. They are not “foreseeable actions” for the purpose of NEPA as defined in 36 CFR 220, however there is potential for future planning of them. Scoping for timber treatments has been conducted. Following scoping this vegetation treatment project has been put on hold pending the CDNST relocation decision addressed in this EA. Establishment of the CDNST in its new location brings with it certain direction which may impinge on these harvesting activities and may cause timber planners to adjust methods of harvest for visual considerations. This is consistent with the inclusion of a ½ mile buffer to protect visual resources. At such time as new management activities, including timber harvesting, are contemplated, and NEPA is completed, consideration must be given to the direction related to the CDNST. Figure 3-4 approximates the areas that could be seen within ½ mile (foreground) from the new trail alignment without the screening of vegetation. As most of the trail would be under forest cover, even these areas are seen only through the trees, or not at all. The new parking area proposed at North Pass on Highway 114 will alter the appearance of the area from trees to that of a developed parking area. This will be a substantial change, however it will be congruent with the highway setting, the pass on which it is located and the expectation of users that there be just such a facility at this location.

50 Roadless Character The proposed trail would move from the north side of this small block approaching the La Garita Wilderness boundary, to the south side of it. Original alignment would remain in place within the Cochetopa CRA. This is consistent with provisions of the 2012 CRR. None of the other facilities (parking, toilet, trailheads) proposed are within or near inventoried roadless areas. High quality or undisturbed soil, water, and air. Activities associated with constructing the trail and subsequent use will have minimal effects on water and soil. See Watershed section for additional details. Activities associated with constructing the trail and subsequent use will have no effect Class I airshed (La Garita Wilderness). Sources of public drinking water. Activities associated with constructing the trail and subsequent use will have minimal and likely immeasurable effects on state defined source water assessment area (municipal water supply). See Watershed section for additional details. Diversity of plant and animal communities. Due to the extremely small footprint of the trail, minimal effects are expected to plant and animal species. See wildlife, migratory bird and plant sections later in this chapter for specific trail related impacts. Habitat for threatened, endangered, proposed, candidate, and sensitive species and for those species dependent on large, undisturbed areas of land. Due to the extremely small footprint of the trail, minimal effects are expected to these species. See Wildlife and migratory bird sections later in this chapter for trail related impacts. Primitive, Semi-Primitive Non-Motorized, and Semi-Primitive Motorized classes of dispersed recreation. Depending on the mode of travel selected for this trail, it may increase trail demands on in the neighboring La Garita Wilderness by providing more desirable semi- primitive non-motorized recreation opportunities that would attract more visitors particularly in the short term. Conversely because of the position of the proposed trail in the roadless area, the semi-primitive non-motorized recreation opportunities on the RGNF side might be more impacted because of the proximity to landscapes that are roaded and experience heavy motorized use. In either case, effects should be minimal while providing for a better user experience. Reference landscapes. The La Garita Wilderness would not be expected to have additional impacts to its reference landscape because of the small footprint of the trail activity in the Cochetopa CRA. Additionally, hiker/horse travel is consistent with activities in wilderness. If non-motorized travel is permitted which includes bicycles, this may impact the reference landscape in two ways either through illegal access in to wilderness or through the incursion of mechanized travel near wilderness which may be visible from parts of the trails in wilderness. Both of these effects are expected to be negligible on the wilderness reference landscape. In Cochetopa CRA, the reference landscape may be more impacted by the addition of the proposed route while keeping the existing route, which will add incrementally to the developed nature of the roadless area. Due to the small footprint of the trail in the CRA, this is expected to be minimal and is consistent with allowing trails in CRR. Natural appearing landscapes with high scenic quality. Cochetopa CRA has predominantly natural appearing landscapes. The small footprint of the trail in the CRA will minimally interrupt the appearance of the landscape with a narrow, linear feature which will be most visible in open areas where tree cover doesn’t camouflage the trail. This trail will incrementally add to a more developed appearance within the CRA because of the addition of a trail even though this activity is consistent with CRR.

51 Traditional cultural properties and sacred sites. Since no traditional cultural properties or sacred sites have been identified in the vicinity of either the existing trail or the proposed trail alignments in Cochetopa CRA, there would be no effect of trail related activities of any of the action alternatives. Other locally identified unique characteristics. Since no locally identified unique characteristics have been identified in the vicinity of either the existing trail or the proposed trail alignments in the Cochetopa CRA, there would be no effect through of trail related activities of any of the action alternatives.

Water (for Drinking along trail) The proposed new alignment follows the ridge or near the ridge of the Continental Divide for most of its length dropping down to live water in only two places: Monchego Park, and Luder’s Campground. Luder’s Campground and Monchego Park are the main sources of water on the proposed route until it starts getting close to Cochetopa Creek. Monchego Park may benefit from some water source development/improvement since it is not very fast flowing and leads into a stock pond. There are two potential water sources about ¾ of a mile northeast of Monchego Park, but they would require improvement. These are small springs which could potentially provide water. There is no proposal to develop either of these water sources at this time. Figure 3-5. Spring near Monchego Park

52 Four miles southwest of Monchego Park there are two stock ponds about a mile off the proposed alignment on road 787 that could provide a source of treatable water. Figure 3-6. Stock Pond

Three miles further west on the proposed route there is a natural pond ¼ mile down road 597 which could serve as water source. Another 3 miles south down the proposed alignment Cochetopa Creek provides good, flowing water.

53 • There are no nationally significant scenic, historic, natural, or cultural qualities (16 U.S.C. 1242) that would be affected differently between any of the action alternatives considered in this EA. Therefore, selection of any of the action alternatives does not cause substantial interference with nature and purposes of The Act for these resources.

Cumulative Effects Elevation/Topography Trail design depending on alternative selected will have effects of having steeper slopes increases the risk of erosion and increased drainage needs. This can be minimized through proper trail design and maintenance. This is a relatively dry site so this concern is minimal to negligible. This may add additional mileage (slight increase) to route as more switchbacks (grade breaks) would be needed. This would also result in slightly more ground disturbance.

Vegetation Management areas impacted by trail alignment are part of both forests’ suitable timber base. There are current beetle attacks occurring in this area which will likely result in high timber mortality. Timber management methodology will be limited in this area because of the number of crossings and roads perpendicular to the trail that will be limited by the trail’s visual corridor buffer. Shaded trail conditions will take longer to dry, and will impact watershed conditions that rely on trail drainage.

Remoteness/ Recreation Opportunity Spectrum Ongoing management activities will continue to affect feelings of remoteness particularly outside of the ½ mile buffer applied to the trail where sights and sounds of things such as timber harvest may occur.

Visual Resources Cumulative effects area is within 4 miles of the trail and beyond. Linear disturbances related to travel system or timber harvest will continue to impact visual resources as seen from vantage points along the trail corridor. Other changes to form and texture will continue to occur based on management activities, although repetition of line, form and texture will keep this consistent with SIOs of the area.

Roadless Character No additional management activities are occurring or proposed that would affect roadless character in the Cochetopa CRA.

Water (for drinking along trail) Where water sources are visible from the trail corridor, increased soil erosion and vegetation disturbance are likely to occur because it is likely that social trails will develop.

54 Trail Use & Access

Existing Condition Mode of Travel Designation All areas of the forests are open to foot travel; however it is preferred that all forest visitors say on existing roads and trails to the extent possible. Much of the existing trail is open for motorized use (existing multiple purpose forest roads), and mechanized (mountain bike) use. It does provide a through route for mountain bike use and hikers. The existing CDNST experience is characterized by transitioning from one type of route to another. Non-motorized and motorized trail users are both on forest roads, which includes commercial hauling of timber and other products at times, results in a reduced experience particularly by non-motorized users. Combining motorized and non-motorized uses which travel at different speeds presents some issues in terms of safety of both user groups. Dusty roads can further reduce visibility which is an additional concern regarding safety for mixed uses in addition to being an undesirable condition for recreational users hoping for a trail experience. Considerable interest has been expressed by the mountain bike community in having a new, non-motorized trail designated as open for mechanized (mountain bike) use.

Access to the Trail Including Parking The existing trail crosses State Highway 114 where there is no safe off-highway parking provided and minimal sight-distance on the highway. Hikers and riders staging at this location must do so on the apron of the highway, or forest road, suffering risk of accident. The next three figures display the existing trail crossing. Figure 3.7 below is a topographic map of the pass area. The existing trail crosses the highway where Lujan Creek does. Figure 3.8 is the same scale representation of the area in an aerial photo. Figure 3 is a closer look at the area, showing road side pull out parking. Figure 3-7. North Pass Topographic Map

55 Figure 3-8. North Pass Aerial Photo

Figure 3-9. North Pass Aerial Photo close-up for where the existing trail crosses SH 114. The existing trail follows the road labeled in white “CR31CC”

The proposed parking area would provide safe and convenient parking with an outhouse facility at this most popular (in this segment) access point to the trail. This may actually invite/induce additional use of this segment of the trail for day hikers in that the presence of the trail will be more apparent, and the access to it will feel more secure. This is a substantial improvement of the existing situation in terms of recreation user experience and recreation opportunity offered. At present there is no sanitary facility at North Pass. The consequence is a very unsanitary situation in the area of the actual pass.

56 Trail Use

Amount of Use As described above, this segment of the CDNST from Lujan to LaGarita is less scenic than many other sections and hence less likely to have the day traffic seen other places. However, it is an important link in the greater trail system. Though no user counts have been conducted for the CDNST in the study area, use of the trail can be characterized through several measures. Use on the trail itself during the peak of the hiking/snow free season is characterized by users themselves as light to moderate. Hikers on the trail in mid-season may encounter four to five parties or hikers over the course of a day of hiking on weekends, and zero to three on week days. Use increases substantially in hunting season (see below) and, conversely, is very light in shoulder seasons of early spring and late fall. In terms of proximity to population centers as a source of users, this segment of the CDT is one of the most remote in Colorado. The nearest towns are Gunnison (Pop. 5,800) 38 miles to the northwest and Saguache (Pop. 580) 32 miles to the southwest. Towns of the San Luis Valley include: Monte Vista (Pop. 4,000) 67 miles away; Alamosa (Pop. 8,800) 84 miles away, and other smaller farm communities. (Note: population figures rounded from 2010 Census Data). Recreation opportunities for day hiking abound in the mountains surrounding each of these communities, making the CDNST from Lujan to LaGarita only one of many choices for local hikers. The population of the San Luis Valley is estimated at 50,000 people. Though this may seem to be a large population base, when compared to the population centers of the front- range, and further north and south along the CDNST, this is a very small population base from which to draw recreation use on this particular trail. As another gauge, even though the Appalachian and the Pacific Crest Trails are different environments, for comparison purposes, the Appalachian Trail receives an average of four million visitors per year along any one portion of its length, yet only 200 to 300 users thru-hike its entire length (AT 2005). Approximately 180 users thru-hike the entire length of the Pacific Crest Trail (PCT 2005). The Monarch Crest Store, located along the CDNST north of the study area, receives and holds packages for “thru-hikers.” According to a store representative, 57 packages were received for thru-hikers in 2004. Additionally, the store is a common starting point for northbound day hikers and southbound mountain bikers. The store representative estimates that 20-30 day hikers and 200-300 mountain bikers leave from the store daily during periods of high use. This is a much higher used area than the project area considered here. The most accurate tally of use on the trail, however, is provided by a volunteer “trail angel,” William Appel. Mr. Appel has surveyed use at Lujan for the past two summers. His report is excerpted below. “Last year (2011) I saw 317 hikers between 7/2/11 and 8/28/11 after uplifting the total by 15% to compensate for the fact that I was only on site until 5 pm each day. I saw only 5 CDNST hikers during this time. I saw 61 mountain bikes, 4 llamas, 17 horses with riders and 41 dirt bikes. This year I was on site from 7/9/12 to 8/12/12 or 23 days less. I counted 236 hikers, 15 of which were CDNST. I counted 77 mountain bikes, 44 llamas, 4 mules, 3 horses with riders, and 40 dirt bikes. To try and compare the 2 years, we can make some conservative assumptions. First, we should add at least 30 hikers for the period from 7/2/12 to 7/9/12 since this was a low snow year and a healthy flow of hikers had already started in early July (total now 266). Next we should add at least 48 hikers for the end of the period between 8/13/12 to 8/28/12 based on at least 3 per day which was the average from last year (total now 314). If we uplift this by 15% again since I was only on site until 5 pm we arrive at a conservative estimate of 361 hikers for the period from 7/2/12

57 to 8/28/12 or an increase of some 14% this year over last year. The increase in mountain bike and dirt bike traffic was similar. For some reason, I did not see many horses this year. There was a healthy increase in CDNST hikers this year, probably due to the lack of snow. (Most CDNST hikers at Lujan are northbound while CT hikers are southbound.) ... My "confirmed hiker count" before the 15% uplift was obtained from personal contact, the sign- in register, footprints, trash left in the garbage can, or information gathered from hikers. I am 100% sure the actual numbers are higher than stated here.”

Winter use Winter use is very light to non-existent. This segment of the continental divide is in the snow shadow of the San Juan Mountains of Southwest Colorado and consequently receives very little snow in comparison with other areas nearby. There is no grooming of or marking of the trail as a cross country ski route, as it often does not have enough snow to ski or snowmobile. The current alignment at low elevations further discourages winter recreation use.

Outfitters There are no outfitters who use the southwest end of this segment of the CDNST to access the La Garita Wilderness. The Quarter/Quarter Circle Ranch uses existing roads, some of which overlap with the existing CDNST route, to access other areas with horseback clients. There is a permitted trekking program with the Colorado Trail Association which does support through hikers of CT/CDNST. This segment of the CDNST is only one small segment of their use, and would actually be much better accommodated by the proposed new trail location. No outfitters or guides hold permits specifying the use of the remainder of the trail from La Garita to Lujan.

Hunting It is common in western Colorado for areas which receive light use for most of the spring/summer/fall season to receive substantial increase in use during the big game hunting seasons. Such is the case here as well. Dispersed camps are set up in the vicinity of the lower segments of the trail along roads which allow for full sized vehicle access. Hunters travel these roads to get to hunting locations, and often walk up non –motorized segments of the trail to access “back country” where game is less disturbed. The activities of dispersed camping, “road hunting,” motorized travel associated with access to hunting, are all inconsistent with the experience sought by hikers of the CDNST.

Environmental Consequences Alternative 1 Under the No Action Alternative, all aspects of the existing alignment, as described above, would remain the same. Objectives for the CDNST/CT for a hiker/horse trail would not be met; however motorized travel is an excepted use under the Act because it was in existence when the Act was passed. Existing CDNST alignment on the GMUG is consistent with 16 U.S.C. 1244(a)(5), 16 U.S.C. 1246(c, j), 36 CFR 212.51, FSM 2353.44a(3) and FSM 2353.44b (11) (d & e) because motorized use is on constructed roads that existed in 1978 and it has also been analyzed in a travel management plan (Gunnison Basin Federal Land Travel Management, 2010). Selection of the No Action Alternative does not cause substantial interference with nature and purposes of The Act.

58 Environmental Consequences All Action Alternatives Mode of Travel Designation Existing motorized recreation would not be impaired by the addition of the non-motorized trail. Under Alternatives 2 and 4, the entire length of the new trail would be designated for hiker/horse use only. Under Alternatives 3 and 5, the trail would be designated for hiker/horse/ mountain bike use. The proposed action relocates the CDNST off of roads; limits use of new trails to non- motorized only (specific non-motorized use specified in each alternative); and provides for safer and more desirable non-motorized experiences than what currently exists. Therefore, any of the action alternatives comply more fully with the direction set forth in The Act than the existing route. Note: according to US Forest Service, Trail Accessibility Guidelines, devices built exclusively to assist those with mobility impairments (i.e., wheelchairs) are not considered mechanical devices excluded from use under Alternatives 2 or 4. Motorized vehicles such as quads or UTV’s are not built exclusively for people with disabilities, and therefore, cannot be used as a substitute for a wheelchair to access non-motorized routes under any of the action alternatives. Addition of the non-motorized trail has the added benefit of reducing mixed-use conflicts on the motorized routes for any of the action alternatives by varying degrees. Designed use and trail class describe the management and design constraints. Designed use is summarized for Trail Classes in Table 3-2. Critical to understanding of designed use is that even though a trail may be designed for a use, other uses are not always precluded. Designation of use either allows or prohibits certain uses. For example, a hiker trail may allow the use of either horses or bikes based on the design features. Table 3-2. Brief Summary of Designed Use and Trail Class Features

Designed Use Hiker Horse Bicycle

Design Feature Trail Class 2 Trail Class 3 Trail Class 2 Trail Class 3** Trail Class 2 Trail Class 3

Tread 1.5 3 2 8 2 3 maximum width (in feet)

Maximum 1.2 0.8 1 0.5 1 0.8 Obstacle height (in feet)

Maximum target 18 12 20 12 12 10 grade (in percent)*

Clearing height 6-7 7-8 8-10 10 6-8 8 (in feet)

Clearing width 4 5 6 8 3-4 6 (in feet)

Turning radius 2-3 3-6 4-5 5-8 3-6 4-8 (in feet)

* Grade is not anticipated to be a limiting factor due to gentle topography of trail alignment ** Trail Cllass 3 for hourses has environmental impacts greater than those considered in the analysis regarding clearing width and acreage impacted.

59 Access to the Trail including Parking Please also see the section of this EA entitled Transportation. Access is substantially improved under Alternatives 2 and 5. Under Alternatives 2 and 5, but not under Alternatives 3 and 4, the addition of a parking area and toilet at North Pass, along with trailhead and parking area at Luder’s campground offers a higher level of convenience and service to the public for using this new trail facility, remedying the sanitary problems created at North Pass by absence of a facility and allowing for multiple entry/exit points along the trail.

Amount of Use All alternatives are expected to increase use with Alternative 5 experiencing the greatest increase in use. Greater use, particularly mechanized use, would be a welcome increase as it is viewed that it will result in additional opportunity for use groups to participate as volunteers for the construction and continued maintenance of the trail. It is also expected to support local communities through the purchase of gasoline, lodging, supplies and equipment to a greater extent than hiker or horse use alone. Encouraging use of volunteers is consistent with the Act. There are very few organized hiking groups in the area, but there are many mountain bike and multiple use groups that have expressed interest in helping with the construction and continued maintenance of the trail. Current use levels are expected to continue on the new trail alignment with the possibility of increased use as a destination in the first couple of years after construction. A user on a semi- primitive non-motorized trail, such as this, could expect to meet 6-15 other parties on a normal day. Current use on existing alignment is consistent with the low end of this level of use, but includes motorized use which would continue on the existing alignment not this new trail. Use on the proposed trail could, in fact, double and still meet what is considered normal for the ROS category (roaded natural or roaded modified) for a semi-primitive non-motorized trail based on Mr. Appel’s documentation of use. In this area carrying capacity will primarily be constrained by physical design or conflicting uses which cause safety concerns, not by the ROS (ROS classes of roaded natural or roaded modified) setting where there is a high expectation of seeing others and ongoing management activities. Due to the relatively low volume of projected use and distance from metropolitan areas, this issue is more of an engineering concern as the design, alignment and sight-distance all respond to the safety issue. Effects on safety will be minimized though the selection of the proper trail class with the correct designed uses for this trail. Use will also be limited by minimizing the size of the trailheads.

Summer Use It is reasonable to expect use to increase with the construction of a true non-motorized trail, with access points at both the State highway and county/forest roads. The opening of a new segment of a national trail will certainly attract new use for a period of time. Over time this is expected to taper off, and to be predominantly hiker use. However, some increase in use may occur among users seeking lower elevation (particularly early season when snow is still on high country), gentler hikes than is found in the more rugged trails in the area. Parking and an easy trail on a pass adjacent to a state highway is expected to result in increased day use. Day use hikers may hike in one to four miles and back out on the new trail, which they seldom do on the current trail.

60 Winter Use Under all alternatives, the proposed new trail does traverse higher terrain than the existing motorized route, and so will receive more snow and trail may be well enough defined to allow a skier to follow it in winter. It is possible that on the occasions when there is enough snow, cross country skiers may find it an attractive route to ski. This would likely be out and back skiing as forest roads providing access are generally not passible in the winter. Under all action alternatives this could become a possible attraction; however neither forest has the intention of plowing this lot for winter use and further would like to discourage winter use because of the possible effects on wildlife including lynx and big game.

Outfitters A new trail location is not expected to alter this use in any way.

Hunting In its new location, the trail will have long segments which are not accessible by any form of motorized equipment. Walk in hunting will still occur near access points; however, none of the new route will be on motorized routes. The trail would provide hunters more easy access to hunting units. This could have several effects including displacement of game along trail, increased hunting away from roads, and conflicting uses of trail during hunting season. Access along the existing trail alignment will remain available except 2 miles that are proposed for decommissioning.

Interference with Nature and Purposes of the Act The pivotal concern received from commenters is whether or not the inclusion of bicycle use is consistent with The Act and that a determination of whether or not substantial interference with the nature and purpose of The Act needs to be made. In addition to review of the laws, policies and other direction related to this issue, the following consideration for restricting use to hiker and horse or include the use of bicycles: • Proposed CDNST is coincident with the CT which is a non-motorized trail. If bikes were determined to interfere with the nature and purposes of The Act, selection of any of the action alternatives would remove a connecting portion of the CT, thereby removing the connectivity of that trail for bikes and reducing options for an entire user group in the area. • Management areas are compatible with all summer non-motorized trail uses. Winter use should be curtailed to the extent practical to protect wildlife. • Existing alignment is dominated by the use of hikers, bikers and motorcycles. For the proposed alignment, use is expected to continue to be primarily hikers and bicyclists unless horse use increases substantially. Motorized uses on existing routes would not be impacted, • Volunteer base consistent with The Act (16 U.S.C. 1250) is primarily mountain biking clubs in this area. Due to limited agency funding and staffing, the GMUG and RGNF would rely heavily on these groups for the construction and long-term maintenance of this trail. CTF would be the likely continue to be coordinator/agency partner for this segment of coincident CDNST/CT who would network with other groups if bike use were included. • Local communities rely on tourism. Rural communities would experience the largest economic benefit from the inclusion of all three user groups who would spend money on gas, food, lodging, supplies and equipment.

61 Therefore, selection of any of the action alternatives does not cause substantial interference with nature and purposes of The Act for these resources.

Cumulative Effects Cumulative effects from Mode of Travel Designation, Access to Trail and Amount of use will improve the access to this segment of trail and existing segments in the La Garita Wilderness and likely to result increased use and desirability of the three segments. These affects are expected to be minor as the trail setting and small trailheads may naturally limit use. Other seasonal access may increase due to the increased access (although not intended to managed for winter use), but would still be minimal. These activities might have additional minor impacts on wildlife and grazing use of the area. Specific impacts are disclosed in subsequent wildlife and grazing sections of this EA.

User Experience & Trail Effects

Existing Condition Social impacts are impacts to other users. Direct social impacts occur through interactions or encounters (i.e., meeting someone on the trail). Indirect impacts occur from such things such as litter, trail wear patterns or the creation of social trails (trails to campsites, to water, etc.). Both direct and indirect social impacts can be positive experiences, neutral experiences, or negative experiences that lead to real or perceived conflict. These tend to be very subjective and personal to the trail user’s desired experience. Land managers often get caught between user groups’ preferences. In the context of this trail alignment, there is a wide spectrum of non- motorized trail users who on one end of the spectrum want hiker exclusive use with very primitive trail design elements that are exclusive to their particular use and the other end of the spectrum multiple-use users who want a trail design that is sustainable and garners local and national support. One end of the spectrum is generally intolerant of direct impacts of other users; the other is much more tolerant. Because desired recreational experiences and tolerances are inherently personal, it is difficult to analyze them in any meaningful way. In this analysis we instead focus on providing recreation opportunities combined with physical impacts realizing that we cannot completely satisfy every user. Recreation setting and ROS have been considered. While we have discussed that the action alternatives would provide a more remote experience above, the ROS of roaded natural or roaded modified within the management areas suggests the norm that in these ROS classes remoteness should be of little relevance, but more remote opportunities may be compatible. Non-motorized trails may be compatible with these ROS classes, but are not the norm. These ROS classes can have SIO levels of high (retention), moderate (partial retention) or low (modified). Facilities should be rustic of which a CXT toilet and dirt or gravel trailheads fit. Trail surfaces that have limited site hardening are compatible, but trails with subtle site hardening would be the norm. And visitor experience in this ROS suggests that meeting 6-15 parties or less per day or less or having 3-6 visible parties at a campsite would be compatible within the ROS yet moderate to low (higher numbers than above) contact on trails and at developed sites would be the norm. Both user groups’ preferences are compatible with the ROS which leaves the land manager with an even more daunting task when all action alternatives have equal merit. The pre-decisional EA discussed effects on trail tread (incising, rutting, hummocking, etc) from mountain bikes. We have reviewed peer-reviewed literature cited by commenters (included in References Cited and Reviewed) and agree that the effects described would likely only apply in

62 very heavily used areas where trails have not been properly designed/constructed or would more likely apply to motorcycle use such as where motorized trail occurs on the existing alignment. Physical impacts are ones that occur though use of the trail on vegetation, soils, water and wildlife. Mountain biking is an increasingly popular outdoor activity with millions of participants. It provides important individual, social, environmental and economic benefits for its enthusiasts and their communities. Horseback riding in this area is at very minimal levels.

Environmental Consequences Alternative 1 Under the No Action Alternative, use of the existing route would continue to have effects on user-experience and physical impacts on vegetation, soil, water and wildlife would continue at the existing levels. Opportunities for volunteers to perform continued maintenance are likely to remain low. Existing CDNST alignment on the GMUG is consistent with 16 U.S.C. 1244(a)(5), 16 U.S.C. 1246(c, j), 36 CFR 212.51, FSM 2353.44a(3) and FSM 2353.44b (11) (d & e) because motorized use is on constructed roads that existed in 1978 and it has also been analyzed in a travel management plan (Gunnison Basin Federal Land Travel Management, 2010). Selection of the No Action Alternative does not cause substantial interference with nature and purposes of The Act.

Environmental Consequences All Action Alternatives The following discussion applies to all action alternatives. On the CDNST and similar trails, people are generally looking for a higher degree of challenge and risk where they can use their outdoor and survival skills. The portion of the CDNST that is proposed, consistently offers this level of challenge and experience .The proposed alignment relocates the CDNST off of roads; limits use of new trails to non-motorized use only; and provides for higher quality scenery, and non-motorized experiences than what currently exists. Under all action alternatives the proposed trail alignment and under Alternatives 2 & 5 with the addition of trailheads would substantially enhance the recreation experience. Instead of what was a series of interconnected, confusing and inconsistent travelways (including roads and trails), the new trail is one single track trail from Lujan to the La Garita Wilderness. Users will more easily be able to navigate the route than in the current situation and will travel near or just below the true Continental Divide. Access points (existing road crossings) are spaced appropriately for support, but are not close together enough to be obtrusive. In short, it will become a true trail experience, consistent with the objective for the CDNST, and provides one more connecting link in the CDNST. The increase in popularity of mountain biking has led to concerns over the potential for undesirable social impacts to recreation environments such as safety of trail users, user conflict, crowding and possible resource degradation. These effects would be minimized through trail design such as minimizing steep trails, including grade breaks that force users to slow down or change direction. Due to the remoteness of the segment of trail and the ROS classes through which the trails pass, crowding is not expected to be a concern that reduces user desirability of these segments regardless of non-motorized user. All recreational use is a consumptive use leaving behind a use footprint that cause trails to deteriorate over time. Foti et al (2006), found that day hikers are "wanderers" who spread impacts along the trail, are prone to creating social trails, often improperly dispose of sanitary

63 waste, and often litter. They found backpackers tend to be destination-oriented, who move along the trail toward their campsite where impacts are concentrated and include barren core development, campfire impacts, social trailing, and vegetative impacts to trees, shrubs, and grasses. They found mountain bikers to be destination-oriented users that once on the trail, tend to have few impacts beyond the footprint of the trail itself; the exceptions to this pattern are the off-trail and multiple trailing impacts in open areas. The pre-decisional EA discussed effects on trail tread (incising, rutting, hummocking, etc.) from mountain bikes. We admit to prescribing the "precautionary principle" (imposing regulations which restrict use based on intuition, public opinion, and the views of others instead of analyzing the scientific literature available with the presumption that it will protect the resource and be exclusively compatible with the Act) in the pre-decisional EA. We have reviewed the peer- reviewed literature cited by commenters (included in References Cited and Reviewed) and agree that the effects we previously described would likely only apply in very heavily used areas where trails have not been properly designed/constructed inconsistent with this setting. People hypothesized that characteristics of tires versus shoes, skidding, area and pressure of impact, and other factors cause big differences in impacts. Scientific research is limited on the physical effects of non-motorized use, but the studies so far do not support that bikes cause more natural resource impacts than hikers. Science supports that all forms of outdoor recreation- including bicycling, hiking, running, horseback riding, fishing, hunting, and bird watching- cause impacts to the environment. Use and construction of the trail will have impacts on vegetation, soils, water and wildlife. Some factors affecting trail impacts are known and include the extent, timing and other use-related issues; ecological attributes, including soil composition and vegetation, and physical aspects of the trail such as trail design, slope and alignment. These are discussed more specific detail in subsequent sections. A summary of the additional literature reviewed is addressed below. Additional vegetation impacts would occur from trail widening, invasive species, and the development of social trails. Keeping the trail tread narrow while maintaining the overstory of trees will minimize the potential for noxious weeds. If there is vegetation/ organic litter and little use there would be limited physical impact from the trail on soils and erosion. As removal of vegetation increases then erosion potential also increases. Thurston and Reader (2001) measured plant stem density, species richness, and soil exposure before, during and after 500 passes in each lane by hikers and bicyclists. Their results indicate impacts on vegetation and soil increased with biking and hiking activity; impacts of biking and hiking measured were not significantly different, and impacts did not extend beyond 30cm of the trail centerline. (p.405) Foti et al (2006) noted that vegetative damage is often due to users increasing the size (width) of the trail. Crockett (1986) studied the erosional effects of bicycling on trail character. Crockett found trail width both increased and decreased at various plots, and the same was true of the cross- sectional area of the transect, which is a measurement of the amount of soil in that spot. Minimal change was observed in the visual trail characteristics in most cases. Weesner (2003) found some non-motorized trail segments widened moderately and some just a little. Where volunteer trail maintenance occurred the trails were effectively kept narrow. Foti et al. (2006) found common ecological regions (common biologic, geologic, topographic, soil, aquatic and land use characteristics-i.e., environmental conditions) were a main factor in both trail width and maximum trail depth. Trails tended to be widest in areas of heavy use and where few environmental constraints (trees) were present. Trail slope was found to be a pivotal factor for potential impacts to soil and vegetation on recreational trails. Slopes greater than 12% were strongly correlated with higher degradation of soil and vegetation. The average maximum trail depth (trail incising) for slopes of less than 5% (1.14 inches) was found to be significantly lower

64 than the averages for slopes between 5% and 10% (1.61 inches) and slopes greater than 10% (1.76).Foti et al’s data also suggests that as slope increases, so generally does the maximum trail width and depth which may be an indication of some riders’ inability to navigate increasingly steeper grades and/or inadequate trail drainage. Trail grade appears to be the most significant variable contributing to trail width and trail incision impacts. Slopes/grades in the proposed alignment are expected to be 10% or less which will minimize impacts. As soil becomes compacted there is proportionally less impact from uses; however, when soils aren’t compacted (i.e., loose soils) there is increased erosion potential. Sediment and runoff is most likely to occur during construction. Soils are also more susceptible to erosion when saturated. Horses were found to loosen more soils than hikers or bikers (Wilson and Seney, 1994). Proper trail design and construction which includes flowing trails, constructing on stable soils and avoiding unconsolidated soil minimizes impacts. Wilson and Seney (1994) found no statistically significant difference when measuring biking and hiking effects on sediment runoff (correlates with erosion potential). They found horses caused the most erosion of the trails. They also concluded, "Horses and hikers (hooves and feet) make more sediment available than wheels (motorcycles and off-road bicycles) on pre-etted trails and that horses make more sediment available on dry plots as well.” (p.74) They suggested precipitation will cause erosion even without human travel and this factor may significantly outweigh the effects of travel; therefore trail design, construction, and maintenance may be much more important factors in controlling erosion than use type. Chiu and Kriwoken compared flat and steep/ wet and dry conditions and found no significant difference in the trail wear caused by the hikers or bikers although impacts on wet trails were greater than on dry for both types of uses. They found significant impact from skidding tires (skidding by many sources is believed to be either the result of poor riding form or poor design or both). Goeft and Alder (2001) examined erosion potential on non-motorized trails. They found erosion was influenced by slope, time, and age of trail, but did not show a clear trend for the uses. Bjorkman (1996) demonstrated hardening trail surfaces on non-motorized trails significantly reduced erosion/ sedimentation potential. Bjorkman’s measurements on existing trails also indicated a rapid and substantial loss of vegetation along the trail centerline. The disappearance of vegetation 2.0 meters to the side was much less and slower. Along the centerline, soil compacted steadily in the trail centerline, but there was little compaction two meters to the side. The trail width where no vegetation existed increased rapidly at first, then a bit more slowly, and was more rapid in shade than in sun, and more pronounced where the soil had more sand or less silt. Taylor and Knight (2003) noted that the hikers, mountain bikers and horse groups surveyed all believed the other two groups caused more impacts to wildlife than their own. Effects on wildlife are very complex depending on species but generally have the following characteristics: predictability of encounters, frequency and magnitude of encounters, timing relative to the animals annual cycle, location of the encounter, season of the encounter, individual and group variations and physiological response. Response frequency is increased in some animals from pedestrians over other types of access (Papouchis et al , 2001). Taylor and Knight (2003) also found the user perception of impacts on wildlife (perceived impacts at ~50-60 meters) for all user three user groups was much lower than the actual physiological response (actual impacts ~140-160 meters); however the difference between user groups was not statistically different. There is no clear indication in the results any of studies considered that any one non-motorized use would have impacts of such a scale to have more than minor ecological impacts even though some variation occurs. Studies indicate that specific impacts to mountain bike trails, width in particular, are similar or smaller than impacts to hiking or multiple-use trails, and appreciably smaller than impacts to equestrian trails. Initial construction causes the greatest ecological impacts; however, trail construction is generally considered to be socially acceptable,

65 as the benefits to the individual and to the community are viewed to be greater than the environmental costs. Likewise, Foti et al (2006) found that while trails they studied were impacted by all user groups, 87% of the trails were impacted at a level that is considered acceptable for any non-motorized recreational activities with the exception where the trail is inappropriate for use due to the presence of special resources, such as threatened or endangered species, or has special designation, such as wilderness. Those special circumstances do not exist on this proposed alignment. As shown by several studies, the best way to mitigate ecological impacts is through proper trail construction which protects trail integrity and prevents erosion by managing grades and getting water off trail. If mountain bikes were to be permitted on the proposed trails, it is recommended they should be designed specifically for mountain biking which will benefit all non-motorized users by minimizing the physical impacts from use and construction and maximizing user experience by having flowing trails while minimizing grades and obstacles that, in turn, will further minimize user conflicts. Economics can be specific to the trail construction, trail maintenance, or larger economic drivers that influence communities and counties that derive tourism or other funding from use of lands including gas, food, lodging, supplies, specialized equipment, etc. It is anticipated that volunteer efforts would minimize any additional government expenditures for construction or maintenance. The pivotal concern received from commenters is whether or not the inclusion of bicycle use is consistent with The Act and that a determination of whether or not substantial interference with the nature and purpose of The Act needs to be made. Nothing found in the literature on resource impacts or use footprint indicates that selection of any of the action alternatives would cause substantial interference with nature and purposes of The Act. Use of volunteers is consistent with the Act and minimized further expenditures by the Forests.

Cumulative Effects User experience may be affected by natural or fiscal considerations outside of this decision. Maintenance funding needs associated with the proposed will likely increase over existing route as new routes are added to the system. This effect to already declining budgets could be off-set through the use of volunteers or partners. The proposed route would also expect to have higher maintenance costs than the existing route due to the trail setting in a forested environment that is experiencing beetle kill which will likely result in high numbers of dead or dying trees. Wildlife-Threatened or Endangered Species A Biological Assessment which evaluates the potential effects of this project on Threatened, Endangered, and Proposed Species of wildlife and fish in compliance with Section 7 of the Endangered Species Act has been prepared, and is part of the project record. That BA and resultant consultation with the U.S. Fish and Wildlife Service is the source of this analysis to comply with the requirements of NEPA. Of the Threatened or Endangered species identified in the pre-field review for species that occur or potentially occur on the Gunnison Ranger District (GMUG) or the Saguache Ranger District (RGNF), including downstream aquatic species that may be influenced by project activities, only Canada Lynx (Lynx canadensis) and North American wolverine (Gulo gulo luscus) were identified as having suitable habitat within or near the project area, and potentially affected. There is no potential habitat in or near the analysis area for any federally listed or proposed species except the Canada lynx and American Wolverine. Therefore, the proposed project will

66 have “no effect” on the Gunnison sage-grouse, southwestern willow flycatcher, Mexican spotted owl, Uncompahgre fritillary butterfly, or greenback cutthroat trout. Furthermore, because there will be no additional Colorado River water depletions beyond authorized limits, the proposed project will have no effect on any Colorado River Basin aquatic species (i.e. bonytail, Colorado pike minnow, humpback chub, razorback sucker,).

North American Wolverine Additional information regarding wolverine is included under the Sensitive Species section later in this document and in the Biological Assessment found in the project file.

Existing Condition The wolverine is included in this analysis because proposed management activities involve suitable, but currently unoccupied habitat. Although occasional sightings of wolverine occur and are reported on the Forest, there had been no documented occurrences locally or in Colorado since 1919 until the recent arrival of M56, an individual male who arrived in 2009 from Wyoming and apparently remains in the north-central portion of the state (Colorado Division of Wildlife Website, Species of Concern, Wolverine, 2013). The wolverine is included in this analysis of federally-listed species because of a recent status change. On February 4, 2013, the U.S. Fish and Wildlife Service (FWS) issued a proposed rule to list the Distinct Population Segment (DPS) of the wolverine that occurs in the contiguous U.S. as a threatened species under the ESA (78 FR 7864). Also on February 4, 2013 the FWS published a proposed special rule under Section 4(d) of the ESA outlining the prohibitions necessary and advisable for the conservation of the wolverine (78 FR 7864). This proposed Section 4(d) rule would prohibit take of wolverine from trapping, hunting, shooting, etc., while allowing incidental take associated with management activities such as dispersed recreation, timber harvest, mining etc., if those activities are conducted in accordance with applicable laws and regulations (78 FR 7890). In the same federal register document the FWS also proposed to establish a nonessential experimental population (NEP) area for the wolverine in the southern Rocky Mountains of Colorado, northern New Mexico, and southern Wyoming. The FWS is not proposing critical habitat at this time.

Environmental Consequences and Cumulative Effects All Action Alternatives Given that all potential habitat associated with the proposed action is currently unoccupied there will be no effect on the species. However, even if the species is eventually reintroduced to or recolonizes Colorado, activities such as non-motorized trail construction are not expected to have any measureable influences on wolverines because they are not identified as a potential threat to the species and are included in the proposed Section 4(d) incidental take allowances.

Effects Determination Based on this analysis, it has been determined that the proposed management activities associated with this analysis “will not jeopardize” the wolverine or influence any future options for achieving a self-sustaining population in the Southern Rocky Mountains.

Canada Lynx Additional information may be found in the project record in the Biological Assessment.

67 Existing Condition The Canada lynx has habitat present and/or occurs in or near the project area. The CDNST Reroute Project involves approximately 32.1 miles of foot-trail construction with a tread width of 24 inches and clearing width of 6 feet as well as facility and trailhead development at two locations. All trail construction and facility/trailhead construction occurs on National Forest lands. Because the project area contains mapped lynx habitat, Lynx Analysis Units (LAUs) will serve as the baseline analysis area for this project.

Lynx Analysis Units A Lynx Analysis Unit (LAU) is a project analysis unit upon which direct, indirect, and cumulative effects analyses are evaluated for Canada lynx. LAUs were established to approximate the size of a typical lynx home range; however, they do not represent the home range of an actual animal. An LAU provides a constant area for comparison of effects to lynx over time. The GMUG currently contains a total of 51 LAUs whereas the RGNF contains 25 LAUs. The proposed CDNST Reroute Project occurs within or directly adjacent to five LAUs, two of which occur on the GMUG (i.e. Cochetopa and Stewart Creek LAUs) and three on the RNGF (i.e. Cochetopa, 4 Mile to La Garita Creek, and Saguache Park; Figure 3). Although no management actions are proposed in the Needle-Razor LAU (GMUG), it is included in the analysis because it contains a portion of the North Pass/Cochetopa Hills Lynx Linkage Area (LLA).

68 Figure 3-10. Lynx LAUs and Linkage Area

69 Environmental Baseline Canada lynx habitat in Colorado primarily occurs in the subalpine and upper montane forest zones. Recent analysis of radio-collared reintroduced lynx in Colorado indicates that the majority of the habitat used occurs between 9,900 – 11,620 feet (Theobald 2011). Forests in these zones typically contain deep winter snows and are dominated by subalpine fir, Engelmann spruce, aspen, and lodgepole pine. A preference for these forest types, particularly spruce-fir associations, has been documented by radio-telemetry and tracking techniques associated with lynx reintroduced to Colorado (Theobald 2011). Other habitats used by reintroduced lynx include spruce-fir/aspen associations and various riparian and riparian-associated areas dominated by dense willow (Shenk 2009). Throughout North America, the distribution of lynx is closely tied to habitats that support an abundant population of snowshoe hare (Koehler 1990, Aubry et al. 2000). These habitats are generally defined as regenerating stands that contain dense, small-diameter stems that provide both food and horizontal cover (Koehler 1990, Aubry et al. 2000). In Colorado, both small diameter lodgepole stands and mature spruce-fir stands support the highest density of snowshoe hares, although the latter may be of more importance on a year-round basis due to the long-term persistence and distribution of mature spruce-fir stands (Ivan 2011). Reintroduced lynx in Colorado are also utilizing red squirrels, cottontails, and other alternate prey items (Shenk 2006). Red squirrels are closely associated with mature forest conditions, and would occur with snowshoe hare as an important alternate prey species (Buskirk et al. 2000). The increased use of riparian-willow systems by reintroduced lynx during late summer and fall is also considered to be associated with alternate prey sources (Shenk 2009). Canada lynx breed from March through April in the northern portion of their range, with kittens usually borne in May through June (Mowat et al. 2000). Births by reintroduced lynx in Colorado occurred in late May to mid-June (Shenk 2006). All den sites found in Colorado have occurred within the spruce-fir zone on steep, north-facing slopes and are most often associated with substantial amount of large diameter woody debris (Merrill 2005, Shenk 2009). The average elevation at Colorado den sites is 11,004 feet (Shenk 2009). Disturbances such as insects and disease and windthrow contribute to the downed log component and are therefore important for reproduction and protection for the kittens (Aubry et al. 2000). For denning habitat to be functional, however, it must be in or adjacent to quality foraging habitat. Because lynx may frequently move their kittens in the first few months, multiple nursery sites are needed that provide kittens with overhead cover and protection from predators and the elements (Ruediger et al. 2000). Downed logs and overhead cover must also be available throughout the home range to provide security when kittens are old enough to travel. Lynx are known to move long distances, but open areas, whether man-made or natural, may not be used as extensively (Mowat et al. 2000). In north-central Washington, lynx typically avoided openings greater than about 300 feet wide (Koehler and Brittell 1990). However, the Southern Rockies consist of more heterogeneous forest types and their response to natural or created openings may differ (Ruggiero et al. 2000). The habitat use information for lynx in Colorado indicates that canopy closures of at least 40% are important at the site-scale, regardless of the type of cover involved (Shenk 2006). Additional analysis of radio-collared data for reintroduced lynx in Colorado indicates that the average proportion of forest (upper montane) in lynx habitat was 0.65, with the majority occurring in areas with at least 20% forested (upper montane) cover. Habitat use was also associated with distance from large patches (>50 ha, 124 ac.) of forest (upper montane) cover, with the majority of habitat within 3.35 km (2.1 mi.), and the average at 0.36 km (0.2 mi). The average proportion of grasslands was 0.16. There was little association of lynx habitat use areas with other land cover types (Theobald 2011). This data indicates that

70 most lynx use in Colorado is associated with larger contiguous blocks of forest that is primarily dominated by spruce-fir forest cover types. Forested conditions between foraging and denning habitat has also been shown to facilitate movement within the home range, particularly along ridgelines where lynx commonly travel (Ruggiero et al. 1994). Linkage areas may be provided by forest stringers that connect large forested areas, or by low, forested passes that connect subalpine forests on opposite sides of a mountain range (Ruediger et. al. 2000). In 1999, the Colorado Division of Wildlife initiated a lynx recovery program intended to augment any existing populations in the Southern Rockies with transplants from Canada and Alaska to re-establish a self-sustaining breeding population. The augmentation program resulted in a total of 218 lynx being transplanted into the San Juan Mountains during 1999-2006. Lynx reproductive rates in Colorado have varied greatly since kittens were first documented in 2003. After den visits identified 16 kittens in 2003, researchers found 39 kittens in 2004; 50 kittens in 2005; 11 kittens in 2006; 11 kittens in 2009; 14 kittens in 2010. During the 2006, 2009 and 2010 seasons, DOW field crews documented that Colorado-born lynx had successfully produced third-generation Colorado kittens. In 2010, researchers estimated that between 30 and 40 percent of female lynx bore litters of kittens (Colorado Division of Wildlife 2010). There were 7 critical criteria established for achieving a viable lynx population in Colorado: 1) development of release protocols that lead to a high initial post-release survival of reintroduced animals, 2) long-term survival of lynx in Colorado, 3) development of site fidelity by the lynx to areas supporting good habitat in densities sufficient to breed, 4) reintroduced lynx must breed, 5) breeding must lead to reproduction of surviving kittens 6) lynx born in Colorado must reach breeding age and reproduce successfully, and 7) recruitment must equal or be greater than mortality over an extended period of time. These criteria were evaluated incrementally over time to gauge whether the reintroduction effort was progressing toward success. All seven criteria have now been met. Due to these factors, the CDOW declared the lynx reintroduction program a success in September of 2010 (Colorado Division of Wildlife 2010).

Species Status in or Near the Project Area There is a general pattern of consistent, year round lynx utilization of habitats on portions of the GMUG, RGNF, and San Juan NF (SJFN) approximately 25 miles west-southwest of the project area. In addition consistent utilization is described for portions of the GMUG, White River, and Pike-San Isabel NFs approximately 24 miles north of the project area (Figure 3-11, Theobald and Schenk 2011). No lynx locations have been reported within 1 mile of the proposed trail project. The closest lynx observation consists of a snow track reported 4 miles west of the project in 2002 (GMUG NRIS dataset). Snow track surveys completed in 2012 on the GMUG west of North Pass along the existing CDNST route did not record lynx occurrence (M. Vasquez, unpublished data, 2012). While no observations have been reported near the project, it is probable that lynx move through the area. Ivan (2011) constructed point-to-point line segments connecting lynx GPS locations up to a week apart in the vicinity of North Pass. While these constructed segments do not represent exact or approximate lynx locations, the data does indicate the likelihood that lynx use the North Pass area for movement between the San Juan Mountains to the southwest and the Sawatch Range to the northeast. In addition, the Cochetopa Hills/North Pass area is described as a well-used lynx movement corridor (USDA Forest Service 2008).

71 Figure 3-11. The utilization distribution for current lynx habitat in Colorado, with Forest Service administrative boundaries and I-70 as a reference. The CDNST Reroute Project vicinity is added for reference. Map is from Figure 7 in Theobald (2011).

72 Lynx Habitat Associated with the Project Area The CDNST Reroute Project is located on and near the Continental Divide at elevations ranging from 9,160 to 11,500 feet. Where the new proposed trail is mapped, approximately 100,687 feet (19.1 miles) of trail would occur within mapped primary suitable lynx habitat, with an additional 8,931 feet (1.7 mi) of trail mapped in secondary suitable habitat (Table 3-3). Trailheads proposed at North Pass and Luder’s Campground are located outside mapped lynx habitat (Figure 3-12). Table 3-3. Proposed Trail Length within Lynx Suitable Habitat

Primary Secondary LAU Suitable (mi) Suitable (mi) Total (mi)

Cochetopa (GMUG) 11.79 0.03 11.82

Stewart Creek (GMUG) 2.97 1.66 4.63

Cochetopa (RNGF) 0.91 0.00 0.91

4 Mile to La Garita Creek (RGNF) 2.44 0.00 2.44

Saguache Park (RGNF) 0.95 0.00 0.95

Needle-Razor (GMUG) 0.00 0.00 0.00

TOTAL 19.07 1.69 20.76

73 Figure 3-12. Characterization of mapped lynx habitat associated with the CDNST Reroute Project.

74 Linkage Areas The Cochetopa (both GMUG and RGNF) and Needle-Razor LAUs contain portions of the North Pass/Cochetopa Hills Lynx Linkage Area (LLA; Figure 3), which covers approximately 33,212 acres. All but 172 acres are under Forest Service ownership. Primary suitable habitat totals approximately 11,950 acres, or 36% of the LLA. All suitable habitats equate to approximately 37% (12,437 ac.) of LLA acres (Table 3-4). Table 3-4. Suitable Lynx Habitat, Cochetopa Hills/North Pass Linkage Area

Primary Secondary Suitable Suitable Forest (ac) (ac) Total (ac)

GMUG 5,804 438 6,242

RGNF 6,146 49 6,195

TOTAL 11,950 487 12,437

Roads and Access The existing CDNST follows a northeast-to-southwest direction in the vicinity of the project. The main road access to local trail segments is located along State Highway 114, approximately 2.5 miles west of the proposed trailhead along that same highway. Access to existing local trail segments can also be attained via several unimproved, native surface roads that require low speeds of travel. For the proposed reroute, primary access to local trail segments would be derived from the proposed trailhead along State Highway 114. In addition, trailheads would be established at sites with existing road access at both Luder’s Creek Campground and Cochetopa Pass. State Highway 114 receives low to moderate traffic volumes. According to Colorado Department of Transportation data attained for 2011, traffic volume for the segment of State Highway 114 associated with the project (MP20 to MP56), Average Annual Daily Traffic (AADT) is 110 vehicles (CDOT 2012a). There is likely some limited recreational use in the project vicinity including dirt bikes, ATVs, and personal 4-wheel drive vehicles during the summer and fall along existing native surface roads that access other trail segments. No road or traffic- related mortalities of lynx are known for State Highway 114 (CDOT 2012b) or for the LAUs associated with the project.

Snow Compaction Snow compaction may be an issue for lynx because it is thought that coyotes use the compacted, dispersed recreation trails to travel more effectively through soft snow areas, thus competing with lynx for similar winter prey species, particularly snowshoe hares (Bunnell et al. 2006). However, the significance of this remains uncertain as additional studies in Montana have found that compacted snow routes did not appear to enhance coyotes’ access to lynx and hare habitat or promote increased competition for prey resources (Kolbe et al. 2007). Snow compaction areas within the GMUG portion of the analysis area consist of three separate routes within the Cochetopa LAU totaling about 15.1 miles. No concentrated snowmobile use areas, often called “play areas” are noted within the associated LAUs. On the RNGF, compacted snow routes occur in the Cochetopa (11.6 miles) and Saguache Park (5 miles) LAUs. No “play areas” are identified within associated LAUs. No downhill ski areas are located

75 within any LAU associated with the project. Winter activities may locally influence lynx use of the landscape through diurnal displacement from activity areas and from indirect effects related to snow compaction.

Current Use Levels Trail user counts have been conducted on the CDNST in the Lujan area over the past two summers. Traffic on the existing trail averaged between 5 and 7 hikers per day (W. Appel, pers. comm). Additional traffic included horseback riders, mountain bikes, and motorcycles. Use on the trail itself during the peak of the hiking/snow free season is characterized by users themselves as light to moderate. Hikers on the trail in mid-season may encounter four to five parties or hikers over the course of a day of hiking on weekends, and none to three on week days. Use increases substantially in hunting season (see below) and, conversely, is very light in shoulder seasons of early spring and late fall. Winter use on the existing trail is very light to non-existent. This segment of the continental divide is actually in the snow shadow of the La Garita Mountains and hence receives very little snow in comparison with other areas nearby. There is no grooming of or marking of the trail as a cross country ski route, as it often does not have enough snow to ski or snowmobile. The current alignment at low elevations further mitigates winter recreation use (J. Burch 2012, CDNST Reroute Project Draft Recreation Specialist Report).

Environmental Consequences Alternative 1 There would be no direct or indirect effects to lynx from management activities, as no treatments would occur under this alternative.

Environmental Consequences All Action Alternatives Measures for minimizing influences on lynx habitat have been considered and built into the proposed action. Given the minimal scope of this project, no additional conservation measures are considered necessary. Conservation measures include: • Placement of the new trail would avoid areas of accumulated down wood that could structurally support lynx denning. Lynx denning habitat characteristics are described in the Southern Rockies Lynx Management Direction, Record of Decision (USDA Forest Service 2008, see Glossary section). • Where practicable, the trail location will avoid areas of multi-storied stands where a dense understory provides snowshoe hare habitat. • In coordination with Colorado Department of Transportation (CDOT) traffic signs would be posted in the vicinity of North Pass and the North Pass trailhead to warn of wildlife crossing and reduce vehicle speeds. • Project activities such as trail and trailhead construction would occur during the period that avoids the need for snowplowing to access sites for project implementation. • Project personnel will be informed to report any individual lynx noted during the duration of project activities. Any sightings or encounters with lynx should be reported to the Forest Service.

Habitat Trail construction activities under the CSNST Reroute Project will cross through approximately 20.76 miles of primary and secondary suitable lynx habitats (Table 4). With a trail clearing width of 6 feet, suitable lynx habitat directly affected by trail construction totals about 15.1 acres. Proposed trailhead construction would occur outside suitable lynx habitat; therefore no loss of

76 mapped habitat would occur as a result of trailhead construction. Ground reconnaissance indicates that the proposed route would cross through a concentration of down wood that may be suitable to support lynx denning. Although the project area is not known to encompass resident lynx, a conservation measure (described below) has been incorporated into the proposed action to avoid physical disturbance of potential denning structure, thereby not precluding future use of such habitat features by lynx if residence is established. Removal of 15.1 acres of suitable lynx habitat constitutes an extremely small amount when compared to suitable habitats available within the associated LAUs. Proportion of primary suitable habitat affected by trail construction ranges from 0.002% to 0.039%, and 0.004% to 0.04% for all suitable habitat in associated LAUs (Table 3-5). Overall, the project would affect approximately 0.009 % of all suitable habitat within the five LAUs where trail construction would occur (i.e., excluding the Needle-Razor LAU). This represents an extremely minor amount of mapped lynx habitat but would be a permanent footprint within the applicable LAUs. The narrow configuration of the trail footprint (up to 6 feet in width) would not represent a movement barrier to lynx and would not alter the functionality of the surrounding stand as suitable habitat. Subsequently, no change in mapped suitable habitat amounts is expected to occur. Therefore, the amount of potential habitat change is immeasurable in relationship to baseline vegetative conditions within associated LAUs. Table 3-5. Acres and Percentage of Lynx Habitat Affected by Proposed Trail Construction

% of % of Total Available Available Acres Primary LAU Secondary LAU (%) Suitable Primary Suitable Secondary Suitable LAU (ac) Habitat (ac) Habitat Habitat

8.6 Cochetopa (GMUG) 8.6 0.034% <0.1 0.001% (0.040%)

Stewart Creek 3.4 (GMUG) 2.2 0.010% 1.2 0.024% (0.034%)

0.7 Cochetopa (RNGF) 0.7 0.004% 0 0% (0.003%)

1.8 4 Mile to La Garita Creek (RGNF) 1.8 0.003% 0 0% (0.003%)

0.7 Saguache Park (RGNF) 0.7 0.002% 0 0% (0.02%)

Needle-Razor (GMUG) 0 0% 0 0% 0

15.1 TOTAL 13.9 0.008% 1.2 <0.001% (0.009%)

77 Linkage Areas and Connectivity Approximately 5.9 miles of proposed trail would be located within the North Pass/Cochetopa Hills LLA, of which approximately 2.1 miles would occur within suitable lynx habitat. With a 6 foot clearing width, suitable lynx habitat affected within the linkage area by the trail totals 1.5 acres. In addition to the trail, a trailhead would also be constructed within the LLA, adjacent to State Highway 114 in the vicinity of North Pass. The trailhead facility would consist of clearing ¼ acre of forest vegetation, consisting mostly of small to moderate-sized aspen, for a 5-car parking area and toilet facility. The trailhead is located outside mapped suitable lynx habitat, but would permanently remove vegetation that may otherwise facilitate lynx travel through the site. However, the trailhead facility and clearing is not expected to become a barrier to lynx travel across North Pass and through the LLA because of its small imprint on the landscape and the available travel options through forested vegetation to the east and west of the proposed location (see Figure 3-14). Linkage areas were established predominately to facilitate lynx dispersal.

78 Figure 3-14. North Pass Area Aerial View

Roads No new or temporary road construction is proposed under this project. Project activities would utilize existing roads and trails to facilitate transportation of work crews, equipment, and supplies. Other than access from State Highway 114, the project will utilize existing native surface roads to access project locations. The existing condition of the roads supports low volume, low-speed vehicular traffic that is unlikely to result in any traffic-related mortality for lynx. This operation period should help to minimize potential encounters with lynx because they are not as active during the summer daylight hours.

79 Activity at the project site may last up to several summer/fall months each year for 2-3 years for project completion. This activity will increase human presence and noise levels above what normally occurs in this area. Current baseline conditions for traffic volume on the segment of State Highway 114 associated with the project is 110 AAVT. The proposed trailhead parking area located along State Highway 114 would hold up to 5 vehicles. When considering the trailhead as a source of increased traffic volume, day-hiking and hunting access are likely sources that would draw additional vehicles to the area. Given the small parking area, it is unlikely that traffic volume would increase more than 5-10 vehicles AAVT, which is far below the threshold of 2,000 vehicles per day that is considered a potential impairment to lynx (Clevenger et al. 2002, Alexander et al. 2005). The minimal increase in traffic volume make it highly unlikely that project activities would result in an increased risk of traffic-related mortality to lynx.

Potential Disturbances Few studies have been conducted on the effects of recreational activities on lynx (Ruediger et al. 2000). Gaines et al. (2003) reviewed recreation trail-associated factors affecting wide- ranging carnivores and identified ‘disturbance at a specific site’ as the only non-motorized trail- associated factor that may impact lynx. Lynx may be able to tolerate moderate levels of human disturbance. However, human presence at den sites during the denning period has the potential to cause den abandonment that may impact kitten survival or lead to movement to a new den site (Claar et al. 1999). Lynx are described as being generally tolerant of humans (Mowat et al. 1999); however, there have been no studies conducted that have defined a “threshold” associated with recreation activities and the degree of lynx behavioral response. Responses such as indifference, temporary avoidance, or long-term displacement may depend on the intensity and frequency of human presence and activities in addition to availability of nearby secure habitats. The CDNST Reroute Project will increase human activities and noise levels within the vicinity of the project site. Trail construction activities conducted by work crews are likely required for several months during several consecutive years to complete the project. These activities including digging and clearing the trail footprint with hand tools as well as clearing trees and vegetation with chainsaws may result in indirect disturbances to any individual lynx that may happen to travel through the general area. Based on anecdotal information, these individuals would most likely avoid disturbance in the immediate area but otherwise continue to utilize undisturbed portions of the LAU and linkage area as well as the project area when human presence is lacking. Currently, the area is not known to support a lynx home range (Figure 3- 11); therefore the project has a lower likelihood of impacting resident lynx. Lynx are known to utilize forested ridge-tops for travel (USDA Forest Service 2008), which coincides with the topographic location of the trail along most of the proposed route. Therefore, the project’s location within and adjacent to the North Pass/Cochetopa Hills Lynx Linkage Area suggests a higher likelihood of lynx-human interaction. The presence and human use of non-motorized trails such as hiking trails is not listed as a risk factor for lynx, with the exception of snow-compacting activities such as cross-country skiing and snowshoeing (Ruediger et al. 2000). Human use of the project area, both during trail construction and subsequent trail use by the public would occur predominately during daylight hours. Less human use is likely during dawn and dusk periods, while lynx use of and travel through the project area would largely be undisturbed during the night.

Snow Compaction Trail and trailhead construction activities are not expected to begin before snowmelt, which is anticipated to occur during the months of May or June. By this time, it is anticipated that much

80 of the snowpack will be melted with periodic drifts remaining. Some amount of snowplowing may be needed to push through the remaining drifts and access work sites. These activities will not result in any temporary or permanent snow compaction above baseline conditions and will therefore have no influence on lynx in regards to snow compaction concerns. Subsequent trail use by the public may include snow-compacting activities such as cross-country skiing and snowshoeing. Data collected at the Cochetopa SNOTEL site, which is at an elevation similar to North Pass (10,020 ft), from 2005 to 2011 shows that snow depths within the project area are relatively low (NRCS 2012). Maximum depth for any given day was at or below 25 inches, but average depth was 16 inches or less (Figure 3-6). In terms of proximity to population centers as a source of users, this segment of the CDT is one of the most remote in Colorado. The nearest towns are Gunnison (Pop. 5,800), 38 driving miles to the NW, and Saguache (Pop. 580), 32 driving miles to the SW. Towns of the San Luis Valley include Monte Vista (Pop. 4,000), 67 driving miles, Alamosa (Pop. 8,800), 84 driving miles, and other smaller farm communities of the Valley. (Note: population figures rounded from 2010 Census Data). Recreation opportunities for day hiking abound in the mountains surrounding each of these communities, making the CDNST from Lujan to La Garita only one of many choices for local hikers. Thus, the level of snowshoeing and cross-country skiing is expected to be low due to the relatively shallow snow accumulations. In addition, the remoteness of the project area decreases recreational use potential. Figure 3-6. Average Snow Depth, Cochetopa Pass SNOTEL site

Average Snow Depth, Cochetopa SNOTEL Site 2005-2011 18 16 14 12 10 8 6 Snow Depth (in) 4 2 0

Date

Cumulative Effects The cumulative effects analysis area (CEA) consists of the area within the boundaries of the LAUs listed in Table 3-10, totaling 387,393 acres. Approximately 3,898 acres are comprised of private lands (2,748 acres), Colorado State Land Board (970 acres) and Colorado Wildlife and Parks (180 acres) ownership. There are no tribal lands within the CEA. In total, non-federal lands within the CEA account for approximately 1.0% of LAU acreage. There are no Tribal lands within the boundary of the CEA. Nearly all non-federal parcels are located in valley bottoms with vegetation primarily consisting of grass/forb/shrub upland and riparian associations

81 in addition to forested communities with varying amounts of Douglas-fir, ponderosa pine, and aspen, and lesser amounts of lodgepole pine and spruce/fir. Elevations range from 8,600 to 11,400 feet, but most parcels are located near or below 10,000 feet. Distances from the proposed trail and trailhead sites vary from 0.5 mile to 39.7 miles, averaging over 13 miles. Of the 22 non-federal parcels, only one is located less than 2 miles from project sites. Approximately 704 acres of suitable lynx habitat occurs on non-federal parcels, accounting for less than 0.4% of suitable habitat within the CEA. Past, present, and reasonably foreseeable activities in non-federal parcels are not well defined. Review of aerial photography indicates little or no recent timber harvest, but does show signs of past or recent small-scale mining activity within several parcels. The large amount of grass/forb/shrub vegetation in juxtaposition to water suggests that livestock grazing was, or is, occurring within a number of parcels. Agricultural leases and public access programs are identified for all Colorado State Land Board (SLB) parcels within the CEA (Colorado State Land Board 2012). Some structural developments consisting of one or more buildings are noted within 10 parcels. Where livestock grazing is ongoing, it is likely to continue as a foreseeable activity. The potential for future timber harvest, mining, and/or development on non-federal parcels is not known. Given the relatively long distances from project activities and low amounts of existing suitable habitat, it is unlikely that the effects of past, present, and reasonably foreseeable activities occurring on non-federal parcels will overlap with effects generated by this project in a manner that measurably affects Canada lynx. Additional activities ongoing and foreseeable activities include snowplowing along State Highway 114, which may create steep snow walls along the highway, possibly prolonging lynx crossing time and increasing vulnerability to highway mortality. Trapping is a potential lynx mortality factors that may occur on federal and non-federal lands. Project activities would increase non-motorized access into lynx suitable habitat, which may include an increase in local trapping pressure of furbearing species. Trapping with lethal traps is restricted to water and tree sites in Colorado, which reduces the potential for accidental take and mortality of lynx by trapping. In addition, visual lures, baits, and oil lures meant to attract felids are not permitted in the Canada lynx recovery area or on properties known to be occupied by Canada lynx (Colorado Parks and Wildlife 2012). Lynx monitoring records from 1999 – 2006 show no known lynx mortalities due to accidental trapping (Shenk 2009). Therefore, the increased risk of furbearer trapping to lynx within the analysis area is low. Predator control activities occur on federal and non-federal lands. These activities can occur in lynx habitat, but more often are located at lower elevations outside lynx habitat. Activities are directed at specific animals or target species. Lynx trapped unintentionally can be released. Animal and Plant Health Inspection Services (APHIS-Wildlife Services) information shows that no lynx have been taken incidentally in the Western Region for the past 30 years (USDA Forest Service 2008). Therefore, it is highly unlikely that predator control activities would contribute impacts that would add to those already associated with the proposed action.

Effects Determination Based on this analysis, it is determined that the Continental Divide Scenic Trail Reroute Project “May Affect, But is Not Likely to Adversely Affect” the Canada lynx. The rationale for this conclusion is as follows: • The proposed project will permanently alter approximately 15 acres of suitable lynx habitat. This represents a very minor and immeasureable amount (0.009%) of the total lynx habitat available within the affected LAUs. The narrow corridor (6 foot width) in which vegetation would be cleared would not alter amounts of mapped lynx habitat. The

82 effects due to the minor amount of direct habitat alteration are expected to be insignificant and discountable to Canada lynx. • The proposed project may increase disturbances to lynx, but not result in any adverse impacts to lynx movement across the landscape and through the linkage area because of the relatively low frequency and intensity of non-motorized use projected to occur along the new trail segment. • The proposed project occurs in an area that is not known to be part of a home range of any resident lynx on the GMUG or RGNF. • The proposed project is expected to increase vehicle traffic along State Highway 114 and along Forest development roads by only a minor amount. Traffic levels on State Highway 114, including increases expected due to the project, would remain well below threshold levels identified as detrimental to lynx. There will be no increase in road maintenance levels that may facilitate increased traffic volume or speeds. All potential traffic-related effects are expected to be insignificant and discountable. • There are no reasonably foreseeable future projects on non-federal lands that are expected to add to the effects of the proposed action. Therefore, no measurable cumulative effects are anticipated. • Project design criteria are included that are expected to assist in minimizing potential effects on lynx and lynx habitat. Wildlife-Sensitive Species & Management Indicator Species The CDNST Reroute Project involves approximately 32.1 miles of foot-trail construction with a tread width of 24 inches and clearing width of 6 feet as well as facility and trailhead development at two locations under Alternatives 2 and 5. All trail construction and facility/trailhead construction occurs on National Forest lands. The area analyzed for direct and indirect effects includes the trail and trailhead locations of proposed activities (i.e., 6-foot clearing width and trailhead construction sites) in addition to Forest Service-administered lands within ¼ mile (400 meters) of these sites to account for effects such as disturbance due to human presence. The boundary for cumulative effects analysis (CEA) varies by species in relation to species home range size and mobility. The CEA is identified for each species addressed further in the analysis. Vegetation databases from the GMUG and RGNF indicate that the new trail segment is located primarily in forested stands dominated by lodgepole pine, spruce/fir, and aspen, with small amounts of bristlecone pine and grass/forb/shrub openings (Table 3-7). The trailhead along State Highway 114 would be located predominately within aspen whereas the trailhead location at Luder’s Campground is a grass/forb/shrub meadow.

83 Table 3-7. Dominant Vegetation within 0.25 mile of Proposed Trail and Trailheads

Percentage of

Area within Dominant Species/Type Acres 0.25 mi.

Grass/Forb/Shrub 541 6%

Bristlecone pine 137 2%

Lodgepole pine 2,739 32%

Spruce/fir 2,892 34%

Aspen 2,132 25%

Douglas-fir 72 <1%

Willow 77 <1%

Sensitive Species Forest Service policy requires that a review of programs and activities, through an effects analysis document (referred to in current Forest Service policy as a biological evaluation or BE), be conducted to determine their potential effect on Regional Forester-designated sensitive species (FSM 2670.3). Preparation of a Biological Evaluation as part of the NEPA process ensures that sensitive species receive full consideration in the decision-making process. R2 sensitive wildlife species that occur or may occur on the RGNF or GMUG (Regional Forester list June 2011) are listed below. Species found within the project area that may be influenced by project activities are evaluated further in the analysis sections. This list includes: American peregrine falcon, Boreal owl, Flammulated owl, Northern goshawk, Olive-sided flycatcher, American marten, Pygmy shrew, Rocky Mountain bighorn sheep, Spotted bat, Townsend’s big- eared bat, Hoary bat, and North American wolverine. Those species that do not have habitat present within the analyses area are evaluated no further in this document. This list includes: the Great Basin silverspot butterfly, Bald eagle, Black swift, Brewer’s sparrow, Burrowing owl, Columbian sharp-tailed grouse, Ferruginous Hawk, Lewis’ woodpecker, Loggerhead shrike, Mountain plover, Northern harrier, Purole martin, Sage sparrow, White-tailed ptarmigan, Yellow-billed cuckoo, Desert bighorn sheep, Fringed myotis, Gunnison’s prairie dog, Kit fox, New Mexico jumping mouse, River otter, White-tailed prairie dog, Rio Grande cutthroat trout, Rio Grande sucker, Rio Grande chub, Boreal toad, Northern leopard frog , Bluehead sucker, Flannelmouth sucker, Roundtail chub, and Colorado River cutthroat trout. Additional information may be found in the BE in the project file.

American Peregrine Falcon Additional species information may be found in the BE in the project file.

Existing Condition Information for the RGNF indicates that peregrine falcons currently nest on the Conejos Peak District (4 sites), the Divide District (2 sites), and the Saguache District (1 site). One other site is

84 located adjacent to the Divide District on Colorado Division of Wildlife land. The Saguache District’s eyrie is located approximately 2.4 miles from the analysis area. The last year this eyrie was known to be active was 2006. No occupancy was detected from 2007 through 2011. No peregrine falcon observations are reported for the Gunnison Ranger District (GMUG NRIS wildlife database). Aerial photograph interpretation as well as digital elevation modeling (DEM) and elevation contour maps do not indicate the presence of potential nesting habitat in the form of prominent cliff sites or large rocky outcrops within the project area. Potential foraging habitat exists throughout the analysis area in the form of grass/forb/shrub openings and areas above forest canopy.

Environmental Consequences Alternative 1 The no-action alternative would maintain the existing CDNST trail location. No construction and subsequent use of new trailheads would occur. Alternative 1 would have no direct or indirect impacts on peregrine falcons.

Environmental Consequences All Action Alternatives The zone of potential human disturbance to nesting peregrines is identified as within one mile of nest sites (Richardson and Miller 1997, Romin and Muck 1999). Review of aerial photographs and elevational datasets indicate no suitable nesting habitat (prominent cliff sites or large rocky outcrops) within the project area (0.25 miles from proposed activities). Several large rocky outcrops do exist within one mile of proposed activities near the southern terminus of the project adjacent to Cochetopa Creek, but because these outcrops are located along the existing CDNST route it is likely that peregrine activity would have been identified if occurring. Therefore, no nesting or potential nesting activity is expected within one mile of proposed treatments. Project Design Criteria have been incorporated into all action alternatives that would address potential disturbance if peregrines were to establish nesting near new trail and trailhead sites (see Project Design Criteria). Therefore, no impacts to peregrine falcon nesting are expected under all action alternatives. Because the project area lies within 2.4 miles of a known eyrie, there is potential that peregrines could utilize natural openings and areas above forest canopy for foraging. Disturbance of foraging peregrines is unlikely due to the low-intensity nature of project activities and subsequent project area use in addition to the aerial nature of peregrine foraging which naturally creates a measure of spatial separation from ground-level project activities. Impacts to peregrine prey availability is also not expected due to the small spatial scope of vegetation treatments (i.e., trail clearing width of 6 feet, trailhead disturbance totaling less that ½ acre) where project activities are spread over a 32-mile span. Therefore, no impacts to peregrine falcon foraging are expected under all action alternatives.

Cumulative Effects Because there are no direct or indirect effects, no cumulative effects would occur.

Determination Based on the analysis discussed above, it has been determined that, as proposed, this project will have “no impact” on the peregrine falcon.

Boreal Owl Additional species information may be found in the BE in the project file.

85 Existing Condition Boreal owls are known to occupy spruce-fir habitat on both the RGNF and GMUG. Numerous sightings have been reported between the two Forests. Only several have been reported for the Gunnison RD and no reports have come from the Saguache RD. All sightings are located more than 20 miles from the project area (GMUG, RGNF NRIS Wildlife Database). Dry overall habitat conditions and limited spruce-fir habitat are suspected for the lack of boreal owl observations on the Saguache District (Irwin 2009). The CDNST Reroute project contains approximately 1,498 acres of Spruce/fir forest in structural stages 4B or 4C containing mature forest with moderate or dense canopy closures.

Environmental Consequences All Action Alternatives Two boreal owl nest sites were recently found near the headwaters of Spanish Creek (Saguache RD) and Lujan Creek (Gunnison RD). Nest site #1is located about 370 feet from the existing trail and about 0.4 mile from the proposed route. Nest site #2 lies in close proximity to an existing road, approximately 0.6 miles east of the intersection of the existing and proposed routes. Trail construction activities and subsequent trail use under the action alternatives would occur at or greater than 0.4 mile from the known nest sites. This distance exceeds the 0.25 mile buffer recommended by Romin and Muck (1999) for activities in proximity to boreal owl nest sites. Therefore, activities proposed under the action alternatives are not expected to increase disturbance at known boreal owl nest sites. All action alternatives would create a 6-foot clearing width associated with the proposed trail. A total of about 4 acres of clearing would occur in portions of spruce-fir stands in Structural Stages 4B and 4C. This would occur along a total of 5 miles of trail scattered throughout the extent of the total 32.1 miles proposed. Due to a lack of existing habitat, no habitat alteration would occur at proposed new trailheads under Alternatives 2 and 5. Creation of the 6-foot clearing width is expected to have minimal impact to boreal owl roosting habitat availability. The affected habitat (4 acres) represents only 0.26% of spruce-fir stand in structural stages 4B and 4C currently within the analysis area. In addition, the narrow width of the affected area precludes any meaningful edge effect or concentrated patch that would constitute an opening devoid of hunting perches or roost opportunities. Openings larger than several hectares (interpreted as more than 7 acres) are expected to eliminate foraging habitat (Hayward 1994). Proposed treatments could remove individual snags within the clearing width or outside the clearing width for safety reasons. Current snag availability and distribution within the affected area is unknown, but larger snags may exist within the proposed clearing width. If a snag is removed while occupied by nesting boreal owls, the activity would lead to nest abandonment or could cause mortality of nestlings if they are present. Because the affected area represents a small, narrow portion of habitat within the analysis area, snag availability for boreal owl nesting at the broader scale is not expected to be measurably impacted at the project area scale. Boreal owls tolerate human and machine noise and have been recorded nesting within 30 meters (100 feet) of a major highway. The species will also tolerate frequent nest inspections and will deliver prey to the nest with humans observing from only several meters away

86 indicating that disturbance is not an important factor in nest loss or individual movements (Hayward 1994). Therefore, human activity during project implementation and subsequent project area use is not expected to impact boreal owls.

Cumulative Effects Boreal owls are known to have rather large home ranges, averaging approximately 3,600 acres. Therefore, the cumulative effects area (CEA) identified for this species extends outside the project area at distance of one home range diameter, or 2.7 miles. In total, the CEA accounts for other activities within 3 miles of project activities. The primary activities of concern for boreal owls include logging and fuelwood gathering. Past logging activities that have occurred within spruce-fir stands have likely affected local availability of nesting, roosting, and foraging habitats. Some past logging in spruce-fir has occurred in portions of the CEA on the GMUG. Past logging in the Saguache RD spruce-fir zone appears to be minimal. No reasonably foreseeable timber harvest activities are identified within the spruce-fir zone of the RGNF. On the GMUG, the Cochetopa Hills Planning Area occurs with the boreal owl CEA for this project. Potential project activities within the planning area include timber harvest and prescribed burning, some of which may occur within spruce-fir stands. Impacts to boreal owls would be analyzed for that project if suitable habitat is affected. Due to the minor habitat impacts predicted as a result of the CDNST Reroute Project, additional cumulative impacts associated with projects in the Cochetopa Hills Planning Area are likely to be insignificant. Other ongoing and foreseeable activities within the CEA include livestock grazing, outfitter/guide and special use permits, and fish habitat improvement projects, none of which are expected to add measurable cumulative effects.

Determination Based on the analysis discussed above, it has been determined that, as proposed, this project “May adversely Impact Individuals, but not likely to result in a loss of viability in the planning area, nor cause a trend toward federal listing” for the boreal owl.

Flammulated Owl Additional species information may be found in the BE in the project file.

Existing Condition There are currently 42 records of flammulated owl occurrence on the RGNF and 150 recorded occurrences on the GMUG, indicating that the species is fairly common. On the RGNF, the majority of these records occurred on the Conejos Peak District during surveys for the Mexican spotted owl. Only five observations have been reported for the Saguache RD. Only a total of four flammulated owl observations are reported for the Gunnison RD, GMUG, the nearest of which is located about 15 miles north of the project area (GMUG NRIS Wildlife Database). Owl surveys have not been conducted in the project area vicinity and no known occurrences are reported for the project area. Although the project area lacks ponderosa pine, the area does contain approximately 72 acres of mature Douglas-fir stands with structural stages 4A, 4B, and 4C that may be used to some extent by the species.

87 Environmental Consequences Alternative 1 The no-action alternative would maintain the existing CDNST trail location. No construction and subsequent use of new trailheads would occur. Alternative 1 would have no direct or indirect impacts on flammulated owls.

Environmental Consequences Action Alternatives All action alternatives propose to create approximately 1,640 feet (0.31 mi.) of new trail within one mature Douglas-fir stand. At a clearing width of 6 feet, this would impact about 0.23 acre of flammulated owl habitat. In addition, snags that pose a safety risk within or near the trail may be removed. Direct impacts to flammulated owls resulting in nest abandonment or mortality of young would occur if owls are nesting in trees or snags being removed. Project design criteria that require reporting of raptor nest activity to the RGNF Forest Biologist may reduce the risk slightly, but the species’ cryptic nature and nocturnal activity period make it unlikely that owls would be detected during daylight project activities. Indirectly, trail construction that affects 0.23 acre would have minimal impacts to habitat availability as this represents only 0.3% of habitat within the project area. The trail’s narrow configuration would also preclude a change in stand suitability for the species. Flammulated owls are known to nest close to sites occupied by humans and tolerate observation by flashlight all night while feeding young, indicating that they are very tolerant of humans. Nest abandonment is rare. However, the effects of mechanical activities such as chainsaw use in proximity to nest sites has not been evaluated (McCallum 1994); therefore there is potential for trail construction activities to affect flammulated owls nesting in proximity to work sites. Subsequent non-motorized trail use is not expected to generate substantial noise nor is it expected to impact flammulated owl nesting.

Cumulative Effects Home range sizes reported for flammulated owls are relatively small, averaging about 20 acres in size during the nesting period (McCallum 1994). Therefore, the project area is of sufficient size to assess the potential cumulative impacts of past, present, and reasonably foreseeable activities. The primary activities of concern for flammulated owls include logging and fuelwood gathering. Review of past activities indicates that no timber harvest has occurred in flammulated suitable habitat within the project area within recent history. On the GMUG, the Cochetopa Hills Planning Area occurs with the CEA for this project. Potential project activities within the planning area include timber harvest and prescribed burning, some of which may occur within suitable habitat. Impacts to flammulated owls would be analyzed for that project if suitable habitat is affected. The lack of open road access to existing suitable habitat makes it very unlikely that firewood gathering is a factor for this species. Other ongoing and foreseeable activities such as livestock grazing and special use permits are not expected to impact flammulated owl suitable habitat within the project area.

Determination Based on the analysis discussed above, it has been determined that as proposed, this project will have “May adversely Impact Individuals, but not likely to result in a loss of viability in the planning area, nor cause a trend toward federal listing” on flammulated owls or their habitat.

Northern Goshawk Additional species information may be found in the BE in the project file.

88 Existing Condition Goshawks are relatively common on the Saguache Ranger District (Irwin 2009). Core areas of goshawk territories are found adjacent to the analysis area in the vicinities of Spanish Creek, Luder’s Creek, and Jakes Creek on the RGNF (NRIS Wildlife Database). A total of 27 goshawk territories were known to occur on the Gunnison RD as of 2008 (USDA Forest Service 2008). Review of available information shows that nesting has occurred in the vicinity of West Pass Creek less than one mile from the project area. In addition, goshawk activity was detected within the project area during the nesting season southeast of Monchego Park in 2010 (Hill 2010). On the RGNF, one nest site has been reported approximately 0.5 mile from the proposed trail site in the vicinity of Cantonment Creek. This nest site was last identified as active in 2006. Approximately 3,247 acres of suitable northern goshawk habitat occurs within 0.25 mile of proposed new trail and trailheads.

Environmental Consequences All Action Alternatives Approximately 14.3 miles of new trail is proposed in suitable goshawk habitat defined as aspen, spruce-fir, Douglas-fir, limber pine, lodgepole pine, or ponderosa pine in structural stages 4B or 4C. The amount of habitat affected by trail clearing activity totals 10.4 acres under all action alternatives representing about 0.3% of habitat available within the project area. The narrow configuration of the trail corridor (6 feet wide) is expected to preclude stand-level changes in goshawk habitat suitability and is unlikely to influence existing goshawk use patterns. Trailhead construction at the State Highway 114 site would occur within modeled goshawk habitat, but the site’s location being directly adjacent to a State highway reduces the potential for use by nesting goshawks. The Luder’s Creek trailhead is located outside suitable habitat. Some removal of snags or trees outside the trail clearing limits may occur to provide for safety. This may affect availability of cavity nesters as prey locally, but the small size of the affected area makes it unlikely that snag removal will impact prey abundance at the scale of a given goshawk territory. In addition, snags or trees removed for safety reasons would be retained onsite and function as down log habitat for other potential prey. Therefore, trail construction under all action alternatives, as well as trailhead construction under Alternatives 2 or 5, is not expected to measurably impact goshawk habitat availability or use. There are no known goshawk active nest stands within the project area. However, goshawk activity recorded near the proposed trail route in the vicinity of Monchego Park in 2010 may indicate goshawk nesting. In addition, because no goshawk surveys have been completed along the trail route, the status of potential nesting along other portions of the trail route is unknown. Trail construction activities in proximity to active nest sites could affect nesting success due to disturbance. Project design criteria that require reporting of TES species to the RGNF Forest Biologist and Gunnison RD District Biologist are likely to reduce the risk of impacts to nesting because the species is often vocalizes and readily displays defensive behavior when humans come near a nest. However, some impacts to nesting success may still occur due to human disturbance. Subsequent trail use by the public may also affect goshawk nesting. The short-term duration of a hiker or horseback rider moving through a stand may create a minor disturbance, but repeated passing of several users per day may create

89 disturbance levels that lead to nest failure or movement to a nesting site in less disturbed areas in subsequent breeding seasons.

Cumulative Effects Goshawk home ranges average about 5,400 acres in size. Therefore, the cumulative effects area (CEA) identified for this species extends outside the project area at distance of one home range diameter, or 3.3 miles. In total, the CEA accounts for other activities within about 3.5 miles of project activities. The primary activities of concern for goshawks include logging and fuelwood gathering. Past logging activities that have occurred within conifer and aspen stands have likely affected local availability of nesting, roosting, and foraging habitats. Reasonably foreseeable timber harvest activities within the CEA on the RGNF include Buffalo Pass Timber Stand and Fuels Reduction Project and Calesa Stewardship Project. On the GMUG, a portion of the Cochetopa Hills Planning Area occurs within the goshawk CEA. The Barnet project may also occur within the CEA. Impacts to goshawks would be analyzed for each of these projects under the NEPA process, with mitigations such as limited operating periods (LOPs) likely required in proximity to active nest sites. In addition, impacts created by the CDNST project would be considered during cumulative effects analysis if this project falls within the goshawk CEAs of those projects listed above. Habitat impacts and additional disturbance effects may result from these other projects and overlap those of the CDNST Reroute project, but due to the minor habitat impacts predicted as a result of the CDNST Reroute Project, additional cumulative impacts are likely to be insignificant.

Determination Based on the analysis discussed above it has been determined that as proposed, this project “May adversely Impact Individuals, but not likely to result in a loss of viability in the planning area, nor cause a trend toward federal listing” of northern goshawk.

Olive-sided Flycatcher Additional species information may be found in the BE in the project file.

Existing Condition The Forest database provides 27 records of olive-sided flycatchers occurring on the Saguache Ranger District predominately from grass/forb/shrub, spruce-fir, Douglas-fir, in spruce-fir, ponderosa pine, and riparian habitats. No records were found for the Gunnison Ranger District, but the species is likely to occur there in similar habitats. Suitable nesting habitat in the form of conifer or aspen that borders an opening is limited, but is more common in the southern portion of the project area where conifer stands are more apt to share a boundary with natural grassy openings and parks. Suitable habitat defined as aspen, spruce-fir, or Douglas-fir in structural stages 4A, 4B, or 4C totals 5,233 acres within the project area. The project area lacks recent post-fire habitat. Snag densities along edges within the project area are unknown.

90 Environmental Consequences All Action Alternatives Creation of the 6-foot clearing width is expected to have minimal impact to habitat availability. The affected habitat (4.8 acres) represents approximately 0.09% of aspen, spruce-fir, Douglas- fir stand in structural stages 4A, 4B, or 4C currently within the analysis area. In addition, the narrow width of the affected area precludes any meaningful creation of edge or concentrated patch that would constitute an opening that may increase habitat availability and benefit the species. Proposed treatments could remove individual snags within the clearing width or outside the clearing width for safety reasons. Current snag availability and distribution within the affected area is unknown, but snags suitable for nesting may exist within the proposed clearing width. If a snag is removed while occupied by olive-sided flycatchers, the activity would lead to nest abandonment or could cause mortality of nestlings if they are present. Because the affected area represents a small, narrow portion of habitat within the analysis area, snag availability for olive-sided flycatcher nesting at the broader scale is not expected to be measurably impacted. Information pertaining to the effects of human disturbance on olive-sided flycatcher nesting success is limited (Altman and Sallabanks 2000). The species may tolerate some activities surrounding the nest, but distance and noise intensity thresholds have not been identified. Therefore, trail construction activities may have an unknown level of effect on nesting activity. Subsequent trail public trail use may also influence nesting, but the intensity and duration of disturbance generated by passing hikers is expected to be less. Repeated exposure to trail traffic may elicit selection of an alternate nest site or individuals may become habituated and tolerant of passing traffic. Therefore, human activity during project implementation and subsequent project area use may impact olive-side flycatchers.

Cumulative Effects Olive-sided flycatcher nesting territories vary between 25-50 acres per pair (Kotliar 2007). Due to this small size, the project area is expected to be of sufficient scale to assess overlapping cumulative impacts. No reasonably foreseeable timber harvest activities are identified within the portion of the project area on the RGNF. On the GMUG, the Cochetopa Hills Planning Area occurs with a portion of the CDNST project area. Potential project activities within the planning area include timber harvest and prescribed burning, some of which may occur within olive-sided flycatcher suitable habitat. Impacts to the species would be analyzed for that project if suitable habitat is affected. Due to the minor habitat impacts predicted as a result of the CDNST Reroute Project, additional cumulative impacts associated with projects in the Cochetopa Hills Planning Area are likely to be insignificant. Fire suppression has likely limited the number of fire-created openings, which is a preferred habitat for this species. Other ongoing and foreseeable activities within the CEA include livestock grazing, outfitter/guide and special use permits, and fish habitat improvement projects, none of which are expected to add measurable cumulative effects.

Determination Based on the analysis discussed above, it has been determined that, as proposed, this project will have “May adversely Impact Individuals, but not likely to result in a loss of viability in the planning area, nor cause a trend toward federal listing” on olive-sided flycatcher or their habitat.

91 American Marten Additional species information may be found in the BE in the project file.

Existing Condition Local survey efforts conducted specifically for American marten have not been conducted on the RiGNF. During the period from 1992 through 1995, however, a considerable amount of information was collected on martens by the Colorado Division of Wildlife during survey efforts for wolverine (Kenvin 1992, 1993, 1994-95). Additional marten information was collected during 1990-91 survey efforts by a consulting firm in the Wolf Creek Pass area (Thompson et al. 1992). These efforts were focused in the alpine and spruce-fir landtypes and included infra-red camera stations, snow tracking routes, hair snag stations, and aerial surveys. A total of 57 site detections of marten are currently known on or near the RGNF. Forty-three (75%) of these locations occur on the Divide Ranger District, 13 (23%) on the Conejos Peak District, and one (2%) on the Saguache District. Marten have also been detected twice in the Cameron Park area and once in the South Crestone and the Rito Alto areas of the Saguache District. The Saguache District is considered under-sampled since none of the wolverine surveys occurred there. On the GMUG, there are 69 documented marten occurrences of which 49 were in spruce-fir, 10 were in lodgepole pine, eight in aspen, and one each in limber pine and grassland edge. Those documented in lodgepole pine have been within the Gunnison Basin. Most marten occurrences have been within ¼ mile of high elevation riparian areas (Vasquez and Spicer 2005). No marten occurrences are shown to occur within or adjacent to the CDNST Reroute project area (NRIS Wildlife Database). The project area contains 2,877 acres of spruce-fir lodgepole habitat capable of supporting marten (i.e., structural stages 4B and 4C). Therefore, occupancy is assumed.

Environmental Consequences All Action Alternatives Approximately 13.4 miles of new trail is proposed within suitable marten spruce-fir and lodgepole pine habitat. The amount of habitat affected by trail clearing activity totals 9.7 acres under all action alternatives representing about 0.3% of habitat available within the project area. The narrow configuration of the trail corridor (6 feet wide) is expected to preclude stand-level changes in habitat suitability and is unlikely to influence existing marten use patterns. Trailhead construction at both the State Highway 114 and Luder’s Creek sites would occur outside suitable habitat. Some removal of snags or trees outside the trail clearing limits may occur to provide for safety. This may affect availability of snag-associated prey species locally, but the small size of the affected area makes it unlikely that snag removal will impact prey abundance at the scale of a given territory. In addition, snags or trees removed for safety reasons would be retained onsite and function as down log habitat for other potential prey. Therefore, trail construction under all action alternatives, as well as trailhead construction under Alternatives 2 and 5, is not expected to measurably impact marten habitat availability or use. Trail construction activities within marten suitable habitat could affect species use patterns due to disturbance. The effects to marten are expected to be avoidance or displacement that would be temporary in nature. Subsequent trail use by the public may also affect marten use patterns.

92 The short-term duration of a hiker or horseback rider moving through a stand may create a minor disturbance, but repeated passing of several users per day may create disturbance levels that lead to longer-term avoidance or displacement near the trail.

Cumulative Effects Marten female home ranges average about 830 acres in size. Therefore, the cumulative effects area (CEA) identified for this species extends outside the project area at distance of one home range diameter, or 0.65 mile. In total, the CEA accounts for other activities within about 0.9 mile of project activities. The primary activities of concern for marten include logging and fuelwood gathering. Past logging activities that have occurred within mature spruce-fir and lodgepole pine stands have likely affected local habitat availability. Reasonably foreseeable timber harvest activities within the CEA include the Cochetopa Hills Planning Area. Impacts to American marten would be analyzed for this project under the NEPA process. In addition, impacts created by the CDNST project would be considered during cumulative effects analysis if this project falls within the Cochetopa Hills Planning Area marten CEA. Habitat impacts and additional disturbance effects may result from these other projects and overlap those of the CDNST Reroute project, but due to the minor habitat impacts predicted as a result of the CDNST Reroute Project, additional cumulative impacts are likely to be insignificant.

Pygmy Shrew Additional species information may be found in the BE in the project file.

Existing Condition No pygmy shrew records are reported for either the Gunnison or Saguache Ranger Districts (NRIS Wildlife Database). However, no surveys for this species are known to have occurred within or adjacent to the project area. Suitable habitat consisting of spruce-fir and wet meadow/riparian cover types total about 3,012 acres within the project area.

Environmental Consequences Action Alternatives Approximately 2,893 acres of spruce-fir stands occur within the project area. The clearing width for the proposed new trail would impact about 8 acres, or 0.2% of existing spruce-fir. Wetland habitat within the project area is limited to 119 acres, most of which (77 acres) occurs along Cochetopa Creek along the existing CDNST south of the point where the proposed trail joins the existing trail. The proposed trail intersects wet or moist areas in only one location consisting of a short meadow crossing (approximately 90 feet) at the northern extent of the project where the proposed trail leaves the junction with the existing CDNST at Lujan Pass. No standing water or wetland vegetation is evident within the meadow at the crossing thereby avoiding optimal pygmy shrew habitat. Width of the trail (24 inches) across the meadow may remove less than 1/100th

93 acre of potential pygmy shrew habitat in that location. No barriers to shrew movement are expected as a result of trail construction and subsequent use. Direct effects include the potential for injury or mortality of an individual shrew if it was stepped on by passing trail traffic, but the potential for direct effects is low.

Cumulative Effects Pygmy shrews are expected to have small home ranges averaging about one acre. Therefore, the project area defines the cumulative effects area for this species. Two activities with potential to impact pygmy shrew habitat are timber harvest and livestock grazing. Because the Cochetopa Hills Planning Area overlaps the CDNST project area, there is potential that timber harvest could occur in suitable spruce-fir stands. The only potential overlapping effect to pygmy shrew habitat in wet meadow settings within the project area would be livestock grazing, which may alter pygmy shrew habitat suitability dependent upon grazing intensity (Beauvais and McCumber 2006). Due to the small scale of habitat impacts generated by the CDNST Reroute Project, no substantial cumulative impacts are expected.

Rocky Mountain Bighorn Sheep Additional species information may be found in the BE in the project file.

Existing Condition The overall components of bighorn sheep range include summer, winter, severe winter, and concentration areas as well as migration routes. All of these components are found throughout the Conejos Peak, Divide and Saguache Districts of the RGNF) and portions of the Bureau of Land Management (BLM) (Natural Diversity Information Source (NDIS), CDOW 2009). Local habitat relationships for bighorn sheep are similar to that described elsewhere for Colorado. Most local bighorn sheep populations occur in steep, mountainous terrain in the alpine and subalpine zones. Most herds display elevational migrations which vary by season although some herds remain in the alpine zone throughout the year. The primary lambing areas on the Saguache Ranger District and Field Office occur on BLM lands (Irwin 2009). The Saguache District and adjacent BLM lands consist of two main bighorn sheep herds and one small remnant herd. The largest herd is the Sangre de Cristo herd (S9) on the District’s east side and the Trickle Mountain (S10) and Carnero Creek (S55) herd on the west side of the District. The Trickle Mountain herd consists of two small groups of sheep found in the Poison Gulch and Trickle Mountain areas. The Carnero Creek herd is located in the Hell’s Gate area and to the south to the Natural Arch area on the Divide RD. There are no reported observations of bighorn sheep within the project area (NRIS Wildlife Databases). The closest bighorn sheep observations occur approximately 15 miles northwest to the northwest on the GMUG and 8 miles east on the RGNF. The project area generally lacks suitable habitat in the form of steep rugged terrain or open south-facing slopes. A small portion (less than 200 acres) of mapped bighorn sheep summer range occurs within the project area near the headwaters of Buck Park Creek (NDIS, CDOW 2006). The project area is located outside the mapped extent of bighorn sheep winter range, winter concentration areas, summer concentration areas, and production areas (NDIS, CDOW 2006).

94 Environmental Consequences Alternative 1 The no-action alternative would maintain the existing CDNST trail location. No construction and subsequent use of new trailheads would occur. Alternative 1 would have no direct or indirect impacts on Rocky Mountain bighorn sheep.

Environmental Consequences Action Alternatives Project activities within mapped bighorn sheep summer range, including trail construction under all action alternatives and trailhead construction under Alternatives 2 and 5, would occur within forested stands on mild slopes not expected to support bighorn sheep. Trail and trailhead construction sites are also located outside the mapped extent of bighorn sheep winter range, winter concentration areas, summer concentration areas, and production areas. Therefore, project activities are not expected to impact bighorn sheep habitat. Bighorn sheep have habituated to human activity in many areas where the activity is somewhat predictable. In Forest Service Region 2, the primary concern for human-related disturbances occurs on winter ranges (Beecham et al. 2007). Winter ranges usually encompass or are close to traditional lambing areas, which are also susceptible to disturbance. However, some disturbances can also be detrimental on summer range areas, such as recreational disturbances along the Continental Divide Trail in Colorado. Human disturbances can alter the movement patterns of individual bighorn sheep and cause them to wander into high-risk areas that may have not otherwise occurred (Beecham et al. 2007). Bighorn sheep generally show a consistent absence within the project area, but there is potential for use of portions of the project area during exploratory movements. Human disturbance during project implementation or subsequent trail use may impact individual sheep if encountered. Sheep response to trail use is likely to consist of avoidance or temporary displacement. Impacts are expected to be short-term because the area is currently unoccupied by the species. Subsequent trail travel would be open to use and presence of pack animals that may include llamas and pack goats. Review of available literature suggests that the presence of llamas is unlikely to lead to transmission of microbes fatal to bighorn sheep. This is consistent with results reported by Foreyt (1994) and a lack of data linking such species to bighorn sheep die- offs (Schommer and Woolever 2001). Garde et al. (2005) conducted a risk assessment that reviewed the potential for disease transmission between domestic pack animals and wild Dall’s sheep and mountain goats and concluded that contact between llamas and wild Dall’s sheep or mountain goats in the Northwest Territories may result in disease transmission, but there was insufficient data to clearly assess the role of camelids as a source of disease at the time the report was written. Scientific evidence reviewed by the U.S. Fish and Wildlife Service suggests that llamas utilized as pack animals present a minimal risk of transmission of known pathogens to Sierra Nevada bighorn sheep (USDI Fish and Wildlife Service 2007). Bighorn sheep are particularly susceptible to Pasteurella/Mannheimia-related pneumonia that can result in substantial die-offs (Cassirer et al. 2007, George et al. 2008). Domestic goats have been reported to contain Pasteurella/Mannheimia strains known to cause mortality in bighorn sheep (Rudolph et al. 2003, Garde et al. 2005). While Foreyt (1994) reported no transmission of Pasteurella between domestic goats and bighorn sheep in exposure trails, Rudolph et al. (2003) concluded that a feral goat in Hell’s Canyon National Recreation Area shared identical strains of Pasteurella with two bighorn sheep, one of which was symptomatic for pneumonia, and suggested that domestic goats may serve as a reservoir of Pasteurella strains that may be virulent in bighorn sheep. Further investigation; however, concluded that the source of additional bighorn sheep mortalities in that Hell’s Canyon die-off was attributed to sources other than the single feral goat (Rudolph et al. 2007). In a risk assessment conducted for the Northwest Territories, Garde et al. (2005) concluded that contact between domestic

95 goats and wild Dall’s sheep would likely result in disease transmission and negative long-term effects on population dynamics and sustainability. The Western Association of Fish and Wildlife Agencies (WAFWA 2010a) considers potential interaction of bighorn sheep and domestic goats a high risk factor for bighorn sheep. Garde et al. (2005), Rudolph et al. (2003), Schommer and Woolever (2001), and WAFWA (2010a) all recommend avoiding contact between domestic goats and bighorn sheep. All new proposed trail segments are outside the current mapped distribution of bighorn sheep. Therefore, the potential for interaction between pack goats and bighorn sheep is currently low. However, exploratory movement of bighorn sheep, as well as incorporation of suitable habitats where the western trail segment is located into overall home ranges, is possible, and use of domestic goats as pack animals would increase risk to bighorn sheep if close contact between the two species occurs.

Cumulative Effects There are currently no domestic sheep allotments on the Saguache District. However, there are active domestic sheep allotments on the Divide District and State lands adjacent to the south side of the Saguache District. There are also domestic sheep on private land to the North of the analysis area in the Trickle Mountain area (Irwin 2009). These are all potential sources for disease transmission to the area’s wild sheep. Habitat does not currently appear to be a limiting factor for sheep on the District’s west side.

Spotted Bat Additional species information may be found in the BE in the project file.

Existing Condition Surveys for spotted bats have not been conducted in the project area, nor have there been any reports of the species occurring in the project area vicinity (GMUG, RGNF NRIS databases). Approximately 541 acres consisting grass/forb/shrub openings occur within the project area. Potential roosting habitats are lacking within the project area. Aerial photograph interpretation as well as digital elevation modeling (DEM) and elevation contour maps do not indicate the presence of prominent cliff sites within the project area. The area does contain suitable foraging habitat as this species is known for utilizing a range of vegetation associations.

Environmental Consequences All Action Alternatives No prominent roosting habitat is identified within the project area. The project area does contain conifer stands and subalpine meadows that potentially serve as foraging habitat. Because this species is an aerial feeder and is known to use large areas for foraging, project activities would have an immeasurable impact on foraging habitat. Therefore, project activities will have no impact on spotted bat roosting or foraging under all action alternatives.

96 Cumulative Effects Because there are no direct or indirect effects to roosting or foraging, there would be no cumulative effects to spotted bats.

Determination Based on the analysis discussed above, it has been determined that, as proposed, this project will have “No Impact” on spotted bats.

Townsend’s big-eared bat Additional species information may be found in the BE in the project file.

Existing Condition Surveys for bat species on the RGNF have primarily been conducted by the CDOW. Nine species of bats, including Townsend’s, have been documented as occurring on or near the Forest. The current information for Townsend’s involves seven abandoned mine sites that are used primarily as temporary roost sites, with one moderately-sized maternity colony also on the Forest. A total of 17 occurrences are located on or near the GMUG, the closest of which is about 54 miles northwest of the project area. No caves features or abandoned mines are known to occur within the project area. The area does contain suitable foraging habitat as this species is known for utilizing a range of vegetation associations.

Environmental Consequences All Action Alternatives No prominent roosting habitat is identified within the project area. The project area does contain conifer stands and subalpine meadows that potentially serve as foraging habitat. Because this species is an aerial feeder and is known to use large areas for foraging, project activities would have an immeasurable impact on foraging habitat. Therefore, project activities will have no impact on Townsend’s big-eared bat roosting or foraging under all action alternatives.

Cumulative Effects Because there are no direct or indirect effects to roosting or foraging, there would be no cumulative effects.

Determination Based on the analysis discussed above, it had been determined that, as proposed, this project will have “No Impact” on Townsend’s big-eared bats.

Hoary bat Additional species information may be found in the BE in the project file.

97 Existing Condition Surveys for hoary bats have not been conducted in the project area, nor have there been any reports of the species occurring in the project area vicinity (GMUG, RGNF NRIS databases). One individual sighting is reported for the RGNF in the Sangre de Cristo Mountains. Potential roosting habitats consisting of foliage within conifer and aspen are available throughout the project area. The area also contains suitable foraging habitat as this species is known for utilizing a range of vegetation associations.

Environmental Consequences All Action Alternatives Roosting and foraging habitat is available throughout the project area. Because the action alternatives could remove trees to create the trail and clearance width, direct impacts to individual roosting bats is possible. However, the small amount of area being impacted (approximately 23 acres) precludes potential impacts to populations. Also, because this species is an aerial feeder and is known to use large areas for foraging, project activities would have an immeasurable impact on foraging habitat.

Cumulative Effects The primary activity of concern for this species is timber harvest (WBWG 2005). Past logging activities that have occurred within forested stands in the project have likely affected local habitat availability. Reasonably foreseeable timber harvest activities within the CEA include the Cochetopa Hills Planning Area. Impacts to hoary bats would be analyzed for this project under the NEPA process. In addition, impacts created by the CDNST project would be considered during cumulative effects analysis if this project falls within the Cochetopa Hills Planning Area marten CEA. Habitat impacts and additional disturbance effects may result from these other projects and overlap those of the CDNST Reroute project, but due to the minor habitat impacts predicted as a result of the CDNST Reroute Project, additional cumulative impacts are likely to be minor.

Wolverine As of February 4, 2013 USFWS is proposing to protect the North American wolverine as a threatened species under the ESA. USFWS is also proposing a special rule that would limit protections of the ESA only to those necessary to address the threats to the species. A 90-day comment period is currently being provided to allow the public and stakeholders an opportunity to comment on these proposals. During that time, USFWS will seek peer review from qualified members of the scientific community to ensure that their final decision is based on solid science. USFWS will make a final determination in 2014 whether to add the wolverine to the Federal List of Endangered and Threatened Wildlife based on the best available science. USFWS will decide whether or not it is prudent to designate critical habitat for the wolverine, and whether such a designation would be beneficial to this species given the threat to its habitat is climate

98 change. Because wolverines are being considered for listing, they were also addressed with the USFWS for this project (see Wildlife-Threatened or Endangered Species section above).

Existing Condition Until recently, the last confirmed wolverine sighting in Colorado was in 1919. Twelve survey efforts conducted in Colorado from 1979-1996 yielded no confirmed sightings. Occasional reports of wolverine sightings were investigated, but wolverine were never officially documented. In spring 2009, researchers with the Greater Yellowstone Wolverine Program tracked a wolverine from Grand Teton National Park south into north central Colorado. This was the first wolverine confirmed in the state in 90 years (CPW 2012a). No confirmed wolverine sightings existing within or adjacent to the project area. The area contains suitable travel and foraging habitat in the form of subalpine conifer and meadows, but lacks alpine habitat and avalanche-prone slopes most likely to support denning.

Environmental Consequences All Action Alternatives Wolverines are unlikely to occur within the project area due to lack of known individuals in southern Colorado. However, due to the secluded nature of the species as well as its naturally low population densities and large home ranges, it is possible that an individual could occur undetected on the GMUG or RGNF. Because the project area lacks alpine habitat and avalanche-prone slopes, impacts to potential wolverine denning is not expected. The project area has potential to provide some limited foraging opportunities and currently provides suitable habitat to support relatively undisturbed wolverine travel across the landscape. Wolverines utilize a wide variety of upper-elevation vegetation types for foraging and travel in addition to having extremely large home ranges. Project activities proposed under all action alternatives, including trail clearance, would affect an area less than 25 acres in size distributed across a distance of about 31 miles. Activities proposed under Alternative 2, including trail clearing and trailhead construction, would affect less than 26 acres total. This represents approximately 0.3% of the project area. In comparison to the home range size utilized by the species (up to 500 square miles), the effect of project activities at the home range is immeasurable. Vegetation changes would not change stand suitability for foraging or travel. Wolverine response to presence/absence of human activity has been described in several studies both locally and at the landscape level. Hornocker and Hash (1981) found no difference in wolverine density between wilderness and non-wilderness portions of their study area, nor was there a difference in wolverine movement, habitat use, or behavior. However, there was seasonal separation between areas of human use and wilderness. Logging roads and foot trails outside wilderness were used by humans primarily in the summer. During this season, wolverines used higher elevation areas within wilderness in response to food availability and cooler temperatures. Winter use of non-wilderness areas by humans was almost nonexistent, but wolverines used these lower elevations in winter in response to food availability, thereby effectively separating wolverines and humans. Copeland (1996) reported abandonment of denning sites after human disturbance. Copeland et al. (2007) found no relationship between wolverine occurrence and proximity to non-motorized trails within established home ranges. Preliminary results reported by Heinemeyer et al. (2010) indicate that adult wolverines in central Idaho established home ranges in landscapes containing a range of winter recreational activities

99 and levels of recreational intensity; however, there may be some indications of behavioral responses or adaptations by wolverines such as shifts in daily activity periods to reduce movement during periods of peak recreational activity. Trail construction and subsequent trail use under all action alternatives as well as trailhead construction and subsequent use under Alternatives 2 and 5 would increase human-caused disturbance by varying intensities in relation to existing levels. Because wolverines are characterized as shy animals, encounters with humans during project implementation or subsequent trail use are likely to result in avoidance by, or temporary displacement of individual animals. However, the probability of existing wolverine occurrence within the project area is low; therefore, the potential for impacts to individuals is also low.

Cumulative Effects Wolverines exhibit large home ranges described as up to 500 square miles (320,000 acres). Therefore, the wolverine cumulative effects area (CEA) identified for this analysis consists of five lynx analysis units (LAUs) associated with project activities (see Terrestrial Wildlife BIOLOGICAL ASSESSMENT for the Continental Divide National Scenic Trail Reroute Lujan to La Garita Wilderness). These include the Cochetopa and Stewart Creek LAUs on the GMUG as well as the Cochetopa, 4 Mile to La Garita, and Saguache Creek LAUs on the RGNF. The area totals about 337,000 acres and is sufficient to assess activities that may cumulatively impact wolverines. Reasonably foreseeable timber harvest activities within the CEA on the RGNF include Buffalo Pass Timber Stand and Fuels Reduction Project and Calesa Stewardship Project. On the GMUG, a portion of the Cochetopa Hills Planning Area occurs within the wolverine CEA. The Barnet project may also occur within the CEA. Impacts to wolverines would be analyzed for each of these projects under the NEPA process. In addition, impacts created by the CDNST project would be considered during cumulative effects analysis if this project falls within the wolverine CEAs of those projects listed above. Habitat impacts and additional disturbance effects may result from these other projects and overlap those of the CDNST Reroute project, but due to the minor habitat impacts predicted as a result of the CDNST Reroute Project, additional cumulative impacts are likely to be insignificant. Past, present, and reasonably foreseeable activities in non-federal parcels are not well defined. Review of aerial photography indicates little or no recent timber harvest, but does show signs of past or recent small-scale mining activity within several parcels. The large amount of grass/forb/shrub vegetation in juxtaposition to water suggests that livestock grazing was, or is, occurring within a number of parcels. Agricultural leases and public access programs are identified for all Colorado State Land Board (SLB) parcels within the CEA (Colorado State Land Board 2012). Some structural developments consisting of one or more buildings are noted within 10 parcels. Where livestock grazing is ongoing, it is likely to continue as a foreseeable activity. The potential for future timber harvest, mining, and/or development on non-federal parcels is not known. Given the relatively long distances from project activities and low amounts of existing suitable habitat, it is unlikely that the effects of past, present, and reasonably foreseeable activities occurring on non-federal parcels will overlap with effects generated by this project in a manner that measurably affects wolverines. Additional activities ongoing and foreseeable activities include snowplowing along State Highway 114, which may create steep snow walls along the highway, possibly prolonging wolverine crossing time and increasing vulnerability to highway mortality. Trapping is a potential mortality factor that may occur on federal and non-federal lands. Project activities would increase non-motorized access into suitable habitat, which may include an

100 increase in local trapping pressure of furbearing species. Trapping with lethal traps is restricted to water and tree sites in Colorado, which reduces the potential for accidental take and mortality of wolverines by trapping. Therefore, the increased risk of furbearer trapping to wolverine within the analysis area is low. Predator control activities occur on federal and non-federal lands. These activities can occur in wolverine habitat, but more often are located at lower elevations outside wolverine habitat. Activities are directed at specific animals or target species. Wolverine trapped unintentionally can be released. Animal and Plant Health Inspection Services (APHIS-Wildlife Services) information that there is a potential for negative effects to the species if present, but predator control activities would have no effect due to the lack of known wolverine occurrence within the State (USDA APHIS 2005). Therefore, it is unlikely that predator control activities would contribute impacts that would add to those already associated with the proposed action. Currently, Colorado Parks and Wildlife (CPW) is working with recovery program researchers to track the wolverine in order to monitor its movements and activities. In July, 2010 the Parks and Wildlife Commission granted the CPW’s request to begin having conversations about restoring wolverines with CPW’s partners and stakeholders. The CPW is having these discussions with a broad spectrum of user groups, government agencies and other interested people and organizations (CPW 2012a). Therefore, there is potential for future reintroduction of wolverine into Colorado. However, because the timing, location, and probability of reintroduction activities occurring are all unknown, reintroduction of wolverines is not a reasonably foreseeable action.

Determination Based on the analysis discussed above as a sensitive species, it has been determined that, as proposed, this project “May adversely Impact Individuals, but not likely to result in a loss of viability in the planning area, nor cause a trend toward federal listing” of wolverine.

101 Table 3-8. Determination and Conservation Measures Summary

Determination of Effects

Species List Status Alt 1 Alt 2 Alt 3 Alt 4 Alt 5

INSECTS

Great Basin Silverspot butterfly Speyeria nokomis nokomis Sensitive No Impact No Impact No Impact No Impact No Impact

BIRDS

American bittern Botaurus lentiginosus Sensitive No Impact No Impact No Impact No Impact No Impact

American peregrine falcon Falco peregrinus anatum Sensitive No Impact No Impact No Impact No Impact No Impact

Bald eagle Haliaeetus leucocephalus Sensitive No Impact No Impact No Impact No Impact No Impact

Black swift Cypseloides niger Sensitive No Impact No Impact No Impact No Impact No Impact

Boreal owl Aegolius funereus Sensitive No Impact MAII MAII MAII MAII

Brewer’s sparrow Spizella breweri Sensitive No Impact No Impact No Impact No Impact No Impact

Burrowing owl Athene cunicularia Sensitive No Impact No Impact No Impact No Impact No Impact

Columbian sharp-tailed grouse Tympanuchus phasianellus columbianus Sensitive No Impact No Impact No Impact No Impact No Impact

Ferruginous hawk Buteo regalis Sensitive No Impact No Impact No Impact No Impact No Impact

Flammulated owl Otus flamineolus Sensitive No Impact No Impact No Impact No Impact No Impact

Gunnison sage-grouse Candidate Centrocercus minimus Sensitive No Impact No Impact No Impact No Impact No Impact

Lewis’ woodpecker Melanerpes lewis Sensitive No Impact No Impact No Impact No Impact No Impact

Loggerhead shrike Sensitive No Impact No Impact No Impact No Impact No Impact

102 Determination of Effects

Species List Status Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Lanius ludovicianus

Mountain plover Charadrius montanus Sensitive No Impact No Impact No Impact No Impact No Impact

Northern goshawk Accipter gentiles Sensitive No Impact MAII MAII MAII MAII

Northern harrier Circus cyaneus Sensitive No Impact No Impact No Impact No Impact No Impact

Olive-sided flycatcher Contopus borealis Sensitive No Impact MAII MAII MAII MAII

Sage sparrow Amphispiza belli Sensitive No Impact No Impact No Impact No Impact No Impact

White-tailed ptarmigan Lagopus leucurus Sensitive No Impact No Impact No Impact No Impact No Impact

Yellow-billed cuckoo Candidate Coccyzus americanus Sensitive No Impact No Impact No Impact No Impact No Impact

MAMMALS

American marten Martes Americana Sensitive No Impact MAII MAII MAII MAII

Desert bighorn sheep Ovis canadensis nelsoni Sensitive No Impact No Impact No Impact No Impact No Impact

Fringed myotis Myotis thysanodes Sensitive No Impact No Impact No Impact No Impact No Impact

Gunnison’s prairie dog Cynomys gunnisoni Sensitive No Impact No Impact No Impact No Impact No Impact

Hoary bat MAII MAII MAII MAII Lasiurus cinereus Sensitive No Impact

New Mexico jumping mouse Candidate Zapus hudsonius luteus Sensitive No Impact No Impact No Impact No Impact No Impact

Pygmy shrew Sorex hoyi Sensitive No Imact MAII MAII MAII MAII

River otter Lontra canadensis Sensitive No Impact No Impact No Impact No Impact No Impact

103 Determination of Effects

Species List Status Alt 1 Alt 2 Alt 3 Alt 4 Alt 5

Rocky Mountain bighorn sheep Ovis canadensis canadensis Sensitive No Impact MAII MAII MAII MAII

Spotted bat Euderma maculatum Sensitive No Impact No Impact No Impact No Impact No Impact

Townsend’s big-eared bat Corynorhinus townsendii townsendii Sensitive No Impact No Impact No Impact No Impact No Impact

White-tailed prairie dog Cynomys leucurus Sensitive No Impact No Impact No Impact No Impact No Impact

Wolverine Candidate Gulo gulo luscus Sensitive No Impact MAII MAII MAII MAII

MAII- May Impact (May Impact Individuals or habitat, but is not likely to cause a trend towards Federal listing or loss of viability in the planning area) BI - Beneficial Impact LI - Likely Impact (Likely to result in a trend towards federal listing or a loss of viability in the planning area)

Management Indicator Species The 1982 Planning Rule 36 CFR 219.19(a)(6) related to Management Indicator Species (MIS) requires the Forest Service to produce a unique list of species to represent Forest communities or ecosystems. These species and the ecosystems which they represent must be considered for each project to evaluate consistency with the Forest Plan. The GMUG and RGNF have a combined total of 21 management indicator species (MIS). Eight species would be potentially affected by project activities due to habitat and management associations, and are analyzed for project effects. The MIS evaluated in detail for this analysis include: brown creeper, hermit thrush, northern goshawk, red-naped sapsucker, vesper sparrow, American marten, elk, and mule deer. The remaining species will not be affected by project activities, due to the lack of project-generated effects on these habitat types. This analysis is disclosed in Table For avian MIS, project level population information is an estimate of potential densities, based on species biology and suitable habitat that is presumed to be occupied. Because MIS were recently amended into the RGNF Forest Plan and avian MIS surveys specific to the Forest were only initiated in 2004, available trend data is derived from existing sources, such as the Rocky Mountain Bird Observatory (RMBO) Monitoring Colorado Birds (MCB) program, the Colorado Land Bird Conservation Plan, and the Colorado Breeding Bird Atlas project, which are currently the primary sources of multi-year monitoring data. Until Forest-wide trend data are established via Forest-wide monitoring protocols, avian MIS population data at the Forest level are of necessity, estimated from known acreages and distributions of habitat types and structural associations, and species habitat affinities, but are considered within the context of available trend data at larger scales. Project level surveys documented species presence and habitat occupancy.

104 For deer and elk, population trends are tracked by the Colorado Division of Wildlife at the Data Analysis Unit level.

Brown Creeper (RGNF)

Existing Condition Suitable habitat for the brown creeper on the RGNF occurs within mid to high elevation coniferous forests, particularly in late-successional mixed-conifer and spruce-fir habitat associations. Existing potential habitat in these two forest cover types occurs on approximately 634,000 acres, or about 51% of total forested land base. Studies conducted locally indicate that the brown creeper exhibits a strong preference for late- successional spruce-fir cover types. Brown creepers have also been noted in low densities in aspen stands on the Forest, where they occur in larger-sized stands in the mid to older structural stages. This association with older forest stands is due to their requirement for snags in the latter stages of decay and large live trees for foraging. The brown creeper has a moderately high relative abundance throughout its global range, but is found in relatively low abundance in the Southern Rocky Mountains. Its global population trend indicates a stable or undetectable population trend. Breeding Bird Survey trend data for the brown creeper from 1966 to 2002 suggests a slow population increase continent-wide, with a larger increase in Colorado and surrounding states. Local breeding population trends indicate a stable to slightly increasing trend within the Southern Rockies-Colorado Plateau Bird Conservation Region. Brown creepers have been located on all districts of the Forest and the current information suggests that they are widely distributed and present wherever suitable habitat occurs. On the RGNF, the brown creeper is an indicator of late-successional conditions (Habitat Structural Stage 4B, 4C, and 5) within the spruce-fir and white-fir/Douglas-fir Land Type Associations. Other species that may be represented by brown creepers include the boreal owl, northern three-toed woodpecker, pine grosbeak, golden-crowned kinglet, hermit thrush, ruby- crowned kinglet, olive-sided flycatcher, Clark’s nutcracker, Hammond’s flycatcher, red squirrel, southern red-backed vole, snowshoe hare, Canada lynx, elk, and hoary bat. Risk factors considered in this analysis include reductions in the large green tree component required for foraging substrate, reductions in the type of snag component required for nesting, reductions in canopy closure and downed woody material, and disruptions in the natural disturbance processes, such as insects and disease factors, which create and maintain habitat components.

Environmental Consequences Alternative 1 There would be no direct or indirect effects to brown creeper from management activities, as no treatments would occur under this alternative.

105 densities within the project area are unknown, but treatment associated with 0.13% of available habitat is not expected to measurably reduce snag densities at the project level. At the Forest level, 3.6 acres of treatment equates to 0.0006% of available habitat. Therefore, the action alternatives are not expected to impact population trend or species viability at the Forest level.

Cumulative Effects Brown creeper breeding territory size ranges up to 16 acres (Hejl et al. 2002). Therefore, the portion of the project area on the RGNF is adequate to assess potential cumulative impacts of other projects. The primary activities of concern for the brown creeper include logging and fuelwood gathering. Past logging activities that have occurred within spruce-fir stands have likely affected local availability of nesting, roosting, and foraging habitats. Past logging in the Saguache RD spruce- fir zone appears to be minimal. No reasonably foreseeable timber harvest activities are identified within the spruce-fir zone of the RGNF. Due to the minor habitat impacts predicted as a result of the CDNST Reroute Project, additional cumulative impacts associated with projects other projects are likely to be insignificant. Other ongoing and foreseeable activities within the CEA include livestock grazing, outfitter/guide and special use permits, and fish habitat improvement projects, none of which are expected to add measurable cumulative effects.

Determination See summary below.

Hermit Thrush (RGNF)

Existing Condition Suitable habitat for the hermit thrush on the RGNF occurs in mid to high elevation coniferous forests, particularly in the mixed-conifer and spruce-fir habitat associations. Existing potential habitat is estimated to occur on approximately 634,000 acres, or about 51% of total forested landbase. Studies conducted locally in spruce-fir and mixed-conifer habitat associations indicate that the hermit thrush exhibits a preference for late-successional but will also frequent sapling-pole sized stands during the latter stages of development. This latter structural stage is defined by trees that vary in size from about 5 to 9 inches DBH and exhibit a canopy closure of greater than 40%. Hermit thrush detected on existing monitoring transects on the Forest achieve their highest densities in spruce-fir habitat types. However, they have also been noted in fairly high densities in aspen stands, where they occur most frequently in larger-sized stands in the mid to older structural stages. This use of aspen may be related to the large amount of spruce-fir inclusions in aspen community types on the Forest. The key habitat components important to hermit thrush include maintenance of patchy understory conditions and coarse woody debris. This association with older forest stands and younger dense stands is due to their requirements for small, dense understory trees for nesting cover and their ground-foraging habits. The hermit thrush as a moderately low relative abundance throughout its global range, but occurs in high relative abundance in the Southern Rockies. It is considered secure globally, although it may be quite rare in portions of its range. BBS trend data for the hermit thrush displays a small population increase continent-wide, but a possible decrease in Colorado and surrounding states. Local breeding population trends indicate a stable or increasing trend.

106 The hermit thrush is considered a common breeder on the Forest and is currently known to occur and reproduce in suitable habitat areas.

Environmental Consequences Alternative 1 There would be no direct or indirect effects to brown creeper from management activities, as no treatments would occur under this alternative.

Environmental Consequences All Action Alternatives Approximately 2,759 acres of mature spruce-fir habitat occurs within the project area. Trail construction activities proposed under all action alternatives would create a clearing 6 feet wide that would impact about 3.6 acres, or 0.13% of available habitat within the project area. Trailhead construction sites proposed under Alternatives 2 and 5 are located outside suitable habitat. The narrow treatment area would preclude impacts to habitat at the stand level. Disturbance could occur from human activities associated with timber and prescribed fire activities. Some nest destruction could occur with the removal of dead trees. Existing snag densities within the project area are unknown, but treatment associated with 0.13% of available habitat is not expected to measurably reduce snag densities at the project level. At the Forest level, 3.6 acres of treatment equates to 0.0006% of available habitat. Therefore, the action alternatives are not expected to impact population trend or species viability at the Forest level.

Cumulative Effects Hermit thrush breeding territory size ranges up to about 6 acres (Montana Field Guide 2012). Therefore, the portion of the project area on the RGNF is adequate to assess potential cumulative impacts of other projects. The primary activity of concern for the hermit thrush is timber harvesting. Past logging activities that have occurred within spruce-fir stands have likely affected local availability of nesting, roosting, and foraging habitats. Past logging in the Saguache RD spruce-fir zone appears to be minimal. No reasonably foreseeable timber harvest activities are identified within the spruce-fir zone of the RGNF. Other ongoing and foreseeable activities within the CEA include livestock grazing, outfitter/guide and special use permits, and fish habitat improvement projects, none of which are expected to add measurable cumulative effects.

Determination See summary below.

Northern Goshawk (GMUG)

Existing Condition On the GMUG, 110 active, alternate or suspected goshawks nests have been found in mature (4B, 4C habitat structural stages) aspen, aspen/mixed conifer, ponderosa pine, Douglas-fir and lodgepole pine stands. Based on data for 110 nest sites, nest site preference is for larger aspen trees (Vasquez and Spicer 2005). On the Gunnison Ranger District, nest productivity is 1.4 fledges per active nest. Known goshawk nest sites occur predominantly in the 4B and 4C habitat structural stages (60% of nest sites). Nest sites were often found in mature stands as small as two acres in size that were inclusions within a larger sapling/pole or mid-aged (3A, 3B, or 3C) dominated stand. Goshawks appear to select for aspen dominated sites for nesting on the Forest. The aspen cover type comprised 64% of known nest sites. Where nests occurred in spruce-fir dominated stands, mature or senescent aspen trees were often a component of

107 those nest sites and nests were typically in aspen trees. There have been no documented occurrences of goshawk nests in Engelmann spruce or subalpine fir trees on the Forest. Modeled high quality goshawk nesting habitat totals 547,997 acres (34%) on the GMUG (Vasquez and Spicer 2005). Goshawks appear to be well distributed across the Forest. The majority of goshawk detections and nest sites were documented during goshawk survey efforts, incidentally by Forest Service personal engaged in fieldwork, or by the public. Suitable (primary and secondary) habitat appears to be well-distributed across the Forest, encompassing approximately 79% of the Forest. Primary habitat (high quality) also appears well-distributed, encompassing approximately 34% of the Forest (Vasquez and Spicer 2005).

Environmental Consequences Alternative 1 There would be no direct or indirect effects to goshawks from management activities, as no treatments would occur under this alternative.

Environmental Consequences All Action Alternatives Approximately 299 acres of mature aspen occurs within the project area. The amount of habitat affected by trail clearing activity totals 0.4 acre under all action alternatives representing about 0.01% of habitat available within the project area. The narrow configuration of the trail corridor (6 feet wide) is expected to preclude stand-level changes in goshawk habitat suitability and is unlikely to influence existing goshawk use patterns. Trailhead construction at the State Highway 114 site would occur within modeled goshawk habitat, but the site’s location being directly adjacent to a State highway reduces the potential for use by nesting goshawks. The Luder’s Creek trailhead is located outside suitable habitat. Some removal of snags or trees outside the trail clearing limits may occur to provide for safety. This may affect availability of cavity nesters as prey locally, but the small size of the affected area makes it unlikely that snag removal will impact prey abundance at the scale of a given goshawk territory. In addition, snags or trees removed for safety reasons would be retained onsite and function as down log habitat for other potential prey. Therefore, trail construction under all action alternatives, as well as trailhead construction under Alternatives 2 and 5, is not expected to measurably impact goshawk habitat availability or use locally. In comparison to the amount of high-quality habitat available on the GMUG (547,997 acres), effects generated by this project on 0.4 acre are immeasurable at the Forest-scale. Therefore, the action alternatives are not expected to impact population trend or species viability at the Forest level.

Cumulative Effects Goshawk home ranges average about 5,400 acres in size. Therefore, the cumulative effects area (CEA) identified for this species extends outside the GMUG portion of the project area at distance of one home range diameter, or 3.3 miles. In total, the CEA accounts for other activities within about 3.5 miles of project activities on the GMUG. The primary activities of concern for goshawks include logging and fuelwood gathering. Past logging activities that have occurred within conifer and aspen stands have likely affected local availability of nesting, roosting, and foraging habitats. On the GMUG, a portion of the Cochetopa Hills Planning Area occurs within the goshawk CEA. The Barnet project may also occur within the CEA. Impacts to goshawks would be analyzed for each of these projects under the NEPA process, with mitigations such as limited operating periods (LOPs) likely required in proximity to active nest sites. In addition, impacts created by the CDNST project would be considered during cumulative effects analysis if this project falls within the goshawk CEAs of those projects listed above. Habitat impacts and additional disturbance effects may result from

108 these other projects and overlap those of the CDNST Reroute project, but due to the minor habitat impacts predicted as a result of the CDNST Reroute Project, additional cumulative impacts are likely to be insignificant.

Determination See summary below.

Red-naped Sapsucker (GMUG)

Existing Condition In Colorado, red-naped sapsuckers forage in aspen, willows and cottonwoods close to their nest sites, which are almost exclusively in mature aspen stands. Typical nest stands, dominated by large aspen, have a variety of diseases that create the heart rot needed for suitable cavity excavation (Kingery 1998). Nest stands have trees infected with shelf or heartwood fungus (for drilling nest cavities) and nearby willow stands (for drilling sap wells). Red-naped sapsuckers have been detected on nine BBS routes on the Forest, with insignificant negative trends observed on three out of four routes within the Uncompahgre Plateau Geographic Area, a significant positive trend observed within the North Fork Valley and Grand Mesa Geographic Areas, and positive upward trends observed on three routes within the Gunnison Basin Geographic Area, one which was significant. Single site analysis on BBS routes within the Forest may not be statistically valid due to low sample sizes and the amount of suitable red-naped sapsucker habitat sampled by the routes: from 1966 to 2004, only 0.92 percent (6,806 ac) of all aspen habitat on the Forest (738,515 ac) was sampled by the BBS (Vasquez 2004). From 1998 to 2004, Monitoring Colorado’s Birds (MCB; a program implemented by the Rocky Mountain Bird Observatory) detected 186 red-naped sapsuckers on 25 transects between 1998 and 2004 on the Forest. Most of the observations occurred in aspen and high elevation riparian dominated habitat types. Interestingly, 62 percent of all red-naped sapsucker observations throughout the MCB survey area were on the Forest. Based on MCB data, red-naped sapsuckers appear to be in an upward trend on the Forest. The average number of red-naped sapsuckers per transect range from 2.2 birds in 2001 to 4.15 birds in 2004 (Vasquez 2004). Although red-naped sapsucker populations appear to be stable to increasing at the national, regional, and forest levels, their habitats have and continue to be impacted by land management activities. On the GMUG, some aspen stands are susceptible to conifer invasion and there is little aspen regeneration, which is likely attributed to fire suppression. Over half (65%) of the aspen dominated habitats on the Forest are in a mature to older condition and are declining in vigor. While decadent aspen (aspen > 100 yrs old) may be beneficial to red-naped sapsuckers in the short term, lack of regeneration and conversion to conifer dominated aspen stands may adversely affect the species in the long term. Degradation and loss of willow riparian habitat due to livestock and elk use (foraging on aspen seedlings, saplings, and bark feeding) could also reduce habitat for the red-naped sapsucker (Vasquez 2004). Approximately 299 acres of mature aspen stands occur within the project area.

Environmental Consequences Alternative 1 There would be no direct or indirect effects to red-naped sapsucker from management activities, as no treatments would occur under this alternative.

109 Environmental Consequences All Action Alternatives The nest-building through fledging period runs from about May 20 through August 25 for this species (Kingery 1998). Project activities during this time may result in abandonment of nests or alteration of territorial boundaries in the analysis area. Individual nests with eggs or young could be lost during project activities if nesting sapsuckers occur within the trail clearance area. This would most likely be either from nest abandonment due to disturbance, or through direct mortality of nestlings. The amount of habitat affected by trail clearing activity totals 0.4 acres under all action alternatives representing about 0.01% of habitat available within the project area. The narrow configuration of the trail corridor (6 feet wide) is expected to preclude stand-level changes in habitat suitability and is unlikely to influence existing sapsucker use patterns. Trailhead construction at the State Highway 114 site would occur within modeled habitat, but the site’s location being directly adjacent to a State highway reduces the potential for use by nesting sapsuckers. The Luder’s Creek trailhead is located outside suitable habitat. Therefore, trail construction under all action alternatives, as well as trailhead construction under Alternatives 2 and 5, is not expected to measurably impact sapsucker habitat availability or use locally. In comparison to the amount of high-quality habitat available on the GMUG (547,997 acres), effects generated by this project on 0.4 acre are immeasurable at the Forest-scale. Therefore, the action alternatives are not expected to impact population trend or species viability at the Forest level.

Cumulative Effects Territory sizes reported for red-naped sapsuckers in Colorado are small, ranging from one to 6.5 acres (Walters et al. 2002). Therefore, the GMUG-portion of the project area is of sufficient size to analyze cumulative impacts to the species. Conifer encroachment and displacement of aspen is ongoing in some locations due to mainly to fire suppression. Aspen regeneration can be susceptible to damage by livestock grazing and elk use. The project area is located within an active grazing allotment in addition to providing elk summer range; however, the status of impacts to aspen due to livestock and big game use in the project area is unknown. Due to the small area impacted by proposed activities, overlapping impacts to availability of mature aspen from other activities are expected to be insignificant.

Determination See summary below.

Elk (GMUG, RGNF)

Existing Condition In Colorado, elk are generally found above 6,000 feet elevation. They utilize a variety of habitats, which include lodgepole, spruce-fir, Douglas-fir, quaking aspen, and mountain shrub types in conjunction with high mountain alpine meadows and lower elevation meadows and pastures, depending on the season. Elk require a combination of open meadows for foraging and woodlands for hiding cover, calving and thermal regulation. The use of open areas by elk tends to decrease 110 yards (100 m) from the forest edge. Slopes from 15-30% are preferred. Ideal winter range includes north and northeast slopes consisting of densely wooded lowlands for cover, combined with south and southwest facing slopes for foraging opportunities. High quality transitional range usually includes meadows or pasture, aspen groves, and other woodland types that provide high quality forage enabling elk to gain weight prior to winter.

110 Open water availability is important in association with the habitat types described (Vasquez and Spicer 2005). Elk populations are intensively monitored by Colorado Parks and Wildlife (CPW). Annual harvest and census data is used to estimate elk populations within specified geographic areas known as data analysis units (DAUs). Several DAUs overlap the boundaries of the Forests while some occur entirely within Forest boundaries. The GMUG contains either all or at least a portion of nine elk DAUs while the RGNF contains all or portions of four DAUs. Population estimates from 1980 to 2003 indicates an overall increase in elk numbers across DAUs that occur on the GMUG. In addition, total population estimates for all DAUs combined that include acreage on the Forest have been above population objectives since 1980, although several individual DAUs have been below population objectives at some point during this 23 year period (Vasquez and Spicer 2005, CPW 2012x). All elk DAUs associated with the RGNF are currently at or above CPW population objectives and average approximately 16% above objective (CPW 2012b). Elk herds appear well-distributed across each Forest. The project area is located primarily along the border of DAUs E-25 and E26, with a small amount in the north occurring within E-43. The entire project area according to CPW habitat maps is elk summer range. About 586 acres (7% of project area) occurs within mapped winter range on the GMUG side. About 585 acres of the project area, including portions of the new trail route, is within a mapped elk production area north of Saguache Park on the Saguache RD. The project area is outside severe winter areas and areas mapped as summer concentration.

Environmental Consequences Alternative 1 There would be no direct or indirect effects to elk from management activities, as no treatments would occur under this alternative.

Environmental Consequences All Action Alternatives Proposed trail construction activities under all action alternatives, and trailhead construction under Alternatives 2 and 5, would occur within mapped elk summer range. The trail footprint consisting of the trail plus 6-foot width clearing limits would alter approximately 25 acres of vegetation, equating to much less than 0.003% of available summer range in each affected DAU (Table 3.9). The new trail and trailheads would be located outside elk winter range, summer and winter concentration areas, and production areas. Vegetation changes within the narrow trail corridor as well as trailheads expected to be less than ¼ acre each in size are not expected to impact elk habitat availability locally or at the DAU scale. Trail construction activities as well as subsequent trail use may impact elk behavior and use patterns via disturbance within the project area, which is currently relatively undisturbed. Elk reactions to disturbance may range from flight and short-term avoidance during the summer season to longer-term avoidance throughout the fall in response to increased pressure from hunters using the new trail. In the spring and early summer, trail activity may impact elk calving within the mapped production area above Saguache Park. These effects would generally be limited to the project area. Area affected by increased disturbance equates to less than 1% of available summer range, winter range, winter concentration or production areas within any of the three DAUs (Table 3.9); therefore, project activities may affect elk locally, there are expected to be no discernible changes in population trends at the DAU level.

111 Table 3-9. Elk Seasonal Use Areas and Project Activities within DAUs

Winter Concentration Production DAUs Summer Range Winter Range Area Area

Trail/Trailhead Footprint (% of DAU total)

E -25 0.0012% 0% 0% 0.0012%

E-26 0.0024% 0% 0% 0.0008%

E-43 0.0001% 0% 0% 0%

Project Area (% of DAU total)

E -25 0.48% 0.01% 0% 0.19%

E-26 0.69% 0.15% 0.04% 0.99%

E-43 0.05% 0% 0% 0%

Cumulative effects The cumulative effects analysis area is defined as the associated DAUs described above. Hunting is the primary activity currently influencing elk population numbers. However, the combination of all sources of mortality, potential competition for resources with livestock, roads, recreational activities and other forms of disturbance have not reduced elk numbers sufficiently to meet CPW management objectives for many years. Therefore, none of the action alternatives is expected to have a negative cumulative effect on elk within the analysis area.

Determination See summary below.

Mule Deer (RGNF)

Existing Condition Mule deer are widely distributed in western North America. In Colorado, they occupy various habitats but achieve their highest densities in shrublands that provide abundant browse and cover. Mule deer also use various habitat types on the Forest, with one of the most important being winter range. The acreages and ecological conditions of mule deer winter range habitat overlaps with that described for elk winter range. During the summer, mule deer are generally well distributed across the Forest and occur at various elevations within different plant communities. Most mule deer summer range is in good to excellent condition and displays a static trend. Mule deer have broad diets and are considered to be intermediate feeders rather than browsers or grazers. Deer food habits are primarily influenced by availability of plant species rather than by selection. Diets are highly variable from year to year and between habitat types. Forage sites with an abundance of browse plants are most beneficial to mule deer. The use of browse species varies by season, but is most prevalent during winter and fall. Forbs and some grasses are particularly important during spring and summer. For maximum use by deer, forage areas

112 should have no point farther than 600 feet from the edge of cover and openings should not exceed 30 acres in size. As with elk, roads can influence deer vulnerability and how they utilize available habitats. Optimum use of habitat can be adversely influenced by the presence of open roads, their type and location, and the amount of vehicle use. CPW has the responsibility of managing mule deer populations in the state and has established herd objectives on the Forest based on the same individual DAUs used for elk. These four DAUs have a combined mule deer population objective of 13,500 to 16,500 animals. The mule deer population has fluctuated above and below this objective since the late 1980’s with population estimates ranging from 13,200 to 14,580 animals over the past six years. For 2011, the estimated 13,500 mule deer population is at the lower population objective. The CDNST Reroute project area occurs within DAU-D-26. In 2011, the mean post-hunt population estimate for this DAU was about 3,905 mule deer which is below the population objective of 4,000 to 5,000 animals (CPW 2012c). The limiting factor for the deer herd in this DAU is the quality and composition of winter range (Weinmeister 2008). The RGNF-portion of the project area (3,293 acres) is mapped entirely as mule deer summer range and is outside all winter range and concentration areas.

Environmental Consequences Alternative 1 There would be no direct or indirect effects to mule deer from management activities, as no treatments would occur under this alternative.

Environmental Consequences All Action Alternatives Proposed trail construction activities under all action alternatives, and trailhead construction under Alternatives 2 and 5, would occur within mapped mule deer summer range on the RGNF. The trail footprint consisting of the trail plus 6-foot width clearing limits under all action alternatives would alter approximately 11 acres of vegetation. Trailhead construction proposed under Alternatives 2 and 5 would alter and remove an additional 0.5 acre. Area affected by all proposed activities equates to less than 0.0003% of available summer range in DAU D-26 (Table 3.10). The new trail and trailheads would be located outside deer winter range and concentration areas. Vegetation changes within the narrow trail corridor as well as trailheads expected to be less than ¼ acre each in size are not expected to impact deer habitat availability locally or at the DAU scale. Trail construction activities as well as subsequent trail use may impact deer behavior and use patterns via disturbance within the project area, which is currently relatively undisturbed. Mule deer reactions to disturbance may range from flight and short-term avoidance during the summer season to longer-term avoidance throughout the fall in response to increased pressure from hunters using the new trail. These effects would generally be limited to the project area. Area affected by increased disturbance is less than 1% of available summer range within DAU D-26 (Table 3.10); therefore, project activities may affect mule deer locally, there are expected to be no discernible changes in population trends at the DAU level. Table 3-10. Mule Deer Seasonal Use Areas and Project Activities within DAU D-26.

Winter Concentration DAU Summer Range Winter Range Area

Trail/Trailhead Footprint (% of DAU total)

D -26 0.00025% 0% 0%

113 Project Area (% of DAU total)

D -26 0.57% 0% 0%

Cumulative Effects The cumulative effects analysis area is defined as DAU D-26. Although hunting is a major activity influencing mule deer numbers, habitat generally has the most restricting influence on mule deer populations. The combination of all sources of mortality, limited habitat conditions, roads, recreational activities, loss of winter range due to development, and other forms of disturbance have all had a negative impact on mule deer numbers within the analysis area. Mule deer numbers have also declined in many areas of the West in the face of increasing elk numbers. However, due to the small amount of habitat impacted by this project, overlapping effects with other activities are expected to be insignificant.

Determination See summary below.

Vesper Sparrow (RGNF)

Existing Condition Vesper sparrow is an indicator of the health of upland bunchgrass/shrub communities. The Colorado Breeding Bird Atlas lists the vesper sparrow as the most abundant species in mountain grasslands. Population information from the Breeding Bird Surveys (Sauer 2008) shows an increasing trend for this species in Colorado (Sauer, et al. 2008). Vesper Sparrows showed no evidence of population change either state-wide from 1998-2005 or within the RGNF from 2004-2007 (RMBO 2008). The primary management influences on these communities and associated wildlife species are related to roads and livestock grazing. Primary habitat for vesper sparrows on the RGNF occurs in montane and lower elevation grasslands. These grasslands generally occur between 8,400 and 10,800 feet in elevation (USDA 2003b). Vesper sparrows primarily nest in the Arizona fescue, Thurber fescue and western wheatgrass Land Type Associations (LTA 8, 9, and 12, respectively). Parks, open meadows and open hill sides provide a majority of this species available habitat. They require a home range of approximately 10 acres of suitable habitat per breeding pair (Gillihan 2002). Livestock grazing activities occur on approximately 87% of the Forest’s vesper sparrow habitat (Irwin 2009). The RGNF contains about 351,914 acres of vesper sparrow habitat. Therefore, the Forest could potentially support 35,191 pairs of vesper sparrow and the analysis area 3,309 pair (Irwin 2009). The project area contains approximately 483 acres of grassland vegetation.

Environmental Consequences Alternative 1 There would be no direct or indirect effects to the vesper sparrow from management activities, as no treatments would occur under this alternative.

Environmental Consequences All Action Alternatives The trail footprint would impact less than one acre of grassland habitat suitable for vesper sparrows under all action alternatives. Under Alternatives 2 and 5, the proposed trailhead site at Luder’s Campground would impact an additional 0.25 acre of grassy habitat. Total area

114 impacted translates into about 0.2% of habitat available within the project area and less than 0.0003% of habitat Forest-wide. Considering the small magnitude of habitat impacts, discernible changes in population trends at the Forest level are not expected.

Cumulative Effects The RGNF portion of the project area constitutes the CEA for this species. Prescribed fire, wildfire, drought, conifer encroachment and unauthorized off road vehicle use may all degrade vesper sparrow habitat or destroy nests. Weeds and non-native grasses like cheat grass may also pose future risk for this species. The action alternatives may increase the risk of weeds and non-native grasses becoming established due to increased human and pack animal traffic, but the magnitude of risk is low due to the small portion of habitat affected. Therefore, implementation of any action alternative it is not expected to add measurable cumulative impacts for this species.

Determination See summary below.

MIS Conclusion Summary The analysis has focused on MIS found in the project area and has determined that impacts to MIS habitats and species may be associated with this project under all action alternatives. Although impacts are expected the magnitude of potential impacts is negligible in comparison to Forest-level habitat distribution and availability. The no-action alternative would have no effect on Forest-level population trends and species distribution. All alternatives are determined as having an insignificant effect on population trends and species distribution at the Forest level.

Migratory Birds The Migratory Bird Treaty Act (MBTA) of 1918 was passed to enforce a treaty between the United States, Mexico and Canada primarily due to the concern for poaching of migratory birds. Except as regulated by permit, it is unlawful under the MBTA for anyone at any time, by any means or in any manner, to pursue, hunt, export, import, transport or carry any migratory bird. Until recently, it was maintained that the MBTA was intended to address issues related to the hunting and poaching of migratory birds, but not habitat modification. However, inconsistent interpretations of the MBTA by federal agencies and contradictory rulings by various circuit courts left the issue regarding habitat modification unclear. On January 10, 2001, Executive Order 13186 (EO 13186) was signed and entitled “Responsibilities of Federal Agencies to Protect Migratory Birds”. EO 13186 states that “environmental analysis of Federal actions, required by NEPA or other established environmental review processes, shall evaluate the effects of actions and agency plans on migratory birds, with emphasis on species of special concern.” EO 13186 further directs action agencies to develop and implement a Memorandum of Understanding (MOU) with the U.S. Fish and Wildlife Service (USDA, USDI 2008) that promotes the conservation of migratory birds. This MOU has been developed as a means to reduce the direct, indirect and cumulative effects of land management activities on migratory birds, including those dealing with habitat modification. Direction concerning landbird conservation in Forest Service Region 2 is to reference the 2008 Birds of Conservation Concern list produced by the U.S. Fish and Wildlife Service for Bird Conservation Regions (BCRs) when completing NEPA evaluations for project activities.

115 Furthermore, Forest Service units are encouraged to interface with the State and Bird Conservation Region working groups for actions and objectives to pursue concerning migratory bird conservation. Bird Conservation Regions consist of a hierarchical framework of nested ecological units that allow for the use of multiple scale-specific approaches to on-the-ground management. Bird Conservation Regions encompass areas that become progressively more ecologically similar as the units are stepped-down to a smaller scale. At the smallest and most local scale, the physiographic area is used for bird conservation efforts. State groups such as local Partners-In-Flight chapters are the primary workforce involved with translating the BCR information into conservation action at the local scales.

Existing Condition There are 37 BCRs in North America with four of these occurring at least partially in Colorado. The RGNF occurs within the Southern Rockies Colorado Plateau Bird Conservation Region (BCR 16), which encompasses portions of Colorado, New Mexico, Arizona, Utah and Wyoming. Information from BCR 16 was synthesized for use in Colorado through the development of the Birds of Conservation Concern list (USDI Fish and Wildlife Service 2008 and the Colorado Landbird Conservation Plan (BCP). These Plans have been or are being developed by every state in the nation based on the individual physiographic areas encompassed by the BCR’s. Thus at the finest scale of analysis, the GMUG and RGNF occur within the Southern Rocky Mountains Physiographic Area (Area 62) of the Southern Rockies Colorado Plateau Bird Conservation Region. The following are the Birds of Conservation Concern for BCR 16, their status within the project area, and projected influence from the CDNST Reroute Project (Table 3-11). Table 3-11. FWS Birds of Conservation Concern for BCR 16, occurrence in the Project Area, and anticipated influence of the action alternatives.

Species General Habitat Occurrence in Effect of Action Alternatives Analysis Area

Evaluated as an R2 sensitive Ferruginous species; No Effect (No habitat Hawk Prairie No present)

Bald eagle Mature trees near water No No Effect; (No habitat present)

No Effect; Project activities are not Golden Eagle Cliffs/grasslands No expected to affect this species.

Evaluated as an R2 sensitive Peregrine Falcon Cliffs No species; No Effect.

No Effect. Project area lacks Prairie Falcon Cliffs No suitable nesting habitat.

Evaluated as an R2 sensitive Gunnison sage- species; No Effect. (No habitat grouse Sagebrush No present).

Snowy Plover Shorelines No No Effect. (No habitat present)

116 Species General Habitat Occurrence in Effect of Action Alternatives Analysis Area

Evaluated as an R2 sensitive species; No Effect. (No habitat Mountain Plover Prairie No present).

American bittern Wetlands No No Effect. (No habitat present)

Long-billed Prairies and meadows curlew near water No No Effect. (No habitat present)

Evaluated as an R2 sensitive Yellow-billed species; No Effect. (Species not Cuckoo Deciduous Riparian No present).

Evaluated as an R2 sensitive species. Project activities may impact the species or habitats (see above). No preferred habitat Flammulated Owl Ponderosa pine/snags Possible exists within the project area.

Burrowing Owl Plains/grasslands No No Effect. (No habitat present).

Evaluated as an R2 sensitive Lewis’s Riparian Cottonwood species; No Effect (no habitat Woodpecker and Ponderosa pine No present).

No Effect, (Insufficient habitat Willow flycatcher Willow riparian No present).

Gray Vireo Oak woodlands/scrub No No Effect. (No habitat present).

No Effect. Project activities are not expected to affect this Pinyon Jay Pinyon/Juniper No species.

Juniper titmouse Pinyon/Juniper No No Effect. (No habitat present).

Open forest with Veery shrubby understory No No Effect. (No habitat present).

Bendire’s Thrasher Rare spp. of arid areas No No Effect. (No habitat present).

Grace’s warbler Ponderosa pine No No Effect. (No habitat present).

Brewer’s sparrow Sagebrush No No Effect. (No habitat present).

Grasshopper May impact, but magnitude of sparrow Open grasslands Possible impact is extremely small (1 ac).

117 Species General Habitat Occurrence in Effect of Action Alternatives Analysis Area

Evaluated as an R2 sensitive Chestnut-collared species; No Effect. (No habitat longspur Plains No present).

Black rosy-finch Alpine tundra No No Effect. (No habitat present).

Brown-capped rosy-finch Alpine tundra No No Effect. (No habitat present).

May impact, but magnitude of Cassin’s finch Open coniferous forest Possible impact is extremely small

The Colorado Landbird Conservation Plan (Beidleman 2000) identified priority species and habitats for each physiographic area in the state based on the Partners-In-Flight species prioritization process. Priority habitats identified for the Southern Rocky Mountains Physiographic Area include alpine tundra, aspen, cliff/rock, high elevation riparian, lowland riparian, mixed-conifer, mountain shrubland, ponderosa pine, sagebrush shrubland, spruce-fir, and wetlands. The priority habitats and species that occur within the project area are identified in Table 3-12. Table 3-12. Priority habitats and species of the Southern Rocky Mountains province and their relationship to assessment for the CDNST Reroute Project.

Priority BCP Priority BCP Potential Potential Effect of Alternatives Habitat Species Issues(s) Influence from Project Activities Type

Aspen Broad-tailed Grazing, snag Issues identified. Species expected to occur hummingbird* habitat, Trail and trailhead in the analysis area.

clearing may Minimal influences Red-naped Altered remove a small anticipated on aspen sapsucker* disturbance amount of mature habitat due to the scope of Purple martin regimes aspen. treatments (less than 1 acre affected). Violet-green swallow*

High Cordilleran flycatcher Grazing, Issues identified. No effects expected. Elevation Trail and trailhead American dipper Recreation Riparian clearing may impacts MacGillivray’s remove a small warbler amount of habitat. Wilson’s warbler

Mixed Dusky grouse Altered Issues identified. Species expected to occur Conifer disturbance Trail clearing may in the analysis area. Williamson’s regimes, snags, remove a small Minimal influences sapsucker timber mgmt. amount of habitat. anticipated on mixed conifer habitat due to the

118 Priority BCP Priority BCP Potential Potential Effect of Alternatives Habitat Species Issues(s) Influence from Project Activities Type

scope and spatial configuration of treatments (less than 11 acre affected).

Spruce/Fir Boreal owl Timber mgmt., Issues identified. Species expected to occur snags, altered Trail and trailhead in the analysis area. Olive-sided flycatcher disturbance clearing may Minimal influences Hammond’s regimes remove a small anticipated on habitat due flycatcher amount of habitat. to the scope and spatial configuration of treatments (less than 8 acres affected).

* Species documented in vicinity of CDNST

Environmental Consequences Four of the seven priority habitats identified in the Colorado Landbird Conservation Plan for the Southern Rocky Mountains province (Beidleman 2000) occur within the CDNST Reroute Project Area. Seven priority bird species are documented as occurring in the project vicinity, with other species possible. Trail construction would occur within a small area (less than 0.20 acre) mapped as riparian vegetation, but aerial photograph interpretation shows the area lacks dense willow thickets and standing or flowing water that creates suitable habitat for the associated priority species. Aspen, mixed conifer stands consisting of Douglas-fir and lodgepole pine forest types, and spruce-fir are present within the project area and in trail construction locations. Trail clearing activities would remove trees on approximately 11 acres in mixed conifer, 8 acres in spruce-fir, and less than one acre of mature aspen. In addition, treatments would remove snags representing a hazard to trail traffic. The amount of habitat affected by trail clearing activity represents about 0.01% of mature aspen, 0.4% of available mixed conifer, and 0.3% of spruce-fir habitat within the project area. The narrow configuration of the trail corridor (6 feet wide) is expected to preclude stand-level changes in habitat suitability and is unlikely to influence existing habitat use patterns by associated species. Trailhead construction at the State Highway 114 site would occur within aspen habitat, but the site’s location being directly adjacent to a State highway reduces the potential for use by associated species. The Luder’s Creek trailhead is located outside suitable habitat. Trail and trailhead construction would occur during the breeding period for most associated species in all habitat types present within the project area. An exception would be blue grouse, which are known to nest in aspen-sagebrush areas that do not occur within the project area, but may utilize the project area outside the breeding period. Tree and/or snag removal would directly impact nesting birds if present, causing nest failure or mortality of young. Table 13 shows that breeding habitat and individuals may be affected by project activities for seven of 13 BCR focal species. Primary breeding periods for most affected species range from April/May

119 through July/August. This would overlap the anticipated trail/trailhead construction seasonal timeframe due to the need to accomplish these activities during the snow-free period (estimated early June – end of September). Approximately one-half of the duration and expected amount of project activities would occur in June and July. Activities conducted during the remainder of the work period (August and September) are less likely to impact nesting birds. Therefore, scheduled timing of project activities may still affect but reduces the potential for direct impacts to focal species. Table 3-13. BCR Focal Species and Breeding Periods

Breeding Habitat Potentially Focal Species Affected? Primary Breeding Period Source

Broad-tailed hummingbird Yes (Green trees) Late May - Mid August Calder and Calder 1992

Red-naped sapsucker Yes (Snags) Late May - Early August Walters et al. 2002

Purple martin Yes Mid April - Late July Brown 1997

Violet-green swallow Yes Late May - Early August Brown et al. 2011

Cordilleran flycatcher No Late April - Late July Lowther 2000

American dipper No Late March - Mid August Willson and Kingery 2011

MacGillivray's warbler No Late May - Late July Pitocchelli 1995

Wilson's warbler No Mid June - End of July Ammon and Gilbert 1999

Dusky grouse No Early May - End of August Zwickel and Bendell 2005

Williamson's sapsucker Yes (Snags) Early May - Mid July Dobbs et al. 1997

Boreal owl Yes (Snags) Early April - End of June Hayward and Hayward 1993

Olive-sided flycatcher Yes (Snags) Late April - Early July Altman and Sallabanks 2000

Hammond's flycatcher Yes (Green trees) End of May - Late July Sedgwick 1994

Cumulative Effects Ongoing management activities and insect and disease epidemics will continue to remove additional aspen, mixed conifer and spruce/fir habitats within the affected BCRs.

Determination Because the affected area represents minor portions of available habitats, potential impacts would be restricted to individuals and are not expected to affect local population densities or trends. Due to consideration and analysis of migratory birds as well as expected project implementation scheduling that reduces the potential for direct impacts as described above, the

120 project is consistent with applicable elements of Executive Order 13186 and the USFS-USFWS Memorandum of Understanding to promote conservation of migratory birds.

Plants-Threatened, Endangered or Sensitive Species

Threatened or Endangered Plants An Endangered plant is one that is in danger of extinction throughout all or a significant portion of its range. A Threatened plant is one that is likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range. A Proposed plant is one that has been officially proposed by the U.S. Fish and Wildlife Service (USFWS) for listing as threatened or endangered under the Endangered Species Act (ESA). A candidate plant is one that the USFWS has on file sufficient information on biological vulnerability and threats to support proposals to list it as endangered or threatened. Threatened and Endangered plants are determined and listed by the USFWS in 50 CFR §17 (available online at: http://endangered.fws.gov/). There are presently no reported records or suspected occurrences of Threatened or Endangered plants on the RGNF. Threatened and Endangered plants in Colorado have unique habitats or ranges that do not occur on this Forest. There are also no plants Proposed for listing or Candidates for listing that occur on the RGNF. On the GMUG, the Colorado hookless cactus (Sclerocactus glaucus) is listed as Threatened by the USFWS. This cactus only occurs on the Grand Mesa National Forest portion of the GMUG, far to the northwest of the project and in very different climate and habitat. The trail project is located on the Gunnison National Forest portion of the GMUG. Furthermore, the trail segments are at much higher elevations that the habitat where this cactus occurs. As a result, for this species, consultation with the USFWS is not required. On the GMUG the De Beque phacelia (Phacelia submutica) is listed as Threatened by the USFWS. This annual plant only occurs on two members of the Wasatch Formation, on the Grand Mesa National Forest near the town of De Beque. This plant only occurs below 6,300 ft elevation in that area, far to the northwest of the project and in very different climate and habitat. As a result, for this species, consultation with the USFWS is not required. No Federally listed Threatened or Endangered plant species, no plant species proposed for listing, and no Federal candidate plant species are expected within the project area or in surrounding areas. Therefore, none of these are included in further analysis.

Sensitive Plants The Forest Service (under FSM 2670) defines a Sensitive plant as one that is not presently listed as Threatened or Endangered by the USFWS, but a population viability concern has been identified as evidenced by: 1. Significant current or predicted downward trends in population numbers or density. 2. Significant current or predicted downward trends in habitat capability that would reduce a species' existing distribution. The Regional Forester has identified Sensitive species for the Rocky Mountain Region (R2) (Regional Supplement 2600-2011-1 to FSM 2670). Documented occurrences of Sensitive plants on the RGNF and GMUG came from Forest files, Forest Service personnel, pertinent literature, and records from the Colorado Natural Heritage Program (CNHP). Then, an evaluation was conducted of the remaining species on the current R2 Sensitive species list to judge the likelihood of occurrence on the RGNF and GMUG. Table 5 displays the species

121 either known or suspected to occur on these National Forests, along with a brief habitat description. Forest Service Sensitive plant species whose habitats are possible within the project area are shown in Table 6. Table 3-14. Species included in further analysis.

Included In Further Scientific Name Analysis Reason for inclusion

Aletes lithophilus (Neoparrya lithophila) No Known habitat is far away and in different climate from project area

Aquilegia chrysantha var. rydbergii No Known habitat is far away and in different climate from project area

Astragalus leptaleus Yes Habitat is possible near trail, near stream crossings

Astragalus missouriensis var. No Known habitat is far away and in humistratus different climate from project area

Astragalus proximus No Known habitat is far away and in different climate from project area

Astragalus ripleyi No Habitat not expected in project area

Botrychium lineare Yes Habitat poorly defined in Subalpine zone

Botrychium paradoxum Yes Habitat poorly defined in Subalpine zone

Braya glabella No No alpine limestone in project area

Calochortus flexuosus No Known habitat is far away and in different climate from project area

Carex diandra No Habitat not expected in project area

Cypripedium parviflorum No Trail locations too dry for this orchid

Draba exunguiculata No Only alpine in project area is well above trail

Draba grayana No Only alpine in project area is well above trail

Draba smithii No Habitat not expected in project area

Drosera rotundifolia No Habitat not expected in project area

Epipactis gigantea No Habitat not expected in project area

122 Included In Further Scientific Name Analysis Reason for inclusion

Eriogonum brandegei No Habitat not expected in project area

Eriophorum altaicum var. neogaeum No Habitat not expected in project area

Eriophorum chamissonis No Habitat not expected in project area

Eriophorum gracile No Habitat not expected in project area

Gilia sedifolia (Aliciella sedifolia) No Only alpine in project area is will above trail, different geology

Kobresia simpliciuscula No Habitat not expected in project area

Malaxis brachypoda No Known habitat is far away and in different climate from project area

Parnassia kotzebuei No Known habitat is far away and in different climate from project area

Penstemon degeneri No Known habitat is far away and in different climate from project area

Phacelia submutica No Known habitat is far away and in different climate from project area

Physaria pulvinata No Known habitat is far away and in different climate from project area

Ranunculus gelidus No No high alpine in project area, only alpine in project area is will above (R. karelinii) trail

Salix arizonica No Known habitat is far away and in different climate from project area

Salix candida No Habitat not expected in project area

Salix serissima No Known habitat is far away and in different climate from project area

Sclerocactus glaucus No Known habitat is far away and in different climate from project area

Sphagnum angustifolium No Habitat not expected in project area

Sphagnum balticum No Habitat not expected in project area

Thalictrum heliophilum No Known habitat is far away and in different climate from project area

123 Included In Further Scientific Name Analysis Reason for inclusion

Utricularia minor No Habitat not expected in project area

Xanthisma coloradoense Yes Occurrences known near trail, in (Machaeranthera coloradoensis) project area

Astragalus leptaleus (park milkvetch)

Existing Condition Ranked G4/S2 by Colorado Natural Heritage Program, “SH” in Wyoming. Grows “in sedge-grass meadows, swales and hummocks, and among streamside willows. … may often occupy the ecotone between soils saturated with water throughout the growing season and adjacent dry uplands. … occurs on loamy, often calcareous soils …on level to gently sloping ground with no aspect favored. … in relatively drier microsites within riparian zones or wet meadows. Often, it grows in the ecotone between wetlands with standing water or wet meadows that are dominated by Poa pratensis or Juncus/Carex, and adjacent upland communities. The community types that include A. leptaleus are willow-Kentucky bluegrass (Salix geyeriana-Poa pratensis), riparian willow (S. geyeriana-S. boothii), and tufted hairgrass (Deschampsia [cespitosa]). Plants have mostly been reported from open sites but also from partially shaded sites occurs in the montane life zone in Colorado and Wyoming” (Ladyman 2006). Astragalus leptaleus is known from Montana, Idaho, Wyoming, Utah, Colorado, and New Mexico, in several hundred occurrences; most of the numbers are from Idaho. Colorado populations seem to be smaller, but much of the habitat has not been searched for the species, so it is difficult to estimate population numbers and sizes in central and south-central Colorado. Known from four locations in the Gunnison Basin, in streamside swales or mid-seral riparian areas, at elevations below 8,000 ft (Ladyman 2006) – well below the project area. This species is difficult to spot, as it is not conspicuous and shorter than the dense grass in which it grows. So it is possible that it could be found in the project area, although not very likely.

Environmental Consequences All Alternatives & Cumulative Effects Astragalus leptaleus was not found in any of the field investigations of this project, and is unknown from the project area or surrounding areas, so impacts cannot be assessed for direct, indirect or cumulative effects.

Determination Implementation of the action alternatives of this project (Alternatives 2, 3, or 4) will have no impact on Astragalus leptaleus or its habitat.

Botrychium lineare (narrowleaf moonwort)

Existing Condition Ranked G2/S1 by Colorado Natural Heritage Program, and S1 in Wyoming. “Local, in open meadows and on rocky slopes, bare-soil roadsides, and earthen dams, mostly subalpine; straddling the length of the Continental Divide…,” in Colorado, “on grassy slopes,

124 among medium-height grasses, and along edges of streamside forests, at elevations of … 7,900 to 9,500 ft” in Colorado, Wyoming, South Dakota, Montana, Idaho, Oregon, Washington, California, and Utah (Rey-Vizgirdas and Behan 2001, Beatty and others 2003, Popovich and Farrar 2012). Documented locations in the Gunnison Basin include sites that are near the Continental Divide but in much wetter climates (more precipitation, especially snowfall) than the project area (B. Johnston personal data).

Environmental Consequences & Cumulative Effects Botrychium lineare was not found in any of the field investigations of this project, but these are very small plants and difficult to see without considerable field experience with Botrychium. Since it is currently unknown from the project area, impacts are difficult to assess.

Determination Implementation of the action alternatives of this project (Alternatives 2, 3, or 4) may adversely impact individuals, but is not likely to result in a loss of viability in the Planning Area1, nor cause a trend toward federal listing of Botrychium lineare.

Botrychium paradoxum (peculiar moonwort)

Existing Condition Tentatively ranked G2 by NatureServe, and tentatively S1 by Colorado Natural Heritage program; ranked S1 in Wyoming. Known from one site in Wyoming and one recent discovery in Colorado, on Crested Butte, over 50 miles from the project area and in a very different climate. These are small plants, difficult to detect. Since this is a recent record, and there is only one, habitat description is largely unknown for Colorado. Crested Butte is a much wetter climate than the project area, so the species is unlikely to be found in the project area.

Environmental Consequences & Cumulative Effects Botrychium paradoxum was not found in any of the field searches of the project area.

Determination Implementation of the action alternatives of this project (Alternatives 2, 3, or 4) will have no impact on Botrychium paradoxum and its habitat.

Xanthisma coloradoense (Machaeranthera coloradoensis (A. Gray) Osterhout) (Colorado tansy-aster)

Existing Condition In Colorado, elevations range 9,500–12,600 ft (2,895–3,840 m), averaging 11,200 ft (3,420 m). In Wyoming, elevations range 8,300–8,500 ft (2,530–2,590 m). In Colorado, populations of Machaeranthera coloradoensis are often associated with limestone, dolomite, shale, or other

1 The “Planning Area” is the area of the Grand Mesa, Uncompahgre, and Gunnison National Forests ( the area covered by its Forest Plan), and the area of the Rio Grande National Forest (the area covered by its Forest Plan).

125 calcareous substrates. In Wyoming, the species occurs in gravelly places in mountain parks, dry tundra, and on sandstone or limestone outcrops. “Gravelly places in the higher mountain parks and on dry tundra” (Weber and Wittmann 2012). Southeastern Wyoming, central and southwestern Colorado. 25-30 known locations in Colorado, probably 5-8 times that many in fact, in nine counties. 10-15 locations in Wyoming in two counties. Tracked by CNHP as G3/S3, WYNDD as S2. This species has been recently transferred to the genus Xanthisma, with no subspecific taxa allowed (Morgan and Hartman 2003). Known from both the RGNF and GMUG (CNHP, COLO, RM, CS, Morgan & Hartman 2003, Parker 2001, Johnston 2001-2002, Weber and Wittmann 2001ab, Beatty and others 2004, Hartman 2006), endemic, perennial forb of south-central Wyoming and western Colorado (Chaffee, Dolores, Gunnison, Hinsdale, La Plata, Lake, Park, Pitkin, Rio Grande, Saguache, and San Juan Counties) (CNHP 2009). There are documented occurrences on the RGNF in the North Clear Creek area, Grayback Mountain, and in the upper Park Creek drainage. This low, prostrate, mat-plant is found on gravelly sites. It is known to grow on relatively barren slopes and ridges in mountain parks and rock outcrops up to dry tundra. Flowering/Fruiting Period: July-early August/August.

Environmental Consequences There are a number of known locations for this species in the project area (Figure 9). Several known locations are near sections of the existing trail that would be “decommissioned” (obliterated) under Alternatives 2-5. This process would be done by hand, creating barriers and revegetating the trail corridor, perhaps using slash to cover the trail and the revegetation (W. Jackson, personal communication). Under the three action alternatives, there may be some direct effects on plants of this species from this decommissioning activity, if there is some trampling activity outside the trail, or slash is dragged across areas outside the trail; however, these plants are mostly resistant to these activities, so the impacts are expected to be small. In addition, there may also be indirect impacts on plants of Xanthisma coloradoense from new trail construction, as the new trail passes above Monchego Park. Trail construction will be by hand, and involve clearing of vegetation, logs, and rocks from the trail corridor (W. Jackson, personal communication). This may cause a small amount of erosion to flow downward into the populations in the park below (Figure 9). Impacts are expected to be slight, since the populations are separated from the new trail by an existing road.

Cumulative Effects The relevant past, present, and foreseeable future activities for consideration in cumulative effects analysis for this specific Analysis Area include consideration of: (a) livestock grazing in the area, (b) wildlife herbivory, (c) timber harvesting/thinning and wood gathering, (d) recreation, (e) private land development, (f) roads and trails, (g) fire suppression and use, (h) mining, and (i) insect and disease. In the project area and surrounding areas, recreation pressure is expected to increase, whether motorized, mechanized, or non-motorized. Use of trails and roads near populations of Xanthisma coloradoense will likely increase, causing more erosion on these populations. Occasional wandering of people and vehicles off roads and trails will cause some impacts as well, although these are expected to be small, since these plants are somewhat resistant to light trampling. Grazing by livestock has been decreasing steadily over the last few decades, and this trend is expected to continue. However, browsing and grazing by big game – elk, mule deer, and

126 moose – has been increasing over the last decades and will likely continue to increase. We can expect more trampling in these habitats by wild animal species. Impacts on this species from climate change are difficult to predict. A recent assessment of the effects of climate change on Gunnison Basin ecosystems and species rated this species as “presumed stable,” but with low confidence (Neely and others 2011).

Determination Implementation of the action alternatives of this project (Alternatives 2-5) may adversely impact individuals, but is not likely to result in a loss of viability in the Planning Area, nor cause a trend toward federal listing of Xanthisma coloradoense (Machaeranthera coloradoensis). Slight direct impacts are expected from existing trail decommissioning, and small indirect impacts from a building a small section of new trail. These activities, that will not involve any mechanized or motorized equipment, may potentially impact one or two occurrences of this species out of probably more than sixty in the Gunnison and Rio Grande Basins. Recent climate change models indicate little change in this species.

Cultural Resources

Existing Condition/Survey The scope of this analysis focuses on the potential impacts to cultural resources that might be reasonably expected from each alternative. Forest Service policy (FSM 2361.3) requires that all areas slated for ground-disturbing activities, or land which will leave Federal agency control through sale or exchange, be surveyed for cultural resources in order to comply with 36 CFR 800, the National Historic Preservation Act (NHPA) of 1966, as amended, the Archeological Resources Protection Act (ARPA) of 1979, the American Indian Religious Freedom Act (1979) and the Native American Graves Protection and Repatriation Act (1992). Pre-field research indicated that there have been thirteen previous cultural resource inventories within or surrounding the proposed area of potential effect (APE). The RGNF obtained the services of Mountain Heritage Enterprise Unit (MHEU), a USDA Forest Service Enterprise Unit specializing in Heritage Resource Management to perform the required Class III (100%) surveys. MHEU surveyed the APE from August 5 to August 12, 2008, September 3 to September 7, 2008 and August 12 and August 13, 2009. RGNF personnel also surveyed a segment on September 23, 29, and 30, 2010. A total of 787 acres were completely inventoried. This effort also inventoried and analyzed the potential for effect to cultural resources resulting from increased use of previously existing trail segments being incorporated into the CDNST and construction of new trail segments for the CDNST. The APE is defined as areas within 15 meters on either side of the proposed trail segments. During the current inventory, three historic sites and seven historic isolates were identified and recorded. Two sites are recommended not eligible to the National Register of Historic Places (NRHP). One site is recommended eligible to the NRHP. Two previously recorded historic sites with an NRHP eligibility status of needs data, including a linear historic site (Cochetopa Pass Stock Driveway) were noted as in or near the proposed APE. All sites recommended as eligible or need data (unevaluated) will be avoided by project actions and implementation crews will be notified of their locations. Sites and isolates that are recommended as not eligible to the NRHP require no further work.

127 Environmental Consequences All Action Alternatives The following stipulation is assumed to be in effect for all alternatives. All persons associated with operations under this authorization must be informed that any objects or sites of cultural, paleontological, or scientific value such as historic or prehistoric resources, graves or grave markers, human remains, ruins, cabins, rock art, fossils, or artifacts shall not be damaged, destroyed, removed, moved, or disturbed. If in connection with operations under this authorization any of the above resources are encountered, the proponent shall immediately suspend all activities in the immediate vicinity of the discovery that might further disturb such materials and notify the Forest Service authorized officer of the findings. The discovery must be protected until notified in writing to proceed by the authorized officer (36 CFR 800.110 & 112, 43 CFR 10.4). Negative direct effects will be mitigated by avoidance, proper documentation, and the stipulation above According to the 2004 revised regulations [36 CFR 800.4(d) (1)] for Section 106 of the National Historic Preservation Act (16 U.S.C. 470f) the recommended determination for the proposed action is no adverse effects if eligible and unevaluated sites are avoided. Under the implementing regulations of Section 106 of the National Historic Preservation Act (36 CFR 800), sites considered not eligible to the NRHP may be directly affected once adequately recorded, and evaluated. Concurrence was received from the State Historic Preservation Office regarding NRHP eligibility and effect on August 14, 2012. Because of the very low archaeological site potential within the APE, the potential for negative direct, indirect and cumulative effects to identified and unidentified cultural resources is very low. Potential indirect effects from vandalism and illegal collection of cultural resources perpetrated by individuals associated with project activities or trail users is possible under each action alternative, but is unlikely due to the low archaeological site density and visibility. Through avoidance of known resources, and mitigation of any resources discovered through implementation, none of the alternatives considered in this EA would have any effect on any historic, or cultural resources.

Cumulative Effects The loss of archaeological resources has happened in the past and will happen in the future. The cumulative effect is that over time fewer archaeological resources will be available to learn about past human lifeways, to study changes in human behavior through time, and to interpret the past to the public. Heritage resource inventory, recording, evaluating and archiving basic information about each site for future reference serves to partially mitigate potential cumulative effects to heritage resources. In conjunction with the proposed project, previous logging activities, recreation activities such as hunting, and livestock grazing have the potential to cause ground disturbance and lead to cumulative, long term, irreversible adverse effects to heritage resources. However, because the archaeological site potential appears very low within the analysis, the potential for negative cumulative effects is also low.

Native American Cultural/Religious Sites Tribes (list) affiliated with the San Luis Valley were consulted by letters sent in August, 2010. One comment was received from a Tribe during the scoping period. However, based on the no adverse effects determination above, the Tribe has no concerns related to traditional cultural

128 properties. Therefore, it is not believed that and Native American Cultural or Religious Sites will be impacted by any of the proposed action alternatives. Watershed Conditions

Existing Condition The project area for the action alternatives is a corridor along or roughly following the Continental Divide. The Continental Divide is the hydrologic divide that follows a line of high peaks across Colorado separating the watersheds that drain into the river systems that feed the Pacific Ocean and those river systems that drain into the Altantic Ocean including the Gulf of Mexico. In the project area, that ridgeline known as the Cochetopa Hills is formed by a series of rounded or dome-like mountains ranging in elevation from 10,000 ft.to 11,500 ft. The majority of the proposed new trail alignment is above 10,000 ft. in elevation. The project area forms the headwaters to both the Gunnison River Basin and the Rio Grande Basin. In this headwater area there are approximately 13 small tributary sub-watersheds with roughly half connected to the Gulf of Mexico system of rivers and the other half draining into the Pacific Ocean system. Because the proposed trail alignment runs along the upper elevations of the hydrologic divide there are few defined drainage channels bisecting the proposed trail. There is little evidence of surface water flow in the project area because of its relative position within the watershed. Neither are there any indications of wetlands occurring along the proposed trail alignment. This is consistent with the position of the project area within the watershed and the soil types of this area. The proposed small spur trail off of the main proposed ridgeline trail to the Luder’s Creek campground parallels Luder’s Creek. This creek is an ephemeral drainage with associated riparian vegetation adjacent to the drainage. Because of the lack of surface water resources within the project area, water quality concerns and potential effects to water quality are minimal and expected to be non-existent. The Cochetopa Hills area is often referred to the “dry side” of the GMUG National Forest because this area is in somewhat of a rain shadow of the higher San Juan mountains to the west. Precipitation totals for this area range between 16 to 25 inches annually which is about 40 to 60 percent of annual precipitation for Red Mountain Pass2 in the San Juans. The soils in the project area are predominately colluvium type soils with volcanic or tuff parent material. Most are classified as gravelly loams and gravelly sandy loams that have low water holding capacity and are generally well drained (NRCS WebSoilSurvey). There is no evidence of areas that could be considered as wetlands within the project area of the proposed action. Based on soil characteristics and precipitation totals, the project area would not be considered to be highly erosive but could be characterized as moderately erosive. There is little evidence of surface erosion in the project area. These loam and sandy loam soils can erode and “unravel” rapidly when vegetative cover is removed and runoff is concentrated and/or accelerated. This is true for most all soil types and not unique to the project area. Watershed condition for the 6th Level Archuleta Creek HUC where the project area is located is classified as good and in proper functioning condition. This classification is based on the Forest Service Watershed Condition Framework (March, 2011).

2 According to the most recent 6 years of precipitation data from NRCS Snotel monitoring sites for Red Mountain Pass and Cochetopa Pass the average total precipitation for Red Mountain was 43.5 inches and Cochetopa Pass annual total precipitation was 16.5 inches.

129 No Action Environmental Consequences Under the no action alternative, essentially the CDNST would stay on a route that keeps travel on existing roads and trails. Because these roads and trails do not follow the Continental Divde through this area of the Cochetopa Hills they are at lower elevations. As a result, the existing roads and trails are in a different position within the watersheds and they cross several perennial and ephemeral streams as well as traverse some wet meadow areas. It is not known whether these wet meadow areas are wetlands. Some of the stream crossings use culverts to pass surface flows under the roadway, there are others where the stream crossings are fords. Most of these roads used for the CDNST under this no action alternative are user created (i.e., not designed or engineered) low level routes which typically are afforded little maintenance by the Forest Service. These roads receive little vehicle use except during the fall hunting seasons and for the most part create limited watershed damage. Under existing conditions there is some erosion from the road surfaces that results in increased sediment in adjacent creeks, increased turbidity and sediment when vehicles ford streams as well as some damage to wet meadow vegetation and compaction of wet soils in the valley bottoms. Examples of where these conditions exist are; on FR 785 along Lujan Creek, FR 878 along Pine Creek, FR 864.2A along Jakes Creek, and FR 597 along Van Tassel Creek. While there are environmental consequences to water quality and watershed condition in these specific locations, these impacts are somewhat seasonally limited and not considered to be severe under existing conditions. With no action there would be no change to the existing conditions.

Environmental Consequences All Action Alternatives The following stipulation measure will be applied to any of the action alternatives: Use of the Forest Service Region 2 Watershed Conservation Practices Handbook (FSH 2509.25) in the development of the proposed trail alignment, design elements and during construction would aid in maintaining existing watershed condition. These practices which are commonly known as Best Management Practices (BMPs) when incorporated with direction and guidance contained in FSH 2309.18 should ensure minimal effects associated with erosion both during construction and from the use of the trail. Use of FSH 2509.18 and FSH 2509.25 in the development of the proposed trail would be consistent with the direction contained in the Forest Service National Best Management Practices for Water Quality Management on National Forest System Lands (Volume 1: National Core BMP Technical Guide, April 2012) publication. The construction and development of 31.2 miles of trail will expose approximately 11 acres of un-vegetated and compacted watershed area. Because this is a linear feature the exposed area will be a very small (approximately 3 feet wide) relative to the watershed area affected. There is a potential for these types of linear features to concentrate and accelerate runoff thereby increasing erosion on the running surface of the proposed trail. A new parking area adjacent to existing roadways would increase the surface area of exposed and un-vegetated soils, but these areas are actually relatively small to the overall watershed area and Forest Service handbook design/construction techniques can lessen or eliminate potential erosion and runoff impacts.

130 Adherence to Forest Service Handbook (FSH) 2309.18 direction for trail pre-construction planning (Chapter 3), trail development direction (Chapter 20), and trail design elements (Chapter 5) would reduce or eliminate the concentration and/or acceleration of surface runoff from the running surface of the proposed trail. Additionally, because the proposed trail will run along the ridgeline and the variations in slope along the trail would be slight (0 to 10 percent) there is less potential for there to be long segments of steep trail which is more susceptible to erosion. There would be no stream crossings and no identified wetland areas affected by the proposed trail alignment. There is little, to no potential to adversely impact water quality. Construction and development of the proposed trail and new parking area (½ acre) would not affect watershed condition ratings for the 6th level HUC sub-watershed. Proper alignment of the short spur trail down to Luder’s Creek campground is important to avoid impacts to the adjacent drainage and riparian systems. Again, adherence to FSH direction for pre-construction planning should be sufficient to avoid potential adverse effects of a trail adjacent to a stream. The action alternatives are essentially differentiated by minor changes in the allowed mode of travel and ancillary facilities. While these variations differentiate the alternates, they create little change in the effects or consequences of each alternative on watershed conditions. The use on a trail does have the potential to effect erosion potential. As soil becomes compacted there is proportionally less impact from uses; however, when soils aren’t compacted (i.e., loose soils) there is increased erosion potential. Sediment and runoff is most likely to occur during construction. Soils are also more susceptible to erosion when saturated. Horses were found to loosen more soils than hikers or bikers (Wilson and Seney, 1994). Proper trail design and construction which includes flowing trails, constructing on stable soils and avoiding unconsolidated soil minimizes impacts. Wilson and Seney (1994) found no statistically significant difference when measuring biking and hiking effects on sediment runoff (correlates with erosion potential). They found horses caused the most erosion of the trails. They also concluded, "Horses and hikers (hooves and feet) make more sediment available than wheels (motorcycles and off-road bicycles) on prewetted trails and that horses make more sediment available on dry plots as well.” (p.74) They suggested precipitation will cause erosion even without human travel and this factor may significantly outweigh the effects of travel; therefore trail design, construction, and maintenance may be much more important factors in controlling erosion than use type. Goeft and Alder (2001) examined erosion potential on non-motorized trails. They found erosion was influenced by slope, time, and age of trail, but did not show a clear trend for the uses. Bjorkman (1996) demonstrated hardening trail surfaces on non- motorized trails significantly reduced erosion/ sedimentation potential. Field observations by Forest Service personnel on the GMUG indicate that more critical than the mode of travel is the frequency and number of users on a trail. Trails experiencing high volumes of traffic from any form of non-motorized travel can experience down-cutting of the trail and increased erosion over those trail segments with less use. Development of the proposed trail using proper and recommended design elements that appropriately address grade and drainage would be expected to be able to adequately handle all modes of non-motorized trail without adverse impacts to the running surface of the trail or with increased erosion. The installation of vaulted toilet(s) and the decommissioning of a short segment of non- motorized trail would not have a measurable effect on watershed conditions, but it is expected that these types of ancillary actions could be somewhat beneficial to watershed condition. They should help to eliminate or reduce the potential for improper human waste disposal and

131 remediate a small area of un-vegetated and erodible landscape associated with the decommissioned trail segment.

Cumulative Impacts Continued livestock grazing, timber harvest, development on private lands will continue to impact watersheds and local soils at the current levels. These impacts when combined with the proposed trail are not expected to lead to water quality or quantity concerns.

Road/Transportation System

Existing Condition The existing portion of the CDNST spanning from Lujan Pass to Cochetopa Creek follows numerous roads, including administrative routes closed to public motorized use, low standard 4x4 roads, and well established gravel roads. The proposed CDNST reroute would eliminate the vast majority of these roaded sections of the trail, replacing it with single-track along the continental divide. The access routes for either a day hiker or supply drop would remain the same however. The three major roads bisecting this section of trail, both existing and proposed reroute, are as follows: Highway 114, Old Cochetopa Pass Road NN-14, and Saguache Pass Road 787.

Environmental Consequences All Alternatives By and large, the roads used for the existing trail alignment would not change if the CDNST was rerouted as proposed. The roads which are currently open to full sized vehicle that share an alignment with the trail would remain open. The only exception to system route management on the existing trail is a 2.0 mile section of converted road 7872.2D that would be decommissioned, though still legally open to hiker and horse use. Winter use of the area would have no foreseeable change in the scenario of the reroute, as no roads other than highway 114 are plowed for winter access along the trail.

132 Figure 3-15. Road System

133 The roads in the area that are currently used by through-hikers are also used for fishing access, camping, and hunting. Under any of the alternatives, use other than through-hiking would presumably not see an impact by the absence of hikers, horseback riders, or bikers on the CDNST. Part of this is a result of non-competing interests, but it is also affected by the fact that the area is rather sparse during the summer months when the CDNST is actively used. Figure 3-16. Decommission Segment

Cumulative Effects Roads would continue to be used for recreation access and continued current forest management activities. Use may increase in the future due to increased forest access to trail or increased access due to current beetle infestations and the need for additional hauling needs.

Livestock Grazing and Spread of Noxious Weeds

Existing Condition Portions of this project are located within two cattle and horse (C&H) range allotments on the RGNF: 1) Spanish Creek allotment, and 2) Saguache Park allotment. There are approximately 8 miles in the Spanish Creek allotment and 6 miles in the Saguache Park allotment. The following permittees hold grazing permits on the aforementioned allotments:

134 Table 3-15. Grazing allotments and permittees in the analysis area.

Permittee: Allotment: Authorized Numbers: Status: Available season:

Gary and Alice Hill Spanish Creek 126 cow/calf pairs Term 06/01-10/15

Coleman Ranches Inc. Spanish Creek 126 cow/calf pairs Term 06/01-10/15

/LD Ranch Corp. Saguache Park 530 cow/calf pairs Term 06/01-10/05 2 horses 05/01-10/30 Gary and Alice Hill Saguache Park 415 cow/calf pairs Term 06/01-10/05 2 horses 05/01-10/30 Flying X Cattle Co. Saguache Park 516 cow/calf pairs Term 06/01-10/05 2 horses 05/01-10/30 Edwin and Anne Nielsen Saguache Park 49 cow/calf pairs Term 06/01-10/05 1 horse 05/01-10/30 Howard Funk Saguache Park 50 cow/calf pairs Term 06/01-10/05 1 horse 05/01-10/30 Cuervo Land and Cattle Saguache Park 230 cow/calf pairs Term 06/01-10/05 3 horses 05/01-10/30

The Spanish Creek and Saguache Park C&H allotments are grazed using rotational grazing strategies. Annual grazing plans are developed every spring. Livestock are controlled using a variety of management techniques including standard barbed-wire fences, temporary electric fences, riding/herding, salting and livestock behavior. A number of range improvements are located on the allotments. While none of these improvements, other than existing fences, are known at this time to be within the proposed CDNST reroute areas, if any are encountered, these improvements need to be protected from disturbance during construction and operation. Several pasture or allotment boundary fences may be encountered along the reroute area. The analysis area on the RGNF has had limited noxious plant inventory due to the remote location. There is a known population of Canada thistle (Cirsium arvense) at the Luder’s Creek campground and downy brome (bromus tectorum) populations along access roadways in the analysis area. These populations are treated annually.

Environmental ConsequencesAll Action Alternatives The following mitigation will be applied to any of the action alternatives: Any fences on the RGNF that require breaching to allow user passage will be modified with properly constructed walk-around structures in addition to gates to minimize the occurrence of gates being left open by hikers. All gates will require proper signage to inform the public to close the gate. The UTM coordinates of all

135 gate locations will be given to the RGNF range specialist for entry into the Forest Service database of record. Maintenance of gates and walk-around structures will be listed as protected improvements and monitored. The proposed trail relocation area currently has minimal existing noxious plant infestations; therefore the most important mitigation will be to minimize new noxious plant seed into the area. Implementation of the following will minimize the introduction of noxious plants to the project area. 1. All equipment/tools used in the project area will be washed and free of noxious plant seed prior to entering the project area. 2. Contractors will be required to certify that their equipment has been properly cleaned prior to entering the project area. It is likely that trail work done using hand tools will not require reseeding. In heavily disturbed sites where there are larger areas of disturbance, such as parking areas and toilet installation areas, reseeding is recommended. All reseeding should be done using a Forest Service approved seed mix. It is recommended that approved seed mixtures from either the Saguache Ranger District or the Gunnison Ranger District be utilized for any needed reseeding. The recommended seed mixture from the RGNF reclamation prescriptions (1998) are attached (see Appendix B). The seed may be broad-cast applied. However, the soil surfaces need to be firm enough to prevent erosion, but loose enough to allow the seed sprouts to penetrate the soil. The seeding should be done by the end of the growing season in which the disturbance takes place. Fall seeding, on snow, is often the best time to seed in the elevations of the project area. Natural materials should be used for erosion and sediment control. Cut brush and or aspen should be used to construct silt and sediment control structures. Engelmann spruce and Douglas-fir should not be used due to the increased risk of bark beetle infestation. Silt fencing has been used on a variety of mining activities on the district and it is often torn down by livestock and wildlife. Natural materials have the additional benefit of not having to be picked up once revegetation has been completed. The proposed project is not anticipated to have any effects on range resources in terms of grazing system, livestock management, forage resources, or access. Potential minor effects from the proposed action that are anticipated include impacts to range improvements and possible increases in noxious plant populations due to ground disturbing activities. Impacts to range improvements Gates are susceptible to being left open by trail users resulting in unplanned livestock movement and possible endangerment of livestock. Noxious plant infestations Ground-disturbing activities create opportunities for infestations of noxious plants. The sources of these plant seeds can be air-born, vehicle-born or transported by wildlife, livestock, or people. Any area where the existing vegetation is removed and bare soil is left exposed creates a potential site for noxious plant infestations. Establishment of a new trail route and the disturbance associated with establishing parking areas and toilets will expose soils, thus

136 providing sites and opportunities for establishment of noxious plants. If mitigated per below, resultant noxious plant levels would not rise above current levels along an established trail and parking areas, and would result in no long term impact.

Cumulative Effects Cumulative effects area is the affected allotments. Continued recreation use on other roads and trails will continue to have minor impacts on livestock management. Timber management and other ground disturbing activities will make the area more susceptible to the spread of noxious weeds. Decommissioning of trail (7872.2D) may also create additional disturbance susceptible to noxious weeds.

137 (Intentionally left blank)

138 CHAPTER 4. CONSULTATION AND COORDINATION The Forest Service consulted the following individuals, Federal, State, and local agencies, tribes and non-Forest Service persons during the development of this environmental assessment: ID TEAM MEMBERS: Jeff Burch – ID Team Leader, Environmental Coordinator, GMUG NF Niccole Mortenson – NEPA Specialist, GMUG Barry Johnston – Botanist, GMUG NF Crystal Powell – Recreation and Lands Program Manager, RGNF Angie Krall – Archaeologist, RGNF Lisa VanAmburg – Rangeland Management Specialist, RGNF Randy Ghormley – Wildlife Staff RGNF Doug Middlebrook –Wildlife Biologist, Gary Shellhorn – Forest Hydrologist, GMUG NF Mary Nelson – Forester, Saguache District Garth Gantt – Engineering Technician, Gunnison District Joe Laughlin – Recreation Trails Technician, Gunnison District OTHER William Apple (Trail Angel)

139 (Intentionally left blank)

140 REFERENCES CITED OR REVIEWED Trail Analysis Baldwin, Malcolm F. 1970. The off-road vehicle and environmental quality. Washington, DC.: The Conservation Foundation. 52 p. Bureau of outdoor Recreation. 1966. Trails for America: report on the nationwide trails study. Washington, DC: United States Department of Interior, Bureau of Outdoor Recreation. 155 p. Bjorkman, A. 1998. Biophysical impacts on and user interactions with mountain bicycle off-road trail corridors. Unpublished Dissertation, University of Wisconsin, Madison. Bjorkman, A. W. (1996). Off-road Bicycle and Hiking Trail User Interactions: A Report to the Wisconsin Natural Resources Board. Wisconsin, Wisconsin Natural Resources Bureau of Research. Cessford, G. R. (1995). Off-road impacts of mountain bikes: a review and discussion Off-Road Impacts of Mountain Bikes: A Review and Discussion Science & Research Series No 92. Wellington, NZ, Department of Conservation. pp: 42-70. Cessford, Gordon. 2003. Perception and reality of conflict: walkers and mountain bikes on the Queen Charlotte Track in New Zealand, Journal for Nature Conservation, Volume 11, Issue 4, 2003, Pages 310-316, ISSN 1617-1381, 10.1078/1617-1381-00062. Chavez, D., P. Winter, et al. (1993). Recreational mountain biking: A management perspective. Journal of Park and Recreation Administration 11 1: 7. Chilman, Kenneth C. 1975. Profile: The trail user. In: Lavely, Philip E. ed. Proceedings, The third national trails symposium. Lake Barkley State Park, KY. USDI Bureau of Outdoor Recreation. 19-31. Chiu, Luke and Kriwoken, Lorne, “Managing Recreational Mountain Biking in Wellington Park, Tasmania, Australia,” Annals of Leisure Research Coello, D. 1989. Vicious cycles? Sierra, 74, 50-54. Cole, D.N. 1981. Vegetational changes associated with recreational use and fire suppression in the Eagle Cap Wilderness Oregon: some management implications. Biological Conservation. 20: 247-270. Cole, D.N. 1983. Assessing and monitoring backcountry trail conditions. Research Paper INT- 303. Ogden, UT: U.S. Department of Agriculture, Forest Service, Intermountain Forest and Range Experiment Station. 10 p. Crockett, Christopher S.1986. “Survey of Ecological Impact Considerations Related to Mountain Bicycle Use on the Edwards Field Trail at Joseph D. Grant County Park, 1986, Santa Clara County (CA) Parks Dept. Edger, C. O. (1997). Mountain biking and Marin Municipal Water District watershed. Trends 34 3: 5. Foin, T.C.,Jr., E. 0. Garton, and C. W. Bowen, C.W. 1977. Quantitative studies of visitor impacts on environments of Yosemite National Park, CA, and their implications for park management policy. Journal of Environmental Management. 5: l-22.

141 Foti, Pam, White, Dave, Brodehl, Grant and Waskey, Troy. 2006. Planning and Managing Environmentally Friendly Mountain Bike Trails: The Southwest Mountain Bike Study http://atfiles.org/files/pdf/Environment-Mountain-Bike-Research-shimano.pdf Fritz, S. C., J. C. Kingston, et al. (1993). Quantitative trophic reconstruction from sedimentary diatom assemblages - A cautionary tale. Freshwater Biology 30(1): 1-23. Goeft, Ute and Alder, Jackie. 2001. “Sustainable Mountain Biking: A Case Study from the Southwest of Western Australia,” Journal of Sustainable Tourism, 9(3):193-211 Gruttz, J. and D. Hollingshead (1995). "Managing the Biophysical Impacts of Off-Road Bicycling" or "Shred Lightly." Environmental Ethics & Practices in Backcountry Recreation Conference, University of Calgary, Alberta. Hammit, W. E. and D. N. Cole, 1998. Wildland Recreation: Ecology and Management. New York, John Wiley and Sons, Inc. Hellmund, P. C., 1998. Planning Trails with Wildlife in Mind: A Handbook for Trail Planners. Denver, Colorado State Parks. Hendricks, W. W. 1997. Mountain bike management and research: An introduction. Trends, 34(3), 2-4. Herrero, Jake, and Stephen Herrero, 2000. Management Options for the Moraine Lake Highline Trail: Grizzly Bears and Cyclists. Unpublished Report for Parks Canada. James, George A. and Hans Schreuder. 1971. Estimating recreation use on the San Gorgonio Wilderness. Journal of Forestry. 69: 490-493. Kasworm, W. F. and T. L. Monley (1990). Road and trail influences on grizzly bears and black bears in northwest Montana. Bears: Their Biology and Management: Proceedings of the 8th International Conference, Victoria, B.C., International Association for Bear Research and Management. Knight, R. L. and D. N. Cole (1991). Effects of recreational activity on wildlife in wildlands. Transactions of the North American Wildlife and Natural Resource Conference. Kottke, Marvin W. 1980. Factors influencing the probability and frequency of participation in cross-country skiing by Northeastern households. In: Proceedings, North American -symposium on dispersed winter recreation. St. Paul, MN. Educational Series 2-3. Agricultural Extension Service, University of Minnesota. 47-51. Krumpe, Edwin E. and Perry J. Brown. 1982. Redistributing backcountry use through information related to recreation experiences. Journal of Forestry. 80(6): 360-362,364. LeChevallier, M. W., M. Abbaszadegan, et al. (1999). Committee report: Emerging pathogens - viruses, protozoa, and algal toxins. Journal American Water Works Association 91(9): 110-121. Leonard, Raymond E. and A. M. Whitney. 1977. Trail transect: a method for documenting trail changes. Research Paper NE-389. Broomall, PA: USDA Forest Service, North eastern Forest Experiment Station. 8 p. Leonard, Raymond E., J. L. McMahon, and K. M. Kehoe. 1985. Hiker trampling impacts on Eastern forests. Research Paper NE-%. Broomall, PA: USDA Forest Service, Northeastern Forest Experiment Station. 5 p. Leung, Y. F. and J. L. Marion (1996). Trail degradation as influenced by environmental factors: A state-of-the-knowledge review. Journal of Soil and Water Conservation 51(2): 130-136.

142 Liddle, M.J. 1975. A selective review of the ecological effects of human trampling on natural ecosystems. Biological Conservation. 7I : 17-36. Lucas, Robert C. 1971. Hikers and other trail users. In: Recreation Symposium Proceedings. Upper Darby, PA: USDA Forest Service, Northeastern Experiment Station. 113-121. Lucas, Robert C. 1975. Low compliance rates at unmanned trail registers. Research Note INT- 200. Ogden, UT: USDA Forest Service, Intermountain Forest and Range Experiment Station. 6 p. Lucas, Robert C. 1979. Perceptions of non-motorized recreational impacts: a review of research findings. In: Recreational impact on Wildlands Conference Proceedings. Oct. 27-29, 1978. Ittner, Ruth and others, eds. Portland, OR: USDA Forest Service, Pacific Northwest Region. 24- 31. Lucas, Robert C. 1980. Use patterns and visitor characteristics, attitudes, and preferences in nine wilderness and other roadless areas. Research Note lNT-253. Ogden, UT: USDA Forest Service, Intermountain Forest and Range Experiment Station. 89 p. Lucas, Robert C. 1981. Redistributing wilderness use through information supplied to visitors. Research Note INT-277. Ogden, UT: USDA Forest Service, Intermountain Forest and Range Experiment Station, 5 p. Lucas, Robert C. 1983. Low and variable visitor compliance rates at voluntary trail registers. Research Note INT-326. Ogden, UT: USDA Forest Service, Intermountain Forest and Range Experiment Station. 5 p. Lucas, Robert C. 1985. Recreation trends and management of the Bob Marshall Wilderness Complex. In: Wood, James D.,Jr. ed. Proceedings, 1985 Outdoor Recreation Trends Symposium II. Atlanta, GA; USDI National Park Service, Southeast Regional Office. 309-316. Lucas, Robert C. and J. L. Oltman. 1971. Survey sampling wilderness visitors. Journal of Leisure Research. 3(l): 28-42. Lucas, Robert C. and Robert P. Rinehart. 1976. The neglected hiker. Backpacker. 4(l): 35-39. Manning, Robert E. and Charles P. Ciali. 1979. The computer hikes the Appalachian Trail. Appalachia. 43(l): 75-85. Marion, J. L. (2006). Assessing and Understanding Trail Degradation: Results from Big South Fork National River and Recreational Area. USDI, National Park Service. Martin, Bumham H. and Dorthy T. Taylor. 1981. Informing backcountry visitors--a catalog of techniques. Gorham, NH: Appalachian Mountain Club Research Department. 104 p. McCay, Roger E. and George H. Moeller, George H. 1976. Compatibility of Ohio trail users. Research Note NE-225. Upper Darby, PA; USDA Forest Service, Northeastern Forest Experiment Station. 4 p. McCool, Stephen F. and Brian Curtis. 1980. Sources of conflict among winter recreationists. In: Proceedings, North American symposium on dispersed winter recreation. St. Paul, MN. Educational Series 2-3. Agricultural Extension Service, University of Minnesota. 73-77. McLaughlin, William J. and W. E. J. Paradice. 1980. Using visitor preference information to guide dispersed winter recreation management for cross-country skiing and snowmobiling. In: Proceedings,North American symposium on dispersed winter recreation. St. Paul, MN. Educational Series 2-3. Agricultural Extension Service, University of Minnesota. 64-72.

143 McMahon, G., Gregonis, S. M., Waltman, S. W., Omernik, J. M., Thorson, T. D., Freeouf, J. A., et al. (2001). Developing a spatial framework of common ecological regions for the conterminous United States. Environmental Management, 28(3), 293-316. Meinecke, E. P. (1928). The effect of excessive tourist travel on the California redwood parks. Sacramento, CA: California Department of Natural Resources, Division of Parks. Murray, Judith- B. 1974. Appalachia:1 trail users in the southern national forests: their characteristics, attitudes and management preferences. Research Paper SE-116; USDA Forest Service, Southeastern Forest Experiment Station. 19 p. Papouchis, Christopher M. & Singer, Francis J., & Sloan, William, 2001. "Responses of Desert Bighorn Sheep To Increased Human Recreation," Journal of Wildlife Management, 65(3):573- 582. Peterson, Margaret. 1981. Trends in recreational use of National Forests wilderness. Research Note INT-319. Ogden, UT: USDA Forest Service, Intermountain Forest and Range Experiment Station. 3 p. Pickering CM, Hill W, Newsome D, and Leung Y-F. 2010. Comparing hiking, mountain biking and horse riding impacts on vegetation and soils in Australia and the United States of America. Journal of Environmental Management, 91:551-562. Ream, C. H. 1980. Impact of backcountry recreationists on wildlife: an annotated bibliography. General Technical Report INT-84. Ogden, UT: USDA Forest Service, Intermountain Forest and Range Experiment Station. 62 p. Roggenbuck, J. W. and D. L. Berrier. 1981. Communications to disperse wilderness campers. Journal of Forestry. 79(S): 295-297. Roggenbuck, J. W., D. R. Williams, et al. (1993). Defining Acceptable Conditions in Wilderness. Environmental Management 17 2: 187-197. Schuett, M. A. (1997). State park directors' perceptions of mountain biking. Environmental Management 21(2): 239-246. Schwartz, D. (1994). Over hill, over dale, on a bicycle built for…goo. Smithsonian, 25(3), 74-87. Spray, R. (1986). The mountain bicycle: Friend or foe? In Proceedings of the International Congress on Trail and River Recreation, 31 May – 4 June 1986, edited by S. Seguire, 239-242. Vancouver, B.C.: Outdoor Recreation Council of British Columbia. Schechter, Mordechai and Robert Lucas. 1978. Simulation of recreational use for park and wilderness management. Baltimore: Johns Hopkins University Press, Resources for the Future. Spahr, Robin, 1990. "Factors Affecting The Distribution Of Bald Eagles And Effects Of Human Activity On Bald Eagles Wintering Along The Boise River, 1990," Boise State University Spencer, Edward L., Herbert E. Echelberger. Raymond E. Leonard and Craig Evans. 1980. Trends in hiking and backcountrv use. In: LaPage, Wilbur F., ed.. Proceedings, 1980 National Outdoor Recreation Trends Symposium. Broomall, PA. General Technical Report NE-57. USDA Forest Service, Northeast Forest Experiment Station. 195-198. Stankey, George H. 1973. Visitor perception of wilderness recreation carrying capacity. Research Paper INT-142. Ogden, UT: USDA Forest Service, Intermountain Forest and Range Experiment Station. 61 p. Stankey, George H. 1979. Use rationing in two Southern California wildernesses. Journal of Forestry. 77(5): 347-349.

144 Stankey, George H. and John Baden. 1977. Rationing wilderness use: methods, problems, and guidelines. Research Paper INT-192. Ogden, UT: USDA Forest Service, Intermountain Forest and Range Experiment Station. 20 p. Staub, F. 1984. Backcountry bicycling: Sport or spoil-sport. American Forests, 90(9), 41-41. Suk, T. J., S. K. Sorenson, et al. (1987). The relation between human presence and occurrence of Giardia Cysts in streams in the Sierra-Nevada, California. Journal of Freshwater Ecology 4(1): 71-75. Taylor, Audrey R. and Knight, Richard L. 2003. "Wildlife Responses to Recreation and Associated Visitor Perceptions," Ecological Applications, (2003), 13(4):951-963 Taylor, D. N., K. T. Mcdermott, et al. (1983). Campylobacter Enteritis from untreated water in the Rocky Mountains. Annals of Internal Medicine 99 1: 38-40. Thurston, E., & Reader, R. J. (2001). Impacts of experimentally applied mountain biking and hiking on vegetation and soil of a deciduous forest. Environmental Management, 27(3), 397- 409. Tyser, R. W. and C. A. Worley (1992). Alien flora in grasslands adjacent to road and trail corridors in Glacier National Park, Montana (USA). Conservation Biology 6(2): 253-262. US Environmental Protection Agency. (2005). Level III Ecoregions. Retrieved December 13, 2005, from http://www.epa.gov/wed/pages/ecoregions/level_iii.htm USDA Forest Service. (2003). Americans' participation in outdoor recreation: Results from NSRE (with weighted data). Retrieved May 5, 2003, from http://www.srs.fs.usda.gov/trends/Nsre/Rnd1t13weightrpt.pdf Van der Zande, A. N., J. C. Berkhuizen, H. C. van Latesteijn, W. J. ter Keurs, and A. J. Poppelaars (1984) Impact of outdoor recreation on the density of a number of breeding bird species in woods adjacent to urban residential areas. Biological Conservation 30: 1-39. Vaske, J. J., M. P. Donnelly, et al. (1993). Establishing management standards - Selected examples of the normative approach. Environmental Management 17(5): 629-643. Webber P (Man. Ed.). 2004. Trail Solutions: IMBA's Guide to Building Sweet Singletrack. International Mountain Biking Association: Boulder, CO. White, D.D. and Waskey, M.T. and Brodehl, G.P. and Foti, P.E. 2006. A comparative study of impacts to mountain bike trails in five common ecological regions of the southwestern US. Journal of Park and Recreation Administration, 24:21-41. Wilson, John P. and Seney, Joseph P. 1994. “Erosional Impacts of Hikers, Horses, Motorcycles and Off-Road Bicycles on Mountain Trails in Montana,” Mountain Research and Development, 47(1):77-88.

Wildlife Abele, S.C., V.A. Saab, and E.O. Garton. 2004. Lewis’s woodpecker (Melanerpes lewis): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/lewisswoodpecker.pdf. Adams, R.A. 2003. Bats of the Rocky Mountain West: natural history, ecology, and conservation. University Press of Colorado, Boulder. 289 p.

145 Alexander, K.D. and A.G. Keck. 2011. Draft Uncompahgre fritillary butterfly monitoring, inventory, and mapping: 2010 report and status. Unpublished report. 33pp. Alexander, S.M., N.M. Waters, and P.C. Paquet. 2005. Traffic volume and highway permeability for a mammalian community in the Canadian Rocky Mountains. Canadian Geographer 49: 321-331. Altman, B. and R.Sallabanks. 2000. Olive-sided Flycatcher (Contopus cooperi), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/502. Ammon, E.M. and W.M. Gilbert. 1999. Wilson's Warbler (Cardellina pusilla), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/478. Andrews, R., and R. Righter. 1992. Colorado birds. Denver Museum of Nat. History, Denver, CO. 254 p. Aubry, K.B., G.M. Koehler and J.R. Squires. 2000. Ecology of Canada lynx in southern boreal forests. Pp. 373-396 In L.F. Ruggiero, K.B. Aubry, S.W. Buskirk, G.M. Koehler, C.J. Krebs, K.S. McKelvey, and J.R. Squires, eds; Ecology and Conservation of Lynx in the United States. University Press of Colorado, Boulder, CO. Baldwin, R.A. and L.C. Bender. 2008. Distribution, occupancy, and habitat correlates of American marten (Martes americana) in Rocky Mountain National Park, Colorado. Journal of Mammalogy 89(2): 419-427. Barrett, N.M. 1998. Goshawk. Pp. 116-117 in H.E. Kingery, ed.; Colorado Breeding Bird Atlas. Colorado Bird Atlas Partnership and Colorado Division of Wildlife. 636 p. Beauvais, G.P. and J. McCumber. 2006. Pygmy Shrew (Sorex hoyi): a technical conservation assessment. . USDA Forest Service, Rocky Mountain Region. Accessed online 09/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/pygmyshrew.pdf. Beecham, J.J., C.P. Collins, and T.D. Reynolds. Rocky Mountain Bighorn Sheep (Ovis canadensis): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 09/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/rockymountainbighornsheep.pdf. Beidleman, C.A. (facilitator). 2000. Colorado Partners In Flight Land Bird Conservation Plan. 320 p. Boyle, S. 2006. North American River Otter (Lontra canadensis): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/northamericanriverotter.pdf. Brown, C.R. 1997. Purple Martin (Progne subis), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/287. Brown, C. R., A. M. Knott and E. J. Damrose. 2011. Violet-green Swallow (Tachycineta thalassina), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/014. Bull, E.L. and A.K. Blumton. 1999. Effects of fuels reduction on American martens and their prey. USDA Forest Service, Pacific NW Research Station. Research Note PNW-RN-539. 9p.

146 Buskirk, S.W. 2002. Conservation assessment for the American marten in the Black Hills National Forest, South Dakota and Wyoming. USDA Forest Service, Rocky Mountain Region, Black Hills National Forest, Custer, SD. 51 p. Buskirk, S.W. and L.F. Ruggiero. 1994. American marten in Ruggiero, L.F., Aubry, K. B.; Buskirk, S.W., Lyon, L. J., Zielinski, W.J., tech. eds. 1994. The Scientific Basis for Conserving Forest Carnivores: American Marten, Fisher, Lynx and Wolverine in the Western United States. Gen. Tech. Rep. RM-254. Ft. Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Forest and Range Experiment Station. 184p. Buskirk, S.W., L.F. Ruggiero, K.B. Aubry, D.E. Pearson, J.R. Squires, and K.S. McKelvey. 2000. Comparative ecology of lynx in North America. Pp. 397-417 in L.F. Ruggiero, K.B. Aubry, S.W. Buskirk, S.W., G.M. Koehler, C.J. Krebs, K.S. McKelvey, and J.R. Squires, eds; Ecology and Conservation of Lynx in the United States. University Press of Colorado, Boulder, CO. Calder, W.A. and L.L. Calder. 1992. Broad-tailed Hummingbird (Selasphorus platycercus), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/016. Cassirer, E.F. and A.R.E. Sinclair. 2007. Dynamics of pneumonia in a bighorn sheep metapopulation. Journal of Wildlife Management 71(4): 1080-1088. CDOT (Colorado Department of Transportation). 2012. Annual roadkill reports. Accessed online 9/10/2012 at: http://www.coloradodot.info/programs/environmental/wildlife/data/annual-roadkill- reports. CDOT 2012b. Traffic volume maps. Accessed online 9/10/2012 at: http://dtdapps.coloradodot.info/Otis/MapSearch. CPW (Colorado Parks and Wildlife). 2012a. Wolverines (online fact sheet and information). Accessed online 09/13/2012 at: http://wildlife.state.co.us/WildlifeSpecies/SpeciesOfConcern/Mammals/Pages/Wolverine.aspx. CPW (Colorado Parks and Wildlife). 2012b. Herd management (DAU) plans. Accessed online 09/10/2012 at: http://wildlife.state.co.us/Hunting/BigGame/HerdManagementDAUPlans/Pages/HerdManageme ntDAUPlans.aspx. CPW (Colorado Parks and Wildlife). 2012c. Big game herd statistics. Accessed online 09/10/2012 at: http://wildlife.state.co.us/Hunting/BigGame/Statistics/Pages/Statistics.aspx. Chambers, C. and M. Herder. 2005. Euderma maculatum, Spotted bat. Western Bat Working Group. Accessed online 9/136/2012 at: http://www.wbwg.org/speciesinfo/species_accounts/species_accounts.html. Claar, J.J., N. Anderson, D. Boyd, and others. 1999. Carnivores. Pages 7.1-7.63 in Joslin, G. and Youmans, coordinators. Effects of recreation on Rocky Mountain wildlife: a review for Montana. Commmittee on effects of recreation on wildlife. Montana Chapter Wildlife Society. 307 pp. Clark, T.W., A.H. Harvey, R.D. Dorn, D.L. Genter, and C. Groves, eds. 1989. Rare, sensitive, and threatened species of the Greater Yellowstone Ecosystem. Northern Rockies Conservation Cooperative, Montana Natural Heritage Program, The Nature Conservancy, and Mountain West Environmental Services. 153 pp. Clevenger, A.P., B. Chruszcz, K. Gunson, and J. Wierzchowski. 2002. Roads and wildlife in the Canadian Rocky Mountain Parks – movements, mortality, and mitigation. Final Report to Parks Canada. Banff, Alberta.

147 Collins, C.P and T.D. Reynolds. 2005. Ferruginous hawk: Buteo regalis: a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/ferruginoushawk.pdf. Colorado Division of Wildlife. 2010. Success of the Colorado Division of Wildlife’s Lynx Reintroduction Program. September 17, 2010. http://dnr.state.co.us/newsapp/Press.asp?PressId=6650. Colorado Parks and Wildlife. 2012. Regulations, Chapter 3 – furbearers and small game, except migratory birds. Accessed online 08/20/2012 at: http:// wildlife.state.co.us/SiteCollectionDocuments/DOW/RulesRegs/Regulations/Ch03.pdf. Colorado State Land Board. 2012. Maps and GIS data. Accessed online 09/10/2012 at: http://trustlands.state.co.us/MapsandData/Pages/MapsAndData.aspx. Copeland , J.P. 1996. Biology of the wolverine in central Idaho. MS Thesis, University of Idaho. 138 p. Copeland, J.P. 2007. Seasonal habitat associations of the wolverine in central Idaho. Journal of Wildlife Management 71(7): 2201-2212. Craig, G.R. and J.H. Enderson. 2004. Peregrine falcon biology and management in Colorado, 1973-2001. Colorado Division of Wildlife, Technical Publication No. 43. 80 p. DeMott, S.L. and G.P. Lindsey. 1975. Pygmy shrew, Microsorex hoyi, in Gunnison County, Colorado. Southwestern Naturalist 20(3): 417-418. Dinsmore, S.J. 2003. Mountain plover (Charadrius montanus): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/mountainplover.pdf. Dobbs, R. C., T. E. Martin and C. J. Conway. 1997. Williamson's Sapsucker (Sphyrapicus thyroideus), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/285. Ferland, C. L. 2002. Northern Goshawk (Accipiter gentiles) Surveys, Rio Grande National Forest, U.S. Forest Service, Summer 2002. USDA Forest Service Internal Report, Rio Grande National Forest, Monte Vista, CO.Fitzgerald, J.P., C.A. Meaney and D.M. Armstrong. 1994. Mammals of Colorado. Denver Museum of Nat. History and Univ. of Colorado Press. 467 p. Foreyt. W.J. 1994. Effects of controlled contact exposure between healthy bighorn sheep and llamas, domestic goats, mountain goats, cattle, domestic sheep or mouflon sheep. Biennial Symposium of the Northern Wild Sheep and Goat Council 9: 7-14. Frey, J.K. 2005. Status assessment of montane populations of the New Mexico meadow jumping mouse (Zapus hudsonius luteus) in New Mexico. New Mexico Department of Game and Fish. 74 p. Gaines, W.L., P.H. Singleton, and R.C. Ross. 2003. Assessing the cumulative effects of linear recreation routes on wildlife habitats on the Okanogan and Wenatchee National Forests. Gen. Tech. Rep. PNW-GTR-586. USDA Forest Service, Pacific Northwest Research Station. 79pp. Garde, E., S. Kutz, H. Schwantje, A. Veitch, E. Jenkins, and B. Elkin. 2005.. Examining the risk of disease transmission between wild Dall’s sheep and mountain goats, and introduced domestic sheep, goats, and llamas in the Northwest Territories. Northwest Territories Agricultural Policy Framework, Environment and Natural Resources, Government of the Northwest Territories, Canada. 139 p.

148 Geist, V. Mountain sheep, a study in behavior and evolution. University of Chicago Press. 383 p. George, J.L., D.J. Martin, P.M. Lukacs, and M.W. Miller. 2008. Epidemic Pasteurellosis in a bighorn sheep population coinciding with the appearance of a domestic sheep. Journal of Wildlife Diseases 44(2): 388-403. George, J.L., G.R. Kahn, M.W. Miller, and B. Watkins, eds. 2009. Colorado bighorn sheep management plan, 2009-2019. Colorado Division of Wildlife, Special Report Number 81. 88 p. Gillihan, S.W. 2002. Population data for avian management indicator species on the Rio Grande National Forest. Colorado Bird Observatory. Brighton, CO. 23 p. Gruver, J.C. and D.A. Keinath. 2006. Townsend’s big-eared bat (Corynorhinus townsendii): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/townsendsbigearedbat.pdf. Hall, S. P. and H. E. Legrand Jr. 1989. Element Stewardship Abstract for Peregrine Falcon. The Nature Conservancy. Arlington, Virginia. Hayward, G.D. 1994. Conservation status of boreal owls in the United States. Pp.139-147 in G.D. Hayward and J. Verner, Eds.; Flammulated, boreal and great gray owls in the United States: a technical conservation assessment. USDA For. Serv. Gen. Tech. Rep. RM-253. Fort Collins, CO. Hayward, G.D., P.H. Hayward and E.O. Garton. 1993. Ecology of Boreal Owls in the northern Rocky Mountains, USA. Wildlife Monographs 124:1-59. Heinemeyer, K., J. Squires, and J. Copeland. 2010. Investigating the interactions between wolverines and winter recreation use: 2010 annual report. 42 p. Hejl, S. J., K. R. Newlon, M. E. Mcfadzen, J. S. Young and C. K. Ghalambor. 2002. Brown Creeper (Certhia americana), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/669. Hill, S. 2010. Continental Divide National Scenic Trail Wildlife Survey Project Notes and Recommendations. Unpublished Report. 8 p. Hoffman, R.W. 2006. White-tailed Ptarmigan (Lagopus leucura): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/whitetailedptarmigan.pdf Hoffman, R.W. and A.E. Thomas. 2007. Columbian Sharp-tailed Grouse (Tympanuchus phasianellus columbianus): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/columbiansharptailedgrouse.pdf. Holmes, J.A. and M.J. Johnson. 2005a. Brewer’s Sparrow (Spizella breweri): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/brewerssparrow.pdf Holmes, J.A. and M.J. Johnson. 2005b. Sage Sparrow (Amphispiza belli): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/sagesparrow.pdf. Hornocker, M. G., and H. S. Hash. 1981. Ecology of the wolverine in northwestern Montana. Canadian Journal of Zoology 59:1286-1301.

149 Humphrey, S.R. and T.H. Kunz. 1976. Ecology of a Pleistocene relict, the western big-eared bat (Plecotus townsendii), in the southern Great Plains. Journal of Mammalogy 57: 470-494. Hutto, R.L. 1995. Composition of bird communities following stand-replacement fires in northern Rocky Mountain forests. Conservation Biology 9:1041-1058. Irwin, D.A. 2009. Biological analysis for the South Saguache range management plan (RMP). USDA Forest Service, Rio Grande National Forest. 101 p. Ivan, J. 2011. Putative Canada lynx (Lynx canadensis) movements across Hwy 114 near North Pass, Colorado. Colorado Division of Wildlife. Accessed online 09/14/2012 at: http://wildlife.state.co.us/SiteCollectionDocuments/DOW/Research/Mammals/Publications/Lynx MovementsNearNorthPassColorado.pdf. Keinath, D.A. 2004. Fringed Myotis (Myotis thysanodes): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/fringedmyotis.pdf. Kennedy, P.L. 2003. Northern goshawk (Accipiter gentiles atricapillus): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/northerngoshawk.pdf. Kenvin, D. 1992. Wolverine Study 1992. Colorado Division of Wildlife Report, Unpublished. Colorado Div. Of Wildlife. Monte Vista, CO. 2 p. + tables. Kenvin, D. 1993. Wolverine Study 1993. Colorado Division of Wildlife Report, Unpublished. Colorado Div. Of Wildlife. Monte Vista, CO. 2 p. + tables. Kenvin, D. 1995. San Juan Wolverine Search 1994-1995. Colorado Division of Wildlife Report, Unpublished. Colorado Div. Of Wildlife. Monte Vista, CO. 4 p. + tables. Kingery, H.E. 1998. Colorado Breeding Bird Atlas. Colorado Bird Atlas Partnership and Colorado Div. of Wildl. 636 pp. Kornet , C.A. 1978. Status and habitat use of California bighorn sheep on Hart Mountain, Oregon. MS Thesis, Oregon State University. 49 p. Koehler, G.M. 1990. Population and habitat characteristics of lynx and snowshoe hares in north central Washington. Canadian Journal of Zoology. 68:845-851. Koehler, G. M. and J. D. Brittell. 1990. Managing spruce-fir habitat for lynx and snowshoe hares. Journal of Forestry 88: 10-14. Kolbe, J.A., J.R. Squires, D.H. Pletscher, and L.F. Ruggiero. 2007. The effect of snowmobile trails on coyote movements within lynx home ranges. Journal of Wildlife Management 71(5): 1409-1418. Kotliar, N.B. 2007. Olive-sided flycatcher (Contopus cooperi): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/olivesidedflycatcher.pdf. Krausman, P. R. and R. T. Bowyer. 2003. Mountain sheep (Ovis canadensis and O. dalli). Pp. 1095–1115 in Wild mammals of North America: biology, management, and conservation. 2nd ed. (G. A. Feldhamer, B. C. Thompson, and J. A. Chapman, eds.). Johns Hopkins University Press, Baltimore, Maryland. Krausman, P. R.,and D. Shackleton. 2000. Bighorn Sheep. Pages 517-544 in S. Demaris and P. Krausman, eds. Ecology and management of large mammals in North America. Prentice-Hall, Inc. New Jersey.

150 Levad, R. 1998. Peregrine Falcon. Pp. 128-129 in H.E. Kingery, ed.; Colorado Breeding Bird Atlas. Colorado Bird Atlas Partnership and Colorado Division of Wildlife. 636 p. Linkhart, B.D, R.T. Reynolds, and R.A. Ryder. 1998. Home range and habitat of breeding flammulated owls in Colorado. Wilson Bulletin 110(3): 342-351. Long, C.A. 1972. Notes on habitat preference and reproduction in pigmy shrews, Microsorex. The Canadian Field-Naturalist 86:155-160. Lowther, P.E. 2000. Cordilleran Flycatcher (Empidonax occidentalis), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/556b. Luce, R.J. and D. Keinath. 2007. Spotted Bat (Euderma maculatum): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/spottedbat.pdf. McCallum, D.A. 1994. Review of technical knowledge: Flammulated Owls. Pp. 14-46 in Flammulated, Boreal, and Great Gray Owls in the United States-a technical conservation assessment. U.S. Forest Service General Technical Report. RM-253. McDonald, D., N.M. Korfanta, and S.J. Lantz. 2004. The Burrowing Owl (Athene cunicularia): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/12/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/burrowingowl.pdf. McQuivey, R. P. 1978. The desert bighorn sheep of Nevada. Nevada Department Fish and Game Biological Bulletin No. 6, Reno, NV. 81pp. Missoula, MT.Meaney et al. 2006 kit fox Montana Field Guide. 2012. Hermit thrush - Catharus guttatus. Montana Natural Heritage Program and Montana Fish, Wildlife and Parks. Retrieved on September 10, 2012, from http://FieldGuide.mt.gov/detail_ABPBJ18110.aspx. Mowat, G., G. Poole, and M. O’Donoghue. 1999. Ecology of lynx in northern Canada and Alaska, Chapter 9 in USDA Forest Service Gen. Tech. Rep. RMRS-GTR-30. Mowat, G., Poole, K.G., O’Donoghue, M., 2000. Ecology of lynx in northern Canada and Alaska. Pp. 265-306 In: Ruggerio, L.F., Aubry, K.B., Buskirk, S.W., Koehler, G.M., Krebs, C.J., McKelvey, K.S., Squires, J.R. (Eds.), Ecology and Conservation of Lynx in the United States. University of Colorado Press, Boulder, Colorado. Navo, K.W. 2003. Data extracted for the Rio Grande National Forest concerning local bat occurrences. Colorado Division of Wildlife. Monte Vista, CO. NRCS (Natural Resource Conservation Service). 2012. SNOTEL data site, Cochetopa Pass, Colorado. Accessed online 08/23/2012 at: http://www.wcc.nrcs.usda.gov/nwcc/site?sitenum=1059&state=co. Pitocchelli, Jay. 1995. MacGillivray's Warbler (Geothlypis tolmiei), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/159. Raphael, M.G. and L.L.C. Jones. 1997. Characteristics of resting and denning sites of American martens in central Oregon and western Washington. Pp. 146-165 in G. Proulx et al., Eds; Martes: taxonomy, ecology, techniques, and management. Prov. Museum of Alberta. Edmonton, Canada. Reynolds, R.T. and B.D. Linkhart. 1992. Flammulated owls in ponderosa pine: evidence of preference for old growth. Pp. 166-169 in M. Kaufmann, W. Moir and R. Bassett, eds.; Old-

151 growth forests in the southwest and Rocky Mountain regions. USDA For. Serv. Gen. Tech. Rep. RM-213. Reynolds, R.T., and B.D. Linkhart. 1992. Flammulated Owls in ponderosa pine: evidence of preference for old growth. Pp. 166-169 in Old-growth forests in the Southwest and Rocky Mountain regions, Proc. of a workshop. U.S. Forest Service General Technical Report. RM-213. Ruediger, B., J. Claar, S. Gniadek, B. Holt, L. Lewis, S. Mighton, B. Naney, G. Patton, T. Rinaldi, J. Trick, A. Vandehey, F. Wahl, N. Warren, D. Wenger, and A. Williamson. 2000. Canada lynx conservation assessment and strategy (2nd. Edition). USDA Forest Service, USDI Fish and Wildlife Service, USDI Bureau of Land Management, and USDI National Park Service. Forest Service Publication #R1-00-53, Missoula, MT. Reynolds, R.T., R.T. Graham, M.H. Reiser, R.L. Bassett, P.L. Kennedy, D.A. Boyce, Jr., G. Goodwin, R. Smith, and E.L. Fisher. 1992. Management recommendations for the northern goshawk in the southwestern United States. USDA Forest Service Gen. Tech. Rep. RM-217. 90 p. RMBO. 2008. Rocky Mountain Bird Observatory. Population densities and trend detection of avian management indicator species on the Rio Grande National Forest. Technical Report # M- MCB-USFS08-03 Brighton, CO. Romin, L.A. and J.A. Muck. 1999. Utah field office guidelines for raptor protection from human and land use disturbances. USFWS Utah Field Office, Salt Lake City. 42 p. Rudolph, K.M., D.L. Hunter, R.B. Rimler, E.F. Cassirer, W.J. Foreyt, W.J. DeLong, G.C. Weiser, and A.C.S. Ward. 2007. Microorganisms associated with pneumonic epizootic in Rocky Mountain bighorn sheep (Ovis canadensis canadensis). Journal of Zoo and Wildlife Medicine 38(4): 548-558. Rudolph, K.M., D.L. Hunter, W.J. Foreyt, E.F. Cassirer, R.B. Rimler, and A.C.S. Ward. 2003. Sharing of Pasteurella spp. Between free-ranging bighorn sheep and feral goats. Journal of Wildlife Diseases 39(4): 897-903. Ruggiero, L.F., K.B. Aubry, S.W. Buskirk, L.J. Lyon, W.J. Zielinski. 1994. The scientific basis for conserving forest carnivores: American marten, fisher, lynx, and wolverine in the Western United States. USDA Forest Service General Technical Report RM-254. Schommer, T. and M. Woolever. 2001. A process for finding management solutions to the incompatibility between domestic and bighorn sheep. USDA Forest Service. 62 pp. Sedgwick, J.A. 1994. Hammond's Flycatcher (Empidonax hammondii), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/109. Seglund, A.E. and P.M Schnurr. 2010. Colorado Gunnison’s and white-tailed prairie dog conservation strategy. Colorado Division of Wildlife, Denver, Colorado. 218 p. plus appendices. Selby, G. 2007. Great Basin Silverspot Butterfly (Speyeria nokomis nokomis [W.H. Edwards]): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/12/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/greatbasinsilverspotbutterfly.pdf. Shenk, T.M. 2006. Wildlife Research Report: Canada Lynx Reintroduction. Colorado Division of Wildlife, Ft. Collins, CO. Shenk, T.M. 2009. Lynx Update, May 25, 2009. Colorado Division of Wildlife, Ft. Collins, CO.

152 Slater, G.L. and C. Rock. 2005. Northern Harrier (Circus cyaneus): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/12/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/northernharrier.pdf. Squires, J.R. 2000. Food habits of northern goshawks nesting in south central Wyoming. Wilson Bulletin 112: 536-539. Sauer, J.R., J.E. Hines, and J. Fallon. 2008. North American Breeding Bird Survey. http://www.mbr-pwrc.usgs.gov/bbs/bbs.html Theobald, D.M. 2011. Areas of high habitat use from 1999-2010 for radio-collared Canada lynx reintroduced to Colorado. Accessed online 9/12/2012 at: http://wildlife.state.co.us/Research/Mammal/Lynx/Pages/Lynx.aspx. Thompson, R.W., T.J. Watts, and J.C. Halfpenny. 1992. Wolverine study in the vicinity of the proposed East Fork Ski Area. Report prepared for the East Fork Joint Venture by Western Ecosystems, Inc. Boulder, CO. 21 p. + maps and tables. Travsky, A. and G.P. Beauvais. 2004. Species assessment for bald eagle (Haliaeetus leucocephalus) in Wyoming. USDI BLM, Wyoming State Office, Cheyenne. 40 p. USDA APHIS. 2005. Final environmental assessment, predator damage control in Colorado. 163 p. USDI Fish and Wildlife Service. 1984. American Peregrine Falcon Recovery Plan (Rocky Mountain/Southwest Population). Prepared in cooperation with the American Peregrine Falcon Recovery Team. U.S. Fish and Wildlife Service. Denver, CO. 105 p. USDI Fish and Wildlife Service. 2002. Southwestern willow flycatcher recovery plan. Albuqueque, NM. 210pp plus appendices. USDI Fish and Wildlife Service. 2007. Recovery plan for the Sierra Nevada bighorn sheep. Sacramento, CA. 199+ pp. USDI Fish and Wildlife Service. 2010. Programmatic consultation agreement between the U.S. Forest Service and U.S. Fish and Wildlife Service for the Southern Rockies Lynx Project Screens. ES/CO:USDAFS TAILS 65413-2011-B-0001/2011-I-0001. USDI Fish and Wildlife Service. 2013a. (78 FR 7864). Endangered and Threatened Wildlife and Plants; Threatened Status for the Distinct Population Segment of the North American Wolverine Occurring in the Contiguous United States. Federal Register, Vol. 78, No. 23, pp. 7864-7890. February 4, 2013. USDI Fish and Wildlife Service. 2013b. (78 FR 7890). Endangered and Threatened Wildlife and Plants; Establishment of a Nonessential Experimental Population of the North American Wolverine in Colorado, Wyoming, and New Mexico. Federal Register, Vol. 78, No. 23, pp. 7890-7905. February 4, 2013. USDA Forest Service. 2008. Supplemental Biological Assessment of the Southern Rockies Lynx Amendment on Threatened, Endangered and Proposed Species For The Following National Forest Land and Resource Management Plan Amendments: Arapaho and Roosevelt National Forests; Grand Mesa, Uncompahgre and Gunnison National Forests; Pike and San Isabel National Forests; Medicine Bow and Routt National Forests; Rio Grande National Forest; San Juan National Forest; White River National Forest. Prepared by Julie Grode, Wildlife Biologist, U. S. Forest Service, Rocky Mountain Region April 25, 2008. USDI Fish and Wildlife Service . 2008. Biological Opinion for the Southern Rockies Lynx Amendment. ES/LK-6-CO-08- F-024. Lakewood, CO.

153 Van Dyke, W.A. 1978. Population characteristics and habitat utilization of bighorn sheep, Steens Mountain, Oregon. M.S. Thesis, Oregon State University, Corvallis, OR. Vasquez, M.. 2004. Red-naped sapsucker (Sphyrapicus nuchalis) species assessment – draft. USDA Forest Service, GMUG National Forest. 34 p. Vasquez, M. and L. Spicer. 2005a. Northern goshawk (Accipiter gentilis) species assessment – draft. USDA Forest Service, GMUG National Forest. 34 p. Vasquez, M. and L. Spicer. 2005b. American marten (Martes americana) species assessment. USDA Forest Service, GMUG National Forest. 23 p. WAFWA (Western Association of Fish and Wildlife Agencies). 2010a. Recommendations for domestic sheep and goat management in wild sheep habitat. Wild Sheep Working Group. Accessed online 03/20/2012 at: http://www.wafwa.org/html/wswg.shtml. Walters, Eric L., Edward H. Miller and Peter E. Lowther. 2002. Red-naped Sapsucker (Sphyrapicus nuchalis), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/663b. Weinmeister, B. 2008. Saguache mule deer herd, data analysis unit D-26. Colorado Division of Wildlife. Accessed online 09/10/2012 at: http://wildlife.state.co.us/Hunting/BigGame/HerdManagementDAUPlans/Pages/HerdManageme ntDAUPlans.aspx. Wiggins, D. 2004. Black Swift (Cypseloides niger): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/12/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/blackswift.pdf. Wiggins, D. 2005a. Loggerhead Shrike (Lanius ludovicianus): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/13/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/loggerheadshrike.pdf Wiggins, D. 2005b. Yellow-billed Cuckoo (Coccyzus americanus): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Accessed online 9/10/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/yellowbilledcuckoo.pdf Wiggins, D.A. 2006. American Bittern (Botaurus lentiginosus): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region, Accessed online 9/12/2012 at: http://www.fs.fed.us/r2/projects/scp/assessments/americanbittern.pdf Willson, Mary F. and Hugh E. Kingery. 2011. American Dipper (Cinclus mexicanus), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/229. Young, J.R., C.E. Braun, S.J. Oyler-McCance, J.W. Hupp, and T.W. Quinn. 2000. A new species of sage-grouse (Phasianidae: Centrocercus) from southwestern Colorado. Wilson Bulletin 112(4): 445-453. Zwank, P.J., S.R. Najera, and M. Cardenas. 1997. Life history and habitat affinities of meadow jumping mice (Zapus hudsonius) in the Middle Rio Grande Valley of New Mexico. Southwestern Naturalist 42(3): 318-322. Zwickel, Fred C. and James F. Bendell. 2005. Blue Grouse (Dendragapus obscurus), The Birds of North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America Online: http://bna.birds.cornell.edu/bna/species/015.

154 Plants Anderson, David G. 2004a. Gilia sedifolia Brandegee (stonecrop gilia): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/giliasedifolia.pdf. Anderson, D.G. 2004b. Neoparrya lithophila Mathias (Bill’s neoparrya): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/neoparryalithophila.pdf. Anderson, D.G. (2006). Eriogonum brandegeei Reveal (Brandegee’s buckwheat): a technical conservation assessment. [Online]. USDA Forest Service, Rocky Mountain Region. Available: http://www.fs.fed.us/r2/projects/scp/assessments/eriogonumbrandegeei.pdf Arizona Willow Interagency Technical Team. 1995. Arizona willow conservation agreement and strategy. U.S. Forest Service, Intermountain Region, Ogden, Utah; U.S. Forest Service, Southwestern Region, Albuquerque, New Mexico; National Park Service, Rocky Mountain Region, Denver, Colorado; U.S. Fish and Wildlife Service, Mountain-Prairie Region, Salt Lake City, Utah; U.S. Fish and Wildlife Service, Southwest Region, Albuquerque, New Mexico. Austin, Gay. 2007. Region 2 Sensitive Species evaluation form for Sphagnum angustifolium. Unpublished report dated 1/7/07. Austin, Gay. 2009. Region 2 Sensitive Species evaluation form for Sphagnum balticum. Unpublished report dated 1/13/09. Beatty, Brenda L.; William F. Jennings; and Rebecca C. Rawlinson. 2003. Botrychium ascendens (triangle lobe moonwort), Botrychium crenulatum (scalloped moonwort), Botrychium lineare (narrowleaf grapefern): A technical conservation assessment. 65 pp. Lakewood, CO: USDA Forest Service, Rocky Mountain Region. Published online. http://www.fs.fed.us/r2/projects/scp/assessments/botrychiums.pdf Beatty, B.L., W.F. Jennings, and R.C. Rawlinson. 2004. Machaeranthera coloradoensis (Colorado tansy-aster): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/machaerantheracoloradoensis.pdf Burt, Julie. 1997. The Effects of Fire and Grazing on Astragalus ripleyi Barneby. Final Report to the Colorado Natural Areas Program Small Grants Program. Unpublished manuscript on file at Rio Grande National Forest headquarters. Monte Vista, CO. February 15, 1997. Burt, Julie. 1998. The Effects of Grazing and Fire on Astragalus ripleyi Barneby. Summary of 1997 Field Work. Unpublished manuscript on file at Rio Grande National Forest headquarters. Monte Vista, CO. June 15, 1998. Burt, Julie. 1999. The Effects of Grazing and Fire on Astragalus ripleyi Barneby. Summary of 1998 Field Work. Unpublished manuscript on file at Rio Grande National Forest headquarters. Monte Vista, CO. March 15, 1999. Colorado Native Plant Societ. 1997. Rare Plants of Colorado (Second Edition). The Colorado Native Plant Society. Falcon Press Publishing Company (Helena, MT) and the Rocky Mountain Nature Association (Estes Park, CO). 105 pp. Colorado Natural Heritage Program (CNHP). 1994. Rare, Threatened, Endangered, and Sensitive Species and Natural Communities of the Rio Grande National Forest. Report prepared

155 for the Rio Grande National Forest by the Colorado Natural Heritage Program. October 21, 1994. Colorado Natural Heritage Program (CNHP). 1998. Saguache County, Closed Basin Biological Inventory Volume I: A Natural Heritage Assessment Final Report. February 1998. Available online: http://www.cnhp.colostate.edu/reports.html Colorado Natural Heritage Program (CNHP). 1999. Biological Survey of Mineral County, Colorado 1999 Final Report. Colorado Natural Heritage Program, Colorado State University, Fort Collins, Colorado. March 1999. Available online: http://www.cnhp.colostate.edu/reports.html Colorado Natural Heritage Program (CNHP). 2000a. Biological Inventory of Rio Grande and Conejos Counties, Colorado. Colorado Natural Heritage Program, Colorado State University, Fort Collins, Colorado. March 31, 2000. Available online: http://www.cnhp.colostate.edu/reports.html Colorado Natural Heritage Program (CNHP). 2000b. Biological Inventory of Rio Grande and Conejos Counties, Colorado Volume II: A Natural Heritage Inventory and Assessment of Wetlands and Riparian Areas in Rio Grande and Conejos Counties. Colorado Natural Heritage Program, Colorado State University, Fort Collins, Colorado. March 2000. Available online: http://www.cnhp.colostate.edu/reports.html Colorado Natural Heritage Program (CNHP). 2003. Upper San Juan Basin Biological Assessment. Colorado Natural Heritage Program, Colorado State University, 8002 Campus Delivery, Fort Collins, CO 80523-8002. 319pp. Available online: http://www.cnhp.colostate.edu/reports.html Colorado Natural Heritage Program (CNHP). 2008. Element Occurrence Records for the Rio Grande National Forest. Unpublished data on file at the Supervisor’s Office for the Rio Grande National Forest. Monte Vista, Colorado. Data compiled 9/2008. Colorado Natural Heritage Program (CNHP). 2009. County occurrence information (4/6/2009) by Colorado Natural Heritage Program. http://www.cnhp.colostate.edu/list.html Daly, Chris; and George Taylor. 1998. Colorado Average Annual Precipitation, 1961-90. Portland, OR: Natural Resources Conservation Service, Water and Climate Center. http://www.ncgc.nrcs.usda.gov/products/datasets/climate/data/precipitation-state/co.html Day, Warren C.; Gregory N. Green; Daniel H. Knepper Jr.; and Randal C. Phillips. 1999. Spatial geologic data model for the Gunnison, Grand Mesa, Uncompahgre National Forests mineral resource assessment area, southwestern Colorado and digital data for the Leadville, Montrose, Durango, and Colorado parts of the Grand Junction, Moab, and Cortez 1° X 2° geologic maps. Open-File Report OF-99-427, 32 pp. Denver, CO: U. S. Geological Survey. Digital maps available at http://pubs.usgs.gov/of/1999/ofr-99-0427/ Decker, K. 2005. Astragalus proximus (Rydberg) Wooton & Standley (Aztec milkvetch): a technical conservation assessment. [Online]. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/astragalusproximus.pdf Decker, K. 2006a. Salix arizonica Dorn (Arizona willow): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/salixarizonica.pdf Decker, K. 2006b. Astragalus missouriensis Nutt. var. humistratus Isely (Missouri milkvetch): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/

156 Decker, K. (2006c). Salix candida Flueggé ex Wild. (sageleaf willow): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Available: http://www.fs.fed.us/r2/projects/scp/assessments/salixcandida.pdf Decker, K., D.R. Culver, and D.G. Anderson. (2006a). Eriophorum chamissonis C.A. Mey. (Chamisso’s cottongrass): a technical conservation assessment. [Online]. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/eriophorumchamissonis.pdf Decker, K., D.R. Culver, and D.G. Anderson. (2006b). Eriophorum gracile W. D. J. Koch (slender cottongrass): a technical conservation assessment. [Online]. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/eriophorumgracile.pdf Dorn, Robert D. 1997. Rocky Mountain region willow identification field guide. Renewable Resources R2-RR-97- 01. Denver, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Region. 107 p. Dorn, Robert D. 2001. Personal communication August 9, 2001 between Dr. Robert Dorn, willow taxonomy specialist, and Dean Erhard, Rio Grande National Forest. Farrar, Donald R.; and Steve J. Popovich. 2012. Ophioglossaceae C. Agardh 1822: Moonwort Family (OPH). Pp.23-34 in William A. Weber and Ronald C. Wittmann, Authors. Colorado Flora: Western Slope, Fourth Edition. 532 pp. Boulder, CO: University Press of Colorado. Fertig, Walt. 1994. Wyoming Rare Plant Field Guide. The Nature Conservancy. Laramie, WY. Fertig, Walter. 2000. State species abstract: Carex diandra. Laramie, WY: Wyoming Natural Diversity Database, 2 pp. Available online: http://uwadmnweb.uwyo.edu/WYNDD Flora of North America Editorial Committee. 1993. Flora of North America North of Mexico. Volume 2 Pteridophytes and Gymnosperms. Oxford University Press. New York. 475 pp. Available online: http://www.efloras.org/volume_page.aspx?volume_id=1002&flora_id=1 Gage, E. and D.J. Cooper. 2006. Carex diandra Schrank (lesser panicled sedge): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/carexdiandra.pdf Harrington, H.D. 1954. Manual of the Plants of Colorado. Sage Books, Chicago, IL. Hartman, Ronald L. 2006. Xanthisma de Candolle. Pp. 383-393 in Flora of North America Editorial Committee, Editors. Flora of North America north of Mexico, Volume 20: Magnoliophyta: Asteridae, part 7: Asteraceae, part 2. 666 pp. New York, NY: Oxford University Press. Hermann, Frederick J. 1970. Manual of the Carices of the Rocky Mountains and Colorado Basin. Agriculture Handbook No. 374. US Dept. of Agric., Forest Service. US Government Printing Office. Washington DC. Johnston, Barry C.; Laurie Huckaby; Terry J. Hughes; and Joseph Pecor. 2001. Ecological types of the Upper Gunnison Basin: Vegetation-soil-landform-geology-climate-water land classes for natural resource management. Technical Report R2-RR-2001-01, 858 pp. Lakewood, CO: USDA Forest Service, Rocky Mountain Region. Johnston, Barry C. 2009. Report on photointerpretation for potential fens of the Rio Grande National Forest. Report to Forest Supervisor, Rio Grande National Forest, Monte Vista, CO. Gunnison, CO: USDA Forest Service, 4 pp. June 1, 2009.

157 Johnston, Barry C.; Benjamin T. Stratton; Warren R. Young; Liane L. Mattson; John M. Almy; and Gay T. Austin. 2012. Inventory of fens in a large landscape of west-central Colorado: Grand Mesa, Uncompahgre, and Gunnison National Forests. Report to Forest Supervisor. Delta, CO: USDA Forest Service, Grand Mesa, Uncompahgre, and Gunnison National Forests, 209 pp. April 6, 2012. http://www.fs.usda.gov/detailfull/gmug/landmanagement/resourcemanagement/?cid=stelprdb53 63685&width=full Komarek, Susan. 1994. Flora of the San Juans. Kivaki Press. Durango, Colorado. 244 pp. Komarek, Susan. 2003. Personal communication 10/29/03 between Sue Komarek, botanist , and Dean Erhard, Rio Grande National Forest. Ladyman, J.A.R. 2003. Astragalus ripleyi (Ripley’s milkvetch): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/astragalusripley.pdf Ladyman, J.A.R. 2004a. Draba grayana (Rydb.) C.L. Hitchcock (Gray’s draba): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/drabagrayana.pdf Ladyman, J.A.R. 2004b. Draba smithii (Smith’s draba): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/ projects/scp/assessments/drabasmithii.pdf Ladyman, J.A.R. 2004c. Eriophorum altaicum Meinshausen var. neogaeum Raymond (whitebristle cottongrass): a technical conservation assessment. [Online]. USDA Forest Service, Rocky Mountain Region. Available: http://www.fs.fed.us/r2/projects/scp/assessments/eriophorumaltaicumvarneogaeum.pdf Ladyman, J.A.R. 2005. Aquilegia chrysantha A. Gray var. rydbergii Munz (Rydberg’s golden columbine): a technical conservation assessment. [Online]. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/aquilegiachrysanthavarrydbergii.pdf Ladyman, Juanita A. R. 2006. Astragalus leptaleus Gray (park milkvetch):A technical conservation assessment. 52 pp. Lakewood, CO: USDA Forest Service, Rocky Mountain Region. Published online. http://www.fs.fed.us/r2/projects/scp/assessments/astragalusleptaleus.pdf Lightfoot, Karen. 1995. Status report on Astragalus ripleyi Barneby. Forestry and Resources Conservation Div., Santa Fe, NM. Prepared for U.S. Fish and Wildlife Service, New Mexico Ecological Services Field Office, Albuquerque, NM. 33 pp. + photos and maps. Mergen, D.E. 2006. Cypripedium parviflorum Salisbury (lesser yellow lady’s slipper): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/cypripediumparviflorum.pdf Morgan, David R.; and Ronald L. Hartman. 2003. A synopsis of Machaeranthera (Asteraceae: Astereae) with recognition of segregate genera. Sida 20(4): 1387-1416. Naumann, Tamara. 1990. Status report for Astragalus ripleyi Barneby. Prepared for Colorado Natural Areas Program, Division of Parks and Outdoor Recreation, Dept. of Natural Res., Denver, Colorado. 46 pp. + appendices. Neely, Betsy; Renée Rondeau; John Sanderson; Chris Pague; Bernadette Kuhn; Jeremy Siemers; Lee Grunau; Jamie Robertson; Patrick McCarthy; Joseph Barsugli; Terri Schulz; and Corrie Knapp, Editors. 2011. Gunnison Basin climate change vulnerability assessment. 262 pp.

158 Boulder, CO: The Nature Conservancy. Published December 31, 2011, by The Nature Conservancy; Colorado Natural Heritage Program; Western Water Assessment, University of Colorado, Boulder; and University of Alaska, Fairbanks. http://conserveonline.org/workspaces/gunnisonclimatechange/documents/gunnison-basin- climate-change- vulnerability/view.html Neid, S.L. 2006. Utricularia minor L. (lesser bladderwort): a technical conservation assessment. USDA Forest Service, Rocky Mountain Region. Available online: http://www.fs.fed.us/r2/projects/scp/assessments/utriculariaminor.pdf O'Kane, Steve L. 1988. Colorado's Rare Flora. Great Basin Naturalist. Vol.48, No. 4. pp. 434- 473. O'Kane, S.L., D.H. Wilken, and R.L. Hartman. 1988. Noteworthy collections: Colorado. Madroño 35:72-74. Panjabi, S.S. and D.G. Anderson. 2006. Calochortus flexuosus S. Watson (winding mariposa technical conservation assessment. Available online. USDA Forest Service, Rocky Mountain Region. http://www.fs.fed.us/r2/projects/scp/assessments/calochortusflexuosus.pdf Popovich, S.J. 2006. Region 2 Sensitive Species evaluation form for Botrychium furcatum. Unpublished report dated 1/25/06. Rey-Vizgirdas, Edna; and Barbara Behan. 2001. Endangered and threatened wildlife and plants; 12-month finding for a petition to list the plant Botrychium lineare (slender moonwort) as threatened. Federal Register 66(109): 30368-30372. June 6, 2001. Root, Peter. 1994. Personal communication July 14, 1994 between Peter Root, Botrychium specialist, and Dean Erhard, Rio Grande National Forest. Spackman, S., B. Jennings, J. Coles, C. Dawson, M. Minton, A. Kratz, and C. Spurrier. 1997. Colorado Rare Plant Field Guide. Prepared for the Bureau of Land Management, the U.S. Forest Service and the U.S. Fish and Wildlife Service by the Colorado Natural Heritage Program. Available online: http://www.cnhp.colostate.edu/rareplants/intro.html USDA Forest Service. 2011. Forest Service Manual 2670 - Threatened, Endangered, and Sensitive Plants and Animals, Supplement No. 2600-2011-1. 22 pp. Denver, CO: USDA Forest Service, Rocky Mountain Region. Effective May 25, 2011. http://www.fs.fed.us/im/directives/field/r2/fsm/2600/2670.doc U. S. Army Corps of Engineers. 2010. Regional supplement to the Corps of Engineers wetland delineation manual: Western mountains, valleys, and coast region (Version 2.0). Publication ERDC/EL TR-10-3, 153 pp. Vickburg, MS: U. S. Army Corps of Engineers, Wetlands Regulatory Assistance Program. http://www.usace.army.mil/CECW/Documents/cecwo/reg/west_mt_finalsupp.pdf USDA Natural Resources Conservation Service. 2012. The PLANTS database, Version 3.5. Baton Rouge, LA: USDA Natural Resources Conservation Service, National Plant Data Center. Downloaded March 15, 2012. http://plants.usda.gov Weber, William A. 1958. Rediscovery of Neoparrya. Rhodora 60:265-271. Weber, William A. 2001. Rare cryptogams in Colorado. Colorado Native Plant Society. Unpublished manuscript on file at the Rio Grande National Forest headquarters. Monte Vista, Colorado. Weber, William A.; and Ronald C. Wittmann. 2012. Colorado flora: Western Slope, Fourth Edition. 532 pp. Boulder, CO: University Press of Colorado.

159 Weber, William A.; and Ronald C. Wittmann. 2012. Colorado flora: Eastern Slope, Fourth Edition. 620 pp. Boulder, CO: University Press of Colorado. Wooten, G. 1993. R-6 Botany News. USDA Forest Service. Pacific Northwest Region. Portland, Oregon. September 1993.

Heritage Andrews, J.T., P.E. Carrara, F. B. King and R. Stuckenrath. 1975 Holocene Environmental Changes in the Alpine Zone, Northern San Juan Mountains Colorado. Evidence from a Bog Stratigraphy and Palynology. Quaternary Research 5:173-197.

Beardsley, John W., 1976. Preliminary Cultural Resources Report for the Sargent’s Mesa Timber Sale. Buckles, William G., and Nancy B. Buckles, 1984. Colorado Historical Archaeology Context. Colorado Historical Society, Denver, Colorado. Burns, George and Sharon Kyle, 1977. Cultural Resource Report. Spanish Bear Timber Sale. Gunnison National Forest. Burns, George and Vince Spero, 1979.Cultural Resources Inventory Report. Cochetopa Timber Sale. Rio Grande National Forest. Burns, George and Wayne Williams, 1977.Cultural Resource Report. Middle Creek Mining Exploration. Rio Grande National Forest. Carter, Carrol Joe and Steven F. Mehls, 1984.Colorado Southern Frontier Historic Context. Colorado Historical Society, Denver, Colorado. Cassells, E. Steve, 1978. Cultural Resource Survey. Divide Timber Sale. GMUGNF. Cassells, E. Steve, 1978.Cultural Resource Survey. Jay Creek Timber Sale. GMUGNF. Cassells, E. Steve, 1997.The Archaeology of Colorado. Johnson Books: Boulder, Colorado. Church, Minette, Steven baker, Bonnie Clark, Richard Carillo, Jonathan Horn, Carl Spath, David Guilfoyle, and Steve Cassells, 2007. Colorado History: A Context for Historical Archaeology. Colorado , Council of Professional Archaeologists, Denver, Colorado. Cook, H. J., 1931. More evidence of the ‘Folsom culture’ race. Scientific American 144: 102- 103. Feiler, E. J. and R. S. Anderson, 1993.The Paleoecology of the Dome Creek Meadow, Bear River Corridor, Garfield County, Colorado. Frison, G. C., 1991. Prehistoric Hunters of the High Plains. Academic Press, New York. Frye, Ken, 2004. Class III Cultural Resource Inventory Report. Bear Creek Timber Sale. Rio Grande National Forest. Garcia, Pete N. 1998. Para-Professional Cultural Resource Inventory Report. North Fork Bladder Bag Extension and Relocation. Rio Grande National Forest. Guthrie, Mark R. and Jill Croft. 1980. A Cultural Resource Survey of the Sargent’s Mesa #3 Timber Sale. Cultural Resource Consultants Inc. under contract for the GMUGNF. Guthrie, Mark R. Powys Gadd, Renee Johnson and Joseph J. Lischka. 1984. Colorado Mountains Prehistoric Context. State Historical Society of Colorado, Denver, Colorado.

160 Hager, M. W., 1972.A Late Wisconsin-Recent Vertebrate Fauna from the Chimney Rock Animal Trap, Larimer County, Colorado. University of Wyoming Contributions to Geology 11:63-71. Harris, Arthur H., 1985. Late Pleistocene Vertebrate Paleoecology of the West. University of Texas Press, Austin. Haynes, Gary, 2002 The Early Settlement of North America: the Clovis Era. Cambridge University Press, Cambridge. Houston, Robert B., 2005.Two Colorado Odysseys. iUniverse Press, Lincoln. Hurst, C. T., 1943.A Folsom Site in a Mountain Valley of Colorado. American Antiquity 8(3):250-253. Kelly, R. L & L. C. Todd, 1988. Coming to the Country: Early Paleoindian Hunting and Mobility. American Antiquity 53(2): 231-244. Kornfeld, M. J. M., L.C. Todd, J. Saysette and G.C. Frison, 1992. Paleoindian Occupation in a Portion of Colorado's Middle Park: Preliminary Report on Several Sites with Goshen Complex Manifestations. Paper presented at the Plains Conference, Lincoln, Nebraska. Lawrence, Justin. 2004. Cultural Resource Inventory of the Sargent’s Mesa Timber Sale. GMUGNF. Martorano, Marilyn A. and George Burns. 1982.Cultural Resources Inventory of Four Timber Sales in the Gunnison and Uncompahgre National Forests. Goodson and Associates under contract with the GMUGNF. Martorano, Marilyn A., Ted Hoefer III, Margaret (Pegi) A. Jodry, Vince Spero, and Melissa L. Taylor 1999 Colorado Prehistory: A Context for the Rio Grande Basin. Colorado Council of Professional Archaeologists, Denver. McFaul, M., C. J. Zier and E. Anderson.1988.The Seaman Reservoir Mammoth Locality (5LR1098), North Fork Cache La Poudre River, Colorado. Current Research in the Pleistocene 5:94-96. Miller, Wick R. 1986.Numic Languages. In Great Basin, edited by Warren L. D'Azevedo, pp. 98- 106. Handbook of North American Indians, vol. 11, edited by William C. Sturtevant. Smithsonian Institution, Washington, D.C. Naze, B. 1986. The Folsom Occupation of Middle Park, Colorado. Southwestern Lore 52(4):1- 32. Overturf, J. L. 1993 A Proposal for Limited Paleontological, Archaeological, and Paleoenvironmental Investigations in the Bear River Corridor, Yampa Ranger District, Routt National Forest, Colorado. Reed, Alan D. 1981. Piedra Pass Archaeological Sites. Colorado Historical Society, Denver, Colorado. Rio Grande National Forest 1995.Heritage Resource Inventory Report. Spanish/Divide Timber Sale. Rio Grande National Forest Rossman, Ray V., 1995.A Cultural Resource Inventory for the North Pass Timber Sale. GMUGNF. Rossman, Ray V., 2002.Cultural Resource Inventory of Millswitch Timber Sale. GMUGNF Spero, Vince 1983 Cultural Resource Inventory Report. Saguache Lodgepole Regeneration Access. Rio Grande National Forest.

161 Spero, Vince 1984 Cultural Resource Inventory Report. Saguache Lodgepole Regeneration 1983. Rio Grande National Forest. Spero, Vince 1985 Cultural Resource Inventory Report. Saguache Lodgepole Regeneration 1984. Rio Grande National Forest. Spero, Vince, 1988.Cultural Resource Inventory Report. Razor Park/Deadman Timber Sale Proposed Access Road. Rio Grande National Forest. Spero, Vince, 1989. Cultural Resource Inventory Report. Deadman Timber Sale. Rio Grande National Forest. Spero, Vince, 1991. Cultural Resource Inventory Report. Vulcan Timber Sale. Rio Grande National Forest. Spero, Vince, 1993 Cultural Resource Inventory Report. Spruce Creek Timber Sale. Rio Grande National Forest. Struthers, E. S. 1990. A Level III Cultural Resource Inventory for the Kidney Lakes Timber Sale, Routt National Forest, North Park Ranger District, Jackson County. Thornbury, W. D., 1965. Regional Geomorphology of the United States. John Wiley and Sons, Inc., New York. Trujillo, John S., 1979a. Archaeological Reconnaissance Report. District Aspen Treatment. Gunnison National Forest. Trujillo, John S, 1979b. Archaeological Reconnaissance Report. Taylor Canyon 8 and 9. Gunnison National Forest. Trujillo, John S , 1989. Para-Professional Cultural Resource Inventory Report. Saguache Park Bladder Bags. Rio Grande National Forest. Trujillo, John S 1996 Para-Professional Cultural Resource Inventory Report. Cochetopa Hills Travel Management. Rio Grande National Forest. Tweto, O. 1979.Geologic Map of Colorado. US Department of Agriculture Natural Resources Conservation Service 2011 Soil Data Mart. Electronic resource: http://soildatamart.nrcs.usda.gov/. Accessed January 3, 2011. Waguespack, Nicole M. and Todd A. Surovell. 2003. Clovis Hunting Strategies, or How to Make Out on Plentiful Resources. American Antiquity 68(2): 333-352. Zieroth, Elaine. 1989. Cultural Resources Report. Ant Creek Water Holes. Gunnison National Forest.

Range USDA-FS. 1998. Reclamation prescriptions for the foothills and mountain ecosystems of the San Luis Valley area. Unpublished document on file at the Headquarters for the Rio Grande National Forest. Monte Vista, CO. February 1998. USDA-FS. 2008. Invasive Species Action Plan: The prevention and management of invasive species (plants, vertebrates, and invertebrates) FY 2008-2010. USDA-FS Rio Grande National Forest and the San Luis Valley Resource Area. Unpublished document on file at the Headquarters for the Rio Grande National Forest. Monte Vista, CO. April 2008.

162 Scenery USDA Forest Service, 1996. Revised land and resource management plan. USDA Forest Service, Rocky Mountain Region, Rio Grande National Forest, Monte Vista, CO. USDA Forest Service, 2009b. The 2009 Continental Divide National Scenic Trail Comprehensive Plan. USDA Forest Service, (n.d.). Continental Divide National Scenic Trail Trailhead Design Guidelines. USDA Forest Service, 1995. AH701 Landscape Aesthetics – A Handbook for Scenery Management. USDA Forest Service, 2006. Forest Service Trail Accessibility Guidelines (FSTAG).

163 (Intentionally left blank)

164 APPENDIX A. DESIGN PARAMETERS EXCERPT (PGS 1-6)

165

Design Parameters

Design Parameters are technical guidelines for the survey, design, construction, maintenance, and assessment of National Forest System trails, based on their Designed Use and Trail Class and consistent with their management intent1. Local deviations from any Design Parameter may be established based on trail-specific conditions, topography, or other factors, provided that the deviations are consistent with the general intent of the applicable Trail Class.

Designed Use

HIKER/PEDESTRIAN Trail Class 1 Trail Class 2 Trail Class 3 2 Trail Class 4 2 Trail Class 5 2 Design Wilderness 0” – 12” 6” – 18” 12” – 24” 18” – 24” Not applicable (Single Lane) Tread Exception: may be Exception: may be 36” – 48” at steep side 36” – 48” at steep side Width slopes slopes Non-Wilderness 0” – 12” 6” – 18” 18” – 36” 24” – 60” 36” – 72” (Single Lane) Non-Wilderness 36” 36” 36” – 60” 48” – 72” 72” – 120” (Double Lane) Structures 18” 18” 18” 36” 36” (Minimum Width) Design Type Native, ungraded Native, limited grading Native with some onsite Native with improved Likely imported material, 3 borrow or imported sections of borrow or routine grading Surface May be continuously May be continuously material where needed imported material, rough rough for stabilization, routine grading Uniform, firm, and stable occasional grading Minor roughness Intermittently rough Protrusions ≤ 24” ≤ 6” ≤ 3” ≤ 3 ” No protrusions Likely common and May be common and May be common, not Uncommon, not continuous continuous continuous continuous Obstacles 24” 14” 10” 8” No obstacles (Maximum Height) Design Target Grade 5% – 25% 5% – 18% 3% – 12% 2% – 10% 2% – 5%

Grade 3 Short Pitch Maximum 40% 35% 25% 15% 5% FSTAG: 5% – 12%2 Maximum Pitch Density 20% – 40% of trail 20% – 30% of trail 10% – 20% of trail 5% – 20% of trail 0% – 5% of trail

10/16/2008

Designed Use

HIKER/PEDESTRIAN Trail Class 1 Trail Class 2 Trail Class 3 2 Trail Class 4 2 Trail Class 5 2 Target Cross Slope Natural side slope 5% – 20% 5% – 10% 3% – 7% 2% – 3% Design (or crowned) Cross Slope Maximum Cross Slope Natural side slope 25% 15% 10% 3%

Design Height 6’ 6’ – 7’ 7’ – 8’ 8’ – 10’ 8’ – 10’ Clearing Width ≥ 24” 24” – 48” 36” – 60” 48” – 72” 60” – 72” Some vegetation may Some light vegetation encroach into clearing may encroach into area clearing area Shoulder Clearance 3” – 6” 6” – 12” 12” – 18” 12” – 18” 12” – 24”

Design Radius No minimum 2’ – 3’ 3’ – 6’ 4’ – 8’ 6’ – 8’ Turn 1 For definitions of Design Parameter attributes (e.g., Design Tread Width and Short Pitch Maximum) see FSH 2309.18, section 05. 2 Trail Classes 3, 4, and 5, in particular, have the potential to provide accessible passage. If assessing or designing trails for accessibility, refer to the Forest Service Trail Accessibility Guidelines (FSTAG) for more specific technical provisions and tolerances (FSM 2350). 3 The determination of trail-specific design grades, design surface, and other Design Parameters should be based upon soils, hydrological conditions, use levels, erosion potential, and other factors contributing to surface stability and overall sustainability of the trail.

Design Parameters

Designed Use PACK AND SADDLE Trail Class 1 Trail Class 2 Trail Class 3 Trail Class 4 Trail Class 5 Design Wilderness Typically not designed 12” – 18” 18” – 24” 24” Typically not (Single Lane) or actively managed for designed or actively Tread May be up to 48” along May be up to 48” along May be up to 48” along equestrians, although steep side slopes steep side slopes steep side slopes managed for Width use may be accepted equestrians, although 48” – 60” or greater along 48” – 60” or greater along 48” – 60” or greater along use may be accepted precipices precipices precipices Non-Wilderness 12” – 24” 18” – 48” 24” – 96” (Single Lane) May be up to 48” along 48” – 60” or greater along 48” – 60” or greater along steep side slopes precipices precipices 48” – 60” or greater along precipices Non-Wilderness 60” 60” – 84” 84” – 120” (Double Lane) Structures Other than -bridges: 36” Other than bridges: 36” Other than bridges: 36” (Minimum Width) Bridges without Bridges without handrails: Bridges without handrails: handrails: 60” 60” 60” Bridges with handrails: Bridges with handrails: Bridges with handrails: 84” 84” clear width 84” clear width clear width Design Type Native, limited grading Native with some onsite Native, with improved 2 borrow or imported sections of borrow or Surface May be frequently rough material where needed imported material, routine for stabilization, grading occasional grading Minor roughness Intermittently rough Protrusions ≤ 6” ≤ 3” ≤ 3” May be common and May be common, not Uncommon, not continuous continuous continuous Obstacles 12” 6” 3” (Maximum Height)

10/16/2008

Designed Use PACK AND SADDLE Trail Class 1 Trail Class 2 Trail Class 3 Trail Class 4 Trail Class 5 Design Target Grade 5% – 20% 3% – 12% 2% – 10%

Grade 2 Short Pitch Maximum 30% 20% 15%

Maximum Pitch Density 15% – 20% of trail 5% – 15% of trail 5% – 10% of trail

Design Target Cross Slope 5% – 10% 3% – 5% 0% – 5% Cross Slope Maximum Cross Slope 10% 8% 5%

Design Height 8’ – 10’ 10’ 10’ – 12’ Clearing Width 72” 72” – 96” 96” Some light vegetation may encroach into clearing area Shoulder Clearance 6” – 12” 12” – 18” 12” – 18” Pack clearance: 36” x 36” Pack clearance: 36” x 36” Pack clearance: 36” x 36” Radius 4’ – 5’ 5’ – 8’ 6’ – 10’ Design Turn 1 For definitions of Design Parameter attributes (e.g., Design Tread Width and Short Pitch Maximum) see FSH 2309.18, section 05. 2 The determination of trail-specific design grades, design surface, and other Design Parameters should be based upon soils, hydrological conditions, use levels, erosion potential, and other factors contributing to surface stability and overall sustainability of the trail.

Design Parameters

Designed Use BICYCLE Trail Class 1 Trail Class 2 Trail Class 3 Trail Class 4 Trail Class 5 Design Single Lane 6” – 12” 12” – 24” 18” – 36” 24” – 48” 36” – 60” Tread Width Double Lane 36” – 48” 36” – 48” 36” – 48” 48” – 84” 72” – 120”

Structures 18” 18” 36” 48” 60” (Minimum Width) Design Type Native, un-graded Native, limited grading Native with some onsite Native, routine grading Likely imported material, 2 borrow or imported with improved sections routine grading Surface May be continuously May be continuously material where needed of borrow or imported rough rough for stabilization, materials Uniform, firm, and stable occasional grading Sections of soft or Sections of soft or Stable with minor unstable tread on unstable tread on Intermittently rough roughness grades < 5% may be grades < 5% may be

common and continuous common Sections of soft or unstable tread on grades < 5% may be present, but not common Protrusions ≤ 24” ≤ 6” ≤ 3” ≤ 3” No protrusions Likely common and May be common and May be common, not Uncommon, not continuous continuous continuous continuous Obstacles 24” 12” 10” 8” No obstacles (Maximum Height) Design Target Grade 5% – 20% 5% – 12% 3% – 10% 2% – 8% 2% – 5%

Grade 2 Short Pitch Maximum 30% 25% 15% 10% 8% 50% on downhill-only 35% on downhill-only segments segments Maximum Pitch Density 20% – 30% of trail 10% – 30% of trail 10% – 20% of trail 5% – 10% of trail 0% – 5% of trail

10/16/2008

Designed Use BICYCLE Trail Class 1 Trail Class 2 Trail Class 3 Trail Class 4 Trail Class 5 Design Target Cross Slope 5% – 10% 5% – 8% 3% – 8% 3% – 5% 2% – 3% Cross Slope Maximum Cross Slope 10% 10% 8% 5% 5%

Design Height 6’ 6’ – 8’ 8’ 8’ - 9’ 8’ - 9’ Clearing Width 24” – 36” 36” – 48” 60” – 72” 72” – 96” 72” – 96” Some vegetation may Some light vegetation encroach into clearing may encroach into area clearing area Shoulder Clearance 0’ – 12” 6” – 12” 6” – 12” 6” – 18” 12” – 18”

Design Radius 2’ – 3’ 3’ – 6’ 4’ – 8’ 8’ – 10’ 8’ - 12’ Turn 1 For definitions of Design Parameter attributes (e.g., Design Tread Width and Short Pitch Maximum) see FSH 2309.18, section 05. 2 The determination of trail-specific design grades, design surface, and other Design Parameters should be based upon soils, hydrological conditions, use levels, erosion potential, and other factors contributing to surface stability and overall sustainability of the trail.

(Intentionally left blank)

172 APPENDIX B. RECOMMENDED SEED MIX Recommended Seed Mixtures This prescription is for well drained sites from about 8,300 to 10,400 feet above sea level and is characterized by ponderosa pine, mixed conifers, Douglas-fir, white fir, Arizona fescue and mountain muhly habitat types. Aspen is the dominant seral tree species following disturbance.

PRIMARY SPECIES Pure Live Recommended Varieties Percent Sodformer/ Native/ Seed lbs/ac. (Planting season Mix Bunchgrass Introduced Broadcast S=Spring; Summer, F=Fall) Noncritical Arriba Western Wheatgrass 35 Sodformer Native 6.3 (Pascopyron smithii) syn: (Agropyron smithii) (F/S) Mountain Brome, Bromar 20 Sodformer Native 3.9 Not listed in Weber, syn: (Bromus marginatus) (S/F) Arizona Fescue Redondo 20 Bunchgrass Native 0.6 (Festuca arizonica) Prairie Junegrass 15 Bunchgrass Native 0.20 (Koeleria macrantha) syn: (Koeleria cristata) Bandera Rocky Mountain 5 Forb Native 1.0 Pentstemon (Penstemon strictus) Blue (Lewis) Flax 5 Forb Native 0.5 (Adenolinum lewisii) syn: (Linum lewisii) For noncritical, broadcast rate (most FS needs) 10.7 lbs/acre

Possible seed sources: Arkansas Valley Seed Solutions 877-957-3337; 4625 Colorado Blvd, Denver, CO 80216 Pawnee Butte Seed Co. 970-356-7002; P.O. Box 1604, Greeley, CO 80632 Sharp Bros. Seed Co.

173 (Intentionally left blank)

174 APPENDIX C. RESPONSE TO COMMENTS

All comments have been summarized. Copies of all comments can be found in the administrative record.

Resource Area Summarized Comment Agency response

Law or Policy

Law or Policy Forest Service violated NEPA and FLPMA by failing EA has been revised to demonstrate to access and fairly disclose impacts of hikers, impacts of various users and to remove equestrians, and mountain bikes on the proposed bias to aid Forest Supervisors in making trail. Pre-decisional EA contained overt prejudice an informed decision. and bias. Pre-decisional EA failed to provide all information necessary to make an informed decision. The Environmental Assessment Misinterprets the Law or Policy CDNST’s 2009 Comprehensive Plan Both mountain EA has been updated with Laws, bikers and the Forest Service employee who Regulations and Policy. EA has oversaw the drafting of the 2009 CDNST considered whether or not a substantial Comprehensive Plan regarded the plan as positive interference with the nature and toward mountain biking. The plan’s final version was purposes of the Act would occur with not intended to impose general limitations on the inclusion of bikes. EA has also been mountain biking; if it had been, mountain bikers updated with best available science would have vigorously opposed the final draft. The regarding impacts of users Environmental Assessment seems to be relying only on the first principle set forth in the comprehensive plan and discounting the second. But all indications are that mountain biking on the 32-mile CDNST reroute will be “consistent with the applicable land and resource management plan and will not substantially interfere with the nature and purposes of the CDNST.” The Environmental Assessment offers no persuasive evidence to the contrary. The Responsible Official for this project has been Law or Policy improperly assigned to District Rangers rather than The Regional Forester has delegated the Regional Forester or the Forest Supervisor. The the authority for this decision to the Forest Service Manual explicitly assigns the “study, Forest Supervisors of the GMUG and planning, location and operation” of the CDNST to RGNF. A corrected legal notice had the Regional Forester for the Rocky Mountain been published in the newspapers of Region. Even without the relocation element of this record for the Forest Supervisors during plan, the proposed action includes a decision the comment period; thereby extending whether bicycle use will be permitted on this the comment period. segment of the CDNST, which is explicitly committed to the Forest Supervisor and it may not be redelegated. Because the appropriate Responsible Official has not been assigned any decision made by the current Responsible Official would be outside of their authority and thus void. The action should be terminated and restarted and assigned to a Responsible Official with the authority to make the decisions proposed. The Environmental Assessment and Proposed Law or Policy Alternative analysis of bicycle use do not meet the EA has also been updated with best “hard look” requirements of the National available science regarding Environmental Policy Act because they are commenter’s concerns to remove bias unsubstantiated assertions rather than critical and to fulfill NEPA’s hard look examinations of the potential environmental, social requirements. or economic effects of bicycle use on the new

175 Resource Area Summarized Comment Agency response singletrack trail. The National Environmental Policy Act (NEPA) decisions that are "arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with the law" will not withstand judicial review and will be overturned by the courts. 5 U.S.C. §706(2)(A). “To withstand scrutiny the agency must have taken a “hard look” at the environmental consequences of the proposed action.” Kleppe v. Sierra Club, 427 U.S. 390, 410 (1976) citing Natural Resources Defense Council v. Morton, 148 U.S. App. D.C. 5, 16, 458 F. 2d 827, 838 (1972). The EA “must articulate a rational connection between the facts found and the conclusions reached.” Midwater Trawlers Co-op v. Envtl. Def. Ctr., 282 F.3d 710, 716 (9th Cir. 2002). Furthermore, “agency action is arbitrary or capricious if the agency… entirely failed to consider an important aspect of the problem, offered an explanation for its decision that runs counter to the evidence before the agency, or is so implausible that it could not be ascribed to a difference in view or the product of agency expertise. Motor Vehicle Mfrs. Ass’n of U.S., Inc. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983). The Draft treatment of bicycle use of trails is so inadequate that we are reluctant to call it an analysis at all. It consists of unsubstantiated conclusory statements Law or Policy The National Trails System Act, enacted in 1968, EA has been updated with Laws, states that National Scenic Trails “will be extended Regulations and Policy. EA has trails so located as to provide for maximum outdoor considered whether or not a substantial recreation potential and for the conservation and interference with the nature and enjoyment of the nationally significant scenic, purposes of the Act would occur with historic, natural, or cultural qualities of the areas the inclusion of bikes. through which such trails pass.” We believe that bicycle use fits within the parameters specified by the National Trails System Act, and that bicycle use would be appropriate for the character and terrain proposed in this new trail prior to the rerouted trails termination into wilderness. Several commenters oppose opening the route to Law or Policy mountain bikes and other vehicles stating such EA has been updated with Laws, vehicular use is inconsistent with the intended use of Regulations and Policy. EA has the CDT. considered whether or not a substantial interference with the nature and purposes of the Act would occur with the inclusion of bikes. The pre-decisional EA states, “In general terms, Law or Policy bicycle use on the CDNST is not consistent with the EA has been updated with Laws, overall objectives for the CDNST.” This statement is Regulations and Policy. EA has not true. The 2009 CDNST Comprehensive Plan considered whether or not a substantial found that while the intent of the trail is for hikers interference with the nature and and equestrians, bicyclists may be allowed in non- purposes of the Act would occur with Wilderness sections of the trail, depending on the the inclusion of bikes. land use management plan. From the 2009 Plan, ”Bicycle use may be allowed on the CDNST (16 U.S.C. 1246(c)) if the use is consistent with the applicable land and resource management plan and will not substantially interfere with the nature and

176 Resource Area Summarized Comment Agency response purposes of the CDNST.” In addition, the "overall objectives" referred to by the EA were drafted in the 1960s, so it is without merit to argue that the objectives of the CDNST at that time meant to ban bikes when mountain bikes were not in existence TMOs need to be developed. Law or Policy TMOs will be developed after a decision on designed use is made. TMOs are an engineering analysis, not a decision subject to appeal. The CDNST directives in the FSM 2343.44b and the Law and Policy 2009 Comprehensive Plan, pp 10 and 11, and A ½ mile buffer (corridor) for the associated 2009 Federal Register Notice, provide protection of visual resources is a for the establishment of a protected corridor up to ½ stipulation that is being applied to all mile wide on both sides of the trail. action alternatives for this proposed FSM 2353.44b (1) and (2) state “Land Management segment of the CDNST (Chapter 2 and Plans and CDNST unit plans ..must establish a Chapter 2). This conservation measure management area for segments of the has been designed to be compatible CDNST…that is broad enough to protect the natural, with existing management areas, scenic, historic, and cultural features” (FSH comply with FSM 2353.44b(7) through 1909.12). FSM 2353.44 b 2. (e) states “Identify and the use of the Scenery Management preserve significant natural….resources along System without designating sections of the CDNST ‘corridor’ that traverse the management areas that must be done unit.” in a Forest Plan revision, and be The CDNST Comprehensive Plan Federal Register compatible with existing GMUG Forest Notice states: “land management plans must Plan requirements (GMUG Forest Plan prescribe desired conditions, objectives, standards at III-82 to III-83) regarding the CDNST. and guidelines for the CDNST corridor…” A Additional conservation measures are protected corridor is needed on the segment of trail included for the protection of lynx in under consideration from La Garita Wilderness to compliance with the Southern Rockies Windy Peak and northward, not only to fulfill the Lynx Amendment. provisions above, but because the trail is located in a critical lynx movement corridor, identified for Forest Plans will not be amended at this protection in the recent Region 2 lynx decision time for the addition of a CDNST document. management area for the same reasons While a protected corridor here might conflict with that we are not preparing a unit plan: existing Forest Plan management prescriptions such • This proposal deals specifically as timber management, we recommend that the with the alignment/realignment Forest Service proceed with corridor designation of only one segment of trail not now and not wait for Forest Plan revisions. management of the trail as a Establishing this protective corridor now is important whole. to ensure that nothing occurs in the near future that • The CDNST in Colorado is might prohibit or limit corridor establishment. If this often on the crest of the requires modification of the timber management Continental Divide which also prescription through a Forest Plan amendment, it happens to be the boundary of should be done. If a corridor is not established now administrative units (forest). In the future of the CDNST in this location is in Colorado this will require question. The Rio Grande National Forest has multiple forests and districts to language in its current Forest Plan which requires all have the same vision for its areas around National Scenic trails to be protected management. to preserve a visual corridor. The most appropriate time to do a CDNST management area would be during a land and resource management plan revision because of the wide-spread impacts across management areas. Law or Policy Forest Service violated NEPA by failing to publish The Forest Service has prepared this notice in the Federal Register of this project EA in compliance with NEPA. NEPA because it is of national interest and further failed to (40 CFR 1506.6(b)(2)) does not require

177 Resource Area Summarized Comment Agency response comply with NEPA because it did not notify IMBA that all projects of be sent to all possible (who has a national level MOU with the Agency) and commenters. It does require that American Hiking Society. actions with “effects of national concern” include Federal Register publication and notice to national organizations who have made such a request. The environmental review of this proposed realignment of the CDNST has not shown anything other than effects primarily of local concern consistent with the preparation of an EA (40 CFR 1508.9, 36 CFR 220.7) which does not require publication in the Federal Register. Additionally, the preparation of the EA has solicited wide public involvement including publication on the internet (40 CRF 1506.6(a)). By virtue that commenters did have the opportunity to submit comments during the 30 day official comment period and are also eligible for appeal of the decision due to their submittal of comments, there is no violation of NEPA particularly since commenters have not requested to be on the hardcopy mailing lists of the Districts or Forests affected by the CDNST in this area pursuant to 40 CFR 1506.6b(1). The pre-decisional EA is not clear why Alternative 2 Law and Policy is preferred over Alternative 3, resulting in the EA has been updated with Laws, exclusion of mountain bikes on the proposed re- Regulations and Policy. EA has route. Although the intent of the CDT is primarily for considered whether or not a substantial hiking and horseback riding, biking may be allowed interference with the nature and “if the use is consistent with the applicable CDNST purposes of the Act would occur with unit plan and will not substantially interfere with the the inclusion of bikes. nature and purposes of the CDNST (FSM 2353.42)”. The pre-decisional EA declares that "in general Law and Policy terms, bicycle use on the CDNST is not consistent EA has been updated with Laws, with the overall objectives for the CDNST" (p.28). Regulations and Policy. EA has We entirely concur with this statement, which considered whether or not a substantial properly reflects the Comprehensive Plan's interference with the nature and description of the nature and purposes of the purposes of the Act would occur with CDNST -- namely, "to provide for high-quality the inclusion of bikes for both physical scenic, primitive hiking and horseback riding and social impacts . EA has also been opportunities and to conserve natural, historic, and updated with best available science cultural resources along the CDNST corridor." regarding impacts of users [referenced in FSM 2353.42] The legislative and administrative record speaks of the trail as a simple facility for foot and horseback use. In this regard, refer to the 1976 study report of the Bureau of Outdoor Recreation (quoted in the Comprehensive Plan) – "one of the primary purposes ... would be to provide hiking and horseback access to those lands where man's impact on the environment has not been adverse to a substantial degree and where the environment remains relatively unaltered.... . The Continental Divide Trail would be a simple facility for foot and horseback use...." The same understanding is

178 Resource Area Summarized Comment Agency response confirmed in the Forest Service's adoption of a final environmental impact statement that refers to adverse impacts that would occur for some of the trail segments due to anticipated increased use by hikers, horseback riders, and pack animals. (46 Fed.Reg., 39867, Aug. 5, 1981) Several potential adverse impacts associated with mountain biking are outlined at page 28 of the EA. We agree with the discussion there, but would elaborate on the social effects that are of particular concern. The survey data provided by Mr. Appel (p.22) shows that the current CDNST route already attracts significant, and increasing, mountain bike use. We consider it very likely that if the CDNST were realigned as proposed, with adoption of Alternative 3, mountain bike travel would mushroom. If it were once established, any efforts to limit or prohibit it might, as a practical matter, be in vain. (Consider the precedent of mountain bike use on the CDNST between Monarch Pass and Marshall Pass.) It is extremely important to maintain the opportunities for solitude and unhurried appreciation of the scenery along a long-distance continuous Trail. For many – and probably most – users, it is these qualities that attract them to undertake the challenge of the CDNST. These are the qualities that offer the "maximum outdoor recreation potential" contemplated by the National Trails System Act. This route should be managed in a manner faithful to its special designation as a national scenic trail and as a component of the National Landscape Conservation System – not just as another Forest trail. An emphasis on the uses mentioned in the history of the CDNST and the Comprehensive Plan will encourage hikers and horsemen to enjoy the experience that the Trail offers; mountain biking (as well as other potential incompatible uses) might lessen its attractiveness, with the result that some of the intended users will be dissuaded from setting out on the CDNST. The Forest Service can accommodate the desires of bicycle users elsewhere while reserving the CDNST for foot and equestrian travel. Although bicycle use may be allowed on the CDNST in certain instances, in this case it would substantially interfere with the nature and purposes of the CDNST, for the reasons set out above. Law and We strongly support trail use, construction and Policy (FSM 2353.44b(9)) directs that Policy/Trail design that will not substantially interfere with the generally the CDNST should be Management and nature and purposes of the CDNST. We believe designed for either Trail Class 2 or Trail Design that a mountain bike trail, especially one constructed Class 3 with a designed use of Pack to current standards for mountain bike trails, is not in and Saddlestock. Both of these trail accord with the essentially rustic and backcountry classes and associated design features quality intended for the CDNST. Due to the torque, are very similar for either hikers or speeds, wheel grinding and other impacts of mountain bikes (see Appendix B). mountain bike wheels, trails standards will have to Allowing horse uses which is also be higher up on the Trail Classification System compatible with the Act increases the scale, including wide, reinforced and hardened trails, footprint of the trail beyond what is discordant with the primitive, natural feel of trails needed for either hikers or mountain

179 Resource Area Summarized Comment Agency response called for in the CDNST directives and desired by bikers. Slope (grade) is not expected to most CDNST trail users. be a factor in the design as it is estimated at less than 10% for the proposed alignment. There is no requirement in these trail classes for a hardened surface if bikes were allowed. AHS is very concerned with the fact that the project Law and Policy did not comply with the public participation Commenter is confusing the Federal requirements of the National Environmental Policy Register requirements of NEPA with the Act (NEPA), and the Forest Service Manual (FSM). requirements for relocating the CDNST. Both NEPA and the FSM specify that notice will be Notice in the Federal Register is provided in the Federal Register, yet in this case, no required for substantive reroutes of the such notice was posted. We could also argue that CDNST. Since this portion has yet to NEPA dictates that the Forest Service should have be located and published in the Federal directly informed AHS about the possible action and Register, this is not considered a comment period. The Council on Environmental substantial reroute requiring Federal Quality has published regulations stating that notice Register notice publication. It will of actions “with effects of national concern” are to be however be initially published by the published in the Federal Register and that they also Chief of the Forest Service. require “notice by mail to national organizations reasonably expected to be interested in the matter.”i The rerouting and management of the CDNST certainly should be viewed as having effects of national concern. The fact that the CDNST has been designated as a National Scenic Trail and is already a part of the National Trails System clearly demonstrates this. National Scenic and Historic trails historically draw users from across the country and area often seen as an international destination as well. The FSM requires the Regional Forester to approve the location of National Scenic Trails and publish notices in the Federal Register. ii The Manual goes so far as to state that the Regional Forester is required to publish “non-substantial relocations” of National Scenic Trails in the Federal Register .iii The Forest Service should have provided notice by mail to AHS. I am concerned with the public notice and comment Law and Policy process. It is my understanding that there was an A corrected legal notice had been error in the original publication of the notice and it published in the newspapers of record has been corrected to allow for additional input. for the Forest Supervisors during the While I appreciate the Forest Service taking a comment period; thereby extending the proactive approach to correcting the deficient notice comment period. The pre-decisional EA process, I am further concerned that such notice was circulated to the mailing lists could have been more thoroughly published. While including media contacts and posted to the local citizens certainly will want to have the internet. Over 900 comments were considerable input and should drive the decision- received from l across the U.S. and making process, this is a nationally designated Canada. Approximately 15 local and recreation asset. There are potential user groups national interested user groups across Colorado and around the country who would responded. be greatly interested in the planning process. To that end, I believe that the path the Forest Service takes will have regional impacts, if not national, and accordingly, it would have been helpful to publish the notice in additional publications such as The Denver Post or the Federal Register. I support for Alternative 2, which restricts allowable Law and Policy uses to hiking and horseback riding. This alternative EA has been updated with Laws, best supports the nature and purposes of the Regulations and Policy. EA has CDNST. If the intent is “to provide for high-quality considered whether or not a substantial

180 Resource Area Summarized Comment Agency response scenic, primitive hiking and horseback riding interference with the nature and opportunities and to conserve natural, historic, and purposes of the Act would occur with cultural resources along the CDNST corridor.” the inclusion of bikes. EA has also been Bicycle traffic is not consistent with a primitive updated with best available science experience. With time, bicycle-churned tread regarding impacts of users becomes undesirable, and the speed of bicycle travel keeps bicycles on your mind, even when they are not there. It is the possibility that they can appear that is unnerving. The predecisional EA includes the vague statement Law or Policy that "In general terms, bicycle use on the CDNST is This has been updated in the EA. not consistent with the overall objectives for the CDNST." Please list the overall objectives of the CDNST and specifically how this EA claims that mountain bike use is not consistent with these objectives. Otherwise, remove this statement from the EA. Law or Policy Forest Service violated the Agency’s policy The Forest Service has reviewed the (Delegations of Authority in FSM 2353.44) in the EA Delegations of Authority regarding by designating the District Rangers as the selection of alternatives that prescribe Authorized Officers for a decision on the allowable uses of the CDNST and found that use(s) of the CDNST. commenter is correct. Only the Regional Forester can approve non- substantial relocations of National Scenic and National Historic Trails (FSM 2353.04g(3)(b)(6)). The Forest Supervisors have been delegated the authority to prescribe the allowable uses of the CDNST (FSM 2353.04i(13)(b,c)). Correct newspapers of record were used for publication of the comment period in accordance with this delegation of authority. This has been corrected in the EA. District Rangers have the authority to approve the Trail Management Objectives (FSM 2353.04(j)) consistent with the Forest Supervisors decision on use. The EA does not detail the CDNST unit plan nor Law and Policy document substantial interference with the nature EA has been updated to address the and purposes of the CDNST that provides impacts of alternatives on “nationally justification for not selecting Alternative 3 as the significant scenic, historic, natural, or preferred alternative. cultural qualities of the areas through which such trails may pass” (16 U.S.C. 1242). Forest Supervisors’ decision will document consistency with The Act. A Unit Plan for the CDNST is not being developed at this time for the following reasons: • This proposal deals specifically with the alignment/realignment of only one segment of trail not management of the trail as a whole. • The CDNST in Colorado is often on the crest of the

181 Resource Area Summarized Comment Agency response Continental Divide which also happens to be the boundary of administrative units (forest). To do a unit plan in Colorado will require multiple forests and districts to all have the same vision for its management. It has been suggested for Colorado in particular that the Unit Plan be more of a regional effort. • The EA has been updated to include analysis of the applicable requirements of a unit plan in FSM 2353 that would apply to just this segment. • Along its entire 3100 mile length there have been no CDNST unit plans developed to date. • The most appropriate time to do a unit plan would be during a land and resource management plan revision because of the wide-spread impacts across management areas. Law or Policy Mountain bike use in this area is consistent with To determine the consistency with these National Trails System Act (16 U.S.C. § 1241 et laws and policy for this segment, the EA seq), March 1977 Continental Divide Study Report has been updated to address the and The 2009 Continental Divide National Scenic impacts of alternatives on “nationally Trail Comprehensive Plan. significant scenic, historic, natural, or cultural qualities of the areas” through which the proposed trail may pass (16 U.S.C. 1242).

Law or Policy EA doesn’t detail CDNST unit plan requirements EA has been updated to address the (FSM 2353.42) nor document substantial impacts of alternatives on “nationally interference with nature and purposes of the CDNST significant scenic, historic, natural, or thereby not providing justification for selecting cultural qualities of the areas through Alternative 2 as the preferred alternative. which such trails may pass” (16 U.S.C. 1242). A Unit Plan for the CDNST is not being developed at this time for the following reasons: • This proposal deals specifically with the realignment of only one segment of trail not management of the trail as a whole. • The CDNST in Colorado is often on the crest of the Continental Divide which also happens to be the boundary of administrative units (forest). To do a unit plan in Colorado will require multiple forests and

182 Resource Area Summarized Comment Agency response districts to all have the same vision for its management. It has been suggested for Colorado in particular that the Unit Plan be more of a regional effort. • The EA has been updated to include analysis of the applicable requirements of a unit plan in FSM 2353 that would apply to just this segment. • Along its 3100 mile length there have been no CDNST unit plans developed to date. • The most appropriate time to do a unit plan would be during a land and resource management plan revision because of the wide-spread impacts across management areas. Law or Policy CDTC recommends the inclusion of a management A ½ mile buffer (corridor) for the area for the CDNST and suggests the following protection of visual resources is a desired condition for the CDNST Corridor: CDNST stipulation that is being applied to all desired conditions should include a recreation action alternatives for this proposed experience not materially different in quality than segment of the CDNST (Chapter 2 and that extended by a bona fide hiking and equestrian Chapter 2). This conservation measure trail and one that is quiet, in a wild and primitive has been designed to be compatible setting, with a natural surface and narrow in width, with existing management areas, that harmonizes and compliments the surrounding comply with FSM 2353.44b(7) through landscapes and one where travel is at a slow pace. the use of the Scenery Management System without designating management areas that must be done in a Forest Plan revision, and be compatible with existing GMUG Forest Plan requirements (GMUG Forest Plan at III-82 to III-83) regarding the CDNST. Forest Plans will not be amended at this time for the addition of a CDNST management area for the same reasons that we are not preparing a unit plan: • This proposal deals specifically with the alignment/realignment of only one segment of trail not management of the trail as a whole. • The CDNST in Colorado is often on the crest of the Continental Divide which also happens to be the boundary of administrative units (forest). In Colorado this will require multiple forests and districts to all have the same vision for its management. The most appropriate time to do a CDNST management area would be

183 Resource Area Summarized Comment Agency response during a land and resource management plan revision because of the wide-spread impacts across management areas.

Law or Policy The CDNST Comprehensive Plan was set forth as A section on Laws, Regulation and policy in 2009. This policy direction is the Policy has been added to the EA. implementation of the National Trails System Act and is the over arching policy incorporated into Forest Plan direction and project proposal evaluation. CDTC commends the USFS for implementing the following policy direction as stated in the CDNST Comprehensive Plan to achieve the desired condition of the CDNST.

Law or Policy 1) Manage the CDNST to provide high-quality A section on Laws, Regulation and scenic, primitive hiking and pack and saddle stock Policy has been added to the EA. opportunities. Backpacking, nature walking, day hiking, horseback riding, nature photography, mountain climbing, cross-country skiing, and snowshoeing are compatible with the nature and purposes of the CDNST. (2) Bicycle use may be allowed on the CDNST (16 U.S.C. 1246(c)) if the use is consistent with the applicable land and resource management plan and will not substantially interfere with the nature and purposes of the CDNST.

Law and Policy We particularly acknowledge and appreciate your Comment noted. emphasis upon this facility as a national scenic trail, with special Congressional designation and goals, a trail envisaged as a simple facility for foot and horseback use. We do not support Alternative 3 for this new Law or Policy segment of trail. Although we generally support quiet EA has been updated with Laws, use recreational activities including mountain biking, Regulations and Policy. EA has and many of our members are mountain bikers, we considered whether or not a substantial do not think that all activities are appropriate for all interference with the nature and locations. We do not think that allowing mechanized purposes of the Act would occur with use on this particular segment of proposed new trail the inclusion of bikes. is appropriate. Allowing mechanized use on this new segment of the CDNST would conflict with the designated primary purpose of this trail as a high quality primitive hiking and horseback trail. Constructing this new trail to properly and fully Law and Policy accommodate bicycle use would require higher EA has been updated with Laws, levels of trail design standards and parameters Regulations and Policy. EA has which would be more difficult and costly to construct considered whether or not a substantial and maintain and have greater impacts on natural interference with the nature and and visual resources. We feel that constructing a purposes of the Act would occur with new route open to bicycle use will substantially the inclusion of bikes. EA has interfere with the nature and purposes of the considered best available science CDNST. Some individuals seeking a primitive trail regarding social and resource impacts. experience have expressed feelings that None of the readily available science encountering mountain bicycles detracts from this suggests a relationship to clothing of experience. They have stated that mountain bikes bikers affecting horses. We would are large visible metal mechanical implements not assume that a biker’s physiological conducive to a primitive experience. Mountain bikers response on a horse would be similar to often wear helmets and other gear which make them that of other animals which we have

184 Resource Area Summarized Comment Agency response appear less human. Some bicycles and the clothing discussed under wildlife comments the riders wear often include bright, unnatural colors. below. Some mountain bikers are more focused on an internal sensation based riding experience (based on the physical exertion, speed, and skill required to negotiate a trail and the feelings derived from that) as opposed to a more external nature based experience sought after by most hikers. The CDNST Comprehensive Plan and FSM 2353 Law and Policy state that backpacking, nature walking, day hiking, EA has been updated with Laws, horseback riding, nature photography, mountain Regulations and Policy. EA has climbing, cross country skiing, and snowshoeing are considered whether or not a substantial compatible with the nature and purpose of the interference with the nature and CDNST. Mountain biking is specifically not listed. purposes of the Act would occur with While mountain biking may be allowed on segments the inclusion of bikes. of the CDNST, mountain biking is not part of the intended nature and purpose of the CDNST. This proposal was driven by a need to establish a trail with a location, character and use-designation consistent with the purposes and intents of the CDNST system. The proposal seeks to move the existing CDNST route off roads and closer to the actual continental divide, and to establish a high quality primitive trail open for hikers and horseback riders. The purpose and need for this trail is not driven by a demand or requirement to establish a new route for mountain biking. Thus, while we recognize that it might be desirable for some if this new trail allowed mountain bike use, there is no purpose or need to accommodate mountain bike use in this proposal. We think that, given the choice, constructing a new trail for mountain bike use in this area is not near the top of the priority list for the mountain bike community. We have supported, and will continue to support, appropriate proposals for new mountain bike trails from the mountain bike community. We have not been aware that constructing this particular segment of trail was being proposed by mountain bikers. We fully support all alternatives prohibiting Law and Policy motorized use on newly constructed CDNST There are no proposed alternatives that segments The 1997 memorandum from the Deputy have motorized use. The existing Chief of the Forest Service to Regional Foresters alignment does have motorized use which is not desirable. clearly supports this by stating “Allowing motorized use on these newly constructed trail segments would substantially interfere with the nature and purpose of the CDNST.” This should include snowmobile use also. Law and Policy Mountain bikes were banned from designated The area of the proposed trail is outside wilderness in 1984. The Wilderness Act needs to be of designated or proposed wilderness; re-drafted to allow mountain bikes. therefore, this issue is outside the scope of this analysis. Additional information is provided to help understand the issue. Only Congress is able to designate wilderness. However, the Wilderness Act (P.L. 88-577, 16 U.S.C. 1131-1136) explicitly states “mechanical transport” is prohibited “except as

185 Resource Area Summarized Comment Agency response necessary to meet minimum requirements for the administration of the area for the purpose of the Act.” Commenters argue that the law has changed. It has not. Only agency interpretation in their own policy had changed based on technology present at the time. Mountain bikes did not exist at the time the Wilderness Act was promulgated in 1964 and were not mass produced until the 1980s. As a side note specific to Colorado, the pertinent language in the Wilderness Act was not changed in either the Colorado Wilderness Act of 1980 (P.L. 96-560) or the Colorado Wilderness Act of 1993 (H. R. 631 (103rd)) when mountain bikes were increasing in popularity. Many mountain bike groups have used this issue pertaining to the evolving agency definitions of “mechanical transport” over the past 50 years as a position on more recent wilderness designation. Many trail segments along the CDNST are in designated wilderness where mechanical transport (i.e., mountain bikes) is prohibited.

Law or Policy Trail should be designated in primitive or semi- In this area trail alignments are located primitive non-motorized ROS Classes to comply with in the roaded natural and roaded the 2009 CDNST Comprehensive Plan. modified environments for both the existing and proposed alignment. Existing roads and forest management have effected this environment such that this opportunity would be limited.

Law or Policy The 2009 CDNST Comprehensive Plan/SMS. The EA has been updated to include a requires that corridor be designated to protect visual conservation measure designating a resources.. corridor for the protection of visual resources (½ mile either side of trail coincident with the foreground view). This can be found in Chapter 2.

Law or Policy The Forest Service violated its own policy because Policy: The Regional Forester roles the Regional Forester has not published non- include per FSM 2353.04(g)(3)(b) “(2) substantial relocations of this trail alignment as Approving the location of these trails required by FSM 2353.04(g)(3)(b)(2 & 6) in the within the applicable corridor and Federal Register. signing notices for the Federal Register of availability of maps and descriptions of the location of these trails (16 U.S.C. 1246(a)(2) and (b))....(6) Approving non- substantial relocations of National Scenic and National Historic Trails, publishing required notices in the Federal Register, and referring recommendations for substantial relocations to the Chief (16 U.S.C. 1246(b))...” Response: While this may be

186 Resource Area Summarized Comment Agency response considered a reroute of the CDNST because there is an existing alignment, it is technically the initial location of the trail. Currently 2400 miles of the 3100 mile CDNST has not been “located” with Federal Register publication. This segment is one of the currently unlocated segments. Because no initial location has been published, there is no “non-substantial relocation” to publish in the Federal Register until such time as a decision has been made by the Forest Supervisors under the delegated authority of the Regional Forester and it goes through the agency’s NEPA appeal process. Then the route information will be forwarded to the Chief of the Forest Service for inclusion in the documents awaiting publication in the Federal Register for initial location.

Recreation Access

Recreation Access Mountain bikes are allowed on other parts of the Many segments of the CDNST do allow CDNST. They should be allowed here. the use of bikes when not located in designated wilderness. This particular segment is being analyzed as it relates to compliance with law, regulation and policy based on environmental impacts of the alternatives and will result in a joint decision by Forest Supervisors on whether or not to allow bikes. Leave CDNST alone and let the foot travellers have Recreation Access the trail. We have other bicycle trails made just for Comment noted. us two wheelers as it is and we need to stay and work on our trails and improve them. The CDNST is too complicated with very few take outs when we get on the trail. It’s for hikers only who can stay for an extended time and can go farther than us bikers. Trailheads need to be properly managed. New Recreation trailheads that are constructed for the CDNST CDNST and CT in this area are Management and should be primarily for hiking and pack and saddle coincident. Trailheads would be of Access access to the CDNST trail. The EA identified safe minimal size (holding approximately 5 public access to the trail at Highway 114 as an vehicles each). There are other identified need. The primary purpose of these reasons for including a toilet such as trailhead facilities should not include serving as minimizing the human waste issue that campgrounds, rest areas or to facilitate motorized is already an environmental problem at use of the trail or surrounding lands. The CDNST North Pass. There is no intent to make Comprehensive Plan states that “Any development these trailheads winter facilities or to of and associated facilities for the CDNST should be provide sufficient space for staging with minimal and appropriate for hiker/pedestrian and trailers for motorized access. pack and saddle stock use.” “A trailhead is defined as a facility provided solely for the trail user to transfer from motorized highway travel to non- motorized or motorized trail travel; as such, the site is primarily for informational services, parking vehicles, rigging pack animals, and restroom facilities. A trailhead is not intended as a site for picnicking or camping.”

187 Resource Area Summarized Comment Agency response Any development of and associated facilities for the CDNST should be minimal and appropriate for hiker/pedestrian and pack and saddle stock use. All of the new proposed trailheads should clearly be marked as no camping areas, they should not allow OHV unloading, and any spur trails leading from these trailheads to the CDNST itself should be designed and available for hiking and horse use only. The EA does not fully account for the potential for the new trailhead/parking areas being used as parking staging areas for OHV use in summer or snowmobile use in winter. The EA needs to fully consider and account for the high probability that new trailheads, and the parking area and toilet at North Pass especially, will likely receive use by the public not related to trail use. These areas may serve as new parking areas for hunters, locations for dispersed motorized camping, parking/staging areas for OHV or snowmobile use, and or just temporary rest stops for drivers on Highway 114. The addition of a restroom at the proposed trailhead/parking area along Highway 114 especially will act as a magnet that will attract visits to this facility by drivers seeking to use this human waste receptacle. It is very likely that this facility will get most of its use by drivers, not CDNST users. The top of a pass is a natural place for drivers to stop to relieve themselves. A restroom located at a trailhead at the top of Kenosha Pass a few hundred yards off CO Highway 285 gets a very high volume of use, and this use is not due to the campground or Colorado Trailhead/parking area that it serves. It is also likely that those wishing to park a vehicle at this trailhead in order to access the trail may find all places occupied by people stopping to take a break from driving and/or to use the restroom, especially because of the small size of the parking area. Similarly, those wishing to use this parking area as a rest area or to stop and use the restroom may find it full of parked vehicles from trail users. We do not suggest these parking areas/trailheads be made larger than they are. Smaller parking areas will serve to indirectly limit use of this segment of trail which will help preserve its primitive character and nature. While we understand that sanitation is an issue at the top of the pass, it must be recognized that the primary purpose of a trailhead/parking area is supposedly for CDNST access as portrayed here. We think that the parking area and toilet at the top of the pass will likely receive more non-CDNST use than trail related use, although trail users will certainly benefit from it. Thus, while it is acceptable to consider the impacts of this facility in this EA, we do not think that the majority of funding for construction and maintenance of this facility should come from the limited trail specific sources. These trailheads and parking areas should not allow

188 Resource Area Summarized Comment Agency response overnight camping, parking for camping or dispersed camping, either in them or within a few hundred yards of them. They should prohibit OHV or snowmobile parking and staging. Only one or two vehicle parking spaces should be available for short term temporary use (15 minutes or less) at the Highway 114 area. The majority of parking spaces should only allow vehicle parking or use that is specifically related to trail use. CDNST parking should take precedence in the temporary parking spaces if all other spaces are occupied. If these trailheads/parking areas are created, allowable uses of these areas should be clearly defined and stated, and these areas should be properly signed and managed as such.

Recreation Access Thousands of miles of wilderness trails are only While designated wilderness areas do open to hiker/horses, so you need to allow mountain preclude recreational “mechanized bikes to access this portion of the CDNST outside of transport”, many other trails are open to wilderness. mountain bikes in the vicinity even though the opportunity for specifically non-motorized trails appears to be limited.

Alternatives

Alternatives Confusion has been expressed by several Clarification has been added to the EA. commenters over what facilities are included in each Alternative 5 was added to the EA to of the alternatives presented in the EA. include facilities such as trailheads to have a mechanized alternative that was comparable to Alternative 2. The Forest Service should adopt a modified version Alternatives of Alternative 3, providing for mountain biking use of Clarification has been added to the EA. the rerouted CDNST section and the infrastructure Alternative 5 was added to the EA to improvement included in Alternative 2. include facilities such as trailheads to have a mechanized alternative that was comparable to Alternative 2. Alternatives Several new alternatives were brought forward for The alternatives identified have been consideration that involved design standards or added to the EA for additional analysis specific alignment. and consideration. These have been addressed in Alternatives Considered in Detail and Alternatives Considered but Eliminated from Detailed Study It is unclear why Alternative 3 does not include the Alternatives proposed trailhead improvements at North Pass that This was an oversight in the EA. To is included in Alternative 2. The inclusion of keep alternatives as they were analyzed mountain bikes does not preclude the trailhead in the draft EA, this has been corrected improvements and would seem to be of benefit to all in the final EA with the addition of trail users if mountain bikes were included in Alternative 5. approved uses. Alternatives Many factors come into play in selecting the best EA has considered best alignment given location for the CDNST treadway. Proximity to the resource concerns (actively managed Continental Divide is one of these factors: as stated area) and removing trail from motorized in the Comprehensive Plan (IV.B.1.b.(3)), the trail routes. Chapter 3 considers trail setting shall be located as close to the geographic including views, roadless area, access Continental Divide as possible. But the route is to be to water, user experience. as far away as necessary to provide for "diverse

189 Resource Area Summarized Comment Agency response recreation appeal" (Ibid.) One aspect of this recreation appeal is enhancement of scenic viewing opportunities. So, if for example, the crest of the Divide is in a viewless forested setting, the location might well be adjusted to pass by a scenic outcrop at a somewhat lower elevation. In addition, from the hikers' perspective, it is important to avoid PUDs -- i.e. pointless ups and downs. Our experience, and feedback from hikers over the years, tells us that the use of contouring footways will often result in much enhanced recreation appeal. As the new trail passes "through predominantly forest cover" (p.23), with limited viewing opportunities, we believe this concern needs to be addressed. Opportunities for middle distance and background views of scenic features such as the La Garitas, the Sangre de Cristo Mountains, and Cochetopa Dome are to be welcomed, but there is no need to remain on the ridge of the Divide where subtended by forest vegetation (p.25). Monitoring

Monitoring Ban bikes if shared use doesn’t work. Use a The trail will be monitored for use monitoring protocol to determine effectiveness of conflicts after construction per agency shared use. policy.

Recreation Experience

Recreation Many commenters have expressed concern over the Desired recreational experience is Experience different recreational experiences of single-track trail unique to each user. riding compared to riding on roads. Commenters emphasized experiences on single-track trail as they relate to family, fitness, connecting with nature, wilderness experiences and safety. "Social effects of mountain bikes" are also included Recreation as a rationale for prohibiting use by mountain bikes. See Chapter 3 for discussion of social Experience Please describe what is meant by social effects. impacts. The limited amount of interaction between multi- Recreation modal trail users (that is, horses, mules, hikers and This segment of trail is in an area Experience bicyclists) on most remote trails I have been on are anticipated to have low to very low typically cordial, involve pleasant conversation and levels of use and would likely fit the celebrate the joy of outdoor experience. experiences had by commenters. See Chapter 3 for discussion of impacts. Mountain bikes are how experience Colorado Recreation Wilderness. Comment noted. We are assuming you Experience are referring to wilderness or backcountry experiences not using your mountain bike in designated wilderness areas. Bicyclists search for wilderness quality experiences, Recreation just like the hiker and equestrian. Bicycling is User is correct. Selection of either Experience entirely consistent with the nature and purposes of Alternative 2 or 4 removes trail the CDNST. Bicycling is common in Roadless Areas connectivity for bikes. EA has been nationwide. From the pre-decisional EA, “As part of updated. EA has considered whether or the proposed action, even with the construction of a not a substantial interference with the new trail alignment, the existing through route for nature and purposes of the Act would mountain bikes would be maintained, and so the occur with the inclusion of bikes. current opportunity is preserved.” Actually this

190 Resource Area Summarized Comment Agency response statement is not true. The maps show that a 2-mile section of the existing alignment is to be decommissioned. Although hikers/ horseback riders and Recreation motor/bicyclists can mix: their uses, their This segment of trail is in an area Experience experiences, the way they dress, the gear they use, anticipated to have low to very low their speed and mode of travel and what they enjoy levels of use. This conflict from heavy about a trail often are very different. These use is not anticipated. See Chapter 3 differences sometimes lead to conflicts, but more for discussion of impacts. often than not it is the hiker or horseback rider who will have their experience negatively impacted by a bicyclist than the opposite. Hikers know that they will always come out on a short end if they collide with a bicyclist wearing a helmet and perhaps other armor, traveling at a high rate of speed, and/or focused internally and on the immediate trail ahead. More often than not, it is the hiker who has to interrupt their walk, stop and step off the trail to avoid the collision. As one of the most remote and isolated segments of Recreation the CDNST in Colorado, hikers and horseback This segment of trail is in an area Experience riders already expect and anticipate this segment of anticipated to have low to very low the route to be one of the most isolated, little levels of use. This conflict from heavy traveled and remote in the state. Feelings and use is not anticipated. See Chapter 3 experiences of solitude, isolation, remoteness and for discussion of impacts. self-sufficiency are valued by hikers and horse riders in this area. Allowing bicycle use on this segment of trail may compromise these experiences for some hikers and horse riders. Recreation Our favorite places to ride in Colorado tend to be the Comment noted. Experience places that aren’t necessarily the most beautiful, but are more importantly, the least crowded. Finding a perfect campsite or a deserted campground is almost as important to us as finding a trail that is not shared with motorized use or also a trail that hasn’t seen a lot of horse or cow traffic. I can say that in conversations with some of the Recreation almost 300 Quiet Use Coalition members, many of This segment of trail is in an area Experience whom hike and ride horses, that bicycle use is anticipated to have low to very low already substantially interfering with the high quality, levels of use. This conflict from heavy scenic and primitive experience they expect on the use is not anticipated. See Chapter 3 CDNST. We have horseback riding members who for discussion of impacts. totally avoid and have been displaced from sections of the CDNST because they have had too many frequent negative encounters with bicycles. Hikers that grew tired of hearing “trail” or being brushed by ~300 or more bicyclists passing them on the ‘Crest’/CDNST north of this segment near Monarch pass, now will only use that route at dawn before the bikers begin to arrive. We do not believe that having to adjust one’s timing for use of a trail is conducive to a high quality experience for using that trail. This area is lightly used by all modes of recreation, Recreation so there is little chance of conflict between user EA has considered trail use and conflict. Experience groups. The mountain bikers who are on trails such EA has also considered whether or not as the proposed CDT/CT segment are looking for a a substantial interference with the quiet experience nature and purposes of the Act would occur with the inclusion of bikes.

191 Resource Area Summarized Comment Agency response Single track riding is a far superior experience over Recreation riding on dirt roads. It provides a much more Comment noted. Experience intimate relationship with nature. Biking affords those who do not have the time to Recreation hike a trail of this length the opportunity to complete Comment noted. Experience more of the trail in their available time. It also makes logistics and support more practical. For this particular section of trail, given its Recreation remoteness, we doubt that conflicts with other user EA has considered whether or not a Experience groups will ever be significant enough to warrant substantial interference with the nature keeping it closed to bikes. The EA states how few and purposes of the Act would occur people visit the current trail (see EA, page 21). That with the inclusion of bikes for both averages out to be a mere 5 hikers a day, 1 physical and social impacts. EA has mountain bike a day and .2 horses per day. We also been updated with best available would assume that on weekdays there would be science regarding impacts of users. light to no use on this trail. But even on the We believe proper trail design will weekends, this trail currently sees very light use. minimize conflict potential. We do not understand how these numbers can truly Commenter’s signing suggestions are justify that mountain bikes would “substantially valid. We will work with our partners to interfere with the nature and purpose of the trail.” determine what works best for this When theye are not visited that often. remote and likely little used site. On page 28 of the pre-decisional EA, the author discusses the social conflicts with mountain bikes-in our twenty-five years of mountain biking, neither one of us have had an encounter with a horseman as described above. We’ve had very few bad incidents with hikers as well. The vast majority of mountain bikers just don’t travel as fast as this statement suggests. We know there are incidents which still occur, but we just can’t accept the above statement as one that is such an issue that it warrants keeping mountain bikes off a trail, especially a trail like this one where it is highly unlikely you’d see another person or horse. Consider using the yield symbology sign again. Maybe IMBA and The Forest Service could work together and have signs posted at every trailhead stating that mountain bikes must not just yield but honestly we must STOP for oncoming horses and hikers.. We also think the sign should state that uphill traffic always has the right of way.

Recreation User conflict will occur, including displacement and The Act did not prohibit biking or Experience disruption of the hiking and quieter trail experiences. motorized uses. The Act (16 U.S.C. The look and feel of mountain bike riding, the 1242) describes that National Scenic speeds, sports gear, relationship to a machine and Trails “will be extended trails so located other aspects of the sport are incompatible with the as to provide for maximum outdoor contemplative, slower paced trail uses envisioned recreation potential and for the for the trail. conservation and enjoyment of the nationally significant scenic, historic, natural, or cultural qualities of the areas through which such trails may pass.” The 1976 Study Report further describes the purposes of the CDNST: “The primary purpose of this trail is to provide a continuous, appealing trail route, designed for the hiker and horseman, but compatible with other

192 Resource Area Summarized Comment Agency response land uses....One of the primary purposes for establishing the CDNST would be to provide hiking and horseback access to those lands where man's impact on the environment has not been adverse to a substantial degree and where the environment remains relatively unaltered. Therefore, the protection of the land resource must remain a paramount consideration in establishing and managing the trail. There must be sufficient environmental controls to assure that the values for which the trail is established are not jeopardized...The basic goal of the trail is to provide the hiker and rider an entree to the diverse country along the Continental Divide in a manner, which will assure a high quality recreation experience while maintaining a constant respect for the natural environment... The Continental Divide Trail would be a simple facility for foot and horseback use in keeping with the National Scenic Trail concept as seen in the Appalachian and Pacific Crest Trails. In 1977, a Legislative Final Environmental Statement (FES) describing the routes was prepared. Using the information from the Study Report and FES, Congress enacted the National Parks and Recreation Act of 1978 (P.L. 95-625, 92 Stat. 3467) which established the CDNST (16 U.S.C.1244) and amended The Act (P.L. 90-543). The amendment established and designated the CDNST “a trail of approximately thirty-one hundred miles, extending from the Montana-Canada border to the New Mexico-Mexico border, following the approximate route depicted on the map, identified as 'Proposed Continental Divide National Scenic Trail' in the Department of the Interior Continental Divide Trail study report dated March l977...Notwithstanding the provisions of section 7(c), the use of motorized vehicles on roads which will be designated segments of the Continental Divide National Scenic Trail shall be permitted in accordance with regulations prescribed by the appropriate Secretary….” (16 U.S.C. 1244). The basic goal of the CDNST is to provide hikers and horseback riders an opportunity to experience the diverse country along the Continental Divide in a manner that will assure a high quality

193 Resource Area Summarized Comment Agency response recreation experience while maintaining a constant respect for the natural environment.

Recreation As a unit of the National Trails System, and EA has considered whether or not a Experience congressionally designated resource, the project substantial interference with the nature proposal should include a fully evaluated section on and purposes of the Act would occur impacts to recreational experiences within, with the inclusion of bikes for both intersected by, or otherwise impacted by the physical and social impacts. EA has proposed project. We realize that each section of also been updated with best available the CDNST is unique with specific localized science regarding impacts of users. conditions; however, there should be consistent Appropriate trail design is expected to treatment of the Trail and its resources and the minimize user conflict and trail impacts experience regardless of where the Trail is located. Substantial Interference defined: A person is entitled to the right to enjoy his recreational pursuits without interference from others. In order for this interference to be considered a nuisance, it must be both substantial and unreasonable. The nuisance complained of by the user cannot be a petty complaint, but one that a reasonable person would find bothersome. It is simply not realistic in this day and age to equate Recreation "wilderness" experience with "no human contact." EA has considered whether or not a Experience That being said, we all enjoy days of solace and substantial interference with the nature solitude in our vast open expanses. This seemingly and purposes of the Act would occur nationwide push to limit or eliminate bicycle use is with the inclusion of bikes for both not only disconcerting, it is foolish. Eliminating a physical and social impacts. EA has large, dedicated group of end users from trails that also been updated with best available by necessity and design require user buy-in and science regarding impacts of users. "adoptiom" for long-term safety and enjoyment of all Alternatives 3 & 5 consider use of users is, simply put, bad management. mountain bikes. Recreation Moving the route off of roads and close to the Divide Comment addressed in Chapter 3 of Experience will represent a great improvement EA. More pointedly, the statements on Page 28 of the Recreation predecisional EA seem to be general in nature and EA has considered whether or not a Experience not necessarily particular to the area between Lujan substantial interference with the nature Pass and the La Garita Wilderness. The 31-mile and purposes of the Act would occur proposed reroute is very remote (200-plus miles with the inclusion of bikes for both from Denver) and is situated in gentle, rolling terrain physical and social impacts. EA has with no appeal of a continuous downhill ride. also been updated with best available science regarding impacts of users. Recreation True backcountry trail experiences are considered Comment addressed in Chapter 3 of Experience very important here in Colorado for all trail users, EA. and cyclists are no exception. Rerouting a section of the CDNST from valley roads closer to the Continental Divide along purpose built single track would challenge and excite cyclists as they attempt to ride the entire Colorado Trail, or undertake the massive Continental Divide Route. However, due to the trail’s inherent remoteness, it’s distance from any sizable towns, as well as rugged and difficult terrain, it is unlikely this section of the CDNST would see any more traffic from cyclists than other trail user groups. Concern about this section of the CDNST becoming overrun with cyclists is unwarranted.

194 Resource Area Summarized Comment Agency response Building a new single track trail to replace the dirt Recreation EA has considered whether or not a Experience road portion of the trail will make the backcountry substantial interference with the nature experience more enjoyable and will attract more and purposes of the Act would occur users. Mountain bike use will be a big part of the with the inclusion of bikes for both user base. To exclude them from this recreation physical and social impacts. EA has opportunity would be a disservice and a loss of trail also been updated with best available constituents that can help build, maintain, and science regarding impacts of users. manage the trail.

Mountain Bikers who might use this section of trail Recreation are likely to coexist with hikers and through hikers in Alternatives 3 & 5 consider the Experience that it is not a "fast" section of trail. Noise from use desirability or the new alignment for will be at a minimum. And Mountain Bikers, like bikes. through hikers, are looking for a quite peaceful wilderness experience that the Forest Service Road currently does not offer. I camp with my family at Lujan Pass quite often and go there for solitude and relaxation. I think this addition of trail would be great for the personal enjoyment of my family as well! In general, biking a well-constructed singletrack trail Recreation is preferred by mountain bikers over biking on a dirt Alternatives 3 & 5 consider the Experience road. Therefore, the proposed re-route would desirability or the new alignment for improve the experience for mountain bikers and bikes/bikepackers. bikepackers. Mountain bikes currently use most of The Colorado Recreation Trail (CT), much of which is in the national forest. EA has added information relative to the Experience Trail conflict on the CT is minimal, despite significant CDNST being coincident with CT in this traffic from hikers, horses and mountain bikes. The area. EA has considered whether or not CT is a great model that shows: 1) that mountain a substantial interference with the bikers cause no more tread impact than other trail nature and purposes of the Act would users; 2) user conflict is minimal and 3) that occur with the inclusion of bikes for both communities can work together for the benefit of the physical and social impacts. EA has trail, such as the Colorado Trail Foundation, IMBA also been updated with best available and others. science regarding impacts of users. The Environmental Assessment cites risks of social Recreation conflict and trail damage as the two reasons to EA has considered whether or not a Experience exclude mountain bikers. Each of these concerns is substantial interference with the nature unfounded. and purposes of the Act would occur with the inclusion of bikes for both physical and social impacts. EA has also been updated with best available science regarding impacts of users. Appropriate trail design is expected to minimize user conflict and trail impacts. Effects Analysis

Effects Analysis Address cumulative effects regarding the CDNST Many segments of the CDNST allow the experience and how an exception (use of mountain use of bikes when not located in bikes) to that use changes the over-all experience. designated wilderness. This is consistent with much of the CDNST/CT in Colorado and in CDNST other states. This concern was primarily stated by commenters who were opposed to mountain bike use on the CDNST. Cumulative effects have been added to the EA. Reduced trail mileage increases user density on Effects Analysis other trails. The segment of trail proposed for

195 Resource Area Summarized Comment Agency response decommissioning is not likely to result in user density increases on the new non- motorized (segment.

Effects Analysis Horses cause the most trail damage. Horses create EA has considered whether or not a a wider trail corridor and are less sensitive to substantial interference with the nature keeping a trail narrow. Horses also tend to churn up and purposes of the Act would occur and loosen rock which quickens erosion and makes with the inclusion of bikes. EA has also mountain biking and hiking awfully unpleasant. But been updated with best available even without horses on trails, it just takes a long science regarding impacts of users. We time to see signs of deterioration. Attention is now agree that most trail problems will occur being given to building sustainable trails instead of from lack of proper design. the previously poorly built or adopted old mining roads or social trails that were formed in the 1970’s Education and trail etiquette are vital to without any knowledge of trail building. The Forest increasing awareness of use impact and Service hasn’t built many new trails in Colorado over minimizing conflict with others. We rely the last twenty years, simply because they can’t on our user-group partners to help us to afford to utilizing the latest in trail building this. knowledge and every effort is made to build sustainable trails which will keep all non-motorized users happy. We also still see signs of old trail building techniques being used by various volunteer groups. These trails are just too steep and yes, ruts develop as you describe above but not because of mountain bikes, but because of drainage issues and erosion and of being too steep. More education and trail etiquette signage would help. Getting IMBA’s trail crew to help design and construct this trail would be great. We would do as much as we could to rally our friends throughout the state to help build this trail. The basis for the FS’s view on this matter is Effects Analysis delineated on Page 28 of the EA under the section EA has been updated (Background “Mountain bikes affect trail tread.” This section section) which includes the CT and CTF describes in three brief paragraphs two physical involvement in this trail and added impacts on the tread (entrenchment and wash Laws, Regulations and Policy boarding) and the perceived social effects of discussion. EA has considered whether encounters of mountain bikes with hikers and or not a substantial interference with the horseback riders. CTF believes some of these nature and purposes of the Act would effects are negligible. Additionally the CTF readily occur with the inclusion of bikes. EA has accepts its responsibilities under the CCSA to also been updated with best available maintain (including repair) the Trail including any science regarding impacts of users effects from mountain biking. The EA concludes with the following-“In general terms, bicycle use on the CDNST is not consistent with the overall objectives for the CDNST.” Mountain biking is recognized as an approved use of the CDNST as presented in the FS’s “The 2009 CDNST Comprehensive Plan”, September 29, 2009. Under Section “ IV. B. 5. b. (2) Policy states… Bicycle use may be allowed on the CDNST (16 U.S.C.1246(c)) if the use is consistent with the applicable land and resource management plan and will not substantially interfere with the nature and purposes of the CDNST.” The CTF does not see in the EA a clear explanation of why the FS wishes to disallow mountain biking under this Policy. The pre-decisional EAi s very biased against Effects Analysis bicycles and opinion-based. It is dependent on EA has been updated with best available science regarding impacts of

196 Resource Area Summarized Comment Agency response conjecture and may have reached erroneous users. conclusions based upon observations of trails adversely worn by motorcycle travel; poor trail design and maintenance, and weather factors. Mountain bikes can sometimes affect trail tread, but not to the extreme as the EA claims. Trail tread wear depends more on a number of factors such as soil type, weather conditions, trail design, and frequency of maintenance. It depends less on the type of use, whether horse, foot, or bicycle. If a trail is worn in such a way as described in the EA, all factors must be examined to discover how the situation should be remedied. In Montana, I have witnessed many trails wearing since newly constructed. All deterioration on non-motorized trails from the ideal of a flat tread has been through trail design and tread compaction combining to channel water down the trail. Trails with a lot of bicycle use have not shown adverse tread wear due to the type of use but instead to design and weather factors. This is true on the CDNST in Montana. Some sections have frequent bicycle use and some do not, but the tread wear is design and weather dependant. Prohibiting bicyclists to achieve mitigation of trail wear is really barking up the wrong tree. Trails need to be constructed with moderate grades, with channel water. Effects described in the pre-decisional EA are Effects Analysis indicative of poorly designed trails. When trails are EA has been updated with best properly designed using a full bench cut to allow the available science regarding impacts of water to flow across them instead of down the trail, users. this is not an issue. The trenching effect caused by horses, especially under wet conditions, is orders of magnitude greater than that caused by mountain bikes. Trenching caused by horses causes problems for mountain bikes because the pedals hit the sides of the trench. Mountain bikes are far less likely to use the trails under muddy conditions because of the extreme difficulty in doing so for any distance. The paragraph referring to bicycles causing a Effects Analysis hummocking effect similar to washboarding while EA has been updated with best going uphill is pure rubbish. Bicycles are human available science regarding impacts of powered, with a human engine capable of producing users. around 1/20th of a horsepower. Motorcycles are capable of causing the described hummocking effect. It appears as though the author has confused motorcycle trail damage with bicycling. EA states, "Another effect observed in mountain Effects Analysis bike trails in certain circumstances of slope and soils EA has been updated with best is the creation of washboard or hummocking effect." available science regarding impacts of This can occur on very steep poorly designed trails. users. It is typically caused by inexperienced riders on trails that get very heavy use. Trail gradient should be limited to 15%. A properly designed trail will enhance the experience for all users and minimize any conflicts between them. Effects Analysis Trailhead on 114 may see increased use of the area Trailhead location on 114 is located at as a road side rest stop and encourage use of the an area at the pass that is already CDNST in winter. receiving heavy use as a rest stop. There are currently no facilities to

197 Resource Area Summarized Comment Agency response address the human waste issue. It is not intended that the trailhead be plowed in winter to be used as a winter trailhead. Limited snow depth in this area generally would not encourage winter recreation activities. Forest Service also wishes to discourage winter use on the CDNST due to concerns regarding possible wildlife use of the area. If minimizing impacts to the trail were of primary Effects Analysis concern, horses would be prohibited. Please EA has also been updated with best consider that bikes may be the 21st century available science regarding impacts of equivalent of horses in terms of the public's choice users and ways to minimize impacts. of conveyance. Properly designed trails will suffer the least impact from all user groups so please mitigate through design rather than prohibition. Consider additional references/best available Effects Analysis science in your analysis. References cited by commenters have been reviewed and included in the References Cited or Reviewed section of the EA. The pre-decisional EA also discusses the impact of Effects Analysis "high volumes of traffic" but as the study has found, EA has been updated to better reflect over a period of approximately 1 month, there were low level of anticipated use. 236 hikers and 77 mountain bikers on this stretch of the CDNST, working out to be approximately 7.8 hikers/day and 2.5 mountain bikers/day (less than 1 user/hour during daylight hours). This is hardly a high volume traffic area. This is a section of trail that is remote and far from the Front Range and other population centers and has little user traffic. It is also hard to access so it is very unlikely that the volume of traffic will materially increase. It is primarily used by a limited number of thru hikers and thru bike packers. Management decisions in the proposed trail reroute Effects Analysis located on public land should be based on science, References cited by commenters have best available land management practices, and been reviewed and included in the should be inclusive to as many user groups as is References Cited or Reviewed section practical. of the EA. Another example of incomplete disclosure and Effects Analysis baseless prejudice against mountain bikes is found Chapter 3 has been revised to remove in the pre-decisional EA on page 29, "Some riders bias and address impacts in accord with may actually prefer the use of roads and more best available science. developed surfaces and less of a feeling of isolation, while others seek that experience." This is another speculative statement without any basis in fact. The idea that some user groups might prefer “roads and more developed surfaces and less of a feeling of isolation” is not limited to mountain bikers. This applies equally to horseback riders and hikers; however it is only used as additional justification to exclude bicycles from the proposed trail. Pre-decisional EA includes several items that need Effects Analysis to be corrected. First, the EA states that mountain Chapter 3 has been revised to remove bike use would have environmental effects. While bias and address impacts in accord with this is true, the environmental effects of foot and best available science. horse use are not discussed in any meaningful

198 Resource Area Summarized Comment Agency response detail. Environmental impacts of all trail uses need to be assessed particularly the cumulative effects of Alternative 3 relative to the other alternatives that do not allow bicycle use. Second, the EA states that the "'cross section profile' of trail tread used by mountain bike traffic is often rounded, or open horseshoe shaped." The EA states that this (the "cross section profile") can affect user experience. Neither the "cross section profile" nor the user experience statements are based on research or a scientific-based assessment. This information needs to be removed from the EA unless actual research or scientific-based assessment(s) are referenced to support the statements made in the EA. Third, the "hummocking effect" discussion is also not based on research or scientific-based assessment. This information needs to be removed from the EA unless actual research or scientific based assessment(s) can be provided that support the statements made in the EA. Mountain bikes are light and human powered, so Effects Analysis create very little damage to trails, especially in small Chapter 3 has been revised to remove numbers such as in the remote location of this bias and address impacts in accord with proposed segment best available science. Mountain bike use on the trail would have Effects Analysis environmental effects. While true, this statement is EA has been updated with Laws, misleading because it is incomplete. Mountain Regulations and Policy. EA has bicycles do have environmental effects, but so does considered whether or not a substantial every other trail use or activity in the forest. The interference with the nature and immediate and substantial albeit short term effect of purposes of the Act would occur with this plan is constructing the trail. The long term the inclusion of bikes. EA has also been environmental effects are mostly attributable to the updated with best available science design, construction and maintenance of the trail regarding impacts of users. IMBA’s and rather than any particular use. When a trail is others publications on trail construction properly designed the potential impacts from use are have been noted. CTF has also been substantially limited. There are comprehensive successful working with various non- publications on building sustainable trails that are motorized groups to collaboratively work available and should be used as references but are together on the CDNST/CT in Colorado. not cited anywhere in the Draft. Reports indicate that non-motorized users are collaborating to build and maintain trails that accommodate as many users as possible and get more people engage in outdoor recreation. In addition to the numerous reasons why the Draft Environmental Assessment falls short of the NEPA requirements there are a number of pragmatic reasons why this CDNST segment should be open to bicycle use. The current administration has made reconnecting Americans with the outdoors and increasing America’s overall physical fitness and well being a top priority. One of the goals of the White House and its initiative on America's Great Outdoors (AGO) is to “Enhance Recreational Access and Opportunities.”24 Allowing bicycles on remote backcountry trails, outside of designated Wilderness, is a very easy way to move in that direction. With 46.2 million participants cycling is only surpassed by running and fishing as American interest in the outdoors.25 Another goal of AGO is to “Engage Young People in Conservation and the

199 Resource Area Summarized Comment Agency response Great Outdoors”26 In outdoor participants ranging from six to seventeen, bicycling is the most popular activity.27 AGO represents a long-range plan to re- engage Americans as active and healthy stewards of our public lands, allowing bicycle use on backcountry trails is a step in that direction. If the Forest Service can not provide peer reviewed scientific justification showing that mountain bikes will substantially interfere with hiker and horse use of the CDNST bicycles should be allowed on the new segment of singletrack. Negative impacts of mountain bikes are identified in Effects Analysis the impacts on hikers and horseback riders, but AA has been updated with Laws, negative impacts of horse use, and to a lesser Regulations and Policy. EA has extent, hikers, are not similarly identified. The considered whether or not a substantial principal impacts of mountain bikes that are interference with the nature and identified are related to trail tread impacts and purposes of the Act would occur with potential negative encounters with other users. The the inclusion of bikes. EA has been impacts of mountain bikes to trail tread seem updated to discuss user conflict and somewhat overstated and ignore similar impacts best available science regarding from horses. In addition, the impact of all user impacts of users and minimization of groups is a function of the number of users and the conflicts and resource impacts through EA includes observational data that indicates that proper design. the number of users is relatively limited. Therefore, the potential impacts of mountain bikes to the trail tread would seem to be limited. The potential negative encounters between mountain bikers and other users again is a function of the number of users. It can also be mitigated by using good trail alignment to control mountain bikers’ speed and avoid “blind” corners. None of the impacts of mountain bikes appear to be significant or incapable of being readily mitigated and it could be argued that the trail tread impacts are no worse than those from horses. Mechanized wheeled use often loosens tread Effects Analysis surfaces and rut trails due to the continuous contact Chapter 3 has been revised to address with the ground, skidding, and rapid acceleration impacts in accord with best available which leads to erosion and exposed rocks (which science. are more easily traversed with wheeled suspension vehicles than on foot). Equines often times do not recognize bike or motorcycle riders as human, especially if the riders are wearing helmets, goggles or sunglasses, and brightly colored unusual clothing, and the encounter spooks the horses. All of these experiences are contrary to what many hikers and horseback riders expect from what is supposed to be a high quality, scenic and primitive experience on this trail. Further, on page 29 of the EA, it states: "Some Effects Analysis riders may actually prefer the use of roads and more Chapter 3 has been revised to remove developed surfaces and less of a feeling of isolation, bias and address impacts in accord with while others seek that experience." However, this best available science. statement is speculative and biased against mountain bikers. The assertion (which is made without factual basis) that some user groups might prefer “roads and more developed surfaces and less of a feeling of isolation” is not limited to mountain bikers. This idea applies equally to horseback riders and hikers. However, it is only used as additional

200 Resource Area Summarized Comment Agency response justification to exclude bicycles from the proposed trail. Recreation Opportunity Trail construction and maintenance can also be Recreation considered a recreation opportunity by mountain We agree that user groups often view Opportunity bikers who support the trail. With increased interest trail work as a type of recreation of this group, there is increased maintenance opportunity either directly as a type of capacity at little or no extra cost to the trail "sponsor" recreation in itself or in support of the or "owner," the USFS. User groups’ ownership of recreation opportunity sought. We also the trail through partnerships are much more agree that user group support is needed effective for design, construction and long-term for this trail to ensure sustainability. Use maintenance of a sustainable trail than the agency of volunteers is encouraged by The Act. trying to fund and maintain the trail with dwindling funds. This segment of the trail does not see high user Recreation volume and has the capacity to accommodate both In this area carrying capacity will Opportunity hikers and mountain bikers as does the Monarch primarily be constrained by physical Crest segment to the north. uses or conflicting uses which cause safety concerns, not by the ROS (ROS classes of roaded natural or roaded modified) setting where there is a high expectation of seeing others and ongoing management activities. Due to the low volume of projected uses and distance from metropolitan areas, this issue is more of an engineering concern as the design, alignment and sight- distance all respond to the safety issue. Effects on safety will be minimized though the selection of the proper trail class with the correct designed uses for this trail. Mountain biking attracts a diverse mix of people to Recreation the outdoors. For some, it is the preferred summer The EA has considered in detail three Opportunity access to trails. Please consider that mountain alternatives that allow mountain bikes bikers are among the compatible "other land uses". and two that do not that address commenters concerns. Recreation Mountain biking is a sport that has become popular The EA has considered in detail three Opportunity in the past 20 to 30 years and the Forest Service alternatives (No Action, Alternative 3 should consider the evolving uses of public lands in and Alternative 5) that allow mountain its management decisions to not exclude major bikes and two that do not (Alternative 2 groups. and Alternative 4) that address commenters concerns. Bicycle use is not a prevalent form of recreation in Recreation the immediate area of this trail right now. The pre- We agree that increased use of bikes is Opportunity decisional EA cites monitoring by Mr. Appel that likely to occur at least in the short-term. state that hikers (but not CDNST thru hikers) are the Accessibility for mountain bikes on this most common users of the area. This trail segment segment of trail will be determined is one of the most remote and least visited jointly by the Forest Supervisors upon segments of the CDNST in Colorado. We feel that review of consistency with laws the construction of a new long section of single track (including consideration of 16 U.S.C. trail open to bicycles can make this trail a bicycle 1246 which includes potential use of destination bicycles), regulation, policy and direction for management of the CDNST and in review of the effects to qualities identified in the National Trails System Act (16 U.S.C. 1242). Increased use of bicycles on a trail has great Recreation potential to negatively impact desired user Primitive (usually synonymous with

201 Resource Area Summarized Comment Agency response Opportunity experiences of hikers and horseback riders seeking wilderness) experiences are generally a primitive, remote experience. not consistent with a roaded natural or roaded modified ROS setting. Setting is remote in that it is not near metropolitan areas, but it does experience on-going management activities and there is an expectation that other users may be encountered. Semi-primitive recreation experiences (non-motorized trail activity) which have higher development and cross roads or highways (both the case under any of the action alternatives) may be provided in these management areas. The length of the trail at 31 miles± and minimal Recreation availability of water lends itself to day-use by Water availability/proximity has been Opportunity mountain bikes. The contrast of open grassland and considered along the trail. Commenter forested terrain has a great deal of appeal to those is correct water is scarce immediately could enjoy the entire length of this segment in one adjacent to trail and bikers are less day. likely to go off trail in search of water sources. Recreation opportunity of day use biking has been noted. Recreation Mountain bikers desire long trails as they can cover Alternatives 3 and 5 propose mountain Opportunity much greater distances than hikers. bike use of the trail. Mountain bikers will need to use existing access on motorized routes to create loop opportunities or go out and back as the southern end of the trail would dead- end at the Wilderness boundary. There are several entry/access points along the nearly 32 mile segment.

Recreation A groomed and hardened 30 mile mountain bike trail While it might become an attraction for Opportunity will most certainly become a destination ride, mountain bikes in the short-term, it is attracting a use that tends to run in packs, and not felt that this will be a long-term permanently altering the character of this segment destination attraction for mountain bikes and the purpose for which the CDNST was created. because it would require either an out There could even be pressure for races and and back experience or connecting with competitive events. existing roads to make a very long loop. Because of the remoteness of this segment it may be challenging to generate interest from groups willing to perform these duties in the long-term. This concern is compounded by changing forest conditions due to spruce beetle attacks that could result in increased need to cut downed trees (perhaps before construction even began) in the near future. Policy (FSM 2353.44b(9)) directs that generally the CDNST should be designed for either Trail Class 2 or Trail Class 3 with a designed use of Pack and Saddlestock. Both of these trail classes and associated design features are very similar for either hikers or mountain bikes (see Appendix B). Allowing horse uses which is also compatible with the Act increases the

202 Resource Area Summarized Comment Agency response footprint of the trail beyond what is needed for either hikers or mountain bikers. Slope (grade) is not expected to be a factor in the design as it is estimated at less than 10% for the proposed alignment. There is no requirement in these trail classes for a hardened surface if bikes were allowed. The CDNST should be kept only for foot trail travel. Recreation People that are hiking the CDNST have gone to a lot This segment has in recent years Opportunity of trouble, expense and inconveniences with what accommodated approximately 5 thru they are doing. They spend an extended a period of hikers per year. The remainder of days and weeks to hike these trails. Usually the foot hikers may be using the current route path is very narrow and only allows a single person for other reasons. Based on and not much room for moving out of the way. economics, there would be no reason to build a trail to accommodate only a few hikers per year. A primitive trail like that described is common in wilderness segments. This portion is not in wilderness it is in a roaded setting where users could expect to meet other parties and see evidence of forest management activities; therefore the trail design would be Class 2 or 3 not Class I as suggested by commenter. There are many roads and trails open to bikes and Recreation other vehicles in the Cochetopa Hills area, so By selecting any of the action Opportunity reserving a decent trail for hikers and equestrians alternatives a portion of what is currently will not deprive bikers of a place to ride. Bikers are open to all users would be closed to free to continue to use the existing patchwork of bikes. Since the CDNST and CT are roads and ATV trails in the area. But in regards to coincident in this area, it would also routing of trails, consideration of biker preferences close a portion of the CT having are secondary to the "nationally significant scenic, negative effects on that trail’s historic, natural, or cultural qualities of the areas continuous nature. There would also be through which such trails may pass." dual routes for non-motorized uses in the same vicinity. There have not been any nationally significant scenic, historic, natural, or cultural qualities identified in this proposed segment except along the road at Cochetopa Pass.

Recreation Inclusion of mountain bikes on this portion of the While it might become an attraction for Opportunity CDNST will become a destination attraction. By mountain bikes in the short-term, it is increasing the user base, there will also be a larger not felt that this will be a long-term volunteer base. destination attraction for mountain bikes because it would require either an out and back experience or connecting with existing roads to make a very long loop. Because of the remoteness of this segment it may be challenging to generate interest from groups willing to perform maintenance duties in the long- term. This concern is compounded by changing forest conditions due to spruce beetle attacks that could result in increased need to cut downed trees (perhaps before construction even

203 Resource Area Summarized Comment Agency response began) in the near future. The Cochetopa Hills are unique and undiscovered Recreation by many folks. There are few users in the hills off We recognize that mountain biking is a Opportunity the main full size routes (roads). The addition of a desirable activity that is increasing in singletrack trail traversing the area would be popularity. The No Action Alternative is welcomed. It would not be for the average biker, but less desirable for all non-motorized neither is the existing trail experience. users. Alternatives 3 and 5 of the EA address the inclusion of mountain bikes on a non-motorized trail which responds to this under-served recreation opportunity. Excluding mountain bikers from the rerouted section Recreation will be counterproductive and is unnecessary and Accessibility for mountain bikes on this Opportunity unwarranted. When the Forest Service recognizes segment of trail will be determined that multiple-use is the preferred approach, people jointly by the Forest Supervisors upon do not consider a trail to be their exclusive preserve, review of consistency with laws nor is there any basis for rule-oriented people to (including consideration of 16 U.S.C. become upset, because no rule is being violated. 1246 which includes potential use of The result is that non-motorized users of all types bicycles), regulation, policy and tend to get along. Selection of Alternative 2 will lead direction for management of the CDNST to the eventual deterioration of the rerouted section. and in review of the effects to qualities As the Environmental Assessment observes, “The identified in the National Trails System opening of a new segment of a National trail will Act (16 U.S.C. 1242). Volunteers and certainly attract new use for a period of time. Over partners would be used to plan, time this is expected to taper off ...” (P. 27.) The develop, manage and maintain trails (16 Environmental Assessment may not realize, U.S.C. 1250) which would result in however, the extent to which use is likely to dwindle reduced cost to the government after if mountain bikers are excluded from the rerouted the planning process is complete. section. Long distance self-supported mountain biking Recreation (bikepacking) and supported mountain biking is Bikepacking and supported mountain Opportunity increasing in popularity and the proposed re-route biking would be consistent with either provides an opportunity for these activities. The fact Alternative 3 or 5 as described in the that the re-route would also be coincident with CT, a EA. popular bikepacking route, for this segment, adds to the appeal. Excerpts from Page 29 states “Addition of the new Recreation trail for mountain bike use would offer a challenging Comment noted. Opportunity opportunity for mountain bike riders to use a single- track trail for long distances, instead of having to ride the series of connected roads that is now the route.” The EA must fully consider the potential for the trail Recreation to be used as a corridor for winter recreation and Winter recreation has been considered Opportunity travel. The EA seems to dismiss and downplay this in the EA. While it will not be prohibited, possibility, stating that the area may not receive this area will not be managed (no enough snow (16” was cited as an average snow plowing of trailheads or signing of trail) depth), and that it is in a remote location. The for winter recreation due to conflicts with potential for this trail and associated facilities to wildlife. receive winter recreational use still does exist. A snow depth of 16” is more than adequate to accommodate winter recreational activities of snowshoeing, cross country skiing and snowmobiling, especially on a cleared visible maintained trail corridor. A new 6’ wide cleared corridor with snow undisturbed by wheeled vehicle use would be potentially very attractive to snowmobile use. Climate change may result in more or less snowfall to this trail in the future. Large

204 Resource Area Summarized Comment Agency response storms and higher than average snowfall may make this area and trail more attractive as a winter snow sport destination. A plowed highway, and parking area with toilet will facilitate this. The human population of all counties surrounding this area is increasing along with participation in winter recreation. People are willing and often expect to travel long distances to access snow for winter recreation. Mountain biking is a very valuable component of the Recreation recreation economy. This segment of trail, while EA has considered whether or not a Opportunity/ remote, is close enough to Gunnison and Crested substantial interference with the nature Butte, areas recognized as mountain biking and purposes of the Act would occur destinations, that it could be a great addition to with the inclusion of bikes for both existing resources. For precisely the same reasons physical and social impacts. While it that this segment will improve the hiking and may become a destination, anticipated horseback riding experiences on the CDNST, there use levels are expected to remain at low is no justification given in the pre-decisional EA to levels. believe that excluding mountain bikers is necessary. Recreation There is a shortage of non-motorized mountain bike We recognize that mountain biking is a Opportunity trails in this region. The trend in Central and desirable activity that is increasing in Southern Colorado is to lump mountain bikes with popularity. The No Action Alternative is the dirt bikes on singletrack. Mountain bikes and less desirable for all non-motorized motorcycles sharing routes is not working because users. Alternatives 3 and 5 of the EA of the motorcycle damage on trails such as churned address the inclusion of mountain bikes up loose rock, rutting on steep slopes, trenches with on a non-motorized trail which responds puddles or silty, dusty trails. to this under-served recreation opportunity. Recreation Access and Management Expansion of "ownership" should be the goal' not Recreation Access exclusion - especially exclusion based upon flawed This discussion of opportunity (non- and Management hypotheses, questionable science and insufficient motorized trail v. hiker/horse only) has "real world" use data to support arbitrary and been revised in EA through capricious determinations of whom shall have consideration of alternatives and access and whom shall not. impacts. Recommend that any plan to manage this or any Recreation other segment of the CDNST severely restrict if not We agree. These types of special Management and prohibit all special events and special use permits events would affect the solitude that Access that might substantially interfere with the nature and would be expected on this type of trail. purpose of the CDNST. These events or permits Future possible events are outside the generally allow and facilitate plans that significantly scope of this analysis. However, increase use and users of the CDNST, and additional environmental review will be generally degrade the primitive characteristics of required if and when events are trail. Given the remote location of the CDNST in this proposed that use the trail. area, we do not think there will be much of a demand for special use or event permits in this area. The proposed re-route is not in Wilderness Area and Recreation Access there is no justification to ban mountain bikes in this This has been considered in Chapter 3. remote region. Since this proposed trail segment transitions to a Recreation trail in a designated Wilderness Area, allowing This trail connects to the Skyline Trail Management bicycle use on this new trail has the potential to before it enters the Wilderness allowing create management problems since legal bicycle an exit point back to roads to create a use is not allowed in Wilderness. loop. Other entry/exit points occur Since legal bicycle use is not allowed in Wilderness, where proposed trail crosses existing and there are no other trails open to bicycle use that roads. It is not felt that this will cause connect to this proposed trail, any bicycle rider any additional impacts beyond what is seeking a quality trail riding experience would have already occurring.

205 Resource Area Summarized Comment Agency response to use this new segment of trail as a less desirable out and back route. Too many roads are being illegally closed by the Recreation Access Forest Service and BLM on state lands without the This comment is outside the scope of mandated coordination with local governments. this analysis as no roads are proposed Roads are good for multiple reasons and the phony for closure. excuses regularly offered by federal personal claiming wildlife habitat is being adversely affected is demonstrably false. We have no shortage of wildlife and the people who live here know this. Other newly rerouted/constructed segments of the Recreation Access CDNST in the area, such as the segment from EA has been updated to consider both Cottonwood Pass South to Tincup Pass, are mechanized and non-mechanized non- prohibiting mechanized use. Allowed uses on this motorized uses. Specific multiple non- newly constructed segment of the CDNST should be motorized uses on this segment of trail similar. will be determined jointly by the Forest Supervisors upon review of consistency with laws (including consideration of 16 U.S.C. 1246 which includes potential use of bicycles), regulation, policy and direction for management of the CDNST and in review of the effects to qualities identified in the National Trails System Act (16 U.S.C. 1242). No substantial interference with the nature and purposes of the Act has been found which preclude the use of bikes on this segment. Recreation Access Numerous commenters have encouraged that the Specific multiple non-motorized uses on and Management trail proposal be managed for multiple non- this segment of trail will be determined motorized uses including mountain biking. jointly by the Forest Supervisors upon review of consistency with laws (including consideration of 16 U.S.C. 1246 which includes potential use of bicycles), regulation, policy and direction for management of the CDNST and in review of the effects to qualities identified in the National Trails System Act (16 U.S.C. 1242).

Recreation Access Many commenters have suggested that access to Accessibility for mountain bikes on this and Management mountain bikes should be granted because they are segment of trail will be determined tax payers paying for the route. jointly by the Forest Supervisors upon review of consistency with laws (including consideration of 16 U.S.C. 1246 which includes potential use of bicycles), regulation, policy and direction for management of the CDNST and in review of the effects to qualities identified in the National Trails System Act (16 U.S.C. 1242). Volunteers and partners would be used to plan, develop, manage and maintain trails (16 U.S.C. 1250) which would result in reduced cost to the government after the planning process is complete.

Trail Management and Design

206 Resource Area Summarized Comment Agency response Trail should be designed to allow other types of Trail Management bicycles such as backcountry handcycles (used by Trail design for any of the alternatives and Design parapalegics) and unicycles. may accommodate those special types of mechanized cycles even though a handcycle has a wider footprint (32”) than a normal mountain bike it is still narrower than the some of the required tread widths identified in this EA (Trail Class 3-Hiker, Trail Class 3- Horse, and Trail Class 3-Bike). The EA’s preferred alternative, Alternative 2, will Trail Management precipitate management problems for the Forest Accessibility for mountain bikes on this and Design Service, cause the rerouted trail to deteriorate over segment of trail will be determined time from lack of use and maintenance, and deny jointly by the Forest Supervisors upon mountain bikers access to a spectacular region for review of consistency with laws no discernible reason. (including consideration of 16 U.S.C. 1246 which includes potential use of bicycles), regulation, policy and direction for management of the CDNST and in review of the effects to qualities identified in the National Trails System Act (16 U.S.C. 1242). Volunteers and partners would be used to plan, develop, manage and maintain trails (16 U.S.C. 1250) which would result in reduced cost to the government after the planning process is complete. Socially all users of trails have a long way to go. All Trail Management trail users can be rude, act Comment noted. CDNST/CT has found and Design abruptly, and over react to others. These social similar success in certain areas of actions are not confined to any one Colorado. group. On the non-Wilderness portions of the Continental Divide trail in Montana, social problems are primarily a myth. Is this remote corner of Colorado that much different? I and other bicyclists spend a significant portion of our summers working with Back Country Horsemen on trail repair projects. We ride together, sometimes at different speeds, and team up on projects. It’s a win- win relationship. Both groups of recreationists have learned a lot and like the experience. Trail Management There is concern that if this segment is approved as We agree. These types of special and Design a mountain bike trail, the Districts will receive events would affect the solitude that pressure to use CDNST as a venue for races and would be expected on this type of trail. other special events that would affect the solitude of Future possible events are outside the the area. scope of this analysis. However, additional environmental review will be required if and when events are proposed that use the trail.

Trail Management Proper trail design minimizes impacts to natural and We agree with this statement. District and Design physical resources. Rangers will approve specific Trail Management Objectives (TMOs) (FSM 2353.04j) that include the appropriate design standards for the uses of the CDNST specified by the Forest Supervisors (FSM 2353.04i(13)(b) and

207 Resource Area Summarized Comment Agency response FSM 2353.44b (8-10)). Trail design can be used to minimize user conflict. It Trail Management can be stated that many users do not like sharing a Trail design has been addressed in and Design trail with other user groups but this should not be Chapter 3. Accessibility for mountain used to prohibit the newest, low impact user group. bikes on this segment of trail will be determined jointly by the Forest Supervisors upon review of consistency with laws (including consideration of 16 U.S.C. 1246 which includes potential use of bicycles), regulation, policy and direction for management of the CDNST and in review of the effects to qualities identified in the National Trails System Act (16 U.S.C. 1242). Trail Management This portion of the CDNST is currently coincident We have considered this comment and and Design with CT which allows bikes. To select an alternative added additional detail to Chapter 3. that prohibits bikes would be removing an existing use from this area.

Trail Management Commenters have indicated that if the trail were to District Rangers have also expressed and Design be hiker/horse only, then trail maintenance including this concern of availability of trail clearing would not be accomplished as it would maintenance. Because of the not be under the partnerships of the mountain biking remoteness of this segment it may be community. challenging to generate interest from groups willing to perform these duties. This concern is compounded by changing forest conditions due to spruce beetle attacks that could result in increased need to cut downed trees in the near future. Volunteers and partners would be used to plan, develop, manage and maintain trails (16 U.S.C. 1250) which would result in reduced cost to the government after the planning process is complete.

Trail Management Forest Service needs to properly sign routes for the This concern has been noted. and Design designated uses particularly where allowed uses changes.

Trail Management Educating users on trail etiquette and route We agree. This will require the and Design enforcement though the use of volunteer groups will participation of volunteer groups and minimize shared-use conflicts. individuals.

Trail Management Trail should be designed to: avoid pointless ups and Additional analysis has been added to and Design downs, enhance recreational appeal by contouring Chapter 3 related to design. footways, maintain views of middle distance and background views of scenic feature, and provide access to water sources. The proximity of the southern end of the relocation Trail Management to the La Garita Wilderness might result in illegal The southern end of the existing trail and Design incursion of mountain bikes in the wilderness area. would have this same concern as the existing Skyline Trail would be joined before the wilderness boundary. This analysis and decision have no bearing on those individuals who might choose to illegally enter the wilderness on

208 Resource Area Summarized Comment Agency response mountain bikes. Chapter 5 of the EA lists William Apple (Trail Angel) Trail Management as one of the individuals included in the EA Mr. Apple has been a trail angel and Design consultation process. I don’t know Mr. Apple or what (volunteer) on the existing mixed use his bias’s might be, however as the only non- route (No Action Alternative). His governmental individual listed in the consultation involvement in the preparation of the EA process, his role and influence on the EA should be was only to disclose his findings of disclosed. current use so the Forest Service might better analyze this segment. As outlined above, mountain bike use causes Trail Management significant tread damage to the trail requiring more Discussion of impacts on trails has been and Design frequent maintenance or a higher standard of trail revised in Chapter 3 to reflect best construction little short of building a miniature gravel available science. We have found that road, a standard which would be much more costly these types of impacts are most in terms of materials and construction labor. I have common in areas where there is personally witnessed the damage described in the improper trail design, excessively heavy EA and have, indeed, found that it degraded my use or as a result of motorcycle use. hiking experience. This trail should not be marked or maintained or Trail Management actively managed for winter use or as a snow trail. Motorized use of the trail will be and Design Snowshoeing and cross country skiing can and will prohibited. There is no intention of still be permitted on this route as an allowed other maintaining this trail or trailheads for use. The trail would still serve as the CDNST in the winter use due to impacts on wildlife. winter and get use by hikers/horses year round if We admit some use may still occur, but snow permits, even though it is not actively it will not be managed just like the rest maintained during the winter. Snowmobile use on of the forest in this area. this trail would substantially interfere with the nature and purpose of the CDNST and should thus be prohibited. Signage prohibiting this use should be installed at all potential access points. The CTF suggests that the FS consider using Trail Management mechanized construction equipment in rerouting this If access to a “trail dozer” is available to and Design trail. A trail machine could be used to 'rough out' the those constructing the trail we agree new tread. This would facilitate the ensuing hand that this is an option for more efficient work particularly considering the short, anticipated 2 construction. year period in which to complete the endeavor and its remote location Trail Management We strongly support the following points: not Commenters concerns support and Design/ increasing trail width, taking steps not to attract conflicting alternatives. Avoiding any Rcreation motorized and snowmobile use, avoiding any new new trail construction supports the No Management trail construction, and no special events permits. Action Alternative which has trails on motorized routes. Taking steps to avoid attracting motorized and snowmobile use supports Alternatives 2-5 through the designation of a non-motorized trail. Not issuing special use permits for events is outside the scope of a decision that is focused on location and designation of uses of a trail. And special use permits would be considered in separate analysis should they be proposed. Trail Management With proper trail construction and alignment, we We agree that mountain bikes may be and Design have found it possible to curb a cyclist’s speed or compatible with other non-motorized extend his/her line of sight, greatly reducing trail uses provided the trail is properly user conflict. designed and maintained and that use levels remain consistent with the

209 Resource Area Summarized Comment Agency response recreation setting. Mountain bikes are an acceptable use of the trail Trail Management Some social impacts are subjective and Design and are compatible with horses and hikers, based on the preferences of the user particularly in more remote backcountry settings as groups. Social impacts are generally proposed. categorized as either direct which includes interaction or encounters and indirect which includes litter, trail wear patterns and creation of social trails. We agree that mountain bikes may be compatible with other non-motorized uses provided the trail is properly designed and maintained and that use levels remain consistent with the recreation setting. Additional analysis has been added to Chapter 3. Construction of new trail segments and trail Trail Management improvements should be minimal EA has considered whether or not a and Design Chapter IV(B)(9) of the CDNST Comprehensive substantial interference with the nature Plan states “ Generally, segments of the CDNST and purposes of the Act would occur should fall into Trail Class 2 or 3 and have a with the inclusion of bikes for both Designed Use of Pack and Saddle Stock (FSH physical and social impacts. This area is 2309.18). However, a CDNST segment may fall into not proposed or considered capable of Trail Class 1, 2, or 3 and have a Designed Use of wilderness designation which suggests Hiker/Pedestrian where a substantial safety or that we wouldn’t have need of removing resource concern exists”. The Plan also states “The use. While it may become a destination, travel route itself will be developed to no higher anticipated low use levels in this area standard than necessary to accommodate safely the are not anticipated to lead to the type and amounts of use anticipated or planned for exclusion of hikers or horseback riders. in any given segment.” EA has also been updated with best We suggest that this new trail be developed as a available science regarding impacts of Trail Class 2 trail (at best), and not be developed as users. Acceptable Trail Classes and a class 3 trail. A Class 2 trail (or even leaning toward uses have been noted in the EA Trail Class 1 for certain segments) would better (Chapter 2) for each alternative. match the desired, expected and anticipated Recommendations for Trail Class have experiences of users in this area. This is one of the been made in Chapter 3. Proper trail most remote and little used segments of the CDNST design is vital to minimizing impacts. in Colorado and an isolated, remote and little used TMOs will be developed once a decision route through this area would be viewed by some as is made on the allowable use. This is a valuable resource. Minimizing trail development an engineering analysis that is not an for the CDNST in this area would add to a primitive appealable decision. less improved experience for this remote segment of trail and better compliment the character of the area. A minimally developed trail built to lower standards would be more visually appealing in this remote area, be easier and less costly to construct and maintain, have less impact on the land and resources, and still adequately serve the anticipated relatively low number of users expected for this segment of trail. An appropriate Trail Management Objective (TMO) should be developed for the new trail segments. Trail segments for this new trail must have completed TMOs. Trail segments should be managed for pack & saddle and hiking use. Mtn biking, motorcycles, ATVs and other motorized uses should be prohibited year round. The trail should be actively managed as open from July 15-Sept 15 each year, or some other appropriate and realistic

210 Resource Area Summarized Comment Agency response time period to coincide with times when the trail is free of snow and when maintenance can occur. This short time frame is due to the high elevation and remote location of this trail, and staffing/funding limits. Trail class should be 1 or 2, depending on the segment. Tread width can be 12-24”, but may be wider for shorter segments only when necessary to provide for safe passage of horses. Clearing width can be up to 6’ wide, with the understanding that light vegetation may (and should) encroach into this cleared area. The 31 miles will likely not be used in its entirety by Trail Management bikes since the logical exit point is approximately Comment noted. and Design midway at Saguache Park Road since there is no exit at the La Garita Wilderness boundary. Once a segment of trail is designated as open to a Trail Management certain mode of use, it is difficult if not impossible to EA has considered whether or not a and Design regulate the amount of use that trail will receive, substantial interference with the nature and/or exclude that mode of use from the trail in the and purposes of the Act would occur future. Bicycle use on this segment of trail has the with the inclusion of bikes for both potential to displace other users over time once it physical and social impacts. This area is reaches certain levels. Bicyclists, like other user not proposed or considered capable of groups, are willing to travel great distances to use wilderness designation which suggests certain routes. A 30 mile long trail specifically that we wouldn’t have need of removing constructed to appropriate design standards to use. While it may become a destination, permit mountain biking could easily become a anticipated low use levels in this area special and popular destination ride for large are not anticipated to lead to the numbers of mountain bikers. exclusion of hikers or horseback riders. EA has also been updated with best available science regarding impacts of users. Acceptable Trail Classes and uses have been noted in the EA (Chapter 2) for each alternative. Recommendations for Trail Class have been made in Chapter 3. Proper trail design is vital to minimizing impacts. If, for some reason, Alternative 3 is selected, we Trail Management suggest that the Trail Management Objective for this EA has been updated with Laws, and Design new trail list bicycling as an other accepted use and Regulations and Policy. EA has not a managed use. Management of the CDNST considered whether or not a substantial should creatively apply trail design features through interference with the nature and maintenance and construction to retain the primitive purposes of the Act would occur with nature of the trail and discourage use by other the inclusion of bikes for both physical unmanaged uses. Using water bars and check dams and social impacts. EA has also been instead of rolling dips, using tighter switchback turns updated with best available science instead of climbing turns, retaining rocky segments regarding impacts of users. Acceptable to keep wheeled vehicle speeds down, not actively Trail Classes and uses have been noted advertising that mechanized use is allowed on the in the EA (Chapter 2) for each trail, and other actions could be used to keep the alternative. Recommendations for Trail CDNST primarily as a high quality hiking and horse Class have been made in Chapter 3. riding trail. It should be noted that the language that Proper trail design is vital to minimizing allows mountain bikes on segments of the National impacts. Trails System does not necessarily refer to the CDNST, which is a more specialized specific part of the National Trails System. While we do and have generally supported increased opportunities for bicycling, we do not feel this proposed segment of trail should be one of them.

211 Resource Area Summarized Comment Agency response Since this trail will relocate a portion of CT it is Trail Management important to integrate the mission Discussion of co-location of the CDNST and Design statement/purpose of the Colorado Trail Foundation and CT has been added to the EA. that includes the use of non-motorized modes of transportation including mountain bikes. The CDNST current purpose and nature in the EA only addresses hiking and horseback riders, since this will become a significant section of CT it would be a grave oversight to not also include the use categories for CT. The vision for the CT is that it will be a non- Trail Management motorized trail from end to end. The CT coincides EA has been updated with information and Design with the Continental Divide National Scenic Trail regarding the CT and CTF as partner. (CDNST) for 314 miles of our approximate 566 miles including the entire distance of the relocation proposed in the FS’s October 2012 Environmental Assessment (EA). We act as managing partner and provide most of the trail construction and maintenance on the co-located trail including the segments of the proposed relocation. Note that our June 2012 “Challenge Cost Share Agreement Between the CTF and the USFS” (CCSA) states in part that the “CTF Shall…Accept the primary responsibility for the development, maintenance, continued improvement, and upkeep of CT” of which the before mentioned 314 miles are a part. We are grateful for the FS’s consideration of and proposal for the relocation. It will allow the construction of new, sustainable tread and will greatly improve trail conditions and the trail experience by removing the CT/CDNST from motorized trails and from trail segments where the trail tread has been damaged beyond repair by motorized use. Note that we were a party with FS representatives to an on-the-ground survey of the existing and proposed reroute and have discussed the proposed reroute with the USFS staff on several occasions. Trail Design and CDTC recommends the consideration of the In response to numbered statements: Management following principals in evaluation of this or any project affecting the CDNST as the route is actually 1. EA analyzed whether bikes would laid on the ground and suggests as the current cause a substantial interference with the proposed Trail route is evaluated and refined to nature and purposes of the Act to include the following: provide more informed decision-making. 1. Any proposed location will serve to protect 2. Proposed route will be moved off of the significant experiences and features that exist roads and motorized trails on or close to along the CDNST. the Continental Divide. 2. Any proposed location will establish the 3. Proper trail design will minimize best location for the CDNST through the most resource and social impacts. primitive, scenic, diverse and undeveloped 4. Water availability is addressed in the landscapes on or near the trail that will provide a EA. Due to the location nearer the crest wide range of experiences and challenges for the of the Continental Divide water is farther hiker and equestrian. from the trail alignment but accessible at 3. Any proposed location will adhere to several locations with a ½ to ¾ mile sustainable Trail design for the hiker/horseman and walk (access to water is often on minimize unnecessary elevation gains or losses in existing roads). place of graded trail location that maintains a 5. Location is consistent with general consistent grade. forest setting. Limited opportunities for

212 Resource Area Summarized Comment Agency response 4. Any proposed location will provide the user expansive views exist. There are no with adequate access to sustainable water sources “attractions” to speak of in the area. for hikers, equestrians and stock. 6. Existing location is being relocated 5. Any proposed location will highlight unique off roads to provide better experience. features of the terrain to provide a diverse set of landscapes and features for the user to enhance 7. Comment noted. This complies with their experience, this may include rock out crops, forest management of the trail. waterfalls, etc. 8. CDNST is coincident with CT in this 6. Any proposed location may allow for area. Partnerships are already in place existing trails to be considered for the final CDNST for its management. route so long as they meet the nature and purpose for a National Scenic Trail, and do not substantially interfere with the nature and purposes for which the CDNST was established. 7. Any proposed location will require on going monitoring and evaluation of the conditions on and around the CDNST. 8. Any proposed location will assure proper and sensitive standards pertaining to establishment, operation and maintenance of the trail. Further, it would provide common objectives and means to coordinate the efforts of many agencies and interests having responsibility for implementation.

Social and Economic Concerns The outdoor recreation economy is vital to the Socio-economics livelihoods and quality of life in southwestern EA analyzed whether bikes would cause Colorado. The recreation economy is dependent on a substantial interference with the public lands available to provide high quality nature and purposes of the Act to recreation experiences. From habitat for fish and provide more informed decision-making. game to developed resorts, these resources all make substantial contributions to our lives. The Forest Service action to develop a new segment of the Continental Divide National Scenic Trail shows that the Forest Service understands the importance of these high quality experiences, and I fully support the development of this single-track route. I have some concerns, however, about the preferred alternative to preclude mountain bikes from sharing in this experience. We encourage the Forest Service to engage with all Socio-economic stakeholders promptly to resolve any issues. This EA been updated to address concerns trail will provide an additional recreation resource to expressed in comments. EA analyzed local, regional and national residents to recreate whether bikes would cause a substantial within Colorado’s Third Congressional District, which interference with the nature and will help drive additional tourism to the region, which purposes of the Act to provide more supports local businesses. informed decision-making. According to the Outdoor Industry Association, Socioeconomics bicycle-related business contributes $133 billion Analysis considers use of volunteers annually to the nation's economy — $6.2 billion in and trail becoming more of a destination the Rocky Mountain region alone. We depend on at least in the short-term. the recreation opportunities provided by federal, state and local land-managing agencies to sustain our business. I hope your decision will reflect the need to provide Americans with plentiful opportunities for healthy outdoor recreation on public lands.

213 Resource Area Summarized Comment Agency response A mechanized travel management decision on this Socioeconomics section would create the possibility of trail Analysis considers use of volunteers stewardship that is currently not evident in the and trail becoming more of a destination proposed area. at least in the short-term. Mountain bikers play a major role for tourism in the Socioeconomics Analysis considers use of volunteers Salida community and Saguache and the and trail becoming more of a destination surrounding communities could use their business at least in the short-term. as well. From a 2012 lodging survey in Salida, bikers were represented in the top three numbers of visitors. Recent studies have shown that for every dollar spent on bike trails there is a return of ten dollars to the communities from people staying in lodging facilities, eating out, and buying merchandise.

Trails and specifically the Salida Mountain Trails Socio-economics (SMT) area are a passive form of economic Analysis considers use of volunteers development. Our small town benefits with visitors and trail becoming more of a destination using the trails and also visiting our restaurants, at least in the short-term. retail, and lodging services. As a trail user we also take note of who we see on the trails, how easy they are to access, and who is going to help design, build, and maintain them once they are completed. The proposed reroute in the San Luis Valley is going to transform a rarely traveled road section of the CDNST to a new section of trail which will be built to IMBA trail standards. The old section will be left motorized and the new section we believe should be mechanized (bicycle friendly), equestrian, and hiking accessible. This creates the economic development small rural towns in the San Luis Valley will openly embrace. It is remotely located yet not too far away from large population areas like the Front Range to visit in one tank of fuel. By allowing bicycle travel it will also increase the chance of a much larger volunteer base to help build the trail and help move along expected completion dates. From our experiences in extremely remote trail locations there is rarely a user conflict, in fact meeting another trail user even though from another group is almost always welcome. I would be loathe to volunteer to help build or Socio-economics maintain a trail to hiking trail standards knowing it Trail Class 2 or 3 for hikers would have would require exceptional maintenance if it were similar design requirements to that for open to mountain bike use bicycles. Based on requests from other CDNST hikers we are unable to distinguish the two Trail Class Uses because hikers have requested the same design features as the bike trails. Our comments are based on County consideration Socio-economics of local/regional socioeconomic, tourism, recreation Alternative 5 includes the features and environmental factors. The proposed rerouting described in comment. Analysis of this trail through Saguache County has many considers use of volunteers and trail potential benefits in these regards, and the BoCC becoming more of a destination at least enthusiastically supports it Based on our in the short-term. understanding of the Alternatives presented, the BoCC is not in favor of Alternatives 1, nor 4. The BoCC wishes to speak in favor of incorporating all

214 Resource Area Summarized Comment Agency response amenities of Alternative 2, with the uses described in Alternative 3 which will offer the recreating public high quality, unique, near wilderness, natural resource experiences to enjoy, in Saguache County. Although some mountain bikers have generously Socio-economics offered to patrol this segment of trail, such patrols We agree that patrols are not likely are not necessary for the relatively experienced set necessary with the low level of use of users this trail will attract. Mountain bike patrols anticipated in this remote area. would detract from the desired experiences of some trail users. Social and Local, rural economies would benefit from increased While it might become an attraction for Economic tourism and purchases related to mountain bike use mountain bikes in the short-term that will Concerns of the CDNST in this area. increase tourism and purchases, it is not felt that this will be a long-term destination attraction for mountain bikes because it would require either an out and back experience or connecting with existing roads to length loops. Because of the remoteness of this segment it may be challenging to generate interest from groups willing to perform these duties in the long-term. This concern is compounded by changing forest conditions due to spruce beetle attacks that could result in increased need to cut downed trees in the near future.

Safety Mountain bikes can’t share trails with motorcycles Safety None of the action alternatives propose this. Only if the No Action Alternative is selected would this be a concern. Safety Mixed uses (motorized and non-motorized) present The No Action Alternative may present safety hazards. these safety hazards on the higher speed, higher traffic roads for all non- motorized users. None of the action alternatives have this concern for hikers due to the topography of the proposed trail. . Selection of Alternative 2 or 4 may present these safety hazards for bicycles on the higher speed, higher traffic roads. Non-motorized mixed uses may present a safety Safety hazard. Horses and bicycles meeting on a narrow This mixed-use concern is particularly trail on steep side slopes is very dangerous. As valid in steep country where bikes are efficient vehicles, bicycles allow humans to cover rapidly descending and hikers or horses more trails much faster than hikers or horseback have nowhere to go. This section of riders. Differences in travel speed can result in trail would not be prone to high speeds mixed use safety concerns for horses and hikers. due to relatively gentle topography. Moving aside allowing other users to pass would generally not be hazardous to either user also due to the gentle terrain. This area is expected to have low levels of use. It is not anticipated that a non-motorized mixed use safety concerns will be an issue.

215 Resource Area Summarized Comment Agency response I have been startled on other trails, by mountain Safety bikes overtaking me at high speed as I descended This mixed-use concern is particularly sections of shared trail. This is particularly valid in steep country where bikes are hazardous to horse riders as horses could be easily rapidly descending and hikers or horses spooked. It could also cause injury to hikers should have nowhere to go. This section of the biker be unable to stop to yield to the hiker, as is trail would not be prone to high speeds required by rule, due to inadequate time to react and due to relatively gentle topography. brake to a halt. Moving aside allowing other users to pass would generally not be hazardous to either user also due to the gentle terrain.

Safety The potential for any conflicts is low due to the We agree. Even if this becomes a infrequent encounters along this section of trail. short-term destination area use is There are no large population centers for more than expected to be relatively low minimizing a hundred miles that will use this trail as their conflict potential and safety further backyard or for frequent visits. minimized by proper trail design and gentle topography. If there is a need to get hikers off the gravel roads Safety that currently make up the route, the same should Selection of the No Action Alternative, apply to mountain bikers.: A car coming around a Alternative 2 or 4 may present these corner at high speed can come upon a biker before safety hazards for bicycles on the higher either party is aware of the other. speed, higher traffic roads. In my recent experience hiking the CDT in this area Safety in the summer of 2012, the trails were severely Existing route is on a combination of eroded due to bike use, and bicycle traffic was so motorized and non-motorized routes. fast as to be dangerous to hikers. This fast traffic is Effects experienced were most likely the clearly inconsistent with the serene, wild corridor result of poor design (if any) and intended for the CDNST. motorized use. Proposed route is a non-motorized trail consistent with the purposes of the CDNST.

Trail Setting

Trail Setting We entirely agree with your statement of the need Comment noted. as presented on pages 2-3 of the EA. Many of the existing segments, as you there recognized, are located well below the continental divide, and have little or no resemblance to a true CDNST. "On many segments of the new trail the hiker will have a strong sense of remoteness from sights, sounds or indications of human development" (EA, p.23), consistent with the Comprehensive Plan's direction to locate the CDNST, where possible, in primitive or semi-primitive non-motorized ROS classes (IV.B.5.c.(1)). Trail Setting We support a protected corridor to permanently A ½ mile buffer (corridor) for the protect this remote and beautiful stretch of land. protection of visual resources is a stipulation that is being applied to all action alternatives for this proposed segment of the CDNST. This stipulation has been designed to be compatible with existing management areas, comply with FSM 2353.44b(7) through the use of the Scenery Management System without designating management areas that must be done in a Forest Plan revision, and be compatible with existing GMUG Forest

216 Resource Area Summarized Comment Agency response Plan requirements (GMUG Forest Plan at III-82 to III-83) regarding the CDNST. Wildlife Additional lynx conservation and design criteria Wildlife measures should be added that include the Conservation measures have been prohibition of snowmobile use on the trail/along the included in Chapter 2 and Chapter 3 for trail corridor and prohibition of use of the Highway Canada lynx consistent with the 114 parking area as a snowmobile parking/staging Southern Rockies Lynx Amendment. area. Prohibiting snowmobile use along this new USFWS will be consulted regarding this cleared trail corridor would prevent a significant project. increase in snow compaction on the trail and in the area, which would help preserve this area as viable lynx habitat. Allowing bicycles on this trail will facilitate increased Wildlife human access and presence in this area. Increased Construction of the trail will facilitate human presence (from bicycle or other use) has increased human access regardless of been shown to result in increases negative effects the mode of transportation and result in on wildlife. This increased use can displace wildlife, negative although minor effects on and alter their behavioral patterns. wildlife. See other wildlife responses. Effects on wildlife are discussed in Chapter 3. The additional increased human presence on this Wildlife trail that mountain bike use will bring would push There is no scientific evidence wildlife away from the trail. Hikers and horseback suggesting that non-motorized use by riders would have a lesser chance of viewing wildlife bicycles would have any more impacts on the trail, and hunters would have to go farther on wildlife than either hikers or horses; from the trail to find game. however, increased use by humans whatever their mode of travel may cause the effects of concern expressed by commenter. Effects on wildlife are a complex issue that is specific to the individuals and the species. What appears to be agreed upon by scientific literature is that the presence of humans (regardless of mode of non-motorized transportation), but particularly humans with dogs, and the loss or fragmentation of habitat causes the most effects. The complexity of the effects on wildlife are compounded by predictability, frequency and magnitude of interaction; timing of the interaction relative to the animals’ annual cycle (breeding, calving/fawning, nesting, etc); location of interaction (escape routes available, cover, etc.); season; individual and species which experience complex variations in behavior; and finally the stressor or biophysical reaction of the individual/group. Response frequency in animals increases most from pedestrians over other types of access (Papouchis et al 2001). Taylor and Knight (2003) describe that hikers perceive that they have impacts on wildlife at approximately 50 meters when in reality effects on wildlife is occurring at approximately 160 meters; bikers perceive impacts at approximately 60 meters and in reality

217 Resource Area Summarized Comment Agency response impact them at approximately 140 meters; horse riders perceive impacts also at approximately 60 meters, but no research describes the true impact. Taylor and Knight (2003) also observed through user surveys that hikers, horsemen and mountain bikers all believed that the other two user groups caused more impacts to wildlife than their own. Some species are much more tolerant of humans and may even be curious. Effects on wildlife are described in Chapter 3. The creation of this new segment of trail will have Wildlife negative impacts on wildlife. These effects can be Effects on wildlife are a complex issue minimized by limiting the allowed modes of use on that is specific to the individuals and the this route to hikers and horseback riders only. species. What appears to be agreed upon by scientific literature is that the presence of humans (regardless of mode of non-motorized transportation) particularly humans with dogs and the loss or fragmentation of habitat causes the most effects. The complexity of the effects on wildlife are compounded by predictability, frequency and magnitude of interaction; timing of the interaction relative to the animals’ annual cycle (breeding, calving/fawning, nesting, etc.); location of interaction (escape routes available, cover, etc.); season; individual and species which experience complex variations in behavior; and finally the stressor or biophysical reaction of the individual/group. Response frequency in animals increases most from pedestrians over other types of access (Papouchis et al 2001). Taylor and Knight (2003) describe that hikers perceive that they have impacts on wildlife at approximately 50 meters when in reality effects on wildlife is occurring at approximately 160 meters; bikers perceive impacts at approximately 60 meters and in reality impact them at approximately 140 meters; horse riders perceive impacts also at approximately 60 meters, but no research describes the true impact. Taylor and Knight (2003) also observed through user surveys that hikers, horsemen and mountain bikers all believed that the other two user groups caused more impacts to wildlife than their own. Effects on wildlife are described in Chapter 3. Related Analysis When will the CDNST segment from Lujan to Windy Related Analysis Point will be fully considered? While we appreciate Travel management implementation from the 2010 Gunnison Travel decision

218 Resource Area Summarized Comment Agency response the Forest Service stating that their intention is to continues to be implemented in this manage the CDNST as a non-motorized trail for area. There is no current timeline for hiking and horse use, the lack of any clear decisions consideration of this segment of the on this segment of trail leaves this trail open to CDNST/CT. Funding and other forest motorized use. Instead of erring on the side of priorities including beetle infestations caution and resource protection by closing the trail will dictate when analysis is possible. to motorized use, a non-decision continues to negatively impact wildlife, hikers, and horseback riders (and bicyclists, where already allowed) and continues to hinder the nature and purposes of the CDNST. Related Analysis Federal regulations pertaining to land and resource Unit Plans are not being developed at management planning for the Forest Service and this time for the reasons stated above. Bureau of Land Management require that the Trail monitoring and evaluation is a National Forest and BLM unit plans include a requirement for all trails, not just the monitoring and evaluation program. The program CDNST. Once a trail is constructed it will provide a basis for a periodic determination and will be monitored. evaluation of effects of management practices. The purpose of this monitoring and evaluation is to initiate the need for management actions, and plan revisions or amendments. Comment goes on to state policy and management direction for the CDNST. Roadless We disagree with the statement on pages 20 and 26 Roadless section in EA has been Roadless of the EA “No effect on roadless values of the updated to reflect the roadless delineated roadless area will occur with construction characteristics that may be impacted. of the proposed trail.” If Alternative 3 is selected, this Portion of the Cochetopa CRA that segment of trail would be open to mechanized use. would be impacted by the proposed One of the values of designated roadless areas is its segment of the CDNST is considered potential as possible future Wilderness area not capable for wilderness designation. The suitability of modes of use allowed designation because of limited in potential future and current land use designations opportunities for a sense of remoteness, must also be considered for this segment of trail. challenge and solitude, and unmanageable boundaries (GMUG 2005 evaluation). Trail use & Carrying Capacity Given the remote location of the segment and the Trail Use lack of highly scenic features, it is unlikely that the We agree that use levels are expected proposed re-route will see a significant increase in to remain low and consistent with (or trail use in any user group due to only the re-route. lower than) the levels considered in the ROS for this area. Additionally, the reroute will almost certainly have Trail Use very low usage. Mr. Appel’s survey period We agree that use levels are expected encompasses the bulk of the usage in this area. I to remain low and consistent with (or have visited Mr. Appel several times in his camp and lower than) the levels considered in the observed his recordkeeping and the CTF has ROS for this area. EA has been conversed with Mr. Appel by telephone over the updated to include user impacts which years therefore we can attest to his diligence in his we also agree would be minimal with survey. Given the above we cannot expect that proper trail design. mountain bike usage would dramatically increase in this area if the reroute were open to biking nor would we expect the low usage would cause negative impacts to the Trail. Trail Use (Carrying Establish a carrying capacity for the CDNST that EA addresses this through Capacity) accommodates its nature and purposes. The Limits consideration of the ROS. In this area

219 Resource Area Summarized Comment Agency response of Acceptable Change or a similar system may be carrying capacity will primarily be used for this purpose. Management Direction (1) constrained by physical uses or Capacity determination within a management area conflicting uses which cause safety will consider the biophysical environmental needs concerns, not by the ROS (ROS and the social capacity factors needed to provide classes of roaded natural or roaded desired recreation experience opportunities. modified) setting where there is a high expectation of seeing others and ongoing management activities. Due to the low volume of projected use and distance from metropolitan areas, this issue is more of an engineering concern as the design, alignment and sight- distance all respond to the safety issue. Effects on safety will be minimized though the selection of the proper trail class with the correct designed uses for this trail. Trail Use (Carrying If mechanized use is reconsidered, CDTC strongly LAC process is synonymous with Capacity) recommends this only be done alongside a Limits of carrying capacity. In this area carrying Acceptable Change (LAC) process undertaken by capacity will primarily be constrained by the USFS, as well as establishing specific physical uses or conflicting uses which management guidelines as to the monitoring of any cause safety concerns, not by the ROS such use so as to ensure that the primary users of (ROS classes of roaded natural or this Trail segment are not displaced, or their roaded modified) setting where there is experience subject to substantial interference. Some a high expectation of seeing others and of these management guidelines should include not ongoing management activities. Due to allowing shuttle services and the use of the segment the low volume of projected uses and for competitive events. These might also include distance from metropolitan areas, this instituting a permit system for users to have issue is more of an engineering concern adequate recognition of the use of the new segment as the design, alignment and sight- and manage impacts resulting from use. CDTC distance all respond to the safety issue. requests that if this type of public process occurs Effects on safety will be minimized that CDTC be a asked to participate. though the selection of the proper trail class with the correct designed uses for this trail. Trail Use (Carrying In making any decision regarding a new use being In this area carrying capacity will Capacity) added to this trail segment, we wish to see a primarily be constrained by physical determination that any new use will not substantially uses or conflicting uses which cause interfere with the nature and purpose of the CDNST. safety concerns, not by the ROS (ROS To evaluate the additional of any new uses should classes of roaded natural or roaded require extensive review of the following issues and modified) setting where there is a high we suggest the following questions be addressed: expectation of seeing others and ongoing management activities. Due to 1. What is the desired recreational experience for the low volume of projected users and this proposed land management decision? distance from metropolitan areas, this 2. What is the carrying capacity of this trail issue is more of an engineering concern segment? What factors will be used to establish as the design, alignment and sight- these base line figures. distance all respond to the safety issue. Effects on safety will be minimized 3. What is the strategy to address carrying capacity though the selection of the proper trail questions and the ability of this trail segment to class with the correct designed uses for support recreational uses (current and any potential this trail. Monitoring will be future uses) in a way to provide a high quality and accomplished to meet Forest Service safe recreational experience? requirements and will likely occur 4. Will a Limits of Acceptable Change (LAC) be through a combination of agency established to help USFS follow requirements and employees and partnerships with user or management of the CDNST? groups such as CTF. 5. How will you address nature and purpose

220 Resource Area Summarized Comment Agency response statement for the CDNST? 6. Can a decision be implemented without changing the nature and character of the current or future CDNST? 7. What is the strategy to address if allowing additional uses does substantially interfere with the CDNST in the future. 8. How will this possible impact be monitored, controlled and managed if a new use is established? 9. If new uses are allowed, what management actions will occur to prevent or address displacement of current users of CDNST? 10. What is the strategy to provide resources to fund a management and monitoring program? 11. How will the public be engaged in a monitoring and management program? 12. Are there other locations suitable for the new uses that avoid the CDNST in order to protect its nature and purpose and minimize impacts from possible decisions resulting from this process?

Trail Use (Carrying In this particular segment, with the amount of There are no shuttle services proposed Capacity) mountain bike use that is currently experienced at this time. Any of the action along the Monarch Crest segment of the CDNST, it alternatives will provide a better is very plausible to assume that the same could experience for primary users than hiking happen in this location, even without the shuttle on roads and motorized trails. Because service operators. This is partly due to promotion by the ROS is roaded natural and roaded user groups to use this area. It is also becoming true modified, visitors should not expect a that once mechanized use is established, the use is primitive experience that would be hard to manage and restrict. We feel that in this inconsistent with the forest management area, this is likely to happen with the allowance of areas. Visitors could expect to mechanized use. We also feel, like in the case of encounter 6-15 parties or more per day the Monarch Crest, the primary users of the CDNST in this segment of the CDNST/CT which have the potential to be displaced or alter their is double the current projected use. behavior due to the desire to avoid this use. Even While it might become an attraction for with low-level use that might be expected by the mountain bikes in the short-term, is not desire for long distance cycling, the reality is without felt that this will be a long-term strong management guidelines regarding this destination attraction for mountain bikes activity, and without additional public involvement because it would require either an out and engagement, it will be unlikely to not have and back experience or connecting with displacement occur. Furthermore, there is an existing roads to create loop alternate route for mechanized use to continue that opportunities. Because of the does not impact the CDNST’s new location. remoteness (in this case lack of Therefore, although mechanized use may be proximity to population centers) of this allowed on the CDNST in certain instances, in this segment it may be challenging to case, we feel it would substantially interfere with the generate sufficient interest from local nature and purposes of the CDNST (FSM 2353.44b groups for the construction and long- 10.) term maintenance. Long-term attraction by bikes is compounded by changing forest conditions due to spruce beetle attacks that could result in increased need to cut downed trees (trail maintenance) or manage forest resources in the vicinity of the proposed trail in the near future.

221

222