Rio Grande National Forest Land Management Plan Final Environmental Impact Statement: Volume II Appendix D: Public Involvement and Response to Comments

United States Department of Agriculture Forest Service Rio Grande National Forest Land Management Plan Final Environmental Impact Statement: Volume II Appendix D: Public Involvement and Response to Comments

Alamosa, Archuleta, Conejos, Hinsdale, Mineral, Rio Grande, Saguache, and San Juan Counties, Colorado April 2020

Crestone Peak viewed through the Natural Arch

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Rio Grande National Forest Land Management Plan Final Environmental Impact Statement: Volume ll Appendix D: Public Involvement and Response to Comments

Contents Contents ...... iii Public Involvement and Response to Comments ...... 1 Introduction ...... 1 Air Quality (AIR) ...... 14 Climate Change (CC) ...... 16 Congressionally Designated Trails (CDT) ...... 19 Cultural Resources (CR) ...... 39 Fire (FIRE) ...... 41 Fisheries (FISH) ...... 43 Geology, Energy, and Minerals (MIN) ...... 47 Infrastructure (INFR) ...... 53 Aquatic and Terrestrial Nonnative Invasive Species and Noxious Weeds (NNIS) ...... 60 Lands and Special Uses (LAND) ...... 65 Management and Geographic Areas (MGA) ...... 66 Monitoring ...... 74 National Environmental Policy Act (NEPA) ...... 77 National Forest Management Act (NFMA) ...... 82 Plan Components (PC) ...... 84 Public Participation ...... 92 Range (RNG) ...... 96 Recreation (REC) ...... 106 Riparian ...... 118 Roadless ...... 126 Socioeconomics and Ecosystem Services (SOCIO) ...... 127 Soils (SOIL) ...... 133 Special Interest Areas and Research Natural Areas (SIA) ...... 135 Vegetation (VEG) ...... 139 Water (WA) ...... 175 Wilderness (WILD) ...... 188 Wildlife (WLDF) ...... 198 Wild, Scenic, and Recreational Rivers (WSRR) ...... 232

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List of Tables Table 1. Name of commenters to the draft environmental impact statement and draft forest plan ...... 1 Table 2. Treatment of nonnative invasive species on the Forest, 2004–2018 ...... 62 Table 3. Primitive and semiprimitive motorized route miles by alternative ...... 111 Table 4. Recreation opportunity spectrum class acres in upper tier roadless areas (percentage) ...... 111 Table 5. Existing motorized and nonmotorized trail miles, by alternative ...... 113 Table 6. Regional guidelines for old forest criteria ...... 151 Table 7. Criteria used to determine old forest ...... 152

List of Figures Figure 1. Comparison of annual forest products production estimates between the 1992 plan, 2017 DEIS, and 2019 FEIS ...... 145

iv Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Public Involvement and Response to Comments This document contains the responses to the public comments that were received for the Rio Grande National Forest Draft Revised Land Management Plan.

Introduction The draft environmental impact statement and forest plan were released for public review for 90 days. The Notice of Availability of the draft environmental impact statement and draft forest plan appeared in the Federal Register on September 29, 2017. Some of the specific changes made to the selected alternative based on public and interagency engagement includes: • Combining and correcting direction in the forest plan; • Reframing management approaches and how they are used in the direction; • Refining direction for Canada lynx based on the best available science that became available after the public comment period. Other components of the involvement and transparency of the public involvement efforts associated with this planning effort include the information made available to the public through the forest plan revision website. As a result of this review, approximately 465 letters of comment were received. People who submitted comments on the draft environmental impact statement and draft forest plan are listed in Table 1.

Table 1. Name of commenters to the draft environmental impact statement and draft forest plan

Letter Signatories Title/Organization Number 1 Brady Van Matre 2 C. Howes 3 Ian Nelson 4 Stu Mennitt 5 David Spencer 6 Meryl Ennis 7 Douglas W. Camp DMA 8 James 9 Kristina "Kay" Crowder Project Coordinator, Solid Waste Management/San Luis Valley 10 Kelsey Urie Ecosystem Council 11 Ana Ruiz 12 Dan and Liz Murray 13 Karl Ford

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Letter Signatories Title/Organization Number 14 Robert Burnett 15 Richard Hasbrouck 20 J. Ely Walker 21 Gary Blakly Trails Manager, Del Norte Trails Org. 22 Brandon Cox 23 Ann Bunting 24 Carolyn Brown Owner, The Silver Star 25 Grace Katherine Anderson 26 Susan M. Pierce 26 Craig MacFarland, PhD 27 James R. Wolf Director, Continental Divide Trail Society 28 John McEvoy 29 Lloyd Liebetrau 30 Bettyann Kolner 31 Steve Nicolais 32 Scott Nicolais 33 Susan Komarek Author of Flora of the San Juans, Botanist, Wildlife Biologist 34 Michael Wisdom 35 John P. Milton CEO and Founder, The Way of Nature 36 John P. Milton 37 Katharine Getchell 38 Robyn Cascade 39 Stacey A. McCulloch 40 Jonathan B. Ratner Director, Western Watersheds Project 41 Barbara Tidd 42 Nick Tolsma 43 Annemieke Wiercx Chair, Way of Nature Netherlands 44 Cindy Pearson Garcia Rhonda Foale and Mike 45 Foale President, La Vereda del Norte chapter of the Old Spanish Trail 46 Ken Frye Association 47 Conejos Clean Water Director, NEPA Compliance and Review Program, Office of 48 Philip S. Strobel Ecosystems Protection and Remediation, United States Environmental Protection Agency 49 Margaret McClymont 50 Ardell Broadbent 51 Fred and Jamie McLeroy 52 Matt DeAmico 53 Peggy Godfrey 54 Deborah Sheinman

2 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments

Letter Signatories Title/Organization Number 55 Erica Prather 56 Gwendolyn Bauer 57 Michael Hurst 58 Adam Berman Executive Director, Urban Adamah 59 Betty Ann Kolner 60 Galaxy E. Dancer, PhD President, Manitou Foundation and Manitou Institute & 61 Hanne Strong Conservancy 62 L. David Vogel Volunteer Bat Host at Orient Land Trust 63 Lyons, Madeleine 64 Liz Alperin Solms Norbert Remco 65 Westerhuijs 66 Yvonne Bartfeld 67 Jennifer Cori Chandler 68 Kenneth H. Price 69 Michael Olwyler 70 Jeremy Romero Coordinator of Wildlife Corridors, National Wildlife Federation Director, Community Relations, Education and Veterans 70 Andrew Black Outreach, New Mexico Wildlife Federation Regional Executive Director, Rocky Mountain Regional Center, 70 Brian Kurzel National Wildlife Federation 70 Suzanne O'Neill Executive Director, Colorado Wildlife Federation 71 J. Michael Chavarria Governor, Santa Clara Indian Pueblo 72 Sofika Cobi 73 Sandra Skibinaki 74 Thomas Davis 75 Zita Xavier Rio Grande Watershed Emergency Action 76 Coordination Team (RWEACT) Board of Directors Mr. & Mrs. Armando 77 Guerra 78 Anne Silver 79 Cindy Cleary 80 Cindy Cleary 81 Brooke Teufel 82 Dennis Wuisan 83 Jeffrey B Noblett Professor and Chair of Geology, Colorado College 84 Ms. Anne Markward 86 Deb Paulson

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Letter Signatories Title/Organization Number 87 Deborah Wood 88 Julie Waechter 89 Nancy Atherton 90 Mr. Ron Margolis 91 Mr. Ryan Root 92 Wayne K. Sheldrake 93 Dan Rosenthal 94 Norbert Lechner 95 Mark Pearson San Juan Citizens Alliance 95 Christine Canaly San Luis Valley Ecosystem Council 95 Rocky Smith Forest Management Analyst (Lead) 95 Lauren McCain Federal Lands Policy Analyst, Defenders of Wildlife 95 Allison Gallensky GIS and IT Director, Rocky Mountain Wild 95 Vera Smith Director of Forest Planning and Policy, The Wilderness Society 95 Matt Reed Public Lands Director, High County Conservation Advocates 95 James Lockhart President, Wild Connections 95 John Mellgren Western Environmental Law Center 95 Rosalind McClellan Rocky Mountain Recreation Initiative 95 Emily Lande Sierra Club Robyn Cascade and Northern San Juan Chapter/Ridgeway Colorado Chapter, Great 95 Laurie Shannon Old Broads for Wilderness 95 Tom Sobal Quiet Use Coalition 95 Greg Dyson, Director Wild Places Program, Wild Earth Guardians 95 Shannon Laun Western Environmental Law Center Heather R. Dutton, 96 Manager/Dee Greeman, Board of Directors, San Luis Valley Water Conservancy District President 97 Teresa Catford 99 Tim Schaldach 100 Anna Royer 101 Mr. Ben Griffith 102 Mr. John Bremer 103 Dr. Kimberly Johnson 104 Mrs. Lisa Pool 105 Dr. Mary L De Luca, MD 106 Ms. Maria Spero 107 Ms. Tristine Roberts 108 Donald S. Holmstrom 109 Ms. Eda Gordon 110 Ella Fenoglio 111 Teresa Catford 113 Brenda Meikle

4 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments

Letter Signatories Title/Organization Number 114 Mike Oliver 115 Andy Butler 116 Ms. Amy Lyons 117 Dr. Joel & Pat Kantor 118 Dr. Judith Vanderryn 119 Kristy Falcon 120 Ms. Kelsey Johnson 121 Karie Luidens 122 Karol Miller 123 Dr. Lauri Costello MD 124 Mrs. Linda Messatzzia 125 Ms. Lisa Popowich 126 Mark Meeks 127 Dr. Victoria Robinson 128 Mr. Zachary Cardosi 129 Ann Linnea 130 Chris Applegate 131 David Bruson 132 Don Thompson/Jan Oen 133 Mark Pearson 135 Megan Strauss 136 Dr. Bruce P. Van Haveren 137 Mr. Ken Goldsmith 137 Cynthia Bryson 138 Mr. Lucas Ratliff 139 Miss Nicole Cookson 140 Mr. Cheri Kelly 141 Mr. Dennis Dougherty 142 Mr. Eric Hickerson 143 Mrs. Karen Hickerson 144 Ms. Paula Ozzello 145 Brad Michael Kahland Board President, San Luis Valley Ecosystem Council; Co-founder 146 Dave Miller and Co-Chair, Crestone Wilderness Stewards 147 Justin Lichter 148 Jennifer L. Rechel 149 James R. Wolf Director, Continental Divide Trail Society 150 May Engquist 151 Mitch Petersen 152 Susan Jacobson

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Letter Signatories Title/Organization Number 153 Tim Hogan 154 Garrett Hanks Southwest Public Lands Coordinator, Trout Unlimited 154 Mark Seaton President, San Luis Valley, Trout Unlimited 154 Kevin Terry Rio Grande Basin Project, Manager, Trout Unlimited 155 Mr. Neal Jones 155 Chris Zorn 156 Dave Van Manen Mountain Coaching & Consulting LLC Regional Environmental Officer, Office of Environmental Policy 157 Courtney Hoover and Compliance, United States Department of the Interior 158 Eli Dokson Julie Mordecai and 159 George Sellman 160 Virginia Getz 161 Robert Getz 162 Mark Seaton Rio Grande County Board of Commissioners - Karla L. Shriver, Chairman, 163 Gene Glover, Vice Chairman, Suzanne Bothell, Commissioner 164 Sarah Hoenninger 165 Mathew P. Crowley Operations Manager, Shumei International Institute 166 Tamara Scattergood 167 Ms. Cathy Cowles 168 Mrs. Chandra Fowler 169 Ms. Elisabeth Price 170 Mr. Gary Hopkins 171 Ms. Beverly Compton 172 Alan R. Apt 173 Anikke Storm 174 William Hiatt 175 Mary Ann DeBoer Citizens Alliance of 175 Northern New Mexico 175 William Clark 176 Carol Beckman 177 Cathy Morin Christian Dillo & Mathew Director, Resident Teacher, Crestone Mountain Zen Center; 178 P. Crowley Crestone Spiritual Alliance, Member Don Brown, 179 Commissioner, Colorado Department of Agriculture 180 Darlene Dawn Gray 181 Donald E. Potter, MD

6 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments

Letter Signatories Title/Organization Number 181 Forrest Getz 183 Helen Sigmond Alamosa County Commissioner 184 Himant and Peggy A Ellis 185 Ian Rich 186 James Corlett 187 Kendall L. Magnussen 188 Matie Belle Lakish Maureen P Lancaster, Ed. 189 D. Mark Mueller and Sandy 190 Kobrock 191 Normand Birtcher Resource Forester, Montrose Forest Products 192 Greg Warren 193 Jeremy Romero Coordinator of Wildlife Corridors 193 Brian Kurzel Regional Executive Director, Rocky Mountain Regional Center 193 Suzanne O'Neill Executive Director, Colorado Wildlife Federation 193 Andrew Black Director, Community Relations, Education and Veterans Outreach MCC/Executive Leadership Coach, Founder of Choice to Change 194 Pamela Ramadei Alliance 195 Robert Antiel 196 Cleave Simpson General Manager, Rio Grande Water Conservation District 197 Richard Jewett 198 Ernest Kuhlman Chairman, San Juan County Board of County Commissioners 199 Suzanne DeVore 200 Shawna Off 201 Chris Rapp 202 Jay Reese 203 Matthew Quam 204 Max Modern 205 Mike Higgins 206 Miles Herrmann 207 Miles Phillips 208 Rich Rapp 209 VaporTrail Productions 210 Mark Pearson Executive Director, San Juans Citizen Alliance Rick Davie and David 211 Colville 212 Ms. Elizabeth Manus 213 Kathy England Gray N. Thornton and President/CEO and 215 Kevin Hurley Senior Conservation Director, Wild Sheep Foundation 216 Thomas A. Troxel Executive Director, Intermountain Forest Association

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Letter Signatories Title/Organization Number 217 Darius Allen Chairman, Alamosa County Commissioner 218 Bill Brinton Southwest Regional Director for Colorado Backcountry Hunters 219 Dan Parkinson and Anglers 220 Brent Miller 221 Claire Barker 222 Robert Randall CDNR 222 Rebecca Mitchell CWCB 222 Kevin Rein CDWR 222 Rick Basagoitia SLV-CPW Richard and Cassandra Rocky Mountain Timber Products Inc., Entermountain Enterprises 223 Doyon Inc. Program Coordinator for Academic Achievement Strategies and 224 Curt Howell Adventure Leadership and Programming, Adams State University 225 Dan Casey Colorado Timber Industry Association President 226 Nathan Coombs Conejos Water Conservancy District 227 Deborah Burns 228 David C. Jones 229 Lauren McCain Federal Lands Policy Analyst 229 Vera Smith Director of Forest Planning and Policy 229 John R. Mellgren Staff Attorney 229 Greg Dyson Wild Places Program Director 230 David Montgomery 231 Douglas T. Clark 232 Ellen Hollinshead 233 Marisa Mckie 234 Christine Canaly 235 Randall Palmgren San Luis Valley Irrigation District 236 Sam Satterwhite President, Satterwhite Log Homes 237 Sarah Witherell 238 Ms. Liana Sun 239 Ms. Penny Holmes 240 Elizabeth Manus 241 Eric Burt Owner/Manager, Kristi Mountain Sports, LLC 242 Frank Evans 243 Grover Cleveland 244 Garry Doyon Wa Travis, Maureen, and 245 Helen Smith 246 Kent D. Ingram 247 Linda Gibas 248 Mary Ann DeBoer Cumbres Nordic Adventures LLC

8 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments

Letter Signatories Title/Organization Number 249 Mark E. Evans 250 Michael Hora 251 Janelle Kukuk Administrator, Mineral County Board of County Commissioners 252 Mark Opincariu 253 Nancy Fishering 254 Nathan Kettner 255 Rio de la Vista 256 Terry Meyers Executive Director, Rocky Mountain Bighorn Society 257 Bob Meulengracht 258 Randi and Terry Young 259 Shara Briggs 260 Ms. Ang Walker 261 Mr. Britt Bassett 262 Mrs. Chrissy Karas 263 Mr. Jim Milstein 264 Mr. Scott Baker 265 Shelby Robinson 266 Mr. Vernon Batty 267 Dr. Brian Dannemann, MD Malcolm MacPherson, 268 Ph.D. 269 Ms. Peggy Petry 270 Dr. Root Routledge, PhD 271 Robert Winslow 272 Stacy Boone 273 Ms. Saundra Holloway 274 Mrs. Terri Andersen 275 Tom Sobal Director, Quiet Use Coalition 276 Beverly Walter 277 Michael Haynes 278 Grant Stevens 279 Julianne Will 280 Jim Callison 281 Glenn Randall 282 Joy Cipoletti 283 Amy McClintock 283 Steve Staley Colorado Trail Foundation 283 Bill Manning Colorado Trail Foundation 284 Robert Wagner 285 Marc Bessho

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Letter Signatories Title/Organization Number 286 Jeremy Hakes 287 Richard Burrell 288 David Rule 289 Tim McDougall 290 Michael N Malick 291 Noreen Haines 292 Renee Roberts 293 Dan 294 William Peck 295 Robert Parmenter 296 Elbert Gesink 297 Steven Goodroad 298 Steven Rothermich 299 Karen Fitzgerald 300 Donald R Seagren 301 Bruce and Angie Many 302 Ms. Kim Morton 303 Ms. Michelle MacKenzie 304 Ms. Marnie gaede 305 Dr. Richard Grossman 306 Ms. Kelly Frisby 307 Dr. Gordon Henriksen 308 Ms. Carol Vilcek 309 Ms. Petra Hinke 310 J Tuomey 311 Mr. Spencer Merage 312 Ms. Carlise Link 313 Ms. Ginger Ikeda 314 Mr. Roy Tarman 315 Mrs. Anne Grice 316 Ms. Nancy Fisher 317 Ms. Michele May 318 Mr. Eric Husted 319 Mr Jon Anderson 320 Mrs. Jayne Looper 321 Ms. Yvonne Fast 322 Rebecca Maloney 323 Susan Butler 324 Mrs. Lisa Newkirk 325 Mr. Kristian Gosar 326 Mr. Steve Kawell

10 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments

Letter Signatories Title/Organization Number 327 Mrs. Robbin Clark 328 Mr. Chris Antonov 329 Manuel Pino 330 Ms. Mary O’Donnell 331 Elizabeth Rodio 332 Mr. Ken Ward 333 Diane Newell Meyer 334 Mrs. Irene Richards 335 Ms. Michelle Bearhart 336 Ms. Elizabeth Rieman 337 Mrs. Sandy Loney 338 Mr. Thomas Gorman 339 Marion Hitzenhammer 340 Ms. Merrilee Williams 341 Allison Anderson 342 Mr. Scott Hobbs 343 Ms. Elisabeth Price 344 Ms. Tristen Gilbert 345 Wendy Volkmann 346 Mr. Gerry Milliken 347 Mr. Daniel Morgenstern 348 Mrs. Rachel Scarlata 349 Ms. Mary Ramsay 350 Mr. Bryan Hile 351 Ms. Jill Stoll 352 Ms. Stacey Peters 353 Ms. Deborah Reade 354 Dr. Lynn Ditto 355 Mr. Chad Alber 356 Dr. Susan Peirce 357 Mr. John Apel 358 Mr. Donald Triola 359 Ms. Charlotte Alexandre 360 Debby Kruzic 361 Dr. Mark Seis 362 Dr. Bill Plotkin 363 Lee Toni 364 Martin Gavurnik 365 Mr. Andrew Gold 366 Mr. Dave Rich

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Letter Signatories Title/Organization Number 367 Mrs. Eliane Viner 368 Kate Hallock 369 Mr. Allen Decker 370 Ms. Jo Ardell 371 Ms. helen low 372 Mr. Nicholas Chatfield 373 Ms. Jaclyn Behringer 374 Mr. Chuck Wages 375 Florence Paillard 376 Mrs. Mary Shabbott 377 Ms. Linda Bunk 378 Mr. Jeremy May 379 Kathy Gynane 380 Kate Harris 381 Dr. Deb Williamson 382 Mr. Josh Kuhn 383 Mr. Ross Douglas 384 Mr. Cliff and Pearl Bove 385 Mr. Giff Cutler 386 Mr. Kevin Vaught 387 Mr. Phil May 388 Ms. Bettina Bickel 389 Mr. Adam Pastula 390 J Webb 391 Mr. Chris Moore 392 Mr. Ted Bartlett 393 Mrs. Esther Greenfield 394 Mrs. Maria Ianc 395 Mr. Steve Smith 396 Mr. Tom Sykes 397 Miss. Line Ringgaard 398 Mr. Mehdi Mansour khodja 399 Mrs. Karen Skelly 400 Rodney Proffitt 401 Ms. Joan MacEachen 402 Mr. Nicholas Sprague 403 Mr. Edward Hall 404 Ms. Elizabeth W. Norton 405 William Sharfman 406 Mr. Jeff Smith 407 Mr. Bill Gardner

12 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments

Letter Signatories Title/Organization Number 408 Mr. Jake Norman 409 Mr. Howard Whitaker 410 Mrs. Wendy Gramadzki 411 Mrs. Kinsey Dickmann 412 Jim Bolen 413 Mr. Perry Gx 414 Ms. Heather Snow 415 Mrs. Caroline Pack 416 Mr. Dale Lewis 417 Michael Duquette 418 Mr. Brian Abel 419 Mr. Jason Meininger 420 Ms. MP Schildmeyer 421 Mr. Randy Willis 422 Charlotte & Jerry Fischer 423 Mrs. Katie Waller Tim Lovato, Chairman 424 Jason Anderson Saguache County Board of Commissioners Ken Anderson 425 Don Riggle Director of Operations, Trail Preservation Alliance 435 Stephen Harris 436 Emmy Savage 438 Paul Wolfram 439 Doug Knudson Unitarian Universalist 440 Fellowship in Alamosa 441 John Mumma 442 Brian Brownell 444 Beth Kinney 445 Todd Olivas 446 Bill Ellbrock Mayor, Village of Chama 447 Kay Watkins 448 Leslie McMenemy 449 Margery Franzen 450 Helen Martin 451 Teresa Martinez Continental Divide Trail Coalition Steve and Tressa 453 Hollander Colorado Native Plant 454 Society 455 Louise Colville 456 Rene Evenson

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Letter Signatories Title/Organization Number Del Norte Small Business 457 Owners 458 Karla Shriver 459 Juli and Jim Manley 460 Mary Elizabeth Merrit 462 Bruce Sheldon 463 Suzanne Off La Vereda del Norte Chapter of Old Spanish Trail Association 464 Sarah Tiers 465 Reyes Garcia 16/18 Dawn Hendry 17/19 Nancy Wilkie

Air Quality (AIR)

Comment AIR – 1 Air quality components, including Desired Conditions 4 and 5, are too restrictive. Response Desired conditions 4 and 5 (draft forest plan DC-AIR-4 and DC-AIR-5) have been removed between the release of the draft and final version of the forest plan. DC-AIR-4 addressed reducing impacts of dust-on-snow by controlling dust from projects. This would not be achievable at the forest-plan level because it depends on consideration of site-specific project factors including project location, prevailing wind, ground disturbance, etc. and is more applicable to a project-level analysis. Additionally, some of the concerns of dust-on-snow may originate from beyond the planning boundary within the San Luis Valley or from the greater Southwestern United States. Dust is considered in the effects analysis in the Air Quality section. Desired condition DC-AIR-5 addresses minimizing the ecological footprint to promote sustainable natural resource management and emit the lowest practicable greenhouse gas emissions of the Forest as a whole. Greenhouse gas emissions and other air quality concerns are addressed during project-level analysis, where appropriate, to comply with law, regulation, and policy.

Comment AIR – 2 The analysis should consider the benefits of vegetation management on air quality related to wildfires. Response To increase clarity, discussion was added to the Affected Environment, Existing Condition and Trends for Air Quality as well as the section on Effects on Air Quality from Timber Harvest. There may be both positive and negative impacts on air quality from vegetation management. Timber harvest can reduce large woody fuel availability, which may result in

14 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments reduced fire severity and intensity, which could reduce negative effects to air quality. However, vegetation management may also result in immediate short-term increases in particulate matter and other air pollutants associated directly with vegetation management activities. Climate-change effects could exacerbate air quality concerns. Additional impacts on air quality particularly are expected with effects of climate change. Carbon stocks and sequestration discussion also considers fire simulation and growth rates as it relates to carbon sequestration for the alternatives.

Comment AIR – 3 The analysis should consider a discussion of acres treated with prescribed fire and potential emissions by alternative. Response The annual level of prescribed burning is primarily influenced by weather conditions and available burn windows. Prescribed burns vary from a few hundred acres to several thousand acres a year. The number of acres burned per year would not be influenced by the different alternatives as much as by weather conditions and available burn windows. Emissions from individual prescribed fire projects vary greatly depending on fuel type and the amount of fuel, and are analyzed at the project level. These variables make an annual estimate of emissions problematic and would not be significantly affected by the different alternatives. Project analysis and plans include parameters that would limit impacts.

Comment AIR – 4 Desired Conditions 1, 2, and 6 should be standards, not desired conditions. Response In response to internal and external comments received, plan components, including desired conditions, objectives, standards, and guidelines, have been revised to better meet the intent and direction of the 2012 Planning Rule (36 CFR 219) and its implementing direction (FSH 1909.12). The intent of the direction did not change; revisions combined like direction, added clarity, and added specificity. Desired conditions are defined as “a description of specific social, economic, and/or ecological characteristics of the plan area, or a portion of the plan area, toward which management of the land and resources should be directed. Desired conditions must be described in terms that are specific enough to allow progress toward their achievement to be determined, but do not include completion dates.” 36 CFR 219.7(e)(1)(i). Whereas, “a standard is a mandatory constraint on project and activity decision-making, established to help achieve or maintain the desired condition or conditions, to avoid or mitigate undesirable effects, or to meet applicable legal requirements.” 36 CFR 219.7(e)(1) (iii)). Draft forest plan desired conditions DC-AIR-1 and DC-AIR-2 have been combined into DC- AIR-1: “Air quality-related values over Class I and Class II wilderness areas meet or exceed

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state standards.” The intention is to meet state standards from air quality-related values. This may not be possible with influences from outside the Forest; however, this is not a project constraint and should not be a standard. Draft forest plan DC-AIR-6 has been removed. This desired condition, about nitrogen and sulfur deposition on air quality-related values in lakes, was specific to oil and gas production. It was removed because it would apply on a very limited, and perhaps unforeseen, basis to oil and gas activities. In the event that oil and gas development increases, the Forest would consider adding plan direction or oil and gas development constraints to address the needs. However, the more broad language of Forest plan component DC-AIR-1 provides overarching desired conditions for all air quality-related values, which nitrogen and sulfur deposition would impact. Oil and gas development projects would still need to be considered in compliance with Clean Air Act requirements.

Comment AIR – 5 G-AIR-2 should be a standard and not a guideline. Response Draft forest plan component DC-AIR-2 and corresponding G-AIR-2 have been simplified in the forest plan. They apply to Class 1 areas. Nutrient and mercury deposition are air quality- related values. The desired conditions in draft forest plan components DC-AIR-1 and DC- AIR-2 have been combined into DC-AIR-1: “Air quality related values over Class I and Class II wilderness areas meet or exceed state standards.” This negates the need for G-AIR-2 as either a standard or a guideline as we would now be meeting or exceeding state standards for air quality-related values that may change during the life of the plan. Further, preventing airborne nutrient and mercury depositions is outside the control of the agency and would be unachievable at the plan level. Air quality-related values are considered through the long- term, ongoing National Atmospheric Deposition Program monitoring and are prescribed in the forest plan (draft forest plan monitoring, Goal 3, Monitoring Question 23; final forest plan, Monitoring, Goal 2, Monitoring Question 14).

Climate Change (CC)

Comment CC – 1 Assumptions used in the carbon models need additional explanation. Response Some commenters requested that more of an explanation needed to be provided about carbon modeling undertaken for the environmental impact statement, as well as running more robust modeling for soils and other aspects of carbon emissions and sequestration. The level of analysis provided in the final environmental impact statement is appropriate. The following assumptions were disclosed for the carbon analysis: average and mean fire effects from 1990 through 2011; static fire occurrence among alternatives; recent insect outbreaks; transition from live to dead carbon pools; and accounts for only carbon in the forest ecosystem, it did not include wood products or other aspects of the carbon cycle. The model was run for alternatives B, C, and D; the final environmental impact statement discloses that alternative

16 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments B Modified would result in less carbon storage than alternative C, but more than alternative B. The level of analysis was appropriate to inform the responsible official’s decision and is also detailed enough for meaningful public involvement and disclosure.

Comment CC – 2 The plan must include plan components that address carbon storage and climate change. Response The environmental impact statement discusses the role of carbon in the Forest as an ecosystem service. There are no requirements to enhance carbon storage in national forests in law, regulation, or policy. There is a requirement to assess carbon stocks, prior to plan revision, under the 2012 Planning Rule. Carbon stocks were assessed and published with the other assessment topics prior to plan revision. Carbon storage was not identified as a key revision topic (FEIS, Chapter 1), nor was it a deciding factor among alternatives for the responsible official. The level of analysis in the carbon assessment, as well as the final environmental impact statement, is appropriate. Some commenters express that alternative D would have the greatest benefit to a carbon sink, since it contains the most recommended wilderness. Carbon sequestration capacity was not a decision factor. It is important to note that active forest management can play a beneficial role in the carbon cycle as well. Active forest management can reduce the fuel loads that result in decreased risk or severity of fire in those areas. Also, wood products store carbon throughout the life of the product. Lumber, and other wood products, can be a substitute for more carbon intensive products, such as concrete and steel. Active forest management can help reduce the risk of wildfire and associated greenhouse gas emissions. Active management often results in immediate release of carbon, from soil disturbance, internal combustion of equipment, and the cutting of trees. However, carbon is sequestered over time with replanting and reforestation efforts.

Comment CC – 3 The plan must establish sustainability metrics for operations to better align with the Climate Change Performance Scorecard and other policies. Response The Rio Grande National Forest will continue to implement and lead in many areas to reduce our environmental footprint. However, the Climate Change Performance Scorecard, and many other aspects of agency operations, are better addressed outside of forest planning.

Comment CC – 4 The plan must consider climate change and address the effects of climate change by providing protections for species and landscapes.

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Response The Rio Grande National Forest Climate Change Plan Revision Workshop was held in October 2016, and convened climate change researchers from the Rocky Mountain Research Station, Colorado State University, and more than 20 staff from the Forest. Workshop topics included reviews of historical climate patterns, as well as projections for future climate in terms of temperature, seasonality, and precipitation. The timing of the workshop was deliberate, prior to development of the draft plan, so that Forest staff could use the information to inform interdisciplinary team meetings, shape plan components, and inform the analysis in the environmental impact statement. Workshop presentations summarized climate change models that suggest a 4.5-degree Fahrenheit increase in maximum daily temperature by 2060. Precipitation projections are highly variable with no discernible trend. Specific impacts of climate change were discussed and recorded in small groups. Existing stressors, such as drought, insect and disease outbreaks, invasive species range expansion, and increases in extreme weather events will be exacerbated by climate change. The second day of the workshop focused on climate change vulnerability and adaptation, including management responses to mitigate the effects of climate change. For example, one group reviewed alpine hydrology and fen ecosystems and made recommendations to be included in the revised plan. Three findings from this group were that management direction could be developed to 1) reduce the impact of biological stressors; 2) maintain or create refugia; and 3) maintain and enhance species structural diversity. The plan, released in 2017, took these recommendations and merged them with public input throughout the process; these recommendations evolved into three specific plan components for the forest plan to protect fens and other groundwater-dependent ecosystems. • DC-GDE-1: Identified groundwater-dependent ecosystems provide habitat for species of conservation concern and other native species. Fens continue to accumulate peat. (Forestwide) • S-GDE-1: Do not authorize management actions that alter the hydrology of groundwater- dependent habitat features. (Forestwide) • G-GDE-1: To maintain ecosystem diversity and function, design projects to avoid or mitigate negative impacts to the ecological services that groundwater-dependent ecosystems provide. (Forestwide) These plan components address all three recommendations for climate change adaptation that were identified in the workshop. The forest plan includes a standard to not alter hydrology for groundwater-dependent ecosystems that directs the Rio Grande National Forest to keep fens intact, as these serve as important refugia for many plant and animal species. This standard, combined with the guideline to maintain ecosystem diversity and function, will promote vegetation species diversity. The forest plan reduces the impact of biological stressors that might result from management decisions absent these components. Coarse- filter fen protection also provides habitat to species of conservation concern that rely on fens. In addition to groundwater-dependent ecosystems, the plan provides standards and guidelines, and other plan components to protect species, landscapes, and ecosystem services from stressors related to climate change impacts. Plan components that help ameliorate these

18 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments impacts include restrictions for range units to allow allotments to rest after grazing; protection for fens and groundwater-dependent ecosystems that are susceptible to drought; reduction and control of nonnative plants that compete with native species; provisions for forest management to reduce the threat of wildfire; and plan components for reduction for habitat fragmentation, as some examples. Large protected areas, such as designated and proposed wilderness, and Colorado roadless areas, also serve as climate refugia for more than half of the lands managed by the Rio Grande National Forest.

Comment CC – 5 Some commenters requested stricter plan components to address climate change impacts, while others suggested more flexibility to address changing conditions associated with climate change. Response The plan finds middle ground between a range of suggestions for dealing with climate change impacts. Some commenters suggested that the forest plan should commit to increasing carbon capture and storage by severely limiting all vegetation management activities, while others cautioned against being overly restrictive for future tree cutting as more vegetation management may be needed to address increased threats from drought and a need for protection from wildfires. The plan provides for an adaptive framework that will be better suited to deal with changing future conditions, rather than hardwiring plan direction for one possible future scenario. Monitoring will inform management about changing impacts being observed because of climate change and other stressors.

Congressionally Designated Trails (CDT)

Comment CDT – 1 The analysis should include more discussion of management that would apply when the Continental Divide National Scenic Trail goes through other management areas. Response Chapter 2 of the forest plan addresses management of the congressionally designated trails and overlapping direction. In situations where management areas overlap, management for both designations applies; however, the most restrictive management prevails over all other direction. As an example, the portion of the Continental Divide National Scenic Trail that passes through wilderness would not be available for mountain bike or over-snow motorized use as these uses are not permitted in designated wilderness.

Comment CDT – 2 The Forest Plan should not have Forestwide plan components, nor a separate management area or geographic area for the Continental Divide National Scenic Trail. Include these components in management areas that the Continental Divide National Scenic Trail crosses. The Forest Plan should include an objective to develop Continental Divide National Scenic Trail unit plan in accordance with Forest Service Manual 2353. 44b.

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Response Forest Service Handbook 1909.12 Chapter 20 Sections 24.2 and 24.43 require that the plan include plan components, including standards or guidelines, for appropriate management of designated areas or recommended designated areas in the plan area and that plan components provide for the nature and purposes of congressionally designated trails. Congressionally Designated Trail plan components complement the National Trails System Act and serve to further protect the trail for a continued long-term quality recreation trail opportunity. As a congressionally designated trail with specific management requirements under law and policy, the Continental Divide National Scenic needs separate forest plan direction as a resource that crosses multiple management areas. Including direction only in management areas would likely lead to inconsistent management of the trail across management areas. ”Natural” appearing conditions are not explicitly stated as a management requirement in the National Trails System Act; however, the term comes from an interpretation of manual direction related to scenery. The Act requires development of a comprehensive plan to provide specific objectives and practices to be observed in management of congressionally designated trails (16 USC 1244 e and f). The 2009 Continental Divide National Scenic Trail Comprehensive Plan identifies the trail as a concern level 1 route, with a scenic integrity objective of high or very high, depending on the trail segment. Forest Service Manual 2353.44b(1, 7) addresses the need for a management area that is broad enough to protect the natural, scenic, historic, and cultural features along the trail (FSH 1909.12). The Forest Service Manual also prescribes a one-half mile foreground viewed from either side of the Continental Divide National Scenic Trail travel route as a primary consideration in delineating the boundary of a Continental Divide National Scenic Trail management area (para. 2b). Forest Service Manual 2353.44b already provides direction to develop a unit plan for the Continental Divide National Scenic Trail and does not need to be readdressed in the forest plan. The forest plan is meant to complement Handbook and Manual direction without having to add direction from each area.

Comment CDT – 3 Cumulative effects analysis inadequately describes Continental Divide National Scenic Trail plan components and would likely be interpreted as more restrictive. Response Cumulative effects analysis does not describe plan components. Cumulative effects result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions. The analysis of cumulative effects provides a larger context in which to evaluate the effects of the forest plan. These describe the impacts of implementing the forest plan under different scenarios. Since the cumulative effects do not describe plan components and do not provide direction, they could not be more restrictive than the plan components.

20 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment CDT – 4 Condense and clarify plan components for the Continental Divide National Scenic Trail and ensure they are consistent with management allowed in the National Trails System Act. This does not require management for "natural" appearing conditions. Response The National Trails System Act, Administration and Development, Section 7 directs the trail manager in subpart (a) to develop and manage each segment of the National Trails System to be designed to harmonize with and complement an established multiple use plan for that specific area in order to ensure continued maximum benefits from the land. Subpart (c) states that “Other uses along the trail, which will not substantially interfere with the nature and purpose of the trail, may be permitted by the Secretary charged with the administration of the trail.” “to the extent practicable, efforts shall be made to avoid activities incompatible with the purposes for which such trails were established. Natural-appearing condition is addressed in comment CDT – 2, above. ”Natural” appearing conditions are not explicitly stated as a management requirement in the National Trails System Act; however, the term comes from an interpretation of manual direction related to scenery. The Act requires development of a comprehensive plan to provide specific objectives and practices to be observed in management of congressionally designated trails (16 USC 1244 e and f). The 2009 Continental Divide National Scenic Trail Comprehensive Plan identifies the trail as a concern level 1 route, with a scenic integrity objective of high or very high, depending on the trail segment.

Comment CDT – 5 Do not remove the Continental Divide National Scenic Trail nor Old Spanish National Historic Trail from suited timberlands. Response Chapter 2 of the forest plan addresses management of the congressionally designated trails and overlapping direction. Where management areas overlap, management for both designations applies; however, the most restrictive management prevails over all other direction. Congressionally designated trails are not removed from the suited timberlands; however, the activities that may occur within the area must conform to the standards and guidelines associated with congressionally designated trails.

Comment CDT – 6 The Forest Plan should include a guideline to relocate motorized sections on the Gunnison National Forest to nonmotorized sections of the Rio Grande National Forest. Response Forest plan objective (OBJ-CDT-1) addresses moving a portion of the Continental Divide National Scenic trail. Where trail reroute(s) may occur, it (they) would be addressed in subsequent site-specific analysis that includes public involvement.

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Comment CDT – 7 The Forest Plan direction for the Continental Divide National Scenic Trail should be consistent with Forest Service Manual 2353.44b(7). Include an objective to develop a unit plan (FSM 2354.44b). Response Forest Service Manual 2353.44(7) prescribes that the Continental Divide National Scenic Trail have a scenic integrity objective of high or very high. Desired condition DC-CDT-1 and guidelines G-CDT-1 and G-CDT-2 are consistent with Forest Service Manual direction. Forest Service Manual 2353.44b(2) already provides direction to develop a unit plan for the Continental Divide National Scenic Trail and does not need to be readdressed in the forest plan. The forest plan is meant to complement Handbook and Manual direction without having to add direction from each area. The forest plan incorporates Forest Service Manual 2353.44b(2)(b) by reference; it states “Except where the Continental Divide National Scenic Trail traverses a wilderness area and is governed by wilderness management prescriptions (36 CFR Part 293) and except where delineated in the applicable land management plan, establish a management area for the segments of the Continental Divide National Scenic Trail that traverse that unit that is broad enough to protect natural, scenic, historic, and cultural features (FSH 1909.12).” Alternative B includes the trail in Specially Designated Geographic Area whereas alternatives B Modified and C address the trail in the Specially Designated Management Area. Plan components ensure management of the trail is consistent with the nature and purposes of the trail as described in the 2009 Continental Divide National Scenic Trail Comprehensive Plan, and any revisions. Additionally, alternative D proposes creating a management area that encompasses the trail and the one-half mile corridor on either side of the trail.

Comment CDT – 8 A management area should be developed for the trail. Response Forest Service Handbook 1909.12 Ch. 20 Sec. 24.43 requires designated trail corridors to be identified and mapped as part of the forest plan, and requires plan components that provide for the nature and purposes of the trails. Plans may provide a management or geographic area for a national scenic or historic trail, but are not required to do so.

Comment CDT – 9 The Continental Divide National Scenic Trail should be located in primitive and semiprimitive nonmotorized recreation opportunity spectrum, or only on a road where it is primitive. Consider identifying segments that do not meet these criteria and include goals or objectives for improvement. Response Maintaining primitive and semiprimitive nonmotorized recreation opportunity spectrum classes throughout the trail would be inconsistent with the management direction for the Continental Divide Scenic Trail, which authorizes “the use of motorized vehicles on roads

22 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments which will be designated segments of the Continental Divide National Scenic Trail shall be permitted in accordance with regulations prescribed by the appropriate Secretary.” The Old Spanish National Historic Trail that coincides with the Rio Grande National Forest is on a highway and National Forest System road.

Comment CDT – 10 The forest plan must provide for the nature and purpose of Continental Divide National Scenic Trail and establish a management area that is broad enough to protect natural, scenic, historic, and cultural features (except in wilderness areas); must prescribe desired conditions, objectives, standards, and guidelines for Continental Divide National Scenic Trail. Response Congressionally designated trails are addressed in the forest plan. The nature and purpose of the trail is provided for in the desired conditions, objectives, standards, guidelines, and management approaches. The final environmental impact statement provides a variety of alternatives that provide for protection of the character of the trail. Forest Service Manual 2353.44b(2)(b) states “Except where the Continental Divide National Scenic Trail traverses a wilderness area and is governed by wilderness management prescriptions (36 CFR Part 293) and except where delineated in the applicable land management plan, establish a management area for the segments of the Continental Divide National Scenic Trail that traverse that unit that is broad enough to protect natural, scenic, historic, and cultural features (FSH 1909.12).” Alternative B includes the trail in Specially Designated Geographic Area whereas alternatives B Modified and C address the trail in the Specially Designated Management Area. Plan components ensure that management of the trail is consistent with the nature and purposes of the trail as described in the 2009 Continental Divide National Scenic Trail Comprehensive Plan, and any revisions. Additionally, alternative D proposes creating a management area that encompasses the trail and the one-half mile corridor on either side of the trail.

Comment CDT – 11 The forest plan should contain stronger standards and guidelines, which supersede those of management areas where the trails pass through. Response Chapter 2 of the forest plan addresses management of the congressionally designated trails and overlapping direction. In situations where management areas overlap, management for both designations applies; however, the most restrictive management that applies prevails over all other direction.

Comment CDT – 12 Remove comma between "primitive hiking" and "horseback" to align with nature and purpose in 2009 comprehensive plan. (Draft Plan, p. 49; DEIS, p. 288) Response The section has been revised in the forest plan.

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Comment CDT – 13 The forest plan should include a standard to manage the Continental Divide National Scenic Trail to provide high-quality scenic, primitive hiking and pack and riding opportunities and to conserve natural, historic, and cultural resources along the trail corridor. Response Forest Service Manuals 2353.31 and 2353.42 direct that the trail should have trail management objectives and be administered consistent with the Act as described by commenter. Desired condition DC-CDT-2 includes this direction. Management activities should move resources toward the desired condition. Scenery is also addressed in the Scenery section of the forest plan.

Comment CDT – 14 The Forest Plan should include the following standards: • Within the management area and on the trail, management actions and allowed uses must be compatible with maintaining or achieving primitive or semiprimitive nonmotorized recreation opportunity spectrum class settings, and providing for high quality primitive opportunities, to the greatest extent practicable. • Other uses that could conflict with the nature and purposes of the Continental Divide National Scenic Trail may be allowed only where there is a determination that the other use will not substantially interfere with the nature and purposes of the Continental Divide National Scenic Trail. • The minimum trail facilities and trail design standards necessary to accommodate the amount of hiking and horseback riding use anticipated on any given segment should be provided and used in order to protect resource values and for health and safety, not for the purpose of promoting user comfort. The purpose is to provide for a naturally appearing setting and primitive experience. • Motorized and mechanized use which is currently occurring on the trail must be periodically monitored (for volume, intensity, potential conflicts, and impacts to the trail) to ensure that the use is not substantially interfering with the nature and purposes of the Continental Divide National Scenic Trail. • Recreational target shooting is prohibited on, from, or across the Continental Divide National Scenic Trail. The reason is to preserve public health and safety and provide for the nature and purposes of the Continental Divide National Scenic Trail. Response Comment appears to include, at least in part, the regulations, general direction, and the direction provided for a unit plan consistent with 16 U.S.C. § 1246 and Forest Service Manual 2353.44b. To the extent this applies, it has already been covered by regulation and policy. Recreational shooting may be restricted by the responsible official. Recreation opportunity spectrum direction is included in the Recreation section of the plan. This applies Forestwide, so to restate the direction under the designated trails section would be redundant.

24 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Determining what uses are allowed on the trail is a site-specific decision better addressed at the project level applying sideboards expressed in the forest plan and other applicable direction. Minimum trail facilities and design standards are addressed through other means based on use and protection of resource values. The forest plan should not repeat other applicable direction. Site-specific analysis would appropriately consider individual uses and segments. Site-specific condition monitoring of the trails is included as part of policy. Monitoring is not included in plan components. The forest plan monitoring is included in Chapter 4. Monitoring of uses is part of the overall recreation program.

Comment CDT – 15 The Forest Plan should include the following guidelines: • Dispersed recreational activities such as recreational target shooting, drone use, camping, campfires, off route hiking or riding, etc., may be restricted, managed or prohibited as necessary if they are determined to substantially interfere with the nature and purposes of the trail. • Carrying capacities for specific segments of the Continental Divide National Scenic Trail should be developed. Conditions on the trail and its use must be monitored. Appropriate management actions to maintain or restore the nature and purposes of the Continental Divide National Scenic Trail should occur if the results of monitoring or other information indicate a trend away from the desired condition. Response The responsible official has the capacity to restrict and manage dispersed recreation activities without including that direction in the forest plan. This is generally based on safety concerns or resource damage and is addressed in project-level analysis. The forest plan does not include direction to complete other studies or carrying capacities. Monitoring and carrying capacity is addressed in the Management Approach section of the forest plan under Congressionally Designated Trails.

Comment CDT – 16 Consider using the latest version of the Continental Divide National Scenic Trail Planning Handbook (attached to letter 192). Response The Forest is following all relevant Continental Divide National Scenic Trail law and policy including the 1920;2350 letter on Developing Forest Plan Direction for the Continental Divide National Scenic Trail signed by Regional Foresters from Regions 1, 2, 3, and 4, and the Continental Divide National Scenic Trail (CDT) Recommended Forest Plan Components (Updated 11.16.2016).

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Comment CDT – 17 The following are recommendations for Continental Divide National Scenic Trail plan component desired conditions, objectives, and standards to be applied to a described management area for either the NEPA proposed action or for an alternative to be considered in detail. Additional Continental Divide National Scenic Trail plan component recommendations are found in the accompanying Continental Divide National Scenic Trail Planning Handbook in Chapter III. Plan component modifications are found. • Recommended Standard: Manage the Continental Divide National Scenic Trail travel route as a visual quality concern level 1 travel route. Resource management actions must meet a Scenic Integrity Level of Very High or High (2009 Continental Divide National Scenic Trail Comprehensive Plan, Chapter IV(B)(4)). • Recommended Standard: Resource management actions and allowed uses must be compatible with maintaining or achieving primitive or semiprimitive non-motorized recreation opportunity spectrum class settings, except motor vehicle use is allowed if such use is in accordance with the 2009 Continental Divide National Scenic Trail Comprehensive Plan, Chapter IV(B)(6) and Forest Service Manual 2353.44b(11). • Recommended Standard: Motorized and mechanized use by the general public may only be allowed where such use is in accordance with the 2009 Continental Divide National Scenic Trail Comprehensive Plan, Chapter IV(B)(5) and (6) and Forest Service Manual 2353.44b(10) and (11). • Recommended Standard: Road construction and reconstruction for public use is prohibited; excepted are motor vehicle use circumstances described in the 2009 Continental Divide National Scenic Trail Comprehensive Plan Chapter IV(B)(6) and FSM 2353.44b(11). • Recommended Standard: Other uses that could conflict with the nature and purposes of the Continental Divide National Scenic Trail may be allowed only where there is a determination that the other use would not substantially interfere with the nature and purposes of the Continental Divide National Scenic Trail (16 USC 1246(c)). • Recommended Standard: Where the Continental Divide National Scenic Trail corridor overlaps with Wilderness designations the most restrictive measures control. Response This direction is addressed in the 2009 Comprehensive Plan, Forest Service Manuals and Handbooks; therefore, it does not need to be added to the forest plan.

Comment CDT – 18 The Forest Plan should establish a Continental Divide National Scenic Trail Management Area to be consistent with the National Trails System Act. A corridor is not addressed in alternatives A, B, and C. Response The trail is presented as a corridor that encompasses the one-half-mile side scenic buffer in alternative B, B Modified, and C. Alternative B includes the trail in a Specially Designated Geographic Area whereas alternatives B Modified and C address the trail in the Specially

26 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Designated Management Area. Plan components ensure management of the trail is consistent with the nature and purposes of the trail as described in the 2009 Continental Divide National Scenic Trail Comprehensive Plan, and any revisions.

Comment CDT – 19 The purpose and need for action should describe the need and purposes that Congress established for National Scenic and Historic Trails. Response The purpose and need for action established for the National Scenic and Historic Trails are addressed in the National Trails System Act of 1968, National Parks and Recreation Act of 1978, and Old Spanish Trail Recognition Act of 2002 as addressed elsewhere.

Comment CDT – 20 The draft environmental impact statement affected environment description does not describe the effects of alternatives being considered, including recreation opportunity spectrum, scenic integrity, and carrying capacity of allowable uses. This section should include various impacts of current management. Response Affected environment established and described the existing condition and does not vary by alternative. Programmatic analysis considers the outcomes that may result from implementing the proposed management direction for each alternative. Estimating effects at the programmatic forest-plan level makes assumptions that the types of resource- management activities allowed under the prescriptions are reasonably foreseeable future actions to achieve the goals and objectives stated in the forest plan. The impacts of current management are addressed in the description of the existing condition. Since forest plans do not prescribe site-specific projects, effects are displayed to programs more than resources. Cumulative effects result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency or person undertakes such other actions. The analysis of cumulative effects provides a larger context in which to evaluate the effects of the forest plan, Cumulative effects described in terms of a program at the forest-plan scale can be discussed only in terms of general programmatic tendencies toward either improved or declining condition.

Comment CDT – 21 The draft environmental impact statement erroneously states that "Alternative A does not have any specific management direction for any congressionally designated trails on the Forest." (DEIS, p. 290) Response Alternative A, which would allow for the Forest to continue using the current forest plan, does not contain any specific management direction for congressionally designated trails.

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Management would adhere to the National Trails System Act of 1968 and other relevant policy.

Comment CDT – 22 This discussion of alternatives B, C, and D does not address the environmental consequences of these action alternatives on the nature and purposes of National Scenic and Historic Trails. The disclosure is inconsistent with 40 CFR 1502.24, including not using the recreation opportunity spectrum and scenery management system planning frameworks to address the environmental effects of the alternatives. This section is inadequate and is inconsistent with the requirements of 40 CFR 1502.16. Response See response to Comment CDT-20.

Comment CDT – 23 The draft environmental impact statements fails to disclose cumulative impacts and fails to describe impacts to the nature and purposes of Continental Divide National Scenic Trail and Old Spanish National Historic Trail. Response Forest plan analysis represents a programmatic level of planning. Since forest plans propose no on-the-ground impacts, effects are expressed relative to how the direction in the forest plan would impact the overall resource program. Site-specific analysis would be conducted for project-level proposals and would address on-the-ground changes and impacts that are likely to occur if the proposal is implemented. Since these trails are managed under higher level direction, the National Trails Act, applying forest plan-level direction would not likely impact the nature or purpose of the trails. See response to Comment CDT-20. Among other analysis, the draft environmental impact statement includes the following: “Implementation of any of the alternatives could result in short-term impacts that result in long-term benefits. Relocation of trails to improve consistency with historic routes would provide a positive overall experience in the long term. Population increases over time could increase the number of users and therefore impact the trails, and increase user-related conflicts. Past management of the Old Spanish National Historic Trail may have resulted in fewer intact cultural resources to identify, evaluate, research, and/or interpret. Past and future forest management projects can cause surface disturbance, bring additional people into contact with cultural resources, and affect the integrity of historic structures. Cumulative effects that are the result of ground disturbance associated with implementing each of the alternatives could result in the inadvertent discovery of, and potential damage to, Old Spanish National Historic Trail sites, artifacts, or trail traces. Protection protocols included in all alternatives would mitigate impacts to inadvertent discoveries.”

28 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment CDT – 24 The draft environmental impact statement effects analysis should include tables that describe the relationship between the proposed Continental Divide National Scenic Trail travel route location and management corridor/rights-of-way extent and the intersection and overlap with the proposed recreation opportunity spectrum classes and scenic integrity objectives allocations. Response Proposed trail relocations would be addressed in site-specific analysis. Maps display overlap of Continental Divide National Scenic Trail in alternatives in relation to management areas, which further define recreation opportunity spectrum classes and scenic integrity objectives.

Comment CDT – 25 The analysis needs to address how the land management planning decisions will 1) provide for the nature and purposes of the National Trail; 2) identify primary users; 3) address carrying capacity; and 4) prevent other uses from substantially interfering with the nature and purposes of the National Trails. Response These concerns are more appropriately addressed in relation to actual site-specific proposals that relocate the trails. Forest plan direction provides sideboards for implementing site- specific proposals.

Comment CDT – 26 Continental Divide National Scenic Trail direction should be coordinated with the GMUG Forest Plan. Response The Rio Grande coordinates with adjacent units, including the GMUG, on the Continental Divide National Scenic Trail.

Comment CDT – 27 Consider the following attachments to our comment letters. • Appendix A - Continental Divide National Scenic Trail Saguache Park High Potential Route Segment Corridor. • Appendix B - Management Corridor and Canada Lynx North Pass Area. • Appendix C - Recommended Continental Divide National Scenic Trail National Trail Management Corridor. Response All comments and attachments were considered. The attachments stated above were in part included in alternative D.

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Comment CDT – 28 Establishing a management area for congressionally designated trails such as Management Area 4.23 outlined in alternative D would be helpful in the forest plan to specifically address the associated rule set. Response The trail is presented as a corridor that encompasses the one-half mile side scenic buffer in alternatives B, B Modified, and C. Alternative B includes the trail in the Specially Designated Geographic Area whereas alternatives B Modified and C address the trail in the Specially Designated Management Area.

Comment CDT – 29 The term “Unit Plan” needs to be defined. Response A unit plan provides direction for the management of a given resource that is only associated with the specific site or Forest. A unit plan is not the same as a forest plan and is further described in Forest Service Manual 2352.44b.

Comment CDT – 30 Bicycle trail construction is a suitable activity for the Continental Divide National Scenic Trail and in a management area designation. Response This would be decided after completion of a site-specific analysis that is in compliance with forest plan direction and direction for the Continental Divide National Scenic Trail.

Comment CDT – 31 A mapped trail corridor might allow more flexibility in future decisions regarding management of the trails. Response The trail is presented as a corridor that encompasses the one-half-mile side scenic buffer in alternative B, B Modified, and C. Alternative B includes the trails in Specially Designated Geographic Area whereas alternatives B Modified and C address the trail in the Specially Designated Management Area. Additionally, alternative D proposes creating a management area that encompasses the trail and the one-half mile corridor on either side of the trail.

Comment CDT – 32 Assertions that the National Trails System Act trail must be nonmotorized are inaccurate and do not provide for a balanced view. Response Section 7c of the National Trails System Act says that National Scenic Trails are to be nonmotorized, with few exceptions. Exceptions are provided for the Continental Divide

30 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments National Scenic Trail. These are described in the Comprehensive Plan. In general trails should be nonmotorized in areas that are already or will be areas that restrict motorized use.

Comment CDT – 33 A one-half-mile buffer on either side of congressionally designated trails does not take into account public safety from hazard trees. Response The one-half-mile-wide buffer addresses scenery concerns related to the trail corridor. Public safety from hazard trees is addressed in Forest Service Manual 2300, Chapter 2350.

Comment CDT – 34 Mandatory exclusionary corridors directly conflict with the congressional intent of the National Trails System Act. Response A mapped trail corridor is required by Forest Service Handbook 1909.12. The corridor itself is not exclusionary, as it is just a spatially identifiable area. Forest plan direction applied to the corridor determines what management activities could occur within the corridor.

Comment CDT – 35 Given the specific recognition of snowmobiling, four-wheel drive, and all-terrain vehicles as allowed trail usages, any attempt to exclude such usages from the Continental Divide National Scenic Trail would be on questionable legal ground. Response The National Scenic Trails Act provides for limited motorized use on the Continental Divide National Scenic Trail. Such use must not substantially interfere with the nature and purpose of the trail. In general motorized use is authorized to continue and when conflicts arise opportunities to relocate the trail would be considered an option. The Trails Act provides for recreation, conservation, and enjoyment of significant scenic, historic, natural, or cultural qualities.

Comment CDT – 36 Creating a landscape-level buffer around the congressionally designated trails prohibiting multiple use would be in violation of the NTSA and the Continental Divide National Scenic Trail management plan. Response See response to Comment CDT – 35. The landscape-level buffer, or mapped corridor, does not in itself prohibit any uses. The mapped corridor ensures potential impacts to the Continental Divide National Scenic Trail, particularly to scenery, are taken into account when planning and implementing projects that may affect the trail.

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Comment CDT – 37 Management of nationally designated trails requires maximizing economic benefits. Response Per Forest Service Manual 2353.3 (b). “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).” While the National Trails System Act does not require “maximizing economic benefits,” National Scenic Trails, as drivers of recreation tourism, indeed help to contribute to local economies.

Comment CDT – 38 A cost: benefit analysis of corridor management related to the trails must be completed. Response Please refer to the Socioeconomics section of the analysis.

Comment CDT – 39 Closure of historical travel routes would incur additional costs to management. Response Closures of historic travel routes would be evaluated on a site-specific basis.

Comment CDT – 40 Consider revising DC-CDT-1: Viewsheds from the Continental Divide National Scenic Trail have high scenic values. The landscape generally appears unaltered by human activities. The potential to view wildlife is high and evidence of ecological processes such as fire, insects, and diseases exist. Response Desired condition DC-CDT-1 has been simplified in the forest plan as follows: “Viewsheds from the Continental Divide National Scenic Trail have high scenic values. The foreground of the trail is natural appearing. The potential to view wildlife is high and evidence of ecological processes such as fire, insects, and diseases exists. (Forestwide)” The direction stated in the forest plan combined with direction related to scenery is very similar. The desired condition as presented is consistent with the 1920;2350 letter on Developing Forest Plan Direction for the Continental Divide National Scenic Trail, signed by Regional Foresters from Regions 1, 2, 3, and 4, and with the Continental Divide National Scenic Trail (CDT) Recommended Forest Plan Components (Updated 11.16.2016).

Comment CDT – 41 Viewsheds from the Continental Divide National Scenic Trail have high scenic values. The landscape along the Continental Divide National Scenic Trail travel route is naturally

32 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments appearing, and generally appears unaltered by human activities. The potential to view wildlife is high and evidence of ecological processes such as fire, insects, and diseases exists. Response The direction in the plan is intended to maintain these values. The desired condition as presented is consistent with and the 1920;2350 letter on Developing Forest Plan Direction for the Continental Divide National Scenic Trail, signed by Regional Foresters from Regions 1, 2, 3, and 4, and with the Continental Divide National Scenic Trail (CDT) Recommended Forest Plan Components (Updated 11.16.2016).

Comment CDT – 42 Rewrite desired condition DC-CDT – 7 as The Continental Divide National Scenic Trail is a well-defined trail that provides for high-quality primitive hiking and horseback riding opportunities, and other compatible nonmotorized trail activities, in a highly scenic setting along the Continental Divide. The corridor encompasses national trail resources, qualities, values, associated settings and the primary use or uses. This includes vistas, campsites, water sources, and other important resource values. The significant scenic, natural, historic, and cultural resources along the trail corridor are conserved. Where possible, the trail provides visitors with expansive views of the natural landscapes along the Continental Divide. Response The comment is restating the Act and policy. Recreational opportunity settings and scenic integrity objectives are described by management areas. These are well described in the forest plan and all direction applicable to the Continental Divide National Scenic Trail. The forest plan should not repeat other direction. This desired condition is addressed in other plan direction.

Comment CDT – 43 The setting of the Continental Divide National Scenic Trail corridor is consistent with or complements a primitive or semiprimitive nonmotorized setting. Recreation opportunity spectrum class inconsistencies are managed to protect trail values. Response Recreational opportunity spectrum classes are described by management areas. These are well described in the forest plan and all direction applicable to the Continental Divide National Scenic Trail. This desired condition is addressed in other plan direction.

Comment CDT – 44 OBJ-CDT-1 should read “Restore or relocate segments of the Continental Divide National Scenic Trail to improve scenic view opportunities and/or to provide for a nonmotorized experience. Response Forest Service Handbook 1900.12 requires that objectives be measurable and time specific.

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Comment CDT – 45 Limit use of the word "corridor" to be consistent with nature and purpose from the 2009 Comprehensive Plan; define to be same as the viewshed. Then add following five standards: • S-CDT-1: Management activities within the landscape of the Continental Divide National Scenic Trail shall be consistent with, or make progress toward achieving, high or very high scenic integrity objectives to protect or enhance scenic qualities. Among other things: • S-CDT-2: Oil and gas or geothermal energy development, or other leasable mineral activities are unsuitable unless they leave the landscape character appearing intact. • S-CDT-3: Common variety mineral extraction (e.g., limestone, gravel, pumice, etc.). are unsuitable unless they leave the landscape character appearing intact. • S-CDT-4: [Insert proposed S-CDT-3 relating to motorized events and motorized special use permits]. A new standard S-CDT-5 should be inserted to implement Section 7(c) of the National Trails System Act (16 U.S.C. § 1246(c)): • S-CDT-5: The use of motorized vehicles on the Continental Divide National Scenic Trail, by members of the general public, may not be permitted unless such use is determined (1) not to substantially interfere with the nature and purposes of the trail and (2) to have been allowed by administrative regulations at the time the Trail was designated (November 10, 1978); or such use otherwise conforms to the Motorized Use Policy stated in the 2009 Continental Divide National Scenic Trail Comprehensive Plan. Response Standards S-CDT-2 and S-CDT-3 have been reworded in forest plan. Standard S-CDT-4 related to motorized events has been deleted. Some areas of the trail coincide with motorized trails or National Forest System road segments; revisions occurred in response to internal and external comments between release of the draft and final documents. Direction was revised and combined while maintaining the intent of the direction. Motorized events on the Continental Divide Scenic Trail are a site-specific decision for a responsible official to make. Decisions are made in compliance with all applicable direction. The direction as presented is consistent with the Continental Divide National Scenic Trail (CDT) Recommended Forest Plan Components (Updated 11.16.2018). The trail is presented as a corridor that encompasses the one-half-mile side scenic buffer in alternative B, B Modified, and C. Standard S-CDT-5 is covered by the Act and 2009 Comprehensive Plan that is included as policy in FSM 2353 and need not be repeated here.

Comment CDT – 46 The final environmental impact statement should consider defining and mapping a corridor in the forest plan with alternatives evaluated. Proposed standard CDT-1, 2, and 4 should be restated to reflect this change.

34 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response The final environmental impact statement considers both congressionally designated trails in several ways. Alternative A addresses only the width of the trail on the landscape. Alternatives B, B Modified, and C consider these trails as corridor with the inclusion of a one-half-mile-wide scenic buffer. Alternative D creates a management area specific to the congressionally designated trails. The selected alternative will display the trail as a one-half- mile-wide corridor on all maps.

Comment CDT – 47 Revise standard S-CDT-3 to exclude permitting motorized events on some sections of the trail. Response Standard S-CDT-3 has been deleted from the forest plan. Some areas of the trail coincide with motorized trails or National Forest System road segments, Motorized events on the Continental Divide Scenic Trail are a site-specific decision for a responsible official to make. Decisions are made in compliance with all applicable direction.

Comment CDT – 48 S-CDT-3 should be corrected to make the trail nonmotorized. Response Standard S-CDT-3 has been deleted from the final version of the forest plan. Some areas of the trail coincide with motorized trails or National Forest System road segments that would be inconsistent with commenter’s request until those segments are designated outside of those areas.

Comment CDT – 49 S-CDT-4 should read management activities in the congressionally designated trail corridors shall must be consistent with, or make progress toward achieving, high or very high scenic integrity objectives to protect or enhance scenic qualities. Response Standard S-CDT-4 has been deleted in the final version of the forest plan and has been addressed in scenery components.

Comment CDT – 50 S-CDT-4 and S-CDT-2 should be consolidated into one standard. Response Standard S-CDT-4 and guidelines G-CDT-2 have been deleted in the forest plan and are addressed in scenery components.

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Comment CDT – 51 Consider deleting G-CDT-2 and S-CDT-4 as the direction is already provided under scenery. Response Standard S-CDT-4 and guideline G-CDT-2 have been deleted in the final version of the forest plan and are addressed in scenery components.

Comment CDT – 52 S-CDT-4 and G-CDT-2 should be combined. Response Standard S-CDT-4 and G-CDT-2 have been deleted in forest plan. This direction is better addressed under scenery and will be combined with other applicable direction.

Comment CDT – 53 G-CDT-3 should read, if forest-health projects result in short-term impacts to the scenic integrity of the trail, mitigation measures should be included, such as screening to reduce short-term impacts to the scenic integrity from management activities adjacent to the trail. Response Guideline G-CDT-3 has been reworded in the forest plan as follows: Forest health projects that result in short-term impacts the scenic integrity of the Continental Divide National Scenic Trail should apply mitigation measures, including but not limited to screening. (Forestwide) Mitigation for resource protection is best addressed at the site-specific level of analysis.

Comment CDT – 54 G-CDT-4 should read, in order to promote a nonmotorized setting, the Continental Divide National Scenic Trail travel route should not be permanently relocated onto routes open to motor vehicle use. Response G-CDT-4 has been removed in the forest plan. Plan direction incorporates policy that already requires this. On July 3, 1997, correspondence from the Deputy Chief of the Forest Service to Regional Foresters stated that “…as the CDT is further developed, it is expected that the trail will eventually be relocated off of roads for its entire length.”: FSM 2353.44b(8) “…Where possible, locate the CDNST in primitive and semiprimitive nonmotorized recreation opportunity spectrum classes, provided that the CDNST may have to traverse intermittently through more developed recreation opportunity spectrum 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).”

36 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment CDT – 55 Rewrite G-CDT-6 to read: new communication sites, utility corridors, and renewable energy sites should not be allowed within the foreground and middle-ground viewshed to protect the scenic values of the trail. Response Guideline G-CDT-6 was deleted in forest plan. Any new communication or other sites are best addressed at the site-specific level in compliance with direction contained in the forest plan. These type of projects are addressed elsewhere in the plan not specific to the congressionally designated trails.

Comment CDT – 56 Rewrite G-CDT-9 to read: the use of the Continental Divide National Scenic Trail for landings or as a temporary road for any purpose should not be allowed to provide for a naturally appearing setting while avoiding visual, aural, and resource impacts. Response G-CDT-9 was deleted in the final version of the forest plan. Many segments of the Continental Divide correspond with roads and therefore could be appropriate for use. This would be addressed in a site-specific analysis of the tradeoffs and impacts.

Comment CDT – 57 G-CDT-11 should read: manage unplanned fires in the foreground (up to one-half mile) of the trail using minimum impact suppression tactics, or other appropriate tactics, for the protection of the congressionally designated trail values. Allow heavy equipment line construction within the corridor only when necessary for emergency protection of life and property. Response G-CDT-11 was deleted in the forest plan. In the event of wildfire many decisions take place. Firefighting resources would be informed of the trail and the associated values and commensurate levels of protection would be undertaken.

Comment CDT – 58 The forest plan should remove requirements for minimum suppression tactics and restrictions on heavy equipment adjacent to the CDT in G-CDT-11, G-CDT-12, and MA-CDT-13. Response G-CDT-11 and G-CDT-12 were deleted in the forest plan. These decisions are made when suppression is implemented. See response to Comment CDT – 54 above.

Comment CDT – 59 The Forest Plan supersedes the Comprehensive Plan until amended. The Forest Plan should clarify the relationship between the Comprehensive Plan and the Forest Plan in G-CDT-13.

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Response The 2009 Comprehensive Plan is included as policy in Forest Service Manual 2353. Guidance is provided in a letter (File Code: 1920;2350) on Developing Forest Plan Direction for the Continental Divide National Scenic Trail, signed by Regional Foresters from Regions 1, 2, 3, and 4, and the Continental Divide National Scenic Trail (CDT) Recommended Forest Plan Components (Updated 11.16.2016). This guidance, along with the comprehensive plan, is used in managing the Continental Divide National Scenic Trail.

Comment CDT – 60 Condense and clarify plan components by deleting MA CDT-6, MA-CDT-10, and MA-CDT- 11. Consider rewriting the others as objectives. Response Revisions made in response to internal and external comments included reformatting management approaches. Management approaches presented in the draft forest plan were carried forward from guidance in the letter (File Code: 1920;2350) on Developing Forest Plan Direction for the Continental Divide National Scenic Trail, signed by Regional Foresters from Regions 1, 2, 3, and 4, and the Continental Divide National Scenic Trail (CDT) Recommended Forest Plan Components (Updated 11.16.2016). Draft Plan MA-CDT-6 has been deleted from final forest plan, but some language has been included in introduction of section. MA-DC-10 has been slightly reworded in the final document. MA-CDT-11 has been deleted.

Comment CDT – 61 The environmental impact statement does not adequately analyze the Rio Grande National Forest revised forest plan’s impact on the Continental Divide National Scenic Trail. Response The Forest Service is the lead agency responsible for management of the Continental Divide National Scenic Trail, which traverses multiple states, land ownerships, and jurisdictions. Management of the entire length of the trail is intended to be consistent with the nature and purposes of the trail as described in the 2009 Continental Divide National Scenic Trail Comprehensive Plan, and any revisions. Specific to the Rio Grande National Forest, the one-mile-wide trail corridor encompasses about 75,445 acres over a span of 170 miles along the Forest’s western boundary. The preferred alternative contains specific management direction for the Continental Divide National Scenic Trail that were developed with consideration of both the Continental Divide National Scenic Trail 2009 Comprehensive Management Plan and the continuously revised 2016 Continental Divide National Scenic Trail Recommended Forest Plan Components. The Continental Divide National Scenic Trail corridor is mapped as a linear feature which overlays multiple management areas in the preferred alternative. In addition to the management direction specific to the Continental Divide National Scenic Trail corridor, plan direction associated with each management area the trail corridor traverses across the Forest would also apply.

38 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Under the preferred alternative, the majority of the trail corridor falls within Management Areas 1 – Wilderness (34,265 acres) and 3 – Colorado Roadless Areas (16,230 acres). These two management areas account for about 50,495 acres (67 percent) within the Continental Divide National Scenic Trail corridor. About 20,300 acres (27 percent) of the trail corridor falls within Management Area 5 – General Forest and Rangelands. The remaining 4,650 acres (6 percent) of the Continental Divide National Scenic Trail corridor encompasses lands within Management Area 4 – Special Designations, including Scenic Byway and Railroad (Management Area 4.21), Eligible Wild and Scenic Rivers (Management Area 4.34), and Ski- Based Resort (Management Area 4.8). Under the preferred alternative, the majority (75 percent) of the Continental Divide National Scenic Trail corridor is located within nonmotorized desired summer recreation opportunity spectrum settings. Specifically, about 22,110 acres (29 percent) of the trail corridor are within a primitive setting while about 34,875 acres (46 percent) are within a semiprimitive nonmotorized setting. The remaining 18,460 acres (25 percent) of the Continental Divide National Scenic Trail corridor encompass motorized desired summer recreation opportunity spectrum settings. About 11,220 acres (15 percent) of the trail corridor are within a semiprimitive motorized setting, about 5,320 acres (7 percent) are within a roaded natural setting, and about 1,920 acres (3 percent) are within a rural setting.

Cultural Resources (CR)

Comment CR – 1 Closures of areas due to cultural resources is not justified. Response Federal statutes including the National Historic Preservation Act, Antiquities Act, Archaeological Resources Protection Act, and Historic Sites Act (Appendix I) require Federal agencies to protect and preserve significant historic properties. Eligible historic properties are also protected under 36 CFR 800.1-2, 800.4 and 800.8 and with aid from the heritage manual 2360. Sometimes these areas are high value nonrenewable resources within historic districts or cultural landscapes that require special management considerations and consider feeling, setting, and integrity. Some cultural resources are considered areas of tribal importance or sacred sites. Federal agencies have a federal trust responsibility to Federally Recognized Indian Tribes and are charged with protecting these areas from certain management activities, require special design features, or both to allow for certain management activities under the American Indian Religious FI tooreedom Act and Sacred Sites Executive Order 13007. Area closures would be used when no other mitigation remedies are successful.

Comment CR – 2 There needs to be a standard protecting cultural sites from any type of management and from vandalism.

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Response The forest plan contains provisions to protect cultural sites from management activities. Forest plan direction S-CR-1 states that all contracts, agreements, and special use permits include provisions as needed to protect cultural resources. The language of this standard was broadened in response to public comment to include protection for all cultural resources rather than limiting the standard to National Register listed or eligible sites. Higher level direction, including the National Historic Preservation Act, the Antiquities Act, the Archaeological Resources Protection Act, and the Historic Sites Act, mandate protections of significant cultural resources. Eligible historic properties are also protected under 36 CFR 800.1-2, 800.4 and 800.8 and with aid from Forest Service Manual 2360. Additionally, the Heritage Program Managed to Standard guides the Heritage Program in seven key indicators: • program planning, • cultural resource inventory, • cultural resource evaluation and official designations, • condition assessment and allocation, • stewardship and protection, • public outreach and benefit, and • heritage volunteerism. With respect to protections against vandalism, forest plans are designed to guide Forest Service activities, and are not intended to regulate the actions of the public. There are laws protecting historic sites from vandalism and prescribing legal penalties for violators. Deterrence and enforcement related to vandalism of historic sites is better managed by statute and the use of law enforcement than through the forest plan.

Comment CR – 3 The Forest should ensure the maximum, balanced, and ecologically advantageous protection of the RGNF in promulgating the new 20-year land management plan. Such protection means including the newly proposed wilderness areas and special interest areas in the new plan. It is in fact the most profound “sense of place” flourishing within the Indo-Hispano culture of northern New Mexico and of the San Luis Valley that is given voice as “querencia.” Sense of place as querencia is a deep feeling of belonging to a place which one loves by caring for that place. Querencia is an essential element of the identity of persons who dwell in a landscape (constituted by land and by the living water originating in wilderness). Response The Rio Grande National Forest acknowledges the importance of a ‘sense of place,’ and the forest plan provides guidance on the area’s distinctive roles and contributions within the broader landscape. Goal 3, for example, speaks to the importance of connecting “people to the past and their land” and managing the Forest in a way that provides “tangible links to historically rooted beliefs, customs, and practices.” Revision Topic 1 also integrates this comment by emphasizing a need for change related to designated areas on the Forest, many of which are linked to important cultural and historic resources. Chapter 3 of the final environmental impact statement also identifies cultural continuity as a trademark of the San

40 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Luis Valley, and by extension, the Forest. Finally, the forest plan included desired conditions and management approaches the ensure protections of these important resources.

Comment CR – 4 MA-CR-1 is confusing, is the intent to protect sites from vegetation management, or make sure they are not subject to islanding. Response In response to this comment, the language of the plan was changed to clarify that the intent of the management approach is to ensure that when heritage sites are buffered from management activities to protect the resource it does not lead to an ‘islanding’ effect where the buffered area stands out from the surrounding landscape. That situation could lead to damage to the site due to erosion, severe fire effects, or livestock grazing.

Fire (FIRE)

Comment FIRE – 1 There is conflicting plan direction regarding wildfire suppression and the desired conditions for wildfire. Response The direction between the draft and final forest plans has been clarified and simplified in response to public comment. The desired conditions were combined to read “Wildland fire and fuels reduction treatments are used to create vegetation conditions that reduce threats to real property and infrastructure from wildfire. Fuel loads on lands adjacent to developed areas and communities are reduced. Lands adjacent to private property and infrastructure have defensible space and dispersed patterns of fuel conditions that would favorably modify wildfire behavior and reduce the rate of spread in and around communities at risk.” This removes discrepancies and potential conflict from the previous desired conditions and other plan in the draft plan related to fire. Wildfire and the threat of future fire continues to be a paramount concern to protect infrastructure, adjacent communities, and the resources we manage.

Comment FIRE – 2 The environmental impact statement includes a discussion of fire suppression states that when factors are not properly aligned, “fires are not typically not successfully suppressed.” To convey the proper meaning here, one “not” should be deleted. Response The wording has been changed to clarify that fires typically are not successfully suppressed when factors are not properly aligned.

Comment FIRE – 3 A more comprehensive method for fire preparedness, response, and funding is needed.

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Response Fire funding and preparedness is beyond the scope of this analysis and is being addressed at the national level. Fire response is addressed in multiple places in the forest plan and the environmental impact statement. The environmental impact statement explains that wildfires are managed on a continuum between meeting protection objectives and resource objectives. The strategic fire management zones and desired conditions outlined in the plan provide direction on where the fire response should fall on that continuum, depending on where the fire occurs. DC-FIRE-2, coupled with the strategic fire management zones, provides additional guidance on the appropriate response to natural ignitions. S-FIRE-1 adds further clarity by mandating that unplanned human-caused ignitions not be managed for resource benefit. Additional direction for fire response is also contained in processes that exist outside the forest plan, such as the Wildfire Decision Support System and the Fire Danger Operation Plan. The environmental impact statement also notes that there many factors that can determine the appropriate response to a wildfire, including firefighter and public safety, risk to property, fire management resource availability, national and regional priorities, costs, and potential resource benefits. The forest plan provides guidance on the appropriate response, but tactical details are best left to be determined as each situation arises.

Comment FIRE – 4 The forest plan lacks the necessary details and parameters that would define how and when wildfire for restoration would be used. As described we believe this would be detrimental to summer tourism. Response Using wildfire for restoration is a decision made at the initiation of each wildfire start. Each individual fire presents a different set of conditions to be assessed to determine if the fire would be allowed to burn to meet a resource objective. Many factors must be considered including location relative to values at risk, topography, current and expected weather conditions, fuel type, fuel loading and arrangement, live and dead fuel moisture, availability of resources to monitor and manage the fire, other on-going fires, and the national need for resources, etc. As stated above, these conditions are unique to each fire and not something that can be displayed or articulated at a forest plan level. During a wildfire, tourism would be considered as a value at risk.

Comment FIRE – 5 Alternative B does not change plans for fire management on the Forest. Response Several management areas considered in alternative A (4.21, 4.3, 5.11, 5.13, 8.22) require that all fires are suppressed regardless of the cause. The action alternatives (B, C, and D) provide for strategic fire management zones corresponding with management areas. These areas allow naturally occurring wildfires to be managed for resource benefit if conditions are favorable to protect important values while still benefiting the resource.

42 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment FIRE – 6 Fire Management (Plan at pp. 57-58): The plan and the other two action alternatives would direct that all human-caused wildfires be suppressed. S-FIRE-1, Plan at 57; DEIS at 23. This would be true even in the Wildfire Management Zone: Resource Restoration, the zone where “managing wildfire to meet resources objectives is the least constrained” (DEIS at 23, 98), and there is “minimal emphasis" on suppression” (Plan at 73). While many human-caused fires will likely have to be suppressed, it should still be an option to let such fires burn under certain conditions, to be decided at the time of the fire. These fires may, in some situations, help meet ecosystem needs and desired conditions. We recommend rewriting S-FIRE-1 and the description of Wildfire Management Zone: Resource Restoration accordingly. Response Forest Service Manual direction is very specific on how human caused fires must be managed and does not allow consideration for achieving resource benefit. Reference FSM 5100 - FIRE MANAGEMENT, CHAPTER 5130 - WILDFIRE RESPONSE, 5130.3 - Policy Human-caused fires and trespass will be managed to achieve the lowest cost and fewest negative consequences with primary consideration given to firefighter and public safety and without consideration to achieving resource benefits.

Fisheries (FISH)

Comment FISH – 1 A standard should be included that prohibits discretionary use or activity in Rio Grande cutthroat trout, and other important fish habitat, unless it is designed to benefit or has no negative effect. Response The Rio Grande National Forest acknowledges the importance of maintaining quality habitat for Rio Grande cutthroat trout. Experience has shown that quality cutthroat trout habitat can be achieved in conjunction with other management objectives. The forest plan includes standards and guidelines designed to maintain persistence of Rio Grande cutthroat trout populations while allowing flexibility to achieve other forest plan goals and objectives. Another plan component, G-FISH-3, directs specialists to consult the Fisheries Activity Period Maps during project development and design. The Fisheries Activity Period Maps delineate restricted activity periods based on critical spawning and recruitment times when the fish are most susceptible to disturbance. Other standards and guidelines, including S- GDE-1, G-GDE-1, S-RMZ-1, G-RMZ1, G-RMZ-2, S-WA-1, G-WA-1, G-WA-1, G-WA-2, G-FISh-1, G-FISH2, and G-MIN-1 provide direction to minimize impacts to aquatic ecosystems and maintain ecosystem conditions for populations of Rio Grande cutthroat and other important fish species. Project-level analysis would include a determination of effects and, if needed, mitigations or additional protections for all occupied streams and levels of Rio Grande cutthroat trout genetic status.

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Comment FISH – 2 We recommend including a standard that prohibits mineral extraction within Rio Grande cutthroat trout core population streams. Response The forest plan includes multiple components designed to minimize the impacts of mineral extraction on Rio Grande cutthroat trout populations. Several changes made between issuing the draft and final forest plans in response to public concerns about the impacts of mineral extraction. For example, G-MIN-1, was broadened to limit impacts on fish and aquatic habitats from all mineral extraction and not just recreational dredging. Recreational dredging and the impact on Rio Grande cutthroat trout is addressed in more detail in a Minerals Management Approach, which, among other things, limits the use of the practice to outside of critical life-stage periods in streams that have Rio Grande cutthroat trout core conservation populations. This Management Approach is further supported by G- FISH-3, which requires consultation of Fisheries Activity Period Maps during the development and design of projects, including recreational dredging, to avoid impacts during critical life-stage periods. Plan direction was revised to include a Management Approach that explains the process of having minerals activities administered through a plan of operations, which includes permits as well as the reclamation and mitigation measures necessary to protect resources. These plans of operation will require site-specific project-level analysis, which will determine the purpose and need of the proposed action and identify effects that may call for additional mitigations or protections for streams containing Rio Grande cutthroat trout.

Comment FISH – 3 The environmental impact statement states "Application of plan direction in alternatives B, C, and D should ensure proper grazing management and reduce the effects to fisheries and aquatic ecosystems," yet the forest plan provides no requirements only general goals and objectives and a few discretionary guidelines. Response The forest plan includes plan components for range management that are intended to protect aquatic ecosystems, riparian zones, and fisheries. For example, G-RNG-3, protects stream habitat integrity by requiring compliance with residual stubble heights that allow for bank protection and entrapment of sediment. Project-level restrictions in the Watershed Conservation Practices Handbook (FSH 2509.25), serve to protect soil and watershed resources, which are the primary impacts related to fisheries from range management. Direction from this handbook, as well as the National Core Best Management Practices (FS-990A), were incorporated into the plan through S-WA- 1. Project-level analysis of range allotments would include a determination of effects and, if needed, mitigations or additional protections for aquatic resources.

44 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment FISH – 4 The Forest’s decision to not to follow the aquatic ecosystem classification structure offered in the Assessment should be explained, including discussion on the implications for ecosystem integrity. Response The assessment process was used to inform the development of the forest plan, but does not necessarily dictate how analysis or the plan itself should be organized and structured. Aquatic ecosystems are linked to nearly all resources within the Forest and therefore it is difficult to limit their discussion and importance in one section. This led to analysis for these systems being covered throughout the analysis in many sections. The analysis found in the Riparian, Wetlands, and Fens section of the environmental impact statement summarizes the primary diversity of aquatic habitats within the Forest, including wet meadows, fens, riparian shrubland, riparian woodland, marsh, wetlands, rivers, and both ponds and lakes. The analysis found in the Aquatics Ecosystems and Forested Ecosystem sections of the environmental impact statement further summarizes the open water systems that provide fisheries habitat, streams and lakes, and montane riparian zones, respectively. Additional analysis on other aquatic ecosystems can also be found in many other sections throughout the environmental impact statement. This fully represents the range of aquatic and riparian ecosystems noted in Assessments 1 and 3. The importance of key ecosystem characteristics, (e.g., unique fen habitats) for each and their effects on ecosystem integrity are analyzed in each alternative. Plan components developed for groundwater-dependent ecosystems and riparian management zones link key species of conservation concern tied to these habitats. Plan components that address species of conservation concern can be found in Appendix D.

Comment FISH – 5 A standard is needed that requires prevention of genetically pure or nearly pure native aquatic species from interbreeding with nonnative species and thereby destroying the gene pool. Response The Rio Grande National Forest recognizes the importance of maintaining the genetic integrity of native aquatic species. The primary mechanism to prevent interbreeding between native and nonnative fish species is physical separation, and in response to public comment, the forest plan addresses the need to prevent interbreeding between native and nonnative species in multiple ways. First, the wording of two plan components related to aquatic organism passage (S-FISH-1 and G-FISH-1) was modified to provide a clear exception for when barriers are needed to protect native aquatic species from undesired nonnative fish. Additional protection for genetic integrity of native aquatic species is found in a fisheries management approach, in which the Forest commits to continuing cooperation in the Rio Grande cutthroat trout, Rio Grande sucker, and Rio Grande chub conservation agreements. Among many things, these agreements identify mechanisms for protecting and enhancing the genetic integrity of the populations. The management approach also notes that the Forest will coordinate with staff from Colorado Parks and Wildlife on fish stocking programs. This

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ensures benefits and reduces degrading effects on native and desired nonnative fish and aquatic species. The importance of maintaining native fish species is also emphasized in the management approach for wilderness. There, “fish stocking emphasizes a wild fishery, where species perpetuate themselves over time and are affected primarily by the forces of nature. Some high mountain lakes may be stocked to support indigenous threatened, endangered, and proposed species as well as species of conservation concern. Species of fish that are not indigenous to the area or that are exotic will not be stocked.” Finally, any proposed restoration project related to these species or construction project that could impact connectivity would include a project-level determination of effects as well.

Comment FISH – 6 Reword DC-FISH-5 to promote connectivity rather than prevent barriers. Desired conditions should design and implement management actions to promote connectivity in physical habitat and genetics of native and desired nonnative fish. Response The Rio Grande National Forest acknowledges the importance of habitat connectivity for aquatic species, and desired conditions related to fisheries were modified in response to public comment. Desired conditions for fisheries speak to the need to prevent barriers caused by management actions, as well as the need to actively promote connectivity. DC-FISH-1 calls for habitat connectivity to be maintained or enhanced through management activities, while DC-FISH-2 points to the importance of avoiding fragmentation caused by management activities.

Comment FISH – 7 Remove reference to "sensitive" in S-FISH-1, G-FISH-2. Response The wording of S-FISH-1 has been changed to clarify that the standard applies to listed, proposed, or candidate species. The G-FISH-2 guideline in the draft forest plan was removed because it would not constrain project and activity decision-making as required by the 2012 Planning Rule. (36 CFR § 219.7(e)(1)(iv)). Public comment correctly pointed out that some plan components in the draft plan needed to better align with the definitions of the 2012 Rule.

Comment FISH – 8 In S-FISH-1 and G-FISH-1, add the phrase after "and for species of conservation concern, except when barriers are needed to protect form undesired nonnative fish." This allows for installation and maintenance of fish barriers when needed for protection of Rio Grande cutthroat trout. Response The Forest recognizes the importance of maintaining the genetic integrity of native aquatic species. In response to this comment, S-FISH-1 and G-FISH-1 have been revised to add a

46 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments clear exception for when barriers are necessary to prevent native species from interbreeding with undesired nonnative fish.

Comment FISH – 9 An objective was not brought forward from internal discussions regarding an annual timeline for updating fisheries activity period maps. Re-insert the language as it would not require a significant effort but would ensure that maps are accurate for project-level analysis. Also the last sentence of MA-FISH-1 could be clarified to read “Fisheries activity period maps provide species-based seasonal timeframes for projects conducted in or near aquatic habitats on the Forest." The maps are for project-level use, not related to agreements as currently stated. Response In response to this comment, the Fisheries management approaches were revised to clarify that fisheries activity period maps facilitate consistent and effective implementation of agreements and guide project-level analysis and oversight of recreational dredging. An objective for annual updates of the Fisheries Activity Period maps was not included in the forest plan in order to maintain the flexibility to update the maps as needed rather than on a schedule that is prescribed by the forest plan.

Geology, Energy, and Minerals (MIN)

Comment MIN – 1 The forest plan should consider incorporating Colorado Parks and Wildlife recommended fluid mineral stipulations to minimize impacts to wildlife. Response The Forest is not completing an oil and gas leasing availability analysis at this time per 36 CFR 228.102. There are no active oil and gas leases on the Forest; lease sales near South Fork and Del Norte remain deferred as of 2017. Leasing direction from the 1996 forest plan, as amended, is still applicable and has been adopted in this proposed plan. When individual lease parcels are processed, additional stipulations will be added to minimize impacts on wildlife in compliance with site-specific species included as plan components in this plan.

Comment MIN – 2 The Forest Plans should have a no surface occupancy stipulation or discretionary no lease for the Chama Basin. Response Chama Basin area has previously been evaluated as possessing high potential for oil and gas resources. In 2011, the Forest completed acquisition of the mineral rights through a project called the Banded Peak Land Exchange. This project consolidated surface and mineral estates under Federal jurisdiction, thereby assuring compatible management. Federal ownership of the mineral estate allows complete discretion to the Forest Service about future mineral

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leasing. All action alternatives in environmental impact statement note updated Federal ownership of the acquired mineral estate. No Surface Occupancy stipulations could be applied either at the leasing availability (if revised) or at lease processing. Discretionary No Lease should be applied at the leasing availability stage if applicable area is greater in size than an individual lease. This forest plan is adopting the leasing analysis from the 1996 forest plan, as amended; it is not amending or revising the current leasing analysis, so we are not determining suitability of lands or developing any new stipulations at the programmatic level. Any agreements reached during the Banded Peak land exchange will be adhered to. That noted, there are several concerns if this area were ever proposed for leasing that would need project-level consideration such as Chama Basin Special Interest Area, current management as roadless, watershed protections, etc. that may allow or restrict surface access. The Forest will continue to work with other agencies regarding mineral leasing.

Comment MIN – 3 Maximum protection of the Rio Grande National Forest from all extractive activities (minerals and logging), and commercial development. Response The Forest Service adheres to a multiple use mission. This includes extractive activities such as mining. With regard to minerals: • Leasing direction from the 1996 forest plan, as amended, is still applicable and has been adopted in this proposed plan. • Minerals activities are administered through a plan of operations or notice of intent. This includes all required permits, reclamation, and mitigation measures necessary to protect resources. See plan component G-MIN-1. • Additionally, a management approach has been reworded for recreational dredging to minimize effects on forest environments and habitats.

Comment MIN – 4 The forest plan should prohibit future oil and gas leases to protect the forest; sensitive areas, wilderness, and other special areas; and ecosystem services. Response The exploration for and production of oil and gas resources is generally allowed on National Forest System lands, exceptions include lands formally withdrawn from mineral leasing by Congress or an Executive order. The agency’s decision to lease lands is not dictated by the forest plan. Instead, the forest plan identifies what lands may be suitable and which standards and guidelines might apply. Leasing direction from the 1996 forest plan, as amended, is still applicable and has been adopted in this proposed plan. The Forest is not completing a revised oil and gas leasing availability analysis at this time per the requirement of 36 CFR 228.102. A separate Forest Service analysis of adopted direction would be provided to the USDI Bureau of Land Management to lease specific parcels and prescribe appropriate stipulations.

48 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment MIN – 5 The analysis should not rely on outdated data (stipulations)/analysis from the 1996 plan to describe the environmental and cumulative effects. Analysis must include impacts of hydraulic fracturing. Response Leasing direction from the 1996 forest plan, as amended, is still applicable and has been adopted in this proposed plan. The Forest is not completing a new oil and gas leasing availability analysis at this time. The oil and gas direction is not being changed at this time; therefore, the cumulative effects analysis is reliant on the stipulations from the 1996 forest plan. New programmatic lease stipulations will be developed when, or if, the Forest determines the need to complete a new leasing analysis. However, lease stipulations consistent with this forest plan may also be applied to individual lease parcels during processing. There currently is not a reasonably foreseeable development scenario for oil and gas development on the Forest (or existing leases) that would warrant analysis at the plan level for impacts that are not anticipated, such as those from hydraulic fracturing. It is speculative, at best, to assume that oil and gas development would even occur and that would result in these effects. Recent trends for the Forest do not suggest otherwise.

Comment MIN – 6 The forest plan should manage future leases with care to protect water quality. Response General direction for protecting water quality and quantity are included in the plan. All potential lease parcels would apply stipulations from the 1996 plan, as amended, and adopted and follow direction from this plan.

Comment MIN – 7 The forest plan should not approve any leasing activities until an updated oil and gas leasing suitability analysis is complete. Response Oil and gas leasing suitability is has been addressed in alternative suitability tables in the environmental impact statement. Leasing direction from the 1996 forest plan, as amended, has been reviewed is still applicable and has been adopted in this proposed plan; therefore, lease parcels may be processed when this plan is in effect in compliance with the Energy Security Act of 1980 that expressly states “It is the intent of Congress that the Secretary of Agriculture shall process applications for leases on National Forest System lands and for permits to explore, drill, and develop resources on land leased from the Forest Service, notwithstanding the current status of any plan being prepared under section 6 of the Forest and Rangeland Renewable Resources Planning Act of 1974.” Additional stipulations may be added at that time to lease parcels to be consistent with the other direction in this plan.

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Comment MIN – 8 The forest plan should offer more protection for aquatic and wildlife resources, including a one-quarter-mile buffer in native trout streams. Response Forest plan direction includes minerals plan component G-MIN-1 and management approaches that address aquatic habitat and water quality. There are various riparian management zone buffers added to the plan to protect native fish and other water resource values. As stated in Appendix F, widths for riparian management zones apply to lakes, open water wetlands, and perennial and intermittent streams, including those inhabited by native trout on the Forest and species of conservation concern. There are multiple criteria that can be used to determine these widths for projects, but the most conservative is up to 300 foot slope distance from the ordinary high water mark. In all cases, these criteria can be adapted with the use of a site-specific analysis determined during project-level analysis to define the riparian management zones that best encompass the extent of the functions and processes necessary to protect the linkage and transitional habitat between hillslopes and upland terrestrial habitat and the aquatic habitats within stream channels. In addition, the management measures of Forest Service Handbook 2509.25 (Watershed Conservation Practices Handbook), and provisions of Forest Service 990a (National Best Management Practices for Water Quality Management on National Forest System Lands) will be employed during individual project execution. Additional protections for those streams that are determined to be eligible or suitable Wild and Scenic Rivers follow Forest Service Handbook 1909.12, documented as Management Area Specific Standard 3.4-S-2, and include at least one-quarter-mile widths. Standard S-WA-1 incorporates best management practices and Forest Service Handbook 2509.25 into plan direction. Fisheries guideline (G-FISH-3) specifically addresses recreational dredging and sets a calendar-based restriction for activities based on whether there are native trout in the streams.

Comment MIN – 9 Minimize impacts from increased oil and gas activities on the Forest that could harm hunting, fishing, tourism, and other forms of recreation. Response Impacts are analyzed at the Application for Permit to Drill phase of the oil and gas approval process. Conditions of approval may also be considered at that time which may reduce impacts to recreational activities. All actions would be addressed in a site-specific analysis.

Comment MIN – 10 Supports reasoning to complete a separate environmental analysis on oil and gas suitability. Response Oil and gas leasing suitability has been addressed in alternative suitability tables in the environmental impact statement. Leasing direction from the 1996 forest plan, as amended, has been reviewed, is still applicable, and has been adopted in this proposed plan; therefore,

50 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments lease parcels may be processed when this plan is in effect. Additional stipulations may be added at that time to lease parcels to be consistent with other direction in this plan.

Comment MIN – 11 The Forest should prohibit new leasing activities until updates are completed following the release of the forest plan and record of decision. Response Leasing direction from the 1996 forest plan, as amended, has been reviewed, is still applicable, and has been adopted in this proposed plan; therefore, lease parcels may be processed when this plan is in effect. Additional stipulations may be added at that time to lease parcels to be consistent with other direction in this plan.

Comment MIN – 12 The Forest Plan should not allow new leasing until updated information can be assessed. Response Leasing direction from the 1996 forest plan, as amended, has been reviewed, is still applicable, and has been adopted in this proposed plan; therefore, lease parcels may be processed when this plan is in effect. Additional stipulations may be added at that time to lease parcels to be consistent with other direction in this plan.

Comment MIN – 13 The analysis needs to document rationale for keeping areas open to leasing under the 1996 Plan (see Handbook references). Response Oil and gas leasing suitability is has been addressed in alternative suitability tables in the environmental impact statement. Leasing direction from the 1996 forest plan, as amended, has been adopted in the record of decision; therefore, lease parcels may be processed when this plan is in effect.

Comment MIN – 14 Future leasing must be done in an environmentally sensitive manner and fully analyzed under NEPA. Response Leasing direction from the 1996 forest plan, as amended, has been reviewed, is still applicable, and has been adopted in this proposed plan; therefore, lease parcels may be processed when this plan is in effect. Additional stipulations may be added at that time to lease parcels to be consistent with other direction in this plan.

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Comment MIN – 15 The forest plan must prohibit oil and gas development in wilderness areas, special interest areas, and other areas in alternative D for resource protection and climate mitigation. Response Management areas that contain proposed designated areas (wilderness, wild and scenic rivers, etc.) should be managed so as to not impair being able to manage for the characteristics that are being considered. This may include discretionary no lease or no surface occupancy stipulations. While there are no active oil and gas leases on the Forest, management areas for designated, proposed for designation, and special interest areas will be consistent with management area direction. Subject to valid existing rights, wilderness areas are withdrawn from mineral leasing at the time of congressional designation.

Comment MIN – 16 Suitability for oil and gas leasing should be determined for all alternatives and leasing stipulations must be stated in management area direction. Response Oil and gas leasing suitability has been addressed in alternative suitability tables in the environmental impact statement (Chapter 2). Leasing direction from the 1996 forest plan, as amended, has been reviewed, is still applicable, and has been adopted in this proposed plan.

Comment MIN – 17 A no-leasing alternative needs to be considered. The proposed plan provides less protection from oil and gas impacts than the current plan but this is not analyzed. Response The exploration for and production of oil and gas resources is an authorized use of National Forest System lands, except on lands that have been formally withdrawn from mineral leasing by Congress or an Executive order. The agency’s decision to lease lands is not dictated by the forest plan. Instead, the forest plan identifies what lands may be suitable and which standards and guidelines might apply. Leasing direction from the 1996 forest plan, as amended, has been reviewed is still applicable and has been adopted in this proposed plan. Additional stipulations may be added at that time to lease parcels to be consistent with the other direction in this plan.

Comment MIN – 18 The plan needs a standard for which lease stipulations will be required under what conditions. The 1996 has guidelines for this. Response Leasing direction from the 1996 forest plan, as amended, is still applicable and has been adopted in this proposed plan. Additional stipulations may be added at the time lease parcels are processed to be consistent with the other direction in this plan.

52 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Infrastructure (INFR)

Comment INFR – 1 The Forest Plan should allow for maintenance of existing infrastructure in designated wilderness areas. Response Handbook and manual direction allows for operation and maintenance of facilities in wilderness. The Forest Service also has a multitude of authorized exceptions under emergency circumstances through the Minimum Requirements Decision Guide process, which is a requirement through the Wilderness Act of 1964. The Wilderness Act designates the Regional Forester as the lowest level line officer authorized to utilize this discretion.

Comment INFR – 2 The analysis should include language that alternative C would be most beneficial for maintenance of roads due to more vegetation projects. Response Maintenance of roads would not necessarily increase under any of the alternatives. Road maintenance would be concentrated in a project area. This could result in lower maintenance of roads elsewhere due to a greater concentration of time and money being expended in vegetation project roads.

Comment INFR – 3 The analysis and forest plan should review required infrastructure maintenance and consider how work could be done more efficiently. Response Infrastructure maintenance needs change from year to year due to lifespan, wear and tear, weather, rodents, vandalism, etc. Therefore, maintenance priorities are difficult to define over the forest planning time horizon. The Forest Facility Master Plan addresses infrastructure maintenance for buildings, water systems, and wastewater systems.

Comment INFR – 4 The forest plan is too complex and inefficient with management direction for maintenance and repair of infrastructure in wilderness areas. Response See response to Comment INFR – 1. Management direction for maintenance and repair of infrastructure in wilderness area is addressed in Forest Service Handbook and Manual direction. The forest plan helps to implement this direction.

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Comment INFR – 5 The forest plan should consider streamlining the process for maintenance undertakings. The Forest should make it easier, more affordable, and simply more efficient with the new plan. Response Maintenance is covered under Forest Service Handbook and Manual Direction. Streamlining for undertakings must adhere to all governmental guidelines for purchase, procurement, contracting, and any other monetary and nonmonetary constraints covered by the Forest Service, the Department of Agriculture, and other Government policies.

Comment INFR – 6 The forest plan should add language to address the types of activities allowed in wilderness for infrastructure maintenance, including a time to review approved tools and methods for different types of projects. The plan should consider new types of tools that reduce noise for situational contexts. Response See response to Comment INFR – 1. Forest Service Handbook and Manual direction address the types of activities allowed in wilderness. The Wilderness Act of 1964 also addresses this issue and provides the approved tools and methods needed to determine what can be done in the wilderness. An example would be that we can perform trail maintenance in wilderness, but in order to use any mechanized or motorized tools (i.e., chain saws), a Minimum Requirements Decision Guide would be needed.

Comment INFR – 7 Include a guideline that discourages public use of administrative sites and permitted roads with signs and structures. Response Administrative sites and permitted roads with signs and structures are evaluated on an as-needed basis and are constantly being updated and monitored. Motorized vehicle use maps identify roads, trails, and areas designated for motor vehicle use.

Comment INFR – 8 The forest plan should clarify or eliminate the statement that "Road and trail construction generally follows direction outlined in the 2012 Colorado Roadless Rule." (Draft Plan, p. 84) Response Forest plan direction says that “Road and trail construction and reconstruction follows direction outlined in the 2012 Colorado Roadless Rule (36 CFR 223).” which is a requirement from Chapter 36, Code of Federal Regulation, Section 223. Direction in the plan will adhere to the Colorado Roadless Rule. The Colorado Roadless Rule does not authorize road and trail construction, and any construction still is subject to the NEPA process.

54 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment INFR – 9 Modify suitability chart (Table 12, p. 91) that suggests motorized travel is not suitable in general or upper tier roadless. Response The table has been corrected and clarified.

Comment INFR – 10 The forest plan should have a suitability determination that no new or additional motorized trails will be authorized or created within roadless areas to be consistent with the Colorado Roadless Rule. Response The Colorado Roadless Rule, 36 CFR Part 294, RIN 0596-AD26 final rule does not prohibit the ability to construct new motorized trails in roadless areas. The intent is to prohibit roads that are highly developed and often leave dramatic linear scars on the landscape. Motorized trails are meant to harmonize with the environment and are intended to leave minimal trace of dramatic change to the environment; trails should be designed to harmonize with the environment.

Comment INFR – 11 The forest plan should contain an additional guideline of "Road and trail maintenance investment on Rio Grande lands should be prioritized by travel analysis that categorizes investment priority based on route value to public lands and loss of agency investment, as well as risk to the environment and the traveling public" using scale ranging from high benefit/low risk to low benefit/high risk. Response Direction is provided in Forest Service Manual 7712.2 Land Management Planning, Travel Analysis and Travel Management Decisions, so there is no need to repeat this direction in the forest plan. Travel analysis provides a bridge from strategic guidance in the forest plan to project-level travel management decisions and can help in prioritizing road management options and priorities, such as maintenance.

Comment INFR – 12 The forest plan should include a guideline for "Roads and trails that are removed from the San Juan National Forest transportation network, as well as maintenance level 1 roads (i.e., roads that have been closed to the public but may be used in the future principally for administrative purposes), should be treated sufficiently where no further management intervention would be necessary in order to sustain long-term natural processes. This will avoid future risks to watershed functions, water quality, and/or aquatic habitat. Sufficient treatments may include removal of unstable fills, effective and permanent breaching of drainage ditches, elimination of persistent in sloped road surfaces; complete removal of

55 USDA Forest Service stream-crossing structures and associated fills with restoration of floodplains, and the maintenance or restoration of fish passages" [copied from the San Juan Forest Plan]. Response Directives are in Forest Service Handbook 7709.59, CH 60; and FSM 7734.1 Decommissioning treatments; there is no need to add this direction as a forest plan guideline. In addition, the National Best Management Practices for Water Quality Management on National Forest Systems Lands provides technical guidance related to road storage and decommissioning practices.

Comment INFR – 13 The forest plan should carry over the existing guideline of “Travelways no longer needed, or that are contributing to resource damage that cannot be mitigated, shall be obliterated, revegetated, and/or sloped to drain.” Response See INFR – 11 and 12.

Comment INFR – 14 The forest plan should consider guidelines to better guide route decommissioning to 1) reduce density, 2) need for route, 3) degradation, 4) cost, 5) alternative routes, 6) resource protection, and 7) low-benefit routes. Response The Travel Management Rule covers this process in that it directs Federal entities that manage Federal lands to protect the resources of those lands. The travel management process and project-level analysis will result in determinations on route decommissioning. See also INFR – 11 and 12.

Comment INFR – 15 The forest plan should include language to allow off-route travel for recreation. Response The forest plan does not address off-route travel and horseback riding. The Travel Management Rule determines motorized travel routes and directs Federal agencies to ensure that the use of off-road vehicles on public lands will be controlled and directed so as to protect the resource of those lands.

Comment INFR – 16 The analysis should include analysis on sustainability of the road system and impacts to ecosystem process and integrity. (See attached literature review) Response See INFR – 11.

56 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment INFR – 17 An adequate road and trail network is necessary to provide access for forest management and emergencies. Response Direction in Forest Service Handbooks and Manuals as well as travel management direction speak to having a road system that meets the needs for public access and management of the resources.

Comment INFR – 18 Duplicative routes offer benefits for distributing use versus concentrating it. Every route has value and provides a unique experience. Response While some duplicative routes are necessary, the Forest needs to present a road system that is able to be maintained. Travel management will address these concerns after the forest plan is complete.

Comment INFR – 19 Designating routes for administrative use should only be done when excluding the public can be justified for site-specific, meaningful and justifiable reasons. Response Designating routes is not included in the forest plan revision process.

Comment INFR – 20 Table 53 on page 216 of the draft environmental impact statement needs to be updated. It is not appropriate to use information from a 2007 document. Response Table 53 reflects alternative A, which is the current forest plan approved in 1996. The numbers in the table are applicable for alternative A, which is a baseline.

Comment INFR – 21 There should be no non-emergency off-road travel in the snow-free season. This allows illegal creation of routes, which become very difficult to decommission. Off-road motorized use is very damaging to soils, especially in wet, non-rocky areas (See DEIS at p. 153). Response Off–road motorized travel is often damaging to soils and vegetation, as well as impacts to stream sediment. As stated on page 153, off-road travel is generally prohibited on the Forest except under very specific conditions. Impacts from recreation will continue to be monitored by the Forest.

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Comment INFR – 22 Consider adding direction to MA-INFR-1 that "newly acquired facilities will be closed to public use if and until they are determined to be safe, functional, and necessary.” Response Management approaches included under infrastructure, state that “Facilities acquired through land donation, exchange, or purchase are not retained unless they serve a definitive purpose and funding is available for maintenance or they are historically significant.” Public access and safety would be evaluated at the time of acquisition.

Comment INFR – 23 Revise MA INFR-4 to state that travelways are closed, unless open. The current language implies that they are open unless closed. This direction needs to be rewritten to make it clear that roads can be close to public motorized use if any of the listed conditions exist. Response Agency policy is that travelways are open unless closed through travel management. The current motorized vehicle use map displays those roads that are open to motorized use. The list presented for closing roads is not an exhaustive list; there are many considerations that could prompt a closure. Most all closures would have analysis prior to closure.

Comment INFR – 24 Regarding MA-INFR-5, the forest plan incorrectly uses management approaches. Plan direction for over-snow vehicle use is closed unless designated as open, after the publication of an Over Snow Vehicle Map. MA-INFRA-5 should be a standard, not a management approach. It should state: After the publication of an over snow vehicle map, over the snow motorized vehicle use on snow is prohibited unless specifically allowed. This direction needs to be rewritten as a standard as suggested: On all lands except designated travelways, motorized use in prohibited unless the motor vehicle use map or a forest order indicates that such use is specifically allowed. This applies to motor vehicles operating over snow as well as on dry land. Response Management approaches are described in Forest Service direction (FSH 1909.12 §22.4) as optional content that could facilitate transparency and give the public and governmental entities a clear understanding of the plan and how outcomes would likely be delivered. Management approaches can describe strategies and program priorities that the responsible official intends to employ to carry out projects and activities. In response to external and internal comments management approaches have been revised in format and content to meet direction in Forest Service Handbook 1909.12. Travel management is meant to allow use unless specifically prohibited. The wording has been changed to clarify the intent.

58 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment INFR – 25 The forest plan should modify MA-INFR-6 to state "allowable modes of travel should be clearly signed at trailheads and route and use information should be signed at intersections." Response The motor vehicle use map identifies roads, trails, and areas designated for motorized use. Many trails are signed for appropriate uses at the trailheads.

Comment INFR – 26 The forest plan should modify MA-INFRA-7 to remove the words "disperse existing use into different areas." Response The forest plan includes a slight rewording to MA-INFRA-7. Dispersal of use into different areas would still need to be consistent with resource management objectives. In response to external and internal comments management approaches have been revised in format and content to meet the direction in Forest Service Handbook 1909.12.

Comment INFR – 27 The forest plan should revisit MA-INFR-8 and its use of "route." INFR-8 needs to be a standard or at least a guideline and amended to state that road use should be managed with seasonal closures if any of the listed conditions exist. Response The forest plan includes a slight rewording to MA-INFRA-8 for seasonal need for protection. We feel that a management approach is appropriate for this specific intent, and it does not need to be in a standard or guideline. The management approach in question correctly uses the term road. Seasonal closures may be instituted as needed or required.

Comment INFR – 28 The forest plan should modify MA-INFR-13 to read "move toward a sustainable route system." Response This direction occurs in other locations and does not need to be repeated in the forest plan. MA-INFRA-13 was modified slightly for clarity that the travel management process is followed.

Comment INFR – 29 You need to add a MA (MA-INFR-14) or G in infrastructure or lands that directs coordination and maintenance of cell towers and communication structures to consider impacts on migratory birds, bats, and other wildlife species.

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Response Communication sites are addressed in the Lands section. Project-level analysis addresses impacts to wildlife and other resources.

Aquatic and Terrestrial Nonnative Invasive Species and Noxious Weeds (NNIS)

Comment NNIS – 1 More clarification is needed to be consistent with the Colorado Department of Agriculture's Rules Pertaining to the Administration and Enforcement of the Colorado Noxious Weed Act 9 for List A and List B species and provisions should be included in the plan to allow for the use of state-approved biological control agents as one of the tools to manage noxious weeds. Response In response to this comment, management approaches were revised to include the term ‘noxious weeds’ so that all biological, cultural, and chemical tools are available to reduce or control nonnative invasive species and noxious weeds. The Rio Grande National Forest prepares an Invasive species Action Plan that outlines a strategy and direction to treat invasive plant and animal species. The Action Plan is prepared in compliance with other direction and analysis, including: • The Forest Service National Strategic Framework for Invasive Species Management • Forest Service Handbook and Manual direction at 2900- Invasive Species • Rocky Mountain Regional Invasive Species Management Strategy • Environmental Assessment for the Management and Control of Noxious Plants on the San Juan/Rio Grande National Forests • Management and Control of Noxious Plants on the San Juan/Rio Grande National Forests Sufficiency Determination and Supplemental Information Report. The Action Plan defines priority nonnative invasive species, outlines the best methods for treatments, and identifies areas of the Forest to target. In response to this comment, nonnative invasive management approaches were revised so that the forest plan clearly outlines the intention of the Forest to align the Invasive Species Action Plan with the Colorado Department of Agriculture’s Rules contained in Colorado Noxious Weed Act 9 for List A and List B species. The Invasive Species Action Plan is better suited than the Forest Plan to provide a high level of detail and direction on nonnative invasive plants.

Comment NNIS – 2 For the last 20 years: What are the trends on the Forest for acres occupied by terrestrial nonnative invasive species; what tools are used to manage/control nonnative invasives; if funding is trending down what can be done to promote funding; where are the most problematic locations on the Forest; which alternative would create the largest stimulation for noxious weed infestations and which would be most resilient; what is the prognosis of infestations on the Rio Grande?

60 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response Available trends of acres treated over the past 10 years has been included. Additional information has been included in the Aquatic and Terrestrial Nonnative Invasive Species and Noxious Weeds section of the environmental impact statement. Funding for treatment of noxious weeds and terrestrial nonnative invasive species varies annually. Funding for treatment of these species generally comes from NFVW (National Forest Vegetation and Wildlife) and CWKV (Knudsen-Vandenberg funds), which are collected as a result of timber harvest. Funding from NFVW remains generally similar across years; however, since CWKV funds are tied to timber harvested on the Forest, these vary greatly. Acres treated are a mix of harvested timber sales and other acres as appropriate. Canada thistle is seen most across the Forest; it is associated with ground disturbance, seed sources are widespread, and seeds sprout quickly in response to disturbance. It is most often found where new road construction or maintenance has occurred, but even natural ground disturbance provides an avenue for sprouting. Canada thistle has been found on natural landslides, beaver dams, or other areas where natural ground disturbance occurs. Oxeye Daisy is increasing and is most likely the result of past reclamation seed mixtures that included the seed for aesthetic reasons. This is prevalent along State highways where the plants have spread out of the right-of-way. Cheatgrass is also mostly propagated by ground disturbance but sometimes just needs bare ground to become established. Areas that have been burned either naturally or from using prescribed fire techniques have produced large stands of cheatgrass. Additionally yellow toadflax, Russian knapweed, black henbane, short whitetop (hoary cress), and others are aggressive invaders and are occupying areas where there is no apparent disturbance and areas with well-established native vegetation. The Forest applies an Integrated Pest Management approach in treating nonnative invasive species and noxious weeds. Integrated pest management is a broad-based approach that integrates practices for economic control of pests. The practice aims to suppress pest populations before infestations get out of control. Treating infestations before they get large and preventing them from spreading is better from an economic and environmental standpoint. To be proactive the Forest requires that heavy equipment used for project work is cleaned before moving onto the Forest or when moving from an area known to have noxious weeds. Large road work contractors are also required to obtain needed road base and gravel from a weed free source. The Forest prepared an Invasive Species Action Plan that outlines a strategy and direction to treat these species, both plant and animal. In the recent past the Forest has begun to implement cooperative agreements with local counties to increase the number of acres treated. Contracting has also been implemented but is not as cost effective as other avenues. Due to its remote location, the Forest receives very few bids on contracts. Also timing constraints are problematic, as contractors are not always available at the proper time for treatment.

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The Forest has worked collaboratively with the Bureau of Land Management in treating weeds, using a permanent seasonal position as well. In 2017, funds were available through the Resource Advisory Council to treat active gravel pits to avoid the spread of nonnative invasive species and noxious weeds during road construction and reconstruction. Lastly, as needed force account crews are available to assist in this work, and volunteers. Since funding varies so widely, all available avenues for treating these species are employed annually.

Table 2. Treatment of nonnative invasive species on the Forest, 2004–2018

Implementation Acres Tools used Funds Year treated 2018 3,293 Herbicides, hand work NFVW, CWKV 2017 920 Herbicides, hand work NFVW, CWKV 2016 300 Herbicides, hand work NFVW, CWKV 2015 8 Herbicides, hand work NFVW, CWKV 2014 1,234 Herbicides, hand work NFVW, CWKV 2013 542 Herbicides NFVW, CWKV 2012 250 Herbicides NFVW, CWKV 2011 37 Herbicides, hand pulling NFVW, CWKV 2010 37 Herbicides, hand pulling NFVW, CWKV 2009 870 Herbicides NFVW, CWKV NFVW, CWKV, 2008 330 Herbicides NFN3 2007 325 Herbicides NFVW, CWKV Herbicides, pulling, domestic sheep 2006 549 NFVW, CWKV grazing 2005 280 Herbicides, domestic sheep grazing NFVW, CWKV 2004 400 Herbicides NFVW, CWKV

Comment NNIS – 3 The forest plan needs to define what effective prevention and control measures are. Response The introduction and spread of nonnative invasive species is a dynamic process that requires the flexibility to respond and adapt management approaches to changing conditions. Over the life of this forest plan, the primary nonnative invasive species threats and the tools available to combat them may evolve. Defining effective prevention and control measures in the forest plan could limit the ability of the Forest to adapt to changing conditions. Instead, the forest plan provides strategic guidance in the form of management approaches, desired conditions, and objectives. This plan content, together with additional guidance in the Forest Invasive Species Action Plan and National and Regional Forest Service policy documents, provides the Forest with the direction needed to effectively respond to the threat of invasive species and noxious weeds. A nonnative invasive species management approach calls for the use of a

62 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Forest Invasive Species Action Plan, which provides a higher level of detail regarding priority invasive species and areas of the Forest to target for treatment. Taken as a whole, forest plan strategy regarding nonnative invasive species calls for a combination of education and integrated pest management approaches to prevent infestations and limit spread. Early detection and rapid response will be critical to achieving the desired condition of a low abundance of nonnative invasive species that do not disrupt ecosystem function. Educating visitors, cooperators, permittees and contractors is one of the best approaches to limiting initial establishment and spread, and partnering with neighboring land managers, counties, and organizations allows for the most efficient use of methods and available funds. The Forest continues to educate users about the importance of cleaning equipment and using weed-free hay for stock. All timber sale contracts include provisions for cleaning equipment before moving to a new area. Other cooperators and contractors also clean equipment before moving to new areas and are required to use weed-free hay. The direction provided by the forest plan allows for the application of the most effective treatments in the places where they are most needed. The plan allows for the use of mechanical, biological, or chemical treatments and provides the flexibility to adapt the methods used in response to the results that are observed. Additional prescriptive details regarding prevention and control measures in the forest plan could limit on-the-ground options and reduce the ability to adapt to situational variables such as the size of area needing treatment, the invasiveness of the species, and the resources that are under threat from the invasive species. One key to effective nonnative invasive species prevention is managing vegetation resources for resilience to invasive species. Maintaining native plant diversity, vigor, and density along with normal amounts of bare ground will help to maintain healthy and resilient vegetation. Many nonnative invasive species and noxious weeds capitalize on bare ground. Routine surveying for invasive species also helps to facilitate early detection and rapid response, and the Forest will continue to work closely with users, permittees, cooperators, and contractors to quickly identify and react to new populations of nonnative invasive species.

Comment NNIS – 4 The Nonnative Invasive Species section of the plan is lacking in plan components and needs a standard. DC-NNIS-1 should include measureable conditions and reference points for aquatic and terrestrial nonnative invasive species, and the Forest should explain how BMP’s and other outside plan direction adequately provide conditions necessary for ecosystem integrity and species persistence. Response The Rio Grande National Forest recognizes the importance of controlling nonnative invasive species in maintaining the integrity of aquatic and terrestrial ecosystems. The introduction and spread of nonnative invasive species is a dynamic process that requires the flexibility to respond and adapt management approaches to changing conditions. Over the life of the forest plan, the primary nonnative invasive species threats and the tools available to combat them may evolve. Defining effective prevention and control measures in the forest plan could limit the ability of the Forest to adapt to changing conditions. Instead, the forest plan provides

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strategic guidance in the form of management approaches, desired conditions, and objectives. This plan content, together with additional guidance in the Forest Invasive Species Action Plan and national and regional Forest Service policy documents, provides the Forest with the direction needed to effectively respond to the threat of invasive species and noxious weeds. Because nonnative invasive species can impact and be affected by multiple resource areas, the forest plan addresses the issue of nonnative invasive species in multiple places, not just in the Aquatic and Terrestrial Nonnatives section. For example, a management approach in the Soils section calls for the use of genetically appropriate, weed-free seed populations of native plants for revegetation, in order to avoid any potential for increasing nonnative invasive species or noxious weeds. The monitoring plan also includes consideration of nonnative invasive species. Monitoring Question 17 includes indicators for presence and extent of nonnative invasive species and noxious weeds, and acres of noxious weeds treated. In addition to the forest plan, the Forest relies on comprehensive direction for managing both terrestrial and aquatic nonnative invasive species that can be found in a number of other documents. These sources include the Forest Service National Strategic Framework for Invasive species Management, Forest Service Handbook and Manual direction at 2900- Invasive Species, Rocky Mountain Regional Invasive Species Management Strategy, and Rio Grande Forest Invasive Species Action Plan. These guiding documents, coupled with project- level identification of site-specific concerns, are the most appropriate methods for addressing the challenges posed by nonnative invasive species. Desired condition DC-NNIS-1 describes an ecological characteristic of the plan area toward which management of the land and resources should be directed. The monitoring plan (Chapter 3) uses the condition described in DC-NNIS-1 to inform several monitoring questions, indicators, and adaptive management questions that identify measurable conditions and reference points for aquatic and terrestrial nonnative invasive species. Monitoring question 10 includes indicators for the presence and distribution of nonnative aquatic invasives and acres treated to eliminate infestations. An adaptive management question inquires whether aquatic nonnative invasive species are continuing to spread and whether there are any other treatment methods available. Monitoring question 17 looks into the presence of invasive species that impact range health.

Comment: NNIS – 5 Convert to MA-NNIS-2 to a guideline unless covered elsewhere. Response NNIS-2 was changed slightly between draft and final versions of the forest plan to clarify and shorten the desired condition. The NNIS objective was also slight changed. The 2012 Planning Rule requires that guidelines act as a constraint on project and activity decision- making. (36 CFR § 219.7(e)(1)(iv)). MA-NNIS-2 is best expressed as a management approach because it does not constrain project activity and decision-making. Instead, it describes a management approach the responsible official is inclined to take. (FSH 1909.12, Ch. 22.4) The Rio Grande National Forest intends to continue to leverage its working relationship with Colorado Parks and Wildlife to reduce introduction and control the spread of aquatic nonnative invasive species and to educate recreational water users on prevention and control methods.

64 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Lands and Special Uses (LAND)

Comment LAND – 1 The Wolf Creek Ski Area should not be expanded, developed, or have a new road, the area is important to the conservation of wildlife, plants, and the watershed. Response Expansion or development of the Wolf Creek Ski Area is assessed in a site-specific, project- level analysis. This analysis is separate and outside the scope of the forest plan revision analysis.

Comment LAND – 2 Prohibition of communications sites should be a standard for the applicable management areas. Response Communication sites are an authorized use of National Forest System lands.

Comment LAND – 3 The Lands section needs standards and guidelines added about priorities for acquisition and conveyance of lands. The 1996 plan has guidelines for this. Response The forest plan includes direction that guides the prioritization and conveyance of lands. Priority acquisitions include (see Forest Plan pg. 56): • Lands within congressionally designated areas, • Lands with water frontage, wetlands, and associated riparian ecosystems, • Lands with habitat for endangered or threatened species, • Lands with unique historical or cultural resources, • Lands primarily of value for outdoor-recreation purposes and lands needed for aesthetic protection, • Key tracts that promote effective resource management, • Lands that consolidate ownership and reduce miles of property lines and corners to be maintained, and • Lands that maintain or stabilize economies of local governments. Because acquisition and conveyance requires willing participants, it is not possible to identify specific parcels for acquisition over the life of the forest plan.

Comment LAND – 4 A standard that prohibits transmission corridors in roadless areas needs to be added.

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Response The Colorado Roadless Rule prohibits tree cutting, road construction and reconstruction, and linear construction zones, with limited exceptions. The forest plan includes a Forestwide management approach that utility lines are designed to be fully developed prior to authorizing new sites and recognizes that new sites may be necessary to fill coverage gaps or meet public needs.

Comment LAND – 5 S-LAND-2 should show where the transportation and utility corridors are on the Forest. The planning documents need to show this. Response The Forest has a transportation atlas that shows National Forest System roads. The motor vehicle use map is produced for the public to show open Forest roads. The Forest also has GIS information showing utility corridors included in the Western Regional Corridor Study. The majority of the corridors included in the study are not on National Forest System lands. The Forest also has access to Section 368 of the 2005 Energy Policy Act; most of these corridors are also not on the Forest.

Comment LAND – 6 MA-LAND-3 should be a guideline, not a management approach. Response The management approach was clarified that management activities in linear corridors should be consistent with all direction for a management area if passes through, not just the desired condition. Compatibility with existing management areas will be a consideration for any proposal including those that follow a linear path.

Comment LAND – 7 MA-LAND-4 should be a desired condition, not a management approach. Response MA-LAND-4 has a slight rewording between draft and final forest plan that clarifies the intent. The management approach provides focus and prioritization. This direction is appropriate as a management approach.

Management and Geographic Areas (MGA)

Comment MGA – 1 We encourage the Forest to continue to streamline alternative C - this would make the plan easier for the public to understand, reduce costs for projects, and build relationships with partners.

66 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response This comment resonated very much with us because we want a forest plan that is understandable by Forest employees, but also our partners and the general public. Reducing complexity was identified as a revision topic in the environmental impact statement. We are working to make all alternatives as clear and unambiguous to, among other benefits, reduce project costs and help build relationships with partners. Changes were made between draft and final forest plan to reduce complexity, which include plan components, but also management areas and geographic areas. Geographic areas were removed in alternative B Modified, and management areas were also simplified.

Comment MGA – 2 Critical management stipulations in the current forest plan for backcountry management areas have been removed, which increases the vulnerability of these areas to resource impacts, including Rio Grande cutthroat trout. Response Most of the Backcountry Management Area as designated in the 1996 forest plan was included as roadless in the Colorado Roadless Rule. However, the management direction in the current forest plan is reflected in alternative A. In addition, alternative D also reflects some of the management direction from the current forest plan by retaining some areas and direction.

Comment MGA – 3 We request that Chama Basin be designated as a special interest area or watershed protection area. Response Alternative D includes the Chama Basin as a special interest area, so it was included in the analysis. Not including Chama Basin as a special interest area does not undervalue the area, but recognizes the needs for some flexibility to address changing conditions.

Comment MGA – 4 The wildlife corridor between the La Garita and Collegiates and the Sangre de Cristos, as well and the Antora Meadows Recommended Wilderness, should be designated. Response Plan direction and management areas are designed to allow energy and genetic flow across landscapes to accommodate a larger concept than just wildlife corridors. Forestwide direction, as well as existing wilderness and Colorado roadless designations, are intended to maintain habitat connectivity across the landscape.

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Comment MGA – 5 The management area structure in alternative C provides the greatest level of flexibility and is the only alternative that adequately addresses concerns about complexity under Revision Topic 3. Response The environmental impact statement identified Revision Topics based on the need for change, to help focus the forest plan and to guide alternative development. Reducing complexity was identified as Revision Topic 3. Alternative C is responsive to this topic because it reduces the layers of direction and proposes larger management areas that will allow for management flexibility at a landscape level.

Comment MGA – 6 Geographic areas seem cumbersome, the plan does not include any details of acreage or location of these areas. These areas are not useful and should be deleted. Response Alternative B Modified was developed in response to public comment on the draft environmental impact statement. Alternative B Modified does not include geographic areas in response to Revision Topic 3 to reduce complexity.

Comment MGA – 7 The discussion of overlapping management area direction should be in the individual management areas. Response We understand the potential confusion resulting from overlapping management area direction, and worked to minimize this between draft and final versions of the forest plan by simplifying management areas and eliminating geographic areas. The draft forest plan includes a detailed discussion of overlapping management direction at the beginning of Chapter 3. Including this discussion in one place in the draft forest plan assists with readability because not all management areas overlap.

Comment MGA – 8 Since Management Area 4.21 – Scenic Byways and Scenic Railroads – includes suitable timber lands, "or visible" and "which feature high quality scenery" should be deleted from the third paragraph. This should also acknowledge the contributions of commercial timber harvest to maintaining or restoring healthy, resilient ecosystems. Response The timber industry helps the Forest achieve multiple management objectives. Timber harvest in this management area would be done in compliance with the applicable scenic integrity objectives and the recreation opportunity spectrum. The final environmental impact statement acknowledges the contributions of timber harvest toward achieving desired conditions. For example, the environmental impact statement

68 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments discloses that the level of planned vegetation management activities influences the rate of progress toward desired conditions for forested vegetation. The final environmental impact statement states that: “As described above, the timber management program may have a small effect on progress toward the desired conditions for vegetation across all alternatives. Under alternative D, because there are fewer vegetation management activities planned, the progress toward the desired conditions in some vegetation types would be close to natural succession rates. Progress toward the desired conditions in these vegetation types would be highest in alternative C because these alternatives have the highest levels of planned vegetation management activities.”

Comment MGA – 9 MA 4.21 Scenic Byways and Railroads (draft forest plan at 85): Table 12 at page 91 needs to be corrected to show that lands in this management area are in the suitable timber base. It might be difficult to implement harvest activities that are not dominant or visible as is stated in the integrated desired conditions. Land assigned to MA 4.21 should not be part of the suitable timber base. Response This direction has been clarified to reflect that timber harvest can be done in a less visible manner using treatments such as single tree selection harvests, or thinning prescriptions. The intent of timber harvest in Management Area 4.21 would be to focus on maintaining or restoring ecosystem integrity and resilience and not on producing cubic feet or fiber.

Comment MGA – 10 Tables in the plan and environmental impact statement should show commercial timber harvest as suitable in MA 5.41. Response This management area is not included in alternative B Modified. Suitable timber acres are described in detail in the environmental impact statement.

Comment MGA – 11 Alternative B only slightly achieves the goal of reducing complexity. Response The final environmental impact statement includes a table that compares alternatives by revision topic, including Revision Topic 3: Management Area Complexity (see FEIS pg. 47). Although alternative B is not the least complex alternative considered, the final environmental impact statement developed alternative B Modified, in part, to address the issue of management area complexity.

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Comment MGA – 12 Management Area 5.41 should specify road densities and route closures to protect big game and winter range. In addition, vegetation management should improve forage and habitat conditions in these areas and occur in a manner that does not displace wildlife. Response In response to public comment to simplify management, this management area is not included in alternative B Modified. The forest plan identifies two desired conditions related to winter range habitat and big game. The forest plan specifies that winter range habitat conditions provide the quantity, quality, and spatial arrangement of forage, cover, and security needed to support population objectives for mule deer, pronghorn, Rocky Mountain bighorn sheep, and Rocky Mountain elk. Desired conditions for motorized and nonmotorized route travel, on and off existing roads, is that it does not negatively affect ecological conditions necessary to maintain population objectives for big game species. The forest plan also restricts management activities and off-road travel on winter range from about December 1 to March 31, as needed. It further identifies road densities of 1 mile per square mile to provide for critical wildlife needs, in areas used for winter concentration, critical winter range, calving areas, and transition habitat. Management actions in Management Area 5.41, such as route densities, seasonal closures, or vegetation management, are evaluated in the environmental impact statement. Site-specific analysis will determine the purpose of and need for any proposed action, and could include vegetation management for forage availability. While the forest plan provides overall management guidance on the desired conditions for winter range, identifying specific route densities or vegetation management proposals will occur during plan implementation. In addition, site-specific analysis also evaluates impacts on the ecological conditions necessary to support big game populations.

Comment MGA – 13 Management areas should include additional information, such as oil and gas leasing availability and lease stipulations, what recreation opportunity spectrum class the area is in, and whether off-road travel for recreation and firewood gathering is limited. The draft environmental impact statement should also show how plan direction would differ among the different alternatives. Response Land suitability determinations, including oil and gas leasing, are identified for each alternative in the final environmental impact statement and in the draft forest plan. Additionally, controlled surface use stipulations and no surface occupancy stipulations are identified in management areas 1, 4, and 5. In addition, the recreation opportunity spectrum class classifications and whether off-road travel for dispersed recreation/firewood gathering is also identified for each management area.

70 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment MGA – 14 Management Area 1.1, Designated Wilderness (draft forest plan at p. 75): The following statement is unclear: “Livestock grazing is present except where previously delineated.” Where were livestock ever “delineated” in wilderness and what does that mean? Response The final forest plan has clarified regarding livestock grazing within designated wilderness. Designed wilderness areas have enacting legislation that may allow or prohibit certain uses on a case-by-case basis.

Comment MGA – 15 Management Area 4.3, Dispersed and Developed Recreation (draft forest plan at p. 86): The description should explicitly state that these lands are not part of the suitable timber base. Response This management area is not included in alternative B Modified.

Comment MGA – 16 In Table 7, draft environmental impact statement (p. 40) it is not clear if prescribed fire is allowed in Management Area 1.1a or if off-road game retrieval is allowed in Management Area 4.21. Response The forest plan has been clarified to display that prescribed fire is an appropriate tool to use in Management Area 1.1a and off-road game retrieval is only allowed in Management Area 5.

Comment MGA – 17 Acreage removed from the Fremont special interest area should be assigned to Management Area 4.3 instead of Management Area 5.13. Response In the case of the Fremont special interest area this was management area 5.13. This was determined to be an appropriate fit as most of the areas consisted of forested lands that had been treated using timber harvest in the past.

Comment MGA – 18 Draft forest plan at page 77, 1.1-MA-6: Rio Grande cutthroat trout are not Threatened, Endangered, or Proposed and need to be continued to be stocked. Rio Grande cutthroat trout are a species of conservation concern; the threatened, endangered, or proposed label references those species that fall under Endangered Species Act protections only. Rewrite second sentence to read: "Some high mountain lakes may be stocked to support indigenous species."

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Response Rio Grande cutthroat trout are a species of conservation concern and have multiple standards and guidelines that contribute to maintaining ecological conditions for a viable population. The Forest understands the need and desire from the public to have fishing opportunities, while continuing to protect native populations of fish. Fish stocking is done in cooperation with Colorado Parks and Wildlife. Direction in the plan is to remain involved in restocking programs.

Comment MGA – 19 1.1-S-2: How large a party could benefit the wilderness character? The standard should be amended to not allow for exceedance. Response Large groups in wilderness areas can negatively impact user experiences, as well as have more resource damage. Group size is described in 1.1-S-3. This standard does not allow for exceedance.

Comment MGA – 20 2.2-MA-1, 2, and 6 should all be at least guidelines if not standards. Response These management approaches are now included in Management Area 4.2 (Research Natural Areas) in the final version of the plan. Management approaches are optional plan content (FSH 1909.12 § 224) that describe the principal strategies and program priorities the responsible official intends to use to carry out projects and activities developed under the plan. Management approaches can convey a sense of priority and focus among objectives and the likely management emphasis. They relate to desired conditions and may indicate the future course or direction of change while recognizing budget trends, program demands, and accomplishments. For research natural areas, the intent of these management approaches is to recognize the future course of recreation use in these areas. The use of standards or guidelines is primarily to constrain projects. Converting these management approaches to standards and guidelines does not fit the definitions of standards and guidelines in the planning rule.

Comment MGA – 21 Guidelines WSR-G-2, -3, and -4 state the recreation opportunity spectrum classifications and scenic integrity objectives for wild, scenic, and recreational rivers, respectively. However, for scenic and recreational, it states: “Activities will meet the adopted scenic integrity objective.” draft forest plan at 81-82. Does this mean the scenic integrity objective adopted at the time a management plan or determination of suitability is approved? Normally, scenic integrity objectives are adopted at the plan level. The scenic integrity objective for scenic river segments should be high, and for recreational segments, it should be moderate.

72 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response Scenic integrity is a forest plan decision. Upon designation as a wild, scenic, or recreational river if the scenic integrity level changes, an adjustment would be made.

Comment MGA – 22 3.4 –M-1 needs to be a standard not a management approach. Response There are often different opinions from the public about what should be considered as a forest plan standard or guideline. We have reviewed all management approaches and plan components, and feel that the changes made between draft and final forest plan incorporate public suggestion and reflect appropriate guidance and direction for categories of plan components and management areas.

Comment MGA – 23 5.11-MA-2, off-road game retrieval must not be allowed. Response Off-road game retrieval direction has been adjusted based on input from Colorado Parks and Wildlife. Off-road game retrieval is provided for in Management Area 5 on open motorized travel routes.

Comment MGA – 24 5.11-MA-1 needs to be written as a standard because a management approach is too easy to ignore. Response Coordination of livestock grazing with vegetation treatments is a standard operating procedure that is appropriately listed as a management approach.

Comment MGA – 25 5.41-MA-2 should be a standard not a management approach. Response Road design routinely incorporates areas of important vegetation and forage and many other resource concerns. This is an appropriate consideration and focus for project-level analyses.

Comment MGA – 26 Regarding 5.41-MA-4: • This should be made a standard to provide sufficient forage quality and quantity to sustain big game populations in winter.

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• This should be a guideline. This is one of the most important aspects of management, and a known conflict in locations at times. A guideline provides the certainty but flexibility needed to meet big game winter range objectives. Response Management approaches convey focus and intent of the program management. Forage quality and quantity management is an important consideration at the project level. Including management approaches to maintain the focus is an appropriate level.

Comment MGA – 27 Regarding 5.41-S-1 in the draft forest plan, page 89, 5.41-S-1, correct timeframe to April 15. This should be strengthened to prohibit off-road vehicle use, including over-the-snow vehicles from November 1 through April 15. Response Timing restrictions were evaluated in the environmental impact statement and incorporated into plan direction and management approaches in alternative B Modified, as appropriate. The plan strikes a balance between the need for resource protection, including wildlife habitat, and the need to provide for recreational interests, including motorize and nonmotorized access.

Comment MGA – 28 Allowing grazing in MA 8.22 contradicts the description, which says that “grazing is not authorized or permitted.” Response This has been corrected. Ski-based Resorts is represented by MA 4.8 in the final version of the plan.

Monitoring

Monitoring Comment 1 Table 13 in the draft forest plan (p. 97) should have triggers for when further action is necessitated. Response Triggers or thresholds for monitoring are not required to be included. Triggers would vary by resource and site-specific conditions. The 2012 Planning Rule requires that questions and indicators are developed using and documenting the best available science. The forest plan and included monitoring plan do not compel any actions to be taken. Biennial monitoring reports are used to evaluate “where plan components are effective and appropriate, and whether management is effective in maintaining or achieving progress toward desired conditions” (FSH 1909.12, Chapter 30, page 4). Monitoring reports are also used to inform project-level decision and forest priorities, as well as potential amendments and corrections to the forest plan.

74 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Monitoring Comment 2 The indicator for priority watersheds should be reworded to state: number and percent of essential projects identified in the watershed restoration action plan completed in priority watersheds. Response The indicator includes the number of projects completed in priority watersheds, as well as best management practices monitoring.

Monitoring Comment 3 Does the indicator for change in riparian vegetation only mean increased or decreased presence? Or increase/decrease in overall riparian vegetation? Response For MQ5 (riparian and wetland vegetation), the indicator for change would be related to the distribution, overall acreage (presence/absence), and plant diversity of riparian vegetation, not necessarily in the condition. Additional condition monitoring indicators would be covered under MQ18 for rangeland health.

Monitoring Comment 4 Monitoring Question 18 needs to be clarified, if the monitoring is looking at the desired conditions in the forest plan they are very general and vague. Response Rangeland health describes the ecological status of rangelands. The question is clarified by the indicators selected. Trend in rangeland health can be predicted based on the selected indicators.

Monitoring Comment 5 Monitoring Question 15, indicator states coarse woody debris - this needs to be corrected, filled in, or deleted. Response The final monitoring plan has been updated between draft and final version of the forest plan and will use terminology consistent with the rest of the forest plan direction.

Monitoring Comment 6 There are no monitoring questions for addressing recreation conflicts. Response Recreation monitoring questions include a question about what recreational activities the public is participating in and level of satisfaction. Level of satisfaction should provide insight toward addressing conflicts among users. Additional monitoring questions for recreation

75 USDA Forest Service could be added in the future to the monitoring plan, especially if collected and provided by partner organizations.

Monitoring Comment 7 The monitoring plan is superficial and falls short of meeting the intent of the requirements of 219.12. Response Monitoring prescribed in the forest plan is one part of the approach. The monitoring program includes plan-level monitoring and broader-scale monitoring. Forest plan-level monitoring is informed by the assessment phase, developed during plan revision, and implemented after plan decision. (36 CFR 219.5) The planning rule at 36 CFR 219.12 prescribes that the monitoring plan determine a change in plan components or other plan content is needed. Monitoring questions and indicators must be designed to inform the management of resources in the plan area. The monitoring program is not intended to depict all monitoring, inventorying, and data- gathering activities undertaken on the Forest, nor is it intended to limit monitoring to just the questions and indicators listed in the table. However, monitoring plans and strategies are constrained by the fiscal and technical capabilities of the agency and should use available information sources and partnerships to expand capabilities.

Monitoring Comment 8 Monitoring activity should tie to plan components. The monitoring plan should evaluate to what extent accomplishment of plan components, including objectives, has contributed to the progress toward achievement of the desired condition. The monitoring plan should be better linked to plan components. The last paragraph on page 92 should include monitoring of desired conditions and objectives. Response Monitoring should also be tied to ecosystem integrity and be within the future means and capabilities of the forest. The 2012 Planning Rule and Forest Service Handbook 1909.12 state that “[p]lan components form the basis for developed the monitoring questions and associated indicators…” (FSH 1909.12, page 9). The direction does not specify which plan component to tie monitoring questions and indicators to. The monitoring plan in the forest plan is tied to desired conditions.

Monitoring Comment 9 Monitoring question 16 should include whether or not the Forest meets the annual timber target.

76 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response Amount of cubic feet sold or harvests is included as a potential. The annual target may not always be met depending on the ability of the timber industry to purchase offered volume. Market fluctuations are outside of our control and these impact the ability of purchasers to successfully bid on contracts.

Monitoring Comment 10 We request an opportunity to be involved in development of the monitoring process. Response See also response to Plan Component Comment #17. The public will be involved in the adaptive management process, which has a direct tie with monitoring.

National Environmental Policy Act (NEPA)

Comment NEPA – 1 The forest plan should be simplified to reduce complexity. Response The environmental impact statement identifies management area complexity as a revision topic, and reducing complexity of management was one of the drivers behind many of the adjustments reflected in alternative B Modified. For example, alternative B Modified reduced the number of management areas from 14 to 9 and incorporates the concepts of geographic area direction from alternative B into management area and Forestwide direction in alternative B Modified.

Comment NEPA – 2 The draft environmental impact statement fails to consider cumulative effects of management actions on Bureau of Land Management lands and other adjacent lands on bighorn sheep. Response The final environmental impact statement identifies disease transmission as one of the primary factors limiting bighorn sheep populations.

Comment NEPA – 3 The Rio Grande should include additional detail and issue a supplemental draft environmental impact statement to address NEPA requirements at 40 CFR 1500-1508. Response An agency must prepare a supplement to a draft environmental impact statement if, after circulation of a draft: (1) the agency makes substantial changes to the proposed action that are relevant to environmental concerns (40 CFR 1502.9(c)(1)(i));

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(2) there are significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its effects (40 CFR 1502.9(c)(1)(ii)); or (3) the agency adds a new alternative that is outside the spectrum of alternatives already analyzed (see Question 29b, CEQ, Forty Most Asked Questions Concerning CEQ's NEPA Regulations, March 23, 1981) The environmental impact statement describes the nature of programmatic NEPA reviews (see FEIS pg. 63). In addition, the Council on Environmental Quality provides guidance on preparing programmatic NEPA documents and recognizes that programmatic NEPA documents should address broad environmental consequences (see CEQ December 18, 2014 Effective Use of Programmatic NEPA Reviews). This environmental impact statement establishes overall management direction where the specific location, design, and extent of future activities are generally not known. As a result it is appropriate to describe the environmental effects in broad terms. Since the draft environmental impact statement, the Forest developed alternative B – Modified in response to public comment. Alternative B modified was largely developed in order to reduce complexity; it combines aspects of both alternative B and alternative C. In response to public comment regarding complexity, this alternative reduces the number of management areas and aligns those boundaries to the geographic area boundaries in alternative B. Given that alternative B – Modified is an outgrowth of public comment and incorporates elements from both alternatives B and C, it is within the spectrum of alternatives considered and does not trigger the need for a supplemental draft environmental impact statement.

Comment NEPA – 4 The forest should combine alternative B with the additions on special interest areas from alternative D. Response The environmental impact statement does not consider an alternative that combines alternative B with the special interest areas from alternative D.

Comment NEPA – 5 The environmental impact statement fails to evaluate effects that inform the decision and should be more than a subjective, qualitative comparison. Response The environmental impact statement evaluates the direct, indirect, and cumulative effects of all alternatives. The Council on Environmental Quality sets guidance on adequate level of analysis detail for programmatic decisions under the National Environmental Policy Act.

Comment NEPA – 6 Only plan components can have effects, and the environmental impact statement must cite plan components as the basis for the effects analysis. The environmental impact statement does not properly characterize what the plan components say and the reader does not know

78 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments the effects of the specific plan components. The environmental impact statement needs to show how specific plan components affect each ecological condition needed by at-risk species. Response Each alternative provides a framework for integrated resource management and for guiding project and activity decision-making. But they do not compel any action, authorize projects or activities, or guarantee specific results. Instead, they provide the vision and strategic direction needed to move the national forest toward ecological, social, and economic sustainability. Due to the nature of forest plans and their integrated content, it is not possible to attribute impacts from individual plan components in the environmental impact statement. The environmental impact statement describes outcomes that may result from implementing the proposed management direction in each alternative. Estimating effects at the programmatic, forest-plan level makes assumptions. One of the assumptions is that the types of resource- management activities allowed under the prescriptions are reasonably foreseeable future actions that could be taken to achieve the goals and objectives stated in the forest plan. However, the specific location, design, and extent of such activities are generally not known. Attempting to attribute specific impacts to individual plan components would be speculative.

Comment NEPA – 7 The environmental impact statements needs to distinguish between the certainty of standards and guidelines versus the uncertainty of desired conditions and objectives. The environmental impact statements needs to distinguish which standards and guidelines contribute most to achieving desired conditions. Response The environmental impact statement reasonably assumes that the forest plan direction will be followed because it is a statutory requirement. Forest plans can be amended at any time, so it is not possible to guarantee certainty in plan components (see 36 CFR 219.13).

Comment NEPA – 8 The environmental impact statement needs to properly account for the effects of wildfire, fire suppression, salvage logging, and other drivers and stressors. Response The environmental impact statement specifically addresses the dominant drivers and stressors on the Forest and their impacts. Chapter 3 of the environmental impact statement includes discussion on the effects from a variety of sources; including: vegetation management, fire management, timber management, recreation management, wildlife management, minerals operations, and climate variably. For each resource examined in Chapter 3, the dominant stressors and drivers were identified and the effects are described. This environmental impact statement is programmatic in nature and appropriately discusses environmental effects from these sources in broad terms (see Response to NEPA-3).

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Comment NEPA – 9 The relative comparison of alternatives in the environmental impact statement is inadequate to comply with NEPA. The environmental impact statement should take into account plan components that are not favorable to wildlife, as well as those that are favorable. Response Chapter 3 of the environmental impact statement includes a discussion the environmental effects to wildlife. The effects analysis includes a discussion of all plan components under each alternative; including those that are not favorable to wildlife. For example, the environmental impact statement includes a discussion in the wildlife and plant section that discusses the impacts from livestock grazing, dispersed and developed recreation, or roads management and acknowledges that plan direction may have effects to wildlife.

Comment NEPA – 10 The environmental impact statement fails to satisfactorily assess the impact of draft plan components to ecosystems and species. Response Chapter 3 of the environmental impact statement includes a discussion on forested, non- forested, and aquatic ecosystems. Chapter 3 also includes a discussion on Wildlife and Plant species. This includes sections that address individual species. Individual species discussions are includes for species that are threatened, endangered, and sensitive and species of conservation concern. The environmental impact statement also includes discussion of the effects that are not in these categories. While this discussion is not organized around individual species, it appropriately organizes the discussion around species grouping with similar habitat needs (e.g. raptors or game species). The environmental effects for a programmatic analysis are broadly described given the scope of the forest plan (see Response to NEPA-3).

Comment NEPA – 11 The environmental impact statement fails to analyze plan components against the no action alternative. The environmental impact statement uses a relative approach to analyze effects that does not use other information available. Specifically, the Forest should have used the wildlife overviews referenced in the environmental impact statement to quantify extent under varying alternatives. Response The environmental impact statement includes a comparison of the alternatives by geographic area, recommended wilderness, and fire management zones. It also includes a comparison table of the alternatives by resource program (e.g., timber, fuels, or wildlife) and allowable activities. These comparisons include alternative A, the no action alternative. Chapter 3 of the environmental impact statement includes an overview in the wildlife and plants section. The overview section includes discussion that lays the foundation for the following effects discussion. It includes information; such as, number of species in the plan area, dominant habitat types, analysis methods and assumptions, and indicators and measures

80 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments used. The overview information is common among all of the alternatives; including the no action alternative.

Comment NEPA – 12 The purpose and need statement should indicate a need to illustrate how the revised plan corrects deficiencies in the current plan. Response The purpose and need in the environmental impact statement stems from both the need for change and the revision topics. The environmental impact statement states that “… the purpose and need is to address the identified needs to change the existing plan that was presented to the public in March 2016. These needs for change were identified through the monitoring reports from 1997 to 2013, internal staff recommendations, and the assessment phase of the revision process” (FEIS pg. 8). All of the alternatives were developed in response to the purpose and need. The purpose and need specifically includes needs to change the existing plan.

Comment NEPA – 13 The environmental impact statement must disclose the possibility and likelihood of effects occurring. The absence of mandatory plan components should result in the greater likelihood of effects. Response The environmental impact statement discloses the environmental impacts of the proposed action and alternatives. Because a forest plan is programmatic, where the specific location, design, and extent of future activities are generally not known, it is appropriate to describe the environmental effects in broad terms. The environmental impact statement describes this uncertainty in disclosing effects. The forest plan meets the requirements in the 2012 Planning Rule and is not missing any mandatory plan components.

Comment NEPA – 14 The draft environmental impact statement is insufficient in the analysis of plan components. The relative comparison “the potential watershed impact of alternative B represent a relative midpoint among alternatives” is inadequate. Relative comparison among alternatives does not satisfy NEPA. Response The environmental impact statement includes a summary table that compares alternatives and Chapter 3 includes a detailed description of the effects of the proposed action and alternatives. This environmental impact statement is a programmatic document where the specific location, design, and extent of future activities are generally not known, it is appropriate to describe the environmental effects in broad terms.

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Comment NEPA – 15 The draft environmental impact statements does not acknowledge the proposal presented by The Wilderness Society nor does it explain why it rejected it for analysis. Response Chapter 2, Alternatives Considered but Eliminated from Detailed Study, addresses the alternatives submitted. One complete alternative we received and reviewed, but dismissed from detailed study. This rationale is described more completely in the final environmental impact statement.

National Forest Management Act (NFMA)

Comment NFMA – 1 Partner support for ongoing maintenance of infrastructure is problematic; the forest plan provides an opportunity to highlight this challenge and guide projects in a manner that provides long-term support and funding. Response Not all aspects of forest management and monitoring are able to be delegated. Some inherently governmental actions will need to be maintained by the Forest Service. The intent is to provide flexibility to allow for increased partnerships and citizen input and monitoring to increase capacity over time as budgets remain flat or decrease or increase.

Comment NFMA – 2 Closing routes due to resource concerns when resources are available is a barrier to partnerships. Response Travel management will be addressed subsequent to forest plan revision. The extent to which closing routes could create barriers to partnerships would be addressed during travel management planning and during site-specific analysis.

Comment NFMA – 3 The identification of partner resources available to Forest managers should be a priority in the development of the forest plan. Response Creating a plan that allows for flexibility in using partner resources was key during plan development and the plan was designed to be flexible and include partnership opportunities. However, specifically identifying partner resources in the forest plan would not be appropriate due to the longevity of a forest plan and because the location, design, and extent of future activities are generally not known. However, the forest plan encourages the use of partnerships to accomplish forest management objectives.

82 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment NFMA – 4 The forest plan needs to facilitate management and maintenance of access in the most cost- effective manner possible by avoiding placing unnecessary restrictions or prohibitions on management. Response Travel management, which will begin subsequent to revising of the forest plan, will address management and maintenance of the existing road system more thoroughly.

Comment NFMA – 5 We encourage more interagency cooperation on planning and projects, and use of the good neighbor authority in addressing watershed management and projects on public lands. Response The Forest considers the use of all appropriate authorities during management. We cooperate and collaborate closely with agencies including but not limited to: USDI Bureau of Land Management, National Park Service, U.S. Geological Survey, and U.S. Fish and Wildlife Service; Colorado Department of Parks and Wildlife; State Historic Preservation Officer; and more.

Comment NFMA – 6 I support the use of House Bill 16-1255 Good Neighbor Authority and continued partnerships and connection of State and Federal agencies with local governments. Response All applicable authorities; including Good Neighbor Authority, are considered for use in implementing the forest plan.

Comment NFMA – 7 The Forest should consider forming a monitoring plan with signage for public participation. Response The forest plan encourages the use of partnerships to accomplish forest management; including signing. The monitoring plan is designed to monitor and adjust the forest plan and is not the appropriate section to include direction to encourage partnerships for signing roads and trails. Please refer to response for comments NFMA-2 and 4, above.

Comment NFMA – 8 Alternative C has the greatest alignment with Hinsdale County principles and values. Response The proposed action and alternatives were developed to fully consider the needs of all publics. We particularly value the need of local citizens, including those of Hinsdale County.

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Plan Components (PC)

Comment PC – 1 Direction in the forest plan needs to be strengthened and focused on standards and guidelines instead of management approaches to ensure protection of resources. The definitions of plan components, including desired conditions, are not in compliance with 36 CFR 219.7. The forest plan overuses and misuses management approaches, they do not conform to the direction at Forest Service Handbook 19009.12, section 22.4. Management approaches are not plan components and cannot be used as such. The uses of these in lieu of plan components is inappropriate; the concept of integrated desired conditions also does not fit the definitions of the plan rule. We recommend that you rewrite the plan components, management approaches, and integrated desired conditions for management areas. Response Management approaches are described in Forest Service direction (FSH 1909.12 §22.4) as optional content that could facilitate transparency and give the public and governmental entities a clear understanding of the plan and how outcomes would likely be delivered. Management approaches can describe strategies and program priorities that the responsible official intends to employ to carry out projects and activities. In response to external and internal comments, management approaches have been revised in format and content to better meet the direction in Forest Service Handbook 1909.12. In response to internal and external comments received, plan components, including desired conditions, objectives, standards, and guidelines have been revised to better meet the intent and direction of the 2012 Planning Rule (36 CFR 219) and its implementing direction (FSH 1909.12). The intent of the direction did not change; rewrites combined similar direction, added clarity, and added specificity. Many of these changes were recommended by the public during the official comment period. Management approaches are included to help facilitate transparency and provide clear understanding of the plan and how outcomes would be delivered, but allow more adaptability to meet changing conditions. They describe strategies and program priorities intended to be used to implement projects and activities developed under the forest plan.

Comment PC – 2 The forest plan should provide emphasis on access for aging and less mobile populations. Response The Forest plan does not generally preclude access to any population, but rather guides implementation of projects. The 40,052 acres of recommended wilderness in this plan could limit access, but we feel those areas are already very difficult to access. Additional boundary modification work in the recommended wilderness areas excluded existing roads from the polygons, which should facilitate existing access into those areas. Goal #3 provides umbrella direction to actively contribute to social and economic sustainability in the broader landscape and connect citizens to the land. Site-specific analysis at the project level would better address concerns about aging and less mobile populations. For example, and new

84 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments campground would undergo site-specific analysis and consider accessibility as appropriate. This type of decision would not be made at the forest plan level.

Comment PC – 3 The adaptive management strategy should allow the Forest Service to recommend minor adaptations to the plan that reflect new technologies. Response New technologies can be brought forward and considered at any time. There are three avenues for making changes to a forest plan. Two require implementing a formal analysis process with specific timeframes and public involvement requirements. The third still requires public comment but does not have a formal decision process. This last level can require as much analysis and data as required by the responsible official.

Comment PC – 4 Reduced complexity of area designations, minimized single-species management, more balanced management of bighorn and domestic sheep conflicts, and an overall focus on multiple-use management should be incorporated into the final forest plan. Response The goal of most management decisions made on the Rio Grande is to balance multiple uses across the Forest. Each users has different values that tie weight to the multiple uses of the National Forest System lands. Responsible officials have the difficult job of considering and maintaining in balance the many uses and values associated with National Forest System lands. Bighorn sheep are addressed in other sections of the plan, particularly in the Range and Species of Conservation Concern sections.

Comment PC – 5 It is uncertain how the plan will be implemented and what the long-term results will be since the forest plan lacks specificity in the plan components. Response In response to internal and external comments received, plan components, including desired conditions, objectives, standards, and guidelines, have been revised to better meet the intent and direction of the 2012 Planning Rule (36 CFR 219) and its implementing direction (FSH 1909.12). The intent of the direction did not change; rewrites combined like direction, added clarity, and added specificity.

Comment PC – 6 Most of the management approaches should be eliminated with the focus put on desired conditions and objectives.

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Response Management approaches are described in Forest Service direction (FSH 1909.12 §22.4) as optional content that could facilitate transparency and give the public and governmental entities a clear understanding of the plan and how outcomes would likely be delivered. Management approaches can describe strategies and program priorities that the responsible official intends to employ to carry out projects and activities. In response to external and internal comments, management approaches have been revised in format and content to meet the direction in Forest Service Handbook 1909.12.

Comment PC – 7 The objectives use different measures of time, which is problematic in a lack of precision or failure to account for all the years until a next plan revision. Response Some objectives have been rewritten between draft and final versions of the forest plan to add more consistency. Objectives are concise, measurable, and time-specific statements of a desired rate of progress toward desired conditions. However, not all objectives present the same timeframe. An effort was made to re-evaluate the timeframes and present consistency in how they are worded and measured. Objectives do not to all correspond with the time until next plan revision; some may be of shorter or longer duration.

Comment PC – 8 Many of the plan components are duplicative, overlapping, or wordy and would benefit from serious editing. Response We heard similar comments from multiple members of the public on the release of the draft plan and draft environmental impact statement. We have used input from the public to make modifications to the forest plan to reduce duplicative direction and clarify plan components, within the range of analysis. In many cases, we combined plan components that had similar intent.

Comment PC – 9 Specific timing restrictions should be deferred to project planning to develop more targeted restriction based on the area, issues, and significance. Response Some timing constraints are part of forest plan standards to reduce impacts to fish and wildlife. Additional timing constraints can be placed at the project level if needed. The best available scientific information was used when determining timing restrictions.

Comment PC – 10 The public recommends that the annual adaptive management meeting include annual monitoring results.

86 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response The adaptive management meeting is designed to relay any available results of forest plan monitoring. Monitoring forms the basis for continuous improvement of the plan and provides information for adaptive management of the plan area. The 2012 Planning Rule requires that evaluation reports of monitoring results be published biennially. That being said, the intent is to share available monitoring information at the adaptive management meetings.

Comment PC – 11 The discussion of the National Forest Reserve Act under Goal 1 does not accurately reflect the discussion of the Act. The Organic Act provided the uses and protections summarized in the 2nd and 3rd sentences of the first paragraph. Response Adjustments to the discussion have been made.

Comment PC – 12 Goal 2 seems to rely on natural processes to achieve increased diversity and resiliency; also, habitat connectivity is over-emphasized. Response To better align with a monthly article that the Forest publishes in local newspapers, the goals have been rearranged. Goal 1, now addresses ecosystem, while goal 2 addresses water. Goal 1 provides focus for management of ecosystems where it is acceptable to do so. The goal specifically speaks to diversifying age classes and structure, seral stages, and habitat classes while providing for multiple ecosystem benefits.

Comment PC – 13 In the first sentence of Goal 3 we recommend that "contributes" be changed to “provides”; we also recommend deleting "natural appearing." Response We feel “contributes” is the proper wording for the intent of the statement. National forests contribute forest products in a sustainable manner, and depending upon ecosystem conditions, products may not always be available depending on natural events. Where management occurs, the Forest does not always look natural. Many managed areas will always look as though they have been managed; therefore, it would be appropriate to use the term natural appearing.

Comment PC – 14 The Background, Roles, and Contributions section is long and rambling, it needs to be rewritten and condensed. Response The section has been condensed and revised.

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Comment PC – 15 We disagree that alternative B is the best choice and question why "sustainable outdoor recreation is a primary resource" is the main driver for a new forest plan. Response Consideration and provision of sustainable recreation is a requirement of the 2012 Planning Rule, and is balanced with other resource needs. The changes made to the draft plan provide for sustainable recreation, will providing other management objectives.

Comment PC – 16 The special interest areas should be included in the preferred alternative or at the very least adopted into the final forest plan. Response All special interest area submitted during public comment have been considered in the alternatives. The decision reflects the inclusion of Forestwide direction that meets the intent of providing additional special interest areas. Protecting these resources across the Forest better provides for ecosystem diversity and inclusion than only providing for them in designated areas.

Comment PC – 17 We request an opportunity to be involved in development of the adaptive management questions. Response Public engagement has been a key component of the development of the land management plan, including the monitoring chapter. We look forward to future engagement to share monitoring information and to improve the monitoring questions and indicators over time as better information becomes available.

Comment PC – 18 Management measures in the forest plan should be strengthened to incorporate agency standards and guidelines to ensure adequate protection of resources. Response Plan components reflect strong direction for the future. All direction in the plan is fully supported and tiers to higher level direction including but not limited to Acts, the Forest Service Handbooks and Manual, and Presidential orders. The forest plan tiers to all higher level direction but does not repeat that direction.

Comment PC – 19 Wilderness coverage and motorized game retrieval are analyzed in separate alternatives and could be combined for a thoughtful and meaningful plan that meets multiple goals and objectives.

88 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response A range of alternatives was presented for the responsible official to choose from. The selection includes portions of a couple of the alternatives analyzed in the environmental impact statement. The record of decision provides rationale for the final selection.

Comment PC – 20 The order of the goals seems to indicate priority, so please consider the clarifying the priority of the goals. Response Please refer to the forest plan under the heading Vision Domain in chapter 1. The last sentence before the goals states, “[t]he goal statements are numbered to allow for reference, not to indicate priority.” The goal statements are overarching and apply to Forestwide management of the Forest in no priority order. The goals have been reordered to be more compatible with agency direction.

Comment PC – 21 Plan components lack specificity, especially desired conditions and objectives, making it difficult to understand how the plan will be implemented. Response Please refer to comment PC – 1.

Comment PC – 22 The goal to reduce complexity was only partially successful, the authors needs to be mindful of who the audience is, and the forest plan needs to be understandable to the public. Response Much work has been done before releasing the final analysis and forest plan. It is a challenge to provide direction that is able to be understood by the general public but that has enough meaning for resource specialists to implement in a scientific context.

Comment PC – 23 The Rio Grande forest plan needs to be responsive and adaptive to the changing landscape due to drought, beetle kill, and now, fire. Response Every effort has been made to provide adaptability for the forest plan. This was the intent of the adaptive management process described in chapter 4.

Comment PC – 24 The standards needed to achieve the goals and objectives are lacking; virtually every section is affected by this same fatal flaw.

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Response See also response to Comment PC – 1.

Comment PC – 25 The goals and objectives in the forest plan are worthless aspirations because nearly all resources and activities lack any standards necessary to ensure that they are achieved. Response According to the 2012 Planning Rule, goals are “broad statements of intent, other than desired conditions.” (36 CFR 219.7(e)(2)) Objectives are specific and measurable and are designed to show progress toward desired conditions. Goals serve as an umbrella for all the direction in the Forest Plan they describe the overarching intent that the Rio Grande will adhere to. Objectives are tied to desired condition. Standards place constraints on projects that will help achieve or maintain desired conditions. See also response to Comment PC-1.

Comment PC – 26 Several plan components that pertain to forest ecosystems are not consistent with best available science and other information presented in Assessments 1 and 3 and in the DEIS. Response The assessments describe information for identifying a need to change the existing forest plan. They describe the nature, extent, and role of existing desired conditions and trends in the plan area and in the broader landscape. They summarize how the best available scientific information and other information informs the assessment and identify additional information needs. It is likely that during analysis additional best available science was found since the assessment were intended to “rapidly evaluate existing information about relevant ecological, economic, and social conditions, trends, and sustainability and their relationship to the land management plan within the context of the broader landscape.” (36 CFR 219.5(a)(1))

Comment PC – 27 The forest ecosystems identified in plan documents vary in reference conditions for structure, composition, and function and how habitat connectivity can be restored or maintained based on these variations. However, several plan components do not sufficiently differentiate management direction for the ecosystems in a way that recognizes this variation. The planning rule requires that integrity be pursued for each ecosystem within the plan area; lumping ecosystems for planning purposes so that integrity is not achieved would violate the planning rule. Response Terrestrial and aquatic ecosystems were evaluated in the assessments, which identified key characteristics of ecosystems; considered in the need to change the forest plan, and are contained the forest plan management approaches and plan components. There is no legal or regulatory requirement to have plan components for each ecosystem, nor each ecosystem characteristic.

90 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments In response to internal and external comments received, plan components, including desired conditions, objectives, standards, and guidelines have been revised to better meet the intent and direction of the 2012 Planning Rule (36 CFR 219) and its implementing direction (FSH 1909.12). The intent of the direction did not change; rewrites combined like direction, added clarity, and added specificity.

Comment PC – 28 Re: Goal #1: question whether the Forest meant to state that the goal is to protect watersheds, water and aquatic systems, and the species that rely on them. The concept of protecting systems in order to protect the systems that depend on those systems is confusing because it leads the reader to think there are ecosystems nested within ecosystems. Response Goals 1 and 2 have been reordered to be more consistent with agency direction. Ecosystems are a combination of systems nested within one another. Ecosystems were defined in 36 CFR 219.9 as a spatially explicit, relatively homogenous unit of the Earth that includes all interacting organisms and elements of the abiotic environment within its boundaries. An ecosystem is commonly described in terms of its composition, structure, function, and connectivity.

Comment PC – 29 On page 89 of the Draft Plan, edit first sentence of Management Area 6.6 – Grassland Resource Production – to read: "Grassland resource production areas produce forage and cover." Please update a bit as they produce much more than forage. Specific wildlife species are tied to these systems. Response This section has been revised based on the final decision.

Comment PC – 30 The objectives are not expansive enough to capture the identified desired conditions in the DLMP/DEIS. Response See also response to Comment PC – 1. Objectives are intended to measure the rate of progress toward a desired condition. They help set the basis for priority areas or activities and set timeframes. Not every desired condition has an objective.

Comment PC – 31 Overly specific plans result in additional costs over the life of the plan. They also can implement standards for issues that are not suitable for implementation at the forest-plan level and are better addressed at a site-specific level.

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Response Forest plans are programmatic in nature and allow for site-specific determinations of specificity through project-level analysis.

Comment PC – 32 The complex nature of landscape-level plans has had impacts to management's ability to deal with major challenges such as the spruce beetle outbreak. Response See also response to Comment PC-31. Forest plans are programmatic. As such they provide a vision and strategic direction need to move a national forest toward ecological, social and economic sustainability. They establish sideboards for how projects and activities occur on the landscape. Focusing on desired conditions provides flexibility when dealing with major challenges such as beetle infestation or large fires.

Comment PC – 33 While I understand the use of management approaches because they add flexibility, I'm concerned they do not provide the degree of protection that a guideline would provide. Response Management approaches are described in Forest Service direction (FSH 1909.12 §22.4) as optional content that could facilitate transparency and give the public and governmental entities a clear understanding of the plan and how outcomes would likely be delivered. Management approaches can describe strategies and program priorities that the responsible official intends to employ to carry out projects and activities. In response to external and internal comments, management approaches have been revised in format and content to meet the direction in Forest Service Handbook 1909.12.

Comment PC – 34 I am concerned that the desired conditions and objectives are not specific enough to implement or measure. The Forest Plan and DEIS need to be as forward thinking and broad as possible in consideration of future impact. Response See response to Comments PC – 31.

Public Participation

Comment Public Participation – 1 The Forest should coordinate with the State of Colorado, including Colorado Parks and Wildlife, for plan revision and for prioritizing areas and developing management prescriptions during and after projects.

92 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response The State of Colorado continues to be an important partner for all National Forest System lands within the state. Throughout the plan revision process, the Rio Grande National Forest has enjoyed a formal cooperating agency agreement with Colorado Parks and Wildlife. In addition to Colorado Parks and Wildlife, the process has also benefited from input from the State of Colorado Water Conservation Board and the Colorado Department of Agriculture, as well as general comments from the Colorado Department of Natural Resources. Colorado Parks and Wildlife provided input to Rio Grande National Forest staff on many occasions throughout the process, including comments on the initial assessment reports and the need for change document. In their December 29, 2017, letter, Colorado Parks and Wildlife correctly points out that they did not have a chance to comment before the general public on the draft plan. Forgoing additional review and comment by cooperating agencies was a difficult decision, but a tradeoff that we made to better align with public expectation for completing the revision process in a timely manner. All Colorado Department of Natural Resources comments were reviewed in detail by Forest Service staff. Some key areas identified by the State are: • Complementary responsibilities for wildlife; Colorado Parks and Wildlife has a statutory responsibility to manage wildlife species, while the Rio Grande National Forest has responsibility to manage wildlife habitat • Acknowledgement of importance and continued provision of water rights settlement in Case No. 81-CW-183 • Concerns about potential limitations for management options with the designation of recommended wilderness areas • Specific suggestions about changing proposed standards and guidelines for more explicit protection of wildlife species • Suggestion to add bighorn sheep to the list of species of conservation concern (SCC) due to concerns about persistence of wild sheep on the Forest • Acknowledgement of the importance of range and grazing programs and their role to the local economy Other Colorado entities have also engaged in the process, including direct participation from the Colorado State Climatologist on the development of a summary of historical climate trends and future projections. Others from the Colorado Climate Center and Colorado State University have assisted in the development of the forest plan. In addition to the State, local counties have also contributed to the effort through formal comments, but also through the cooperating agency process. The State will continue to have an important role with project design and implementation when appropriate. The Forest Service coordinated with Colorado Parks and Wildlife throughout the revision process. We coordinate with them during project-level analysis as needed. Colorado Parks and Wildlife provided input in prioritizing areas and developing management prescriptions for vegetation projects.

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Comment Public Participation – 2 Further study and local public involvement are needs in Bear Creek (Town?), the Upper Conejos River, and the Sangre de Cristo site. Response The recommendations for these areas resulted from the wilderness inventory and evaluation process, which was subject to public input. Any recommended wilderness carried forward would be subject to additional study and consideration directed by Congress.

Comment Public Participation – 3 The 2010 bighorn sheep Conservation Assessment was not available for access during the comment period. Response The 2010 Bighorn Sheep Conservation Assessment has been available throughout the revision process and comment period.

Comment Public Participation – 4 The public was not consulted during revision of the Species of Conservation Concern list, bighorn sheep was removed to avoid completing a viability assessment. Response The public was consulted multiple times over two and half years regarding bighorn sheep as a Species of Conservation Concern. These opportunities included: • During the Assessment phase from December 2014 to March 2016; • During development of the Need for Change in the spring 2016; and • During scoping in the fall of 2016 (including the draft Regional Forester’s species of conservation concern list. Finally the draft forest plan and environmental impact statement comment period, in the fall of 2017, provided an opportunity for public comment. Bighorn sheep were not removed to avoid completing a viability assessment. Information from project-level assessment has been used to reach a final decision. Bighorn sheep were not included on the species of conservation concern list based on rationale provided in Table 122 of the draft environmental impact statement. During public comment, we received many comments about concern regarding persistence of Bighorn sheep, including a letter from the State of Colorado. The Regional Forester considered these comments and has added Bighorn sheep back on the final species of conservation concern list.

Comment Public Participation – 5 The public participation process did not provide opportunities for meaningful collaborative participation and did not involve key stakeholders.

94 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response Multiple opportunities were provided for public comment during the revision process. Opportunities included: • October to December 2014 - pre-assessment; • December 2014 to March 2016 - assessment phase; • March 2016 to August 2016 – development of the need for change; • Fall 2016 – scoping of proposed action; • Fall 2017 - draft forest plan and environmental impact statement comment period. Key stakeholders were identified early in the pre-assessment phase and invited to participate throughout the process. Not all key stakeholder chose to engage, however, despite repeated invitations. Staff was also to meet with any interested organization, regardless of previous involvement, throughout the process to ensure all groups were fairly, openly and transparently involved in the process. The Forest chose not to create a collaborative group but to instead be more inclusive in the collaborative effort.

Comment Public Participation – 6 Management Approaches should not be changed/deleted/added without an opportunity for public review and comment. Response Forest Service Handbook 1909.12 identifies management approaches as optional plan content which have different criteria than required plan components. The adaptive management process included in the forest plan is intended to inform the public on needed changes to any portion of the plan and explain the mechanisms available to keep the forest plan up-to-date and as accurate as possible. Any changes to the forest plan require public notice.

Comment Public Participation – 7 The public involvement process took a lot of extra work, had value, and provided for extensive public participation and partner engagement. Response Thank you for your comment. The Forest Service was committed to providing multiple public involvement opportunities during the forest plan revision process.

Comment Public Participation – 8 The process did not include enough meetings in Alamosa and none outside of the San Luis Valley.

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Response Meetings were spread across the San Luis Valley as much as feasible. Meeting space in the area is often a limiting factor which required that meetings often are held in Forest Service offices to provide opportunities for as much participation as possible. A few meeting were held in Alamosa. Additionally, staff held meetings as requested and provided updates at meetings of other groups and agencies. To provide for those unable to attend webinars were held allowing people to learn about the process through webinars.

Comment Public Participation – 9 The adaptive management approach is supported and would be the appropriate mechanism to keep the public engaged in the forest plan. The forest plan should outline a process to implement adaptive management. Response The process has been clarified in the final forest plan and will continue to develop as we go forward. The adaptive management process would be held annually to provide information on implementation of the forest plan and ongoing monitoring. This would provide opportunities to adaptively change the forest plan keeping the document as relevant as possible.

Comment Public Participation – 10 The Forest should consider the letter and petition dated August 29, 2017 concerning protection of the headwaters of the Chama Basin. Response All comments submitted during the revision process are being considered. Comment Public Participation-11: The concept of an annual State of the Forest meeting and/or report is a great idea and would engage the public to a greater degree. I also support the continued development of partnership opportunities between the U.S. Forest Service, State agencies, and local non-profits who are all interested in the future of healthy Rio Grande Forest and Rio Grande Basin watershed. The annual stakeholder and information sharing meeting followed by public comment will allow local Forest Service management an opportunity to adapt to current conditions and include public engagement and outreach throughout the process, allowing the Forest Service to recommend minor adaptations to solutions given new technology. Response See responses to Comment Public Participation 6 and 9.

Range (RNG)

Comment RNG – 1 Some commenters suggest that livestock grazing be banned, or strictly reduced with the forest plan. Other suggest that livestock grazing should be expanded by removing

96 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments restrictions. Comment letters also point out that livestock grazing should be managed to enhance forest viability and vigor and be compatible with wildlife. Response The benefits of grazing domestic livestock are the result of program design, monitoring and flexibility in modifying treatments. Properly managed livestock grazing is a valuable tool in managing species composition and structure. Additionally, grazing maintains open spaces and important habitat conditions that benefit other uses. According to the Range section, annual monitoring data shows that livestock grazing is ecologically feasible at current levels.

Comment RNG – 2 Livestock permittees should be held to higher ecological standards to use public lands. Response Livestock grazing is authorized though a multi-step process to protect forest resources and in accordance with agency policy. By the very nature of the process, permittees are held to a higher standard than the public. The Allotment Management Plan guidance ties to the forest plan desired conditions and guidelines and details the management objectives of the particular allotments. Permits are then issued for allotments. The permits have additional terms and conditions that permittees are required to follow. Permits may be modified at any time to improve or protect National Forest System lands and resources. Each year Annual Operating Instructions are developed to manage that year’s activities. Visibility of grazing (i.e., livestock, infrastructure, livestock protection dogs, etc.) on the landscape creates additional social pressures that permittees and rangeland managers have to address as well. See Range plan components regarding ecological conditions (i.e., wildlife forage, reforestation, vegetation residual, riparian areas, aspen stands, etc.).

Comment RNG – 3 The forest plan could put in place citizen monitoring to report cattle in streams or other rule breaking found on the Forest. Response We regularly get reports from the public on the location of livestock, both sheep and cattle. Often the reports indicate that livestock are exactly where they are authorized to be, but sometimes the reports show livestock where they are not authorized. All reports are passed along to the appropriate resource manager and investigated as soon as practical. As we move forward implementing the forest plan there will be more opportunities for citizen monitoring as described in the Specific Requirements for Monitoring and Proposed Forest Monitoring Framework sections.

Comment RNG – 4 The analysis and plan should reference relevant science regarding the positive impacts that properly managed grazing can have on ecological conditions.

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Response Since the forest plan does not authorize any particular grazing activity actions, a more detailed analysis is required at the allotment management plan level. This is a more appropriate venue for consideration of effects of grazing livestock, both positive and negative.

Comment RNG – 5 The draft environmental impact statement fails to adequately analyze past and future impacts to the domestic sheep industry. Response The Range Management section provides an overview of current and historical livestock grazing, including domestic sheep, in the planning area. This discussion recognizes the downward trend of sheep grazing overtime and cites factors influencing these trends. The range management analysis also addresses the ecological impacts of grazing of cattle and domestic sheep on Forest resources and documents capable acres for sheep grazing between the alternatives. The Contributions to Social and Economic Stability section describes potential impacts of the alternatives on forage for grazing. This analysis discloses an estimate of the economic contribution to surrounding communities associated with livestock grazing (both cattle and sheep) on the Forest. As stated in this section, the number of animal unit months grazed under all alternatives is not expected to vary; however, cost to permittees may increase under alternative D.

Comment RNG – 6 Direction in DC-RNG-3 should be amended to include "and livestock grazing for the benefit of local communities." Response Draft forest plan DC-RNG-3 “Rangelands sustain biological diversity and ecological processes” has been deleted in the forest plan because it was felt that there was contextual overlap with DC-RNG-1 “Domestic livestock grazing is managed to promote landscape diversity (composition, structure, and function) with both a spatial context (what species, what kind of structure, and what landscape patterns are natural for each ecosystem) and a temporal context (which seral stages and how many are natural for each ecosystem).” While the revised desired condition does not include commenter’s concern, the environmental impact statement Contributions to Social and Economic Sustainability section discusses concerns of local communities in terms of ecosystem services and grazing (Forage for Grazing) effects.

Comment RNG – 7 To account for changes in climate, plan direction should adjust forage utilization targets across a five to ten year period versus a year-to-year basis. Response We believe the commenter is referring to draft forest plan G-RNG-1 (Tables 3 and 4) and final forest plan G-RNG-1 (Tables 1 and 2). Forage utilization is addressed annually in

98 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments response to the amount of precipitation, available forage as a result of past practices and wildlife, and many other factors. Weather variation from climate change will make it difficult to predict forage utilization capacities across a 5- to 10-year period. Addressing this at the annual implementation meetings is appropriate and provides a more nimble response to assessing site-specific changes needed in rotations, numbers, timing, or other range management tools. Any changes in the timing of when forage utilization is assessed would be included during monitoring and adaptive management processes. In response to climate change, range management is one of the most adaptive management programs on the Forest. It allows for rapid response to not only climate stressors but localized weather events and growing conditions that impact forage utilization. Based on continued range monitoring, we believe that the existing program allows adjustments, generally made on an annual basis, are appropriate to address drought, changes in vegetation, and other climate change stressors.

Comment RNG – 8 Controlled driving of livestock is a necessary management action, limiting this use is inconsistent with congressional guidelines for grazing in wilderness areas. Response Controlled driving of livestock is a necessary management action. Driving of livestock is a practice used to access allotments and move livestock from area to area. Site-specific analysis addresses the impacts of this practice and keeps the use to the established stock driveways. Forest plan direction has been adjusted relative to the comment. In most cases, livestock driveways have been in existence and used for many years. Plan components address grazing in wilderness: • SUIT-MA 1-4: Grazing is permitted. • SUIT-RNG-1: Grazing in national forest wilderness areas is authorized by the Congressional Grazing Guidelines (§108, P.L. 96-560, H.R. Report 96-617 dated 11/14/79). Grazing authorizations would be included as part of any legislation on Management Area 1.1a, Recommended Wilderness. However, the acres of recommended wilderness are not currently grazed. Management Area 1 further defines direction for trails, which would include stock driveways: • Existing trails are primitive and maintained to minimize resource damage. The following actions will be taken as needed: . Reduce evidence of trails . Eliminate duplicate routes . Remove trails from maps where repeated travel over the same route is to be discouraged.

Comment RNG – 9 The grazing analysis is inadequate in that it does not address future changes in climate or consider vegetation trends at a variety of elevations.

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Response Site-specific analysis is a better fit to consider changes in temperature and precipitation timing and amount as well as vegetation trends at a smaller scale, which is better suited for site-specific analysis at the project level.

Comment RNG – 10 The 2003 capability and suitability analysis is inadequate in addressing soils; other soil types should be removed, including granitic and highly erosive soils. Response Site-specific analysis addresses soils for health and erosiveness. The smaller scale analysis is better suited to determine needs and mitigation than the programmatic level. The forest plan provides the sideboards for consideration at the site-specific analysis level.

Comment RNG – 11 The 2003 capability and suitability analysis results in unrealistic stocking levels by using a 40 percent slope limit; 30 percent would be more appropriate. Response Forest Service Manual direction that applied to the determination of range capability was included in previous direction that is currently being rewritten. That Forest Service Manual direction defined the process to be used to determine capable and suitable rangelands. That direction stated that slopes greater than 40 percent should be removed from consideration. Sheep are more likely graze slopes 41 to 60 percent, but cattle generally will not.

Comment RNG – 12 The 2003 capability and suitability analysis does not address distance to water as one of the most critical parameters affecting livestock use; areas greater than one mile from water should be removed from the capable acres. Response Refer to response to comment RNG – 11 also. The process defined above states that it is optional to remove areas far from water. Allotment management plans can implement herding and the purposeful use of available forage, and other practices, to reach water. The acres of suitable range can be best modified through project-level analysis.

Comment RNG – 13 The draft environmental impact statement and forest plan need to address how to avoid grazing in areas within allotments that are not capable. Response Suitability of areas to be grazed was analyzed in the 1996 Forest Plan. This information was reconsidered and analyzed in a 2003 amendment to the forest plan. The information at a Forest scale has not changed and is still applicable. Site-specific analysis addresses allotment

100 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments management and grazing impacts as a smaller scale and is the most appropriate scale to determine areas within specific allotments where grazing should be limited.

Comment RNG – 14 The analysis should address animal damage control work conducted in support of livestock grazing. Response Animal damage control is not generally used on the Rio Grande National Forest, but may be considered at the project level for range programs.

Comment RNG – 15 The analysis and forest plan should consider that livestock weights have increased by greater than 35 percent since animal unit months were developed, allowing for more forage to be being grazed while number of animals are reduced. Response Animal weight is not within the scope of forest plan direction and analysis. Forage utilization is determined by on-the-ground triggers that are not directly influenced by animal weights.

Comment RNG – 16 The current permits are not in compliance with the areas that are identified as suitable for grazing. Response To our knowledge, permits are in compliance with areas identified as suitable for grazing. Site-specific analysis may have determined areas unsuitable for reasons other than were used at the forest plan-level determination. This is an appropriate tiering of direction from broad and programmatic to the site-specific level.

Comment RNG – 17 Table 14 in the DEIS (p. 46) does not have totals in the columns. Response Draft environmental impact statement Table 14 and final environmental impact statement Table 15 list capable acres for cattle and sheep grazing by management area. Direction varies by management area and grazing is not an allowable use in all areas. Acreage of capable rangeland does not vary by alternative. However, because slight differences in mapping systems and site-specific adjustment were made, the total numbers are not identical between alternatives for capable acres.

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Comment RNG – 18 There is no difference for areas suitable for grazing among the alternatives; suitability should change with the management emphasis of the alternative. If not, then another alternative should be developed that would have less suitable land for grazing. Response Grazing is an acceptable use across all alternatives. There is no proposal to change or modify this use. Critical to the understanding of the comment is understanding of the terminology as described in the Rangeland Suitability Determination (project record). Per 36 CFR 219.3 and Forest Service Manual 1905 Capability is defined as: The potential of an area of land to produce resources, supply goods and services, and allow resource uses under an assumed set of management practices and at a given level of management intensity. Capability depends upon current resource conditions and site conditions such as climate, slope, landform, soils, and geology, as well as the application of management practices, such as silviculture or protection from fire, insects, and disease. Capability is the initial step in the determination of suitability. It is portrayed as a separate step both for reasons of clarity and because the actual product of “capability” often has utility in planning beyond its role in the determination of Suitability. For forest planning purposes, rangeland capability does not vary by alternative and is therefore only determined once during the land management planning process. Per 36 CFR 219.3 and Forest Service Manual 1905 suitability is defined as: The appropriateness of applying certain resource management practices to a particular area of land, as determined by an analysis of the economic and environmental consequences and the alternative uses forgone. A unit of land may be suitable for a variety of individual or combined management practices. Rangeland suitability is a determination of the appropriateness of grazing on capable lands based on economic and environmental consequences and consideration of alternative uses foregone if grazing is allowed. Rangeland suitability may vary by alternative or grouping of similar alternatives being considered in the land management planning process. Acreage of capable rangeland does not, appreciably, vary by alternative. Capable acres for cattle and sheep are identified in environmental impact statement Table 15 for alternatives by management area. The environmental impact statement describes “The 2012 Planning Rule requires that forest plans identify suitability of lands (36 CFR 219. 7(e)(l)(v)). The 31 percent of the Forest lands identified in the 2002 amendment of the forest plan continue to be considered suitable for grazing. Lands determined as not suitable for grazing have been

102 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments administratively closed to grazing. These include administrative sites, fenced recreation areas, fenced highway right-of-ways, designated management areas or parts of management areas, watersheds, areas within city limits, research facilities and study areas, special-use sites, and critical habitat for threatened and endangered species.” Suitability is also considered in forest plan components.

Comment RNG – 19 Statement of support for continued grazing on the Forest with no reduction in size or scope. Response Livestock grazing is an historic use that through proper application provides resource benefits. There is proposed reduction in size or scope of suitable lands from the 2003 amendment.

Comment RNG – 20 Draft Plan, page 34, Table 4 – Clary and Webster reference is outdated. Response A literature search for new information was conducted during preparation of the forest plan. The citation represents the best available scientific information for grazing residue stubble heights.

Comment RNG – 21 The 2003 capability and suitability analysis does not address the incompatibility of bighorn sheep and domestic sheep grazing. Response The 2003 Rangeland Suitability Determination analysis is not a decision, it was a comparison between 1996 and 2003 suitability determinations as it pertained to the new process. It was prepared for a specific purpose to address Forest Service handbook changes to determine if there was a need to change the record of decision for the Forest’s 1996 Forest Plan final environmental impact statement; there was not. Forest plan direction (draft forest plan S-WILD-10; forest plan S-SCC-2) is included to address the need to maintain separation to prevent disease transmission between bighorn sheep and domestic sheep. Currently, many but not all of the existing bighorn sheep herds have been assessed for potential movements within and beyond their core herd home range in relationship to domestic sheep allotments and other bighorn sheep herds, including movements on adjacent administrative units and state and private lands (draft EIS, page 238).

Comment RNG – 22 The 2003 capability and suitability analysis does not address threatened, endangered, proposed, and candidate species habitat where livestock grazing could have an adverse effect on threatened, endangered, proposed, and candidate species populations and bighorn sheep.

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Response The 2003 Rangeland Suitability Determination analysis is not a decision; it was a comparison between 1996 and 2002 suitability determinations as it pertained to the new process. It was prepared for a specific purpose to address Forest Service Handbook changes to determine if there was a need to change the record of decision for the 1996 Forest Plan final environmental impact statement; there was not a need to change the decision. Forest plan direction is followed unless stated otherwise in the project-level analysis. Site-specific concerns are best addressed at the project level.

Comment RNG – 23 The 2003 capability and suitability analysis did not address the carrying capacity of the Forest and is therefore an academic process with no effect on the Forest Plan or management. Response The forest plan identifies lands that are capable and suitable for livestock grazing. The final environmental impact statement states “Projected capacity for livestock grazing is 143,000 head months, which includes grazing for both cattle and sheep.”

Comment RNG – 24 Monitoring is key to determining if and how grazing is achieving the desired outcomes. Response Monitoring is included in the forest plan in Chapter 4. This monitoring will help determine if plan direction needs to change or is addressing resource needs on the ground.

Comment RNG – 25 DC-RNG-2 needs riparian considerations. Riparian areas can see some of the greatest impacts from grazing, and it would be wrong not to acknowledge this and include those concerns in Forestwide desired conditions for grazing practices. Response This desired condition applies to riparian areas as much as terrestrial areas. More specific direction can be found in the standards and guidelines for riparian and range management.

Comment RNG – 26 Regarding DC-RNG-4, define “slight departure.” Response Draft forest plan DC-RNG-4 has been removed from the forest plan. In response to internal and external comments received, plan components, including desired conditions, objectives, standards, and guidelines have been revised to better meet the intent and direction of the 2012 Planning Rule (36 CFR 219) and its implementing direction (FSH 1909.12). This direction has been combined with other direction to increase clarity and add specificity.

104 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment RNG – 27 Edit text of DC-RNG-6 to reflect fish barriers and wildlife example as: "Range improvements on grazing allotments should support ecologically sustainable grazing and benefits for wildlife when opportunities exist. New and replacement improvements are designed to benefit and allow for passage of aquatic (except when barriers are required for species protection) and terrestrial species (e.g., water trough escape ramps). (Forestwide) Response DC-RNG-6 has been revised in the final forest plan (now DC-RNG-4) as follows: Range improvements support ecologically sustainable grazing and benefits for wildlife when opportunities exist. New and replacement improvement are designed to benefit aquatic and terrestrial species.

Comment RNG – 28 G-RNG-2 needs to be a standard, not a guideline. Response G-RNG-2 has been revised in the forest plan. The direction has been revised to better reflect what is occurring on the ground. This direction is appropriate as a guideline to allow for flexibly while meeting the intent of the direction.

Comment RNG – 29 Regarding G-RNG-3: • G-RNG-3 needs to be expanded to include impacts to riparian areas from livestock. • The forest plan needs to consider more standards to benefit the long-term health of the Forest; G-RNG-3 should be reconsidered as a standard to address grazing issues in various classes of riparian management zones. Response Site-specific impacts from livestock grazing on riparian areas are addressed at the project level. The long-term health of the Forest is the intent of all forest plan direction. We feel the direction G-RNG-3 is appropriate as a guideline. Guidelines provide flexibility as long as the intent of the direction is met.

Comment RNG – 30 MA-RNG-1 must be a standard, not a management approach. Response This plan component describes how the program works and what the intent of management is. This is an appropriate management approach.

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Comment RNG – 31 MA-RNG-3 and MA-RNG-6 are duplicates. MA-RNG-3 and 4 are the same and MA-RNG-4 should be a standard. Response Duplication of MA-RNG-3 and 6 has been corrected in the forest plan (i.e., MA-RNG-6 has been removed) and changes have been made to MA-RNG-3 adding language surrounding livestock use in sensitive riparian, wetland, and spring ecosystems. MA-RNG-3 and MA- RNG-4 are not the same. MA-RNG-3 addresses the use of created openings for livestock grazing while MA-RNG-4, which has also been slightly reworded in the final version of the forest plan, addresses management of rangelands to provide various benefits. MA-RNG-4 does not pose any project constraints that would be appropriate as a standard.

Comment RNG – 32 MA-RNG-7 needs to include riparian consideration, not only uplands. Response MA-RNG-5 appears to be the plan component described. MA-RNG-5 has been slightly updated in the final forest plan. However, it has not changed with regard to the addition of riparian areas. Forest managers specifically wanted direction that provided focus to managing uplands. Riparian management and restoration is considered in other areas of the forest plan.

Recreation (REC)

Comment REC – 1 To provide for an increasing, aging, and less ambulatory populations, the forest plan must provide flexibility to expand recreational facilities and opportunities. Response The forest plan provides for consideration of expanding recreational facilities and opportunities through sustainable recreation. Forest plan direction, including desired condition DC-REC-1, provides for universal accessibility which includes increasing and aging populations throughout the life of the plan.

Comment REC – 2 Forest plans should include thresholds and triggering mechanisms that allow for the expansion and addition of recreational opportunities and not just the curtailments, restriction, and elimination of opportunities. Response Overall, forest plan direction (including DC-REC-1, OBJ-REC-1, and S-REC-1) provides adaptive guidance to address both current and future needs of the public and allow for expansion, addition, or both, of forest recreational opportunities and resources. Standard S- REC-1 includes thresholds with consideration of the natural and human environments that trigger responsive management actions to occur when those thresholds are reached in

106 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments dispersed recreation areas. Desired condition DC-REC-1 also provides for universal accessibility, which allows for opportunities to the greater public.

Comment REC – 3 The Forest Service must designate as open the discrete, delineated areas appropriate for cross-country over-the-snow vehicle use and minimize environmental damage and conflict with other recreation uses. Response The travel management process will be completed subsequent to the forest plan revision process. This process includes and will be completed in compliance with 36 CFR 212 Subpart C, Over-Snow Vehicle Use. As part of forest plan revision, areas suitable and not suitable for over-snow vehicle use were preliminarily identified and mapped across the forest. Areas suitable for over-snow vehicle use include restrictions that minimize environmental damage and conflicts while providing for the protection of endangered species and winter habitat for deer and elk. The over-snow vehicle use suitability map included in the forest plan will be used when completing the over-snow vehicle use requirements of the travel management process.

Comment REC – 4 The Forest should have a plan to enforce minimum snow depth restrictions including protocols for monitoring snow depth, communicating conditions with the public, and implementing emergency closures when snowpack falls below relevant thresholds. Response Minimum snow depth restrictions, or similar measures, may be considered and incorporated in compliance with Travel Management Subpart C, Over-Snow Vehicle Use. Emergency closures are implemented on a case-by-case basis.

Comment REC – 5 Winter recreation opportunity spectrum should be included in the forest plan. Response As discussed in the draft environmental impact statement, the travel management process will address winter recreation opportunity spectrum in compliance with Travel Management Subpart C (36 CFR 212). The forest plan includes an over-snow vehicle use suitability map that preliminarily identifies areas suitable and not suitable for over-snow vehicle use across the Forest. This map will be considered and refined during travel management analysis.

Comment REC – 6 It is not clear how the Forest came to the determinations for over-snow suitability. Response Over-snow vehicle use suitability for the forest plan was determined by considering habitat restrictions for big game (such as deer and elk), endangered species protections, wilderness

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area protections, recommended wilderness management, special interest areas, existing Forest closure orders, and current over-snow trail permits.

Comment REC – 7 Trails should have trail management objectives defined and recorded in INFRA to document the intended purpose and management of trails. Response The INFRA database is used to house a catalogue of geo-spatial features and related coding on the Forest. This has been updated and replaced with a new database. Pertinent information, including management type, for current authorized National Forest System trails are recorded in NRM. The content and maintenance of this database is beyond the scope of forest plan revision, but the database does provide information used in subsequent analysis.

Comment REC – 8 The analysis should discuss the use of snowmobiles to access backcountry skiing and snowboarding in terms of desired terrain, ecological impacts, and conflict management. Response Using snowmobiles to access backcountry snow sport opportunities is a dispersed recreation activity that generally occurs at high elevations. The forest plan provides over-snow vehicle use suitability that identifies what areas are suitable or not suitable for over-snow vehicle use, and applicable restrictions (FEIS, Table 7). Forest plan direction S-REC-1 provides guidance for addressing impacts to the natural (ecological) and human (use conflicts) environments resulting from dispersed recreation activities when certain thresholds are reached.

Comment REC – 9 Travel management rules require that motorized trails and areas be located to minimize damage to Forest resources and conflict, but the analysis and plan do not address these. Response Management area direction and recreation plan components specify some direction for trails. See also Infrastructure plan components regarding the transportation system. Motorized trail location and areas are designated on a project-level basis and are designed to be sustainable. Site-specific design and analysis allow for the ability to provide for a trail that minimizes damage to forest resources and mitigates conflict. The travel management process will further address resource protection.

Comment REC – 10 The analysis needs to clarify that over-snow wheeled vehicles are only allowed on the designated system displayed on the motor vehicle use map. Response The Rio Grande National Forest will be addressing this during implementation of the Travel Management Rule Subpart C, Over-Snow Vehicle Use. Over-snow vehicle use suitability determinations (FEIS, Table 7) included in the forest plan are not travel management

108 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments decisions; however, these preliminary suitability determinations can be used to inform travel management decisions when the Forest undergoes that separate decision-making process.

Comment REC – 11 The Forest needs to correct the misstatement in the environmental impact statement on page 274 that “motorized vehicle use is currently limited to designated routes outside wilderness or Colorado Roadless Areas.” Over-snow vehicle use is currently allowed off routes, and motorized use is allowed and occurs in Colorado roadless areas. Response Revisions have been made to clarify motorized use. Motorized trails are not prohibited in Colorado roadless areas, per the Colorado Roadless Rule.

Comment REC – 12 The statement in the environmental impact statement at page 373 that reads "Alternatives B and D would also reduce the mechanized dispersed recreation opportunities…" as very few of the trails in recommended wilderness are managed for mountain bike use. Response Few trails in the recommended wilderness are managed for mountain bike use. However, mountain bike use occurring within any recommended wilderness areas prior to recommendation can continue until the area is designated as wilderness so long as the existing use does not prevent the protection and maintenance of the social and ecological characteristics that provide the basis for wilderness designation.

Comment REC – 13 The definition of "Mechanized" on page 455 of the DEIS and 130 of the forest plan needs to be clarified; it is not the definition of mechanized but of mechanized travel or transportation. Response The definition of mechanized has been clarified in the final documents.

Comment REC – 14 The standard that enforces the recreation opportunity spectrum classes should be reworded to be consistent with travel management. Response Standard S-REC-1 (Recreation development and travel routes shall be consistent with the recreation opportunity spectrum class designations) has been changed in the final version of the forest plan. Language similar to how S-REC-1 appeared in the draft forest plan was added to DC-REC-1 and management approaches. We feel that the changes made to the direction are consistent with travel management.

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Comment REC – 15 Offered below are examples of plan components that we recommend for inclusion in the final forest plan: DESIRED CONDITIONS The primitive recreation opportunity spectrum class provides recreation opportunities in unroaded and nonmotorized settings. Unmodified natural and natural-appearing settings dominate the physical environment. The semiprimitive nonmotorized recreation opportunity spectrum class provides for nonmotorized recreation opportunities in unroaded and nonmotorized settings. A natural-appearing setting dominates the physical environment, with only subtle or minor evidence of human-caused modifications. OBJECTIVES Within 10 years, all motorized roads and trails within primitive and semiprimitive nonmotorized recreation opportunity spectrum classes will be decommissioned or converted to nonmotorized trails. STANDARDS Roads and motorized trails that are inconsistent with primitive and semiprimitive nonmotorized recreation opportunity spectrum classes and will be prohibited. MANAGEMENT APPROACHES Evaluate the differences between current and desired recreation opportunity spectrum settings, and develop a strategy to move towards desired recreation opportunity spectrum settings through project-level actions. Lastly, we are disappointed that the environmental impact statement does not provide an analysis of the recreation opportunity spectrum settings of inventoried roadless areas – whether existing roadless areas protected under the Colorado Roadless Rule or newly inventoried areas under the Chapter 70 process. Establishing primitive or semiprimitive nonmotorized recreation opportunity spectrum settings for areas identified in the wilderness evaluation process as having moderate to high-upper tier ranks is a good strategy to maintain the wilderness and natural characteristics of areas that do not benefit from a wilderness recommendation in the forest plan. We therefore ask that the final environmental impact statement include this analysis, and in at least one alternative adopt primitive or semiprimitive nonmotorized settings for the majority of areas ranked moderate to high. This may require a revised or supplemental environmental impact statement. See 40 C.F.R. § 1502.9(a) and (c). Response We have considered the recommended plan components provided by commenter as follows. Desired Condition: Recreation opportunity spectrum class defines settings. The desired conditions are defined in the Glossary section, including definitions of primitive and semiprimitive nonmotorized. The conditions presented come from the Recreation Opportunity Spectrum Users Guide. The primitive recreation opportunity spectrum class

110 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments provides recreation opportunities in unroaded and nonmotorized settings. Unmodified natural and natural-appearing settings dominate the physical environment. The semiprimitive nonmotorized recreation opportunity spectrum class provides for nonmotorized recreation opportunities in unroaded and nonmotorized settings. A natural- appearing setting dominates the physical environment, with only subtle or minor evidence of human-caused modifications. Objective: Table 3 lists the miles of current motorized routes in primitive or semiprimitive nonmotorized settings for alternatives B, B modified, C, and D. Alternative A does not have motorized routes in primitive and semiprimitive nonmotorized recreational opportunity spectrum classes.

Table 3. Primitive and semiprimitive motorized route miles by alternative

Alternative Alternative B and Alternative Alternative Alternative

A B Modified C D Primitive (miles) 0 0 0 18 Semiprimitive 0 9 3 26 nonmotorized (miles)

Standard: The described process is addressed in the management approaches. Management Approaches: The environmental impact statement includes comparison of existing and desired recreation opportunity spectrum classes across alternatives. Plan direction includes consideration of mapped desired recreation opportunity spectrum classes during site-specific analysis. The Colorado Roadless Rule already provides direction for roadless management area. This recommended management approach is not necessary because the designations already meet the criteria. The strategy is expressed in the existing management approaches. Table 4 lists the acres for each recreation opportunity spectrum class in designated upper tier roadless areas. Estimated acres of upper tier roadless areas on the Forest are 339,900.

Table 4. Recreation opportunity spectrum class acres in upper tier roadless areas (percentage)

Alternative C and Alternative A Alternative B Alternative D Alternative B Modified Primitive Less than 1 Less than 1 Less than 1 52 Semiprimitive Nonmotorized 66 67 56 27 Semiprimitive Motorized 25 27 37 16 Roaded Natural 9 6 7 4 Roaded Less than 1 Less than 1 Less than 1 Less than 1

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Comment REC – 16 A recreation niche statement needs to be presented. This provides a useful tool to help inform project-level decisions related to recreation and access. Response The 2012 Planning Rule does not require a niche statement. The recreation program has developed a niche statement to guide program management outside of the forest revision process. The Rio Grande National Forest’s “niche” statement is as follows: “Solitude in every Season” From the Sangre de Cristo to the San Juan Mountains, the jagged peaks and rushing rivers of the San Luis Valley public lands wrap themselves around this Rocky Mountain basin. Whether viewing the mountain scenery from roads or finding challenge on trails, visitors discover solitude and self-reliance through uncrowded year-round recreation opportunities. As recreation pressures increase in other parts of Colorado, the public lands of the San Luis Valley maintain their remote spirit and traditional culture.” The recreation facility analysis process identified niche settings on the Forest with corresponding niche emphasis activities and opportunities: remote adventure, solitude, scenic corridors, scenic backways, and winter overlay (USDA Forest Service 2007).

Comment REC – 17 The analysis must analyze and consider the impacts of recreation use and development on wildlife, and plan components must include direction to balance use and development with the needs of wildlife. Response Forest plan direction addressing recreation uses [hiking, motorized recreation, fishing (chytrid fungus), pack goat use, over-snow/off-route travel, etc.] are included in the Wildlife and Species of Conservation Concern section. Guideline G-REC-1 also provides direction to reduce resource damage from recreation activities.

Comment REC – 18 The analysis should properly describe the definitions for scenery; page 260 seems to show no difference between moderately and heavily altered views. Response To show the changes is difficult at the scale presented in the analysis. Table 64 in the draft environmental impact statement relies on percentages of disturbance in footnotes to Table 63. Plan components for scenery help describe the processes better. The photos are general representations of what resource specialists intend as outcomes.

112 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment REC – 19 Recreation opportunity spectrum opportunities are not accurately reflected in the analysis. Recreation opportunity spectrum route mileage is inaccurately portrayed and there are no routes that are open only to motorized use. Response National Forest System roads are open to all motorized and nonmotorized uses. Table 5 shows existing motorized and nonmotorized trail miles by recreation opportunity spectrum setting across alternatives. The table does not distinguish between classes of motorized trail uses.

Table 5. Existing motorized and nonmotorized trail miles, by alternative

Alternative C and Alternative A Alternative B Alternative D Alternative B Modified

Non- Non- Non- Non- Motorized Motorized Motorized Motorized Motorized Motorized Motorized Motorized Primitive 0 214 0 206 0 206 42 646 Semi- primitive 0 506 1 540 1 455 4 149 Non- motorized Semi- primitive 273 79 269 74 266 142 225 44 motorized Roaded 72 78 74 58 77 72 75 45 Natural Roaded 3 11 3 10 3 13 1 4

Comment REC – 20 The draft environmental impact statement seems to show a shortage of hiking routes, which is more basis to recommend additional wilderness; this is incorrect. Response There are a total of 1,399 miles of trails on the Forest, with 490 miles (35 percent) located in wilderness areas and 909 miles (65 percent) located outside of wilderness areas. Table 73 lists the total miles of trails on the Forest by primary managed use. “Managed use” indicates a mode of travel that is actively managed and appropriate on a trail, based on its design and management. “Primary management use” means that while several uses are allowed on a given trail, the primary managed use type reflects the most demanding design, construction, and maintenance parameters. For example, trails managed primarily for motorcycle use require more demanding design, construction, and maintenance parameters than trails only managed for hiking. However, trails specifically designed, constructed, and maintained for motorcycle use also accommodate less demanding use types such as pack-and-saddle and/or hiking. While Table 73 lists the 63 miles of trails that are primarily managed for hikers,

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hiking is also allowed on the other categories of trails managed for a more demanding primary use, such as pack-and-saddle and motorcycle use.

Comment REC – 21 User conflict should not be created in buffer areas in an attempt to create exclusive use areas on the forest. Response The forest plan does not create exclusive use areas. Further, forest plan direction includes guidance in S-REC-1 and G-REC-1 regarding use conflicts and other impacts to the human environment resulting from recreational use.

Comment REC – 22 Flexibility for winter recreation management is needed to account for the development of new technology; laying this ground work in the forest plan is sound policy and good management. Response Forest plan direction (including DC-REC-1, OBJ-REC-1, and S-REC-1) provides adaptive guidance to address both current and future needs of the public, including flexibility to adjust for the development of new technology.

Comment REC – 23 Recreation projects and opportunities must be reviewed for funding stability in the future. Response All projects are screened for fiscal capability over time. Further, a Forestwide recreation management approach in the plan states: “Available resources (e.g., time, budget, and expertise) are strategically invested to support long-term recreation program goals. Developed recreation assets are aligned with projected facility budgets, partnership capabilities, and other re-investment strategies.”

Comment REC – 24 The plan must seek a more balanced and fair allocation of resources to recreation and especially multi-use/motorized recreation opportunities. Response The forest plan, and alternatives considered, presents a balance of uses. Table 79 of the draft environmental impact statement presents the percent of area for motorized and nonmotorized uses by alternative.

Comment REC – 25 Recreation opportunity spectrum is an important concept that is not listed in the table of contents; also the following headings need to be included: sustainable recreation opportunities, access, use, settings overview, sustainable recreation, recreation opportunities

114 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments spectrum, application of the recreation opportunities spectrum, affected environment, existing conditions, and trends. Response These topics are addressed throughout the recreation-related analysis and forest plan direction.

Comment REC – 26 Connectivity is extremely important to Rio Grande and San Luis Valley citizens, who support improvement of existing trails or recreation areas, and development of new ones to ensure connectivity. Additionally, having an adequate trail network is necessary to providing access for resource management, public safety, recreation, etc. Response Connectivity is also addressed outside of the forest plan in the Forest Service’s 2016 National Strategy for a Sustainable Trail System. This Forest Service-wide National Strategy describes the need for a sustainable trail system that is “a holistic network of diverse physical and social resources comprised of actual on-the-ground routes and associated community health and economic benefits.” The national strategy aspires for the entire National Forest System of trails to encourage trail stewardship and use by people across all ages and abilities, and for trails to function as a vehicle that connects people and communities to public lands. Desired condition DC-REC-1 is in line with the intent of the Forest Service’s 2016 National Strategy for a Sustainable Trail System. A Forestwide recreation management approach included in the forest plan states that “trail development is coordinated with systems developed by municipalities, counties, states, other agencies, and partners to promote integration and connectivity.” Additionally, OBJ-REC-1 provides plan direction to develop three trail connections between strategic community areas and National Forest System trails within 15 years.

Comment REC – 27 DC-REC-2 needs to be clarified. Response The direction at DC-REC-2 as presented in the draft forest plan is covered at a higher level and was not needed, so it has been removed in the final version of the forest plan.

Comment REC – 28 Amend DC-REC-4 to include "that conflicts with users and natural resources are infrequent to preserve the recreation experience.” Response Desired condition DC-REC-4 is not included in the forest plan. However, forest plan direction includes guidance in S-REC-1 and G-REC-1 regarding use conflicts and other impacts to the human environment resulting from recreational use.

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Comment REC – 29 Add the following Desired Condition for Recreation: “Recreation uses are developed, managed, and maintained in consideration with fish and wildlife habitat needs, including potential impacts on habitat disturbance.”, as well as a Guideline for managing potential recreation and wildlife conflicts, including coordination of bear-human conflicts in campgrounds. Response Forest Plan direction addressing recreation uses (hiking, motorized recreation, fishing (chytrid fungus), pack goat use, over-snow/off-route travel, etc.) are included in the Wildlife section and Species of Conservation Concern. Guidelines G-REC-1 also provides plan direction to reduce resource damage from recreation activities.

Comment REC – 30 G-REC-1 should be a Standard, not a Guideline. Response Guideline G-REC-1 (“Manage winter recreation activities within lynx analysis units such that lynx habitat connectivity is maintained or improved where needed.”) that was included in the draft plan is not included in forest plan direction. That direction is prescribed in the Southern Rockies Lynx Amendment.

Comment REC – 31 MA-REC-10 represents the type of standard that has been put into place without meaningful analysis or discussion. Response Management Approach MA-REC-10 included in the draft plan has been reworded and included as G-REC-1 in the forest plan, which includes the intent of the direction.

Comment REC – 32 MA-REC-7 is in conflict with S-WLDF-3 and S-WLDF-12. Response Consideration of loop trails is included as a recreation management approach in the forest plan. Draft forest plan standards S-WDLF-3 and -12 dealt with critical lifecycle times. Any trails created would have to comply with direction in S-WLDF-3 and S-WLDF-12; these standards have been simplified in the final version of the forest plan to G-WLDF-1 as follows: To reduce stress at a critical point in the lifecycle of big game, restrict activities on winter range from approximately December 1 to March 31, as needed. (Forestwide).

Comment REC – 33 Add the following recreation Management Approach: “Collaborate with Colorado Parks and Wildlife and other partners to manage potential bear-human conflicts in campgrounds under the guidance of the Be Bear Aware Program.”

116 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response Forest plan direction includes the management approach that states: “Relationships with partners, cooperators, and permittees are vital to the success of the recreation program, as are building, sustaining, and leveraging strategic relationships to sustain high-quality recreation settings and opportunities.”

Comment REC – 34 Amend S-REC-3 to make clear that campsites should be closed if any of the listed conditions are present. Response Draft forest plan standard S-REC-3 has been revised to S-REC-1 in the final version of the forest plan as follows: S-REC-1: Manage, rehabilitate, or close dispersed recreational use areas when: • Use area condition reaches Frissell-Cole Class 4 or 5 (compromised natural environment), or • Use conflicts substantially disrupt user experience, safety, or both, and closure is the only alternative (compromised human environment). The standard is written to apply condition 1 or condition 2. Many considerations are made and the public is involved in any decision to close areas.

Comment REC – 35 Modify 2.2-G-1 to allow motorized and mechanized use when approved as necessary. Response Guideline 2.2-G-1 (“Activities should meet assigned recreation opportunity spectrum class and scenic integrity objectives.”) included in the draft forest plan, now included as G-MA4.2-1 in the forest plan, provides for flexibility as long as the intent is met. However, S-MA4.2-1 included in the final forest plan does “prohibit motorized and mechanized use, except when necessary for research or educational access.” Existing trails that are user created are evaluated and considered against trail design criteria.

Comment REC – 36 Regarding 2.2-MA-2, allow trails created prior to establishing the area to be used for recreation and scientific research or educational access, except when values for establishment are threatened. No new trail construction should occur unless needed to correct resource damage from existing trails.” This must be clarified so that trails refers to officially designated trails, and not user-created routes. Response Management Approach 2.2-MA-2 (“Allow trails created prior to establishing the area to be used for recreation and scientific research or educational access, except when values for establishment are threatened. No new trail construction should occur unless needed to correct

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resource damage from existing trails.”) included in the draft forest plan was revised and is now a management approach for Management Area 4.2 (Research Natural Areas). The management approach in the forest plan states, similarly, “Trails created prior to establishing the area can continue to be used for recreation and scientific research or educational access, unless values for establishment of the area are threatened. No new trail construction should occur unless needed to correct resource damage from existing trails.” This management approach generally refers to existing National Forest System trails, but provides for user- created trails present on the landscape to be evaluated for inclusion in the trail system.

Comment REC – 37 Funding from Non-Governmental Organizations for off-highway vehicle community groups has played an integral part in efforts to maintain access to public lands for all user groups. This funding has become more important each year as federal budgets continue to decline. Keeping trails open to motorized use significantly expands available funding for these travel routes. Response Forestwide recreation management approaches included in the forest plan state that the Forest’s recreation program: “Relationships with partners, cooperators, and permittees are vital to the success of the recreation program, as are building, sustaining, and leveraging strategic relationships to sustain high-quality recreation settings and opportunities. Available resources (e.g., time, budget, and expertise) are strategically invested to support long-term recreation program goals. Developed recreation assets are aligned with projected facility budgets, partnership capabilities, and other re-investment strategies. The Forest intends to encourage cooperators to be involved in stewardship activities.”

Riparian

Comment Riparian – 1 Direction for riparian management zones should be included as plan direction and not in an appendix. Response Plan direction related to riparian management zones in contained in Chapter 2, under the heading Riparian Managements Zones. The referenced Appendix (F) describes the procedure for the delineating riparian management zones, and was separated for ease of use.

Comment Riparian – 2 Riparian management zone direction should be consistent with the Region 2 Watershed Conservation Handbook, the NRCS direction for Montana, and the Colorado Forestry BMPS; no more than 50 to 100 feet wide. Response The reference by the commenter to “NRCS direction for Montana” is vague, the exact reference was unable to be located. Colorado Forestry best management practices, while valuable in assisting Forest personnel, fail to meet the minimum requirements set forth in the

118 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Region 2 Watershed Conservation Practices Handbook (FSH 2509.25) that the Water Influence Zone (Riparian management zone according to the 2012 Planning Rule) be defined for perennial and intermittent streams as being a minimum of 100 feet from the top of each bank. “The water influence zone includes the geomorphic floodplain (valley bottom), riparian ecosystem, and inner gorge. Its minimum horizontal width (from top of each bank) is the greater of 100 feet or the mean height of mature dominant late-seral vegetation. The water influence zone protects interacting aquatic, riparian, and upland functions by maintaining natural processes and resilience of soil, water, and vegetation systems (Reid and Ziemer 1994).” FSH 2509.25 12.1 Per FS 990-A the terms water influence zone, aquatic management zone and riparian management zone are functionally the same. Riparian Management Zone is the terminology used in Forest Service Handbook 1909.12, Section 23.11e.

Comment Riparian – 3 The bibliography should include the NRCS SMZ Rule for Montana and the Colorado Forestry Best Management Practices to Protect Water Quality in Colorado (2010). Response See response to Comment Riparian – 2.

Comment Riparian – 4 Riparian Management Zones - We recommend that you rewrite all of the desired conditions to conform to the definition so they are measurable and able to be monitored. They should also be condensed. Response Four of the five desired conditions in the draft forest plan (DC-RMZ-1, 2, -4, and -5) have been reworded and combined in the forest plan. Forest plan direction for DC-RMZ-2 (draft forest plan DC-RMZ-3) has also been updated. Commenter has included the requirements of an objective “an objective is a concise, measurable, and time-specific statement of a desired rate of progress toward a desired condition or conditions.” (36 CFR 219.9 (e)(1)(i)). Desired conditions do not require measureable and time specific statements.

Comment Riparian – 5 Direction from FS 990A should be added to the forest plan: “Proactively manage the AMZ to maintain or improve long-term health and sustainability of the riparian ecosystem and adjacent waterbody consistent with desired conditions, goals, and objectives in the land management plan.” Response The FS-990A is Forest Service direction that has been incorporated by reference and will be utilized by the Rio Grande National Forest in the design, implementation, and monitoring of individual projects.

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Comment Riparian – 6 The effects analysis regarding wetlands and fens from management of the resources is incorrect; alternative C would not treat the maximum acres because harvest operations are limited in riparian and wetlands; best management practices and design features would limit impacts; and road construction associated with timber harvest has more effects. Response Alternative C proposes the highest level of timber harvest and would likely have the highest impacts on wetland ecosystems. This assumption is appropriate for programmatic effects analysis; at this point, we do not know where the timber harvest would take place, and therefore cannot draw more specific conclusions about impacts to fens and wetlands. However, we can generally surmise that more timber harvest will likely impact more of these areas. Management measures, including plan direction, are applied to reduce impacts to wetlands (via limitations on treatments in these areas), they do not entirely eliminate impacts from harvesting in areas adjoining wetlands. In a programmatic analysis it is a reasonable assumption that the total impacts to wetland ecosystems scales proportionally to the total number of acres proposed for timber harvest, as a consequence alternative C has the greatest potential to impact wetlands and fens.

Comment Riparian – 7 Riparian Management Zones warrant stronger protections from grazing and logging practices. Response Professional experience shows that the forest plan components related to the protection of riparian management zones, and watershed resources, are sufficient to provide protection for riparian areas.

Comment Riparian – 8 The effects analysis is biased toward negative effects and does not display the effects of implementing Best Management Practices or design features. Response Best management practices do not generate positive impacts, they protect from or mitigate to an extent, not wholly, negative impacts associated with management actions. As stated in the Watershed Resources section of the environmental impact statement, it is anticipated that all vegetation management will comply with the most current best management practices, and the analysis of impacts and disclosure of effects was made under this assumption.

Comment Riparian – 9 Riparian Management Zone designations need stronger management direction to better protect Rio Grande cutthroat trout.

120 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response The riparian management zone and fisheries plan components, including standards and guidelines, along with the use and implementation of the fisheries activity period maps, provide the necessary level of direction. Project-level analysis would include a determination of effects and, if needed, mitigations or additional protections for all occupied streams and levels of Rio Grande cutthroat trout genetic status.

Comment Riparian – 10 Amend riparian management zone desired conditions to include the wider benefits associated with beaver placement and enhancement. Response The benefits of beaver presence in terms of riparian health are addressed at the broader watershed scale in forest Plan DC-WA-1.

Comment Riparian – 11 More specific standards and guidelines are needed to the types of riparian management zone outlined; an additional class of riparian management zone is needed that considers native fish bearing streams. Response The plan components for riparian management zones provide the level of detail and protection needed at the Forest level. See also responses to comments Riparian – 9 and Riparian – 14 relating to native fish and the process for delineation and implementation of riparian management zones at the project level.

Comment Riparian – 12 The science associated with the use of site-potential tree height in delineating riparian management zone width is outdated and potentially problematic. Response The use of site-potential tree height is just one of the variables that can be used in the determination of riparian management zones but could only be used if it provided the greatest distance of buffer. As suggested, the most intensive and accurate method would include site- specific analysis by a specialist and would be defined using best judgement to protect riparian function and ecological processes. For options 2 and 3 of delineation, the edge of riparian vegetation if greater is the preferred method when field verification can be conducted, and provides the best buffer. An additional reference is provided for this here and in the plan (Anderson et al. 2007). Anderson, P.D., D.J. Larson, and S.S. Chan. 2007. Riparian buffer and density management influences on microclimate of your headwater forests of western Oregon. Forest Science 53(2), pp. 254-269.

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Comment Riparian – 13 The primary impacts to aquatic and riparian resources is livestock grazing; the analysis provides little information or data to address the issue. Response Direction for livestock grazing in the forest plan is in addition to direction found in the Forest Service Manual and Handbook related to livestock management, watershed management, and management of riparian areas. This direction in the forest plan accompanies the higher level direction, and project-level analysis will provide riparian protections and mitigations for riparian and wetlands areas.

Comment Riparian – 14 In the introduction to the Riparian Management Zones section (Plan at 14-15), the plan mentions the process for determining the width of riparian management zones, as required by the Planning Rule at 36 CFR 219.8(a)(3)(ii). The process is described in forest plan appendix F. However, the plan does not further mention this process, and it is not included in any plan component. There should be a least a guideline, if not a standard, that requires this process to be used, unless another process is later developed or discovered that incorporates the best available science. Response The delineation process described in appendix F will be applied at the site-specific project level to determine if riparian management zones occur in the project area. If riparian management zones occur, the plan components (desired conditions, standards, guidelines) presented in the Riparian Management Zone section of Chapter 2 will be applied.

Comment Riparian – 15 The groundwater dependent ecosystems should have standards requiring the limitation of roads and livestock grazing. There are citations omitted at page 163. Response In the professional experience and judgement of the interdisciplinary team, the plan components related to the protection of groundwater-dependent ecosystems, wetlands, riparian management zones, and watershed resources are sufficient to provide protection for groundwater-dependent ecosystems.

Comment Riparian – 16 I am concerned about the lack of protection of waterways in alternatives B and D. Standards and guidelines delineating the width of riparian areas is warranted. There should also be a demand that cattle be kept out of the riparian areas. Response Appendix F covers the delineation of riparian management zones and will be used on all site- specific project proposals. The plan components that protect watershed resources apply Forestwide and to all alternatives.

122 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment Riparian – 17 We recommend that you delete the second sentence in G-GDE-1. Response Two draft forest plan guidelines (DC-GDE-1 and -2) were replaced with one standard and one guideline in the forest plan (S-GDE-1 and G-GDE-1). The standard provides stronger protection for groundwater-dependent habitat features. Revisions also removed special emphasis on large, unusual, or pristine fens that was included in the second sentence of the draft guideline that was the subject of commenter’s concern.

Comment Riparian – 18 Please correct the last line of DC-RMZ-1 to indicate that beavers can enhance riparian ecosystem composition, structure, and function. Amend DC-RMZ-1 to include the ability to pair in-stream or near stream work with project work to complete landscape scale restoration and rehabilitation. Response The Forest recognizes the role of beaver habitat for restoration. Beaver habitat language as suggested is addressed in forest plan direction DC-WA-1 and DC-RMZ-1. Pairing instream or near-stream work with project work is provided for in many sections of the forest plan, including management approaches for species of conservation concern.

Comment Riparian – 19 In DC-RMZ-1, “healthy” is not particularly useful in this case, as we question how it will be measured/evaluated. Please note the desirable native species and the desired condition for age classes. Please provide more information so that the public can measure/evaluate progress towards “diverse” and “vigorous” conditions. Provide more information on how the Forest intends to evaluate “sufficient vegetative cover.” There need to be measurable desired conditions for riparian composition, structure, and function, likely employing key characteristics that were presented within the Assessment. Response Desired condition DC-RMZ-1 has been revised in the forest plan to better describe a healthy system.

Comment Riparian – 20 Regarding DC-RMZ-2, rule requirement and does not add value to this forest planning process. Response Desired condition DC-RMZ-2 has been combined with other desired conditions in the final forest plan (DC-RMZ-1). Forest plan guideline G-RMZ-1 further provides direction to achieve the desired conditions for ecological integrity.

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Comment Riparian – 21 DC-RMZ-3, provide a measurable desirable condition for hydraulic regimes and define “appropriate channel and floodplain development, maintenance, and function.” Response These concerns are defined in other direction such as forest plan desired condition DC-WA-1.

Comment Riparian – 22 DC-RMZ-4 is an excellent goal statement. Please describe the resilient condition in terms that the public is able to measure/evaluate. For management threats to resiliency, plan direction that abates the threat so that rule requirements are met will be necessary. Response Desired condition DC-RMZ-1 was rewritten to describe resilient conditions.

Comment Riparian – 23 Provide a measurable description of the ecological needs of the target species. For management threats to sensitive habitats, plan direction that abates the threat so the rule requirements are met will be necessary. Response This direction is addressed in forest plan desired condition DC-RMZ-1, and measurable objective in OBJ-RMZ-1 and S-RMZ-1.

Comment Riparian – 24 G-GDE-1 should be a standard. Response Revisions made between draft and final broadened the consideration for this direction and included it as a standard (S-GDE-1) as follows: Do not authorize management actions that alter the hydrology of groundwater-dependent habitat features. (Forestwide)

Comment Riparian – 25 In addition to willow carrs in G-RMZ-2 please include in the guideline that grazing and other management activities provide a diversity of sedges, rushes, grasses, shrubs and trees which can provide the structural, forage, cover requirement for birds, small mammals, reptiles and amphibians that depend on healthy riparian areas to complete their lifecycle requirements. Also, the target structural condition (healthy willow carrs) should be defined. Response The direction is broad enough to provide for diversity. The intent of the direction is to maintain willow carrs dependent on existing conditions.

124 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment Riparian – 26 Including direction in G-RMZ-3 could be used to restrict livestock grazing in riparian management zones with no demonstrated need. Response Draft forest plan guideline G-RMZ-3 has been removed from the final forest plan. Activities to prevent or minimize introduction and spread of cowbirds is not well developed or needed.

Comment Riparian – 27 We recommend that MA-GDE-2 be deleted. The operative portion of this management approach is that fens will be inventoried. We don’t see any reason to monitor and evaluate all fens on the Forest. Response Management approach MA-GDE-2 has been revised in the final forest plan. New language clarifies that inventory and evaluation of fens will depend on capacity. Fens are of particular interest on the Forest. A significant investment has been made to inventory and map these. The Forest intends to continue inventorying and mapping these resources as time and funds allow.

Comment Riparian – 28 In OBJ-RMZ-1, delete “prioritize and.” Response Suggested revision has been made to OBJ-RMZ-1.

Comment Riparian – 29 Without measurable desired conditions for riparian management zone structure, composition, function, and connectivity, OBJ-RMZ-1 cannot be effectively implemented and does not contribute to meeting rule requirements; you cannot enforce a standard to maintain or restore an undefined condition. Response The combination of higher level direction, which is not repeated here, with forest plan direction allows for measurable indicators to evaluate desired conditions.

Comment Riparian – 30 S-RMZ-1 needs to be tailored to address the kind and amount of activity that can take place within an RMZ. Response Forest plan direction provides sideboards to reduce project-level impacts. Standard S-RMZ-1 has been revised as follows: Management activities may have short-term impacts (generally less than 5 years) to composition, function, and structure of riparian areas and fish habitat.

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Over the long term (generally greater than 20 years), projects shall not impair connectivity, composition, function, and structure. (Forestwide).

Roadless

Comment Roadless – 1 In Management Area 3.5 delete the "no new road construction occurs…" as there are exceptions of road construction. Response There are exceptions to prohibition of road construction and road reconstruction in the Colorado Roadless Rule. The correction has been made.

Comment Roadless – 2 The forest plan should reflect the use of motorized and mechanized travel in roadless areas. Response Thank you for correctly pointing out that motorized and mechanized travel is not prohibited in Colorado roadless areas. The correction has been made. Construction or reconstruction of these trails would still undergo subsequent environmental analysis that would consider effects on roadless area characteristics.

Comment Roadless – 3 Under Management Area 3.6 – Upper Tier Colorado Roadless Area, there is an incorrect citation to the Code of Federal Regulations: “Road and trail construction and reconstruction follows direction outlined in the 2012 Colorado Roadless Rule (36 CFR 223).” Forest plan at 84. The proper citation is 36 CFR 294.43. Response Thank you for pointing out the error. The citation has been corrected.

Comment Roadless – 4 It does not make sense to switch roadless areas to management area 3.1 - the Colorado Roadless Rule still applies to these areas, the final plan should overlap 3.5 and 3.6 with 3.1 where applicable. Response Because the Colorado Roadless Rule applies regardless of forest plan direction, we feel that it would be clearer if the direction was incorporated into the forest plan as management area direction. This simplifies the direction and consolidates it into one place. Management Area 3.1-Special Interest Areas still apply and are represented in alternatives A and D. The special interest area allocation emphasizes the use and interpretation of these areas. While the Colorado Roadless Rule still applies to these areas, management direction in the forest plan is more specific to the protection and enhancement of the unique characteristics of those areas. When guidance in a forest plan is more restrictive than direction described under the Colorado Roadless Rule, actions must be consistent with the more restrictive direction.

126 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment Roadless – 5 Development of areas for the Colorado Roadless Rule was a site-specific analysis of many of the areas proposed for wilderness, the Colorado Roadless Rule provided guidance for development of non-wilderness management in these areas. The Colorado Roadless Rule clearly states that no further protections of these areas is warranted and that the characteristics inventoried should be protected and preserved. Response The Colorado Roadless Rule does not preclude consideration for the wilderness inventory and evaluation process as prescribed in FSH 1909.12, Chapter 70. The analysis in the environmental impact statement occurred through the wilderness evaluation process required by the 2012 Planning Rule.

Comment Roadless – 6 The Colorado Roadless Rule sought to provide dispersed recreation use for all users. Response The Forest provides diverse recreational experiences, across a spectrum of land management designations, and will continue to do so.

Comment Roadless – 7 How conditions have changed in the roadless areas to make them eligible for wilderness in such a short period of time needs to be clarified. Response Wilderness inventory and evaluation prescribed in the 2012 Planning Rule is a separate and different process than roadless area designation under the Colorado Roadless Rule. The intent of the Colorado Roadless Rule was to identify roadless areas with specific criteria. The wilderness evaluation uses different criteria, as articulated in Forest Service Handbook 1909.12, Chapter 70. The 2012 Planning Rule does not preclude Colorado Roadless Rule lands from further evaluation, including wilderness.

Socioeconomics and Ecosystem Services (SOCIO)

Comment SOCIO – 1 The analysis should determine if revision of the forest plan would have adverse impacts on the identified communities. Response The Contributions to Social and Economic Sustainability section of the environmental impact statement addresses the human environment. The effects analysis describes potential social and economic consequences of the alternatives across the planning area, including a county-level evaluation. As a programmatic document that does not authorize particular site- specific activities, it was not feasible to analyze the specific nature and location of social and

127 USDA Forest Service economic effects resulting from activities that may be authorized and implemented in the future. Subsequent site-specific analyses will evaluate social and economic consequences at a finer geographic scale, where these are identified as issues.

Comment SOCIO – 2 Update table 103 to include Trinchera Forest Products. Response The Trinchera Ranch sawmill is captured in the Timber (Including Non-Timber Forest Products) section. As noted in this section, “A new mill in Costilla County (currently utilizing timber from within their own property) was also included due to its potential to utilize timber from the Forest in the future.” The new mill referenced in this section is the Trinchera Ranch sawmill. Therefore, no updates have been made. SOCIO There is no discussion in the analysis of the economic impacts of hunting, fishing, and watchable wildlife. Response Forest visitors engaged in hunting, fishing, and wildlife viewing are captured in the National Visitor Use Monitoring surveys, on which the Outdoor Recreation, Tourism, Landscapes, and Features Providing Recreation and Scenery subsections are based. Economic impacts associated with recreation are reported for local and non-local visitors, rather than by activity type. Therefore, the economic impact of hunting, fishing, and wildlife viewing is included in the approximately 549 jobs and $14.4 million in labor income annually due to recreation visitor spending. Recreation participation rates by the top five activities are shown in Table 76. Approximately 20 percent of the visitors identified fishing and hunting as their main activity. None of the alternatives are expected to affect recreation visitation numbers or visitor spending.

Comment SOCIO – 4 The analysis should address the capacity for businesses to build up for a short time relative to the anticipated salvage harvest. Response The Timber Processing Capacity and Use by Size Class section addresses the trends and challenges associated with salvage harvest. The analysis notes, “One of the major risks and drivers affecting the continued provision of the Forest’s commercial timber supply is the large amount of Engelmann spruce mortality from spruce beetle. Although efforts have been underway to increase the harvest of these trees in recent years, the harvest is sustainable only in the near short to medium term because the larger, and financially viable, dead trees cannot retain their value as saw or house logs indefinitely. The market for lower quality woody biomass such as decayed dead timber is difficult (Forest Stewardship Concepts, Ltd. 2014)”. Additionally, the analysis notes that, “it is increasingly critical for markets to expand, in order to accommodate small-diameter material and salvaged timber”.

128 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment SOCIO – 5 The forest plan needs to fairly and adequately provide an environmentally, economically, and socially sustainable end state. Response The purpose of the forest plan is to “guide project implementation, practices, uses, and protection measures to assure sustainable multiple use management.” However, “Forest plans are strategic in nature and do not compel any action, authorize projects or activities, or guarantee specific results. Instead, they provide vision and strategic direction needed to move a national forest toward ecological, social, and economic sustainability.” The forest plan identifies three goals, which aim to provide for ecological, social, and economic sustainability: (1) maintain and restore sustainable, resilient terrestrial ecosystems; (2) protect and restore watershed health, water resources, aquatic ecosystems, and the systems that rely on them; and (3) actively contribute to social and economic sustainability in the broader landscape and connect citizens to the land. The draft forest plan clarifies these goals through the identification of desired conditions, objectives, standards, guidelines, and management approaches for each resource. Subsequent forest management activities must be compliant with the forest plan.

Comment SOCIO – 6 Using the 16 county area is confusing and unclear and not very useful, it does not connect the people of the San Luis Valley. Also, Hinsdale County is added on to the San Luis Valley mix, but Hinsdale more likely relates to the Gunnison area. Response The social and economic analysis describes the rationale for the selected areas of influence. The 16-county area was selected based on agency data on timber, grazing, recreation, Forest Service payments to states and counties, as well as local knowledge. The selection criteria are described in more detail in the environmental impact statement. Hinsdale County is included in the more targeted area of influence – the San Luis Valley area of influence – due to the close ties and interest the county has in the management of the Rio Grande National Forest.

Comment SOCIO – 7 There is no mention (Table 92, p. 347) that the forest is an important carbon sink to offset global warming. Response The Carbon Stocks and Sequestration section of the environmental impact statement analyzes the Forest’s role as a carbon sink. This section notes that while the Forest is currently a carbon sink, “the future of the terrestrial carbon sink of Western forests, including Rio Grande National Forest, is uncertain due to the multiple interacting factors that influence

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carbon stocks and fluxes” including climate change, other disturbances, and land management practices.

Comment SOCIO – 8 Table 98, p. 349, should show Rio Grande County as farm dependent versus nonspecialized. Response The economic dependence typology was developed by the USDA Economic Research Service to classify all U.S. counties according to six mutually exclusive categories of economic dependence. According to this, Rio Grande County does not meet the criteria for farm dependence, which are farm earnings accounting for 25 percent or more of total county earnings or farm employment accounting for 16 percent or more of total employment.

Comment SOCIO – 9 Aren't creative class employment, measure of productivity, and economic diversity better suited to more urban areas? Response Creative class employment, productivity, and economic diversity are importance economic measures that are relevant to both urban and rural areas. Indeed, the analysis area counties with the highest levels of creative class employment in the planning area, Hinsdale and San Juan counties, are both rural. As described in the environmental impact statement, natural amenities contribute to population and economic growth and change in rural areas: “Natural amenities, often provided by public lands, have been found to influence population and employment changes in amenity-rich communities (Knapp and Graves 1989, Clark and Hunter 1992, Treyz et al. 1993, Mueser and Graves 1995, McGranahan 1999, Lewis et al. 2002).”

Comment SOCIO – 10 The Forest Service appears to be saying that goods and services are only important to those that obtain benefits from nature. Response All people benefit from nature, whether or not those benefits are recognized. Clean air and water, food, fuel, and shelter are essential to human well-being. Forest ecosystems contribute to these benefits. The environmental impact statement defines ecosystem services as the benefits people obtain from nature. The Multiple Uses and Ecosystem Services section is one component of the analysis, which focuses on the relationship between people and goods and services provided by forest lands. The multiple uses and ecosystem services analysis takes an expansive view of how people benefit from nature—consumptive uses, non-consumptive uses, and even without any direct use of forest lands or resources. The analysis describes a variety of non-use values: “For others, simply knowing that wild lands (such as wilderness), wildlife (such as black bears and lynx), and wild, scenic, and recreational rivers exist in the Forest is a benefit, even if they never plan to visit.” Much of the analysis describes the ecological importance of the Forest. For example, the environmental impact statement addresses the importance of habitat connectivity for wildlife

130 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments and the role of fens, wetlands, seeps, and springs in ecosystem resilience. Benefits such as these are described throughout the environmental impact statement.

Comment SOCIO – 11 Gravel should be included as a salable material. Response Gravel is identified as a salable mineral. The analysis notes that “gravel is commonly used for road resurfacing projects.” None of the alternatives would meaningful affect the availability of gravel or other salable minerals from the Forest.

Comment SOCIO – 12 The statement on page 372 of the draft environmental impact statement that “San Juan Country used the majority of its water for aquaculture” needs to be verified. Response The U.S. Geological Survey estimates county-level water use in the United States. Their latest analysis, based on 2010 data, shows that aquaculture accounts for the majority of water withdrawals in San Juan County. These data are correctly reported in table 108. The U.S. Geological Service county-level water use data are publicly available online at https://water.usgs.gov/watuse/data/2010/.

Comment SOCIO – 13 Birding should be included as a bonafide recreational activity. Response The national visitor use monitoring survey records the number of visitors who report wildlife viewing during their trip to the national forest, which includes birders. The Forest Service does not have data to distinguish birding from other wildlife viewing activities. The Contributions to Social and Economic Sustainability section has been updated to note that birding opportunities draw recreational visitors to the Rio Grande National Forest.

Comment SOCIO – 14 The estimates on pp. 375-376 of the draft environmental impact statement are too small and are missing things. It is not clear if these only relate to the five-county area of influence. Response Economic impacts reported on pp. 375-376 relate to agency expenditure associated with the management of the Forest, as well as additional impacts from county payment received locally. All impacts are estimated for the broader economic analysis area as described in the Area of Influence section.

Comment SOCIO – 15 “Key ecosystem services” are not defined.

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Response The term “key ecosystem services” is defined in the Multiple Uses and Ecosystem Services subsection of the affected environment analysis. Key ecosystem services are benefits from nature that (1) are important to people in the areas of influence and the broader landscape and (2) may be affected by Rio Grande National Forest management actions. The assessment identified key ecosystem services as: (a) fish and wildlife, (b) forage, (c) mineral deposits, (d) non-timber forest products, (e) timber, (f) cultural, historic, and sacred sites, (g) landscapes and features providing recreation and scenery, (h) solitude, spirituality, and sense of escape, (i) water quality, quantity, storage, and flood control, (j) pollination, and (k) support of habitat and species diversity, abundance, and distribution (Rio Grande National Forest Assessment 7, 2016). These key ecosystem services are analyzed in the environmental impact statement. This is not an exhaustive list of ecosystem services provided by the Forest. Key ecosystem services were selected based on discussions with Forest staff and public involvement.

Comment SOCIO – 16 In the County-Level Summaries on page 384 of the draft environmental impact statement, the county profiles are viewed through the typology constructs, which is a strange view to base analysis on. Response The environmental impact statement describes the relevance of the county typologies for understanding economic sustainability. The county-level summaries reference the same indicators that were introduced earlier in the analysis. Use of these typologies to evaluate economic sustainability is professionally accepted. The typologies are based on clearly defined criteria, which avoid subjective judgments regarding economic sustainability.

Comment SOCIO – 17 On pages 384-385 of the draft environmental impact statement - Alamosa County, “The Direct Basic percentage may be the lowest among the seven-county area of influence,” but the absolute amount of direct may represent a very large share of all the direct in the seven- county area. Response This section has been updated to include the following: “Direct basic industry makes up 59 percent of Alamosa County’s economy, the lowest among the seven-county area of influence. However, Alamosa County is the largest economy in the San Luis Valley. Therefore, while direct basic industry is small in percentage terms in Alamosa County, it is large in absolute terms in the San Luis Valley.”

Comment SOCIO – 18 On pages 387-388 of the draft environmental impact statement, Conejos County, the context that Conejos County is “more diverse” does not make sense, in relation to the other San Luis Valley counties. Also, why are tourism predictions so pessimistic in this and other counties?

132 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response The sentence: “Relative to contributions from the Forest, because Conejos County is more diverse, it would be less likely to see dramatic economic impacts, if the Plan Area’s contributions were to change, for instance” has been removed. This now reads: “Due to moderate economic diversity and relatively high dependence on forest-related sectors, Conejos County’s economy may be affected by changes in public land management.” The discussion of anticipated change in the tourism sector are based on projections from the Colorado State Demographer’s Office. These projections are detailed in the civilian labor force projection section and Table 100.

Comment SOCIO – 19 It is unlikely that residents of Custer County, which is on the far side of the Sangre de Cristo mountain range, rely on the Forest (page 7 of the DEIS). Response We agree that “rely” might be too strong, but in this case it is used in the context of economic contribution models. We strive to make the relationship among local populations and the Rio Grande National Forest mutually beneficial. The Forest benefits tremendously from relationships with local counties and their residents. Custer County is included based on the current or historic flow of timber sales and on the location of timber-related employment. A total of eight counties qualified under this criteria. See McIver et al. (2017) as cited in the reference section for detailed information.

Soils (SOIL)

Comment SOIL – 1 Language should be included to address the benefits of timber harvesting on soils in terms of the benefits of road maintenance and road reconstruction. Response To add clarity the following was added to the Soils, Effects on Soils from Timber Harvest section of the environmental impact statement. Timber roads, skid trails, and landings are often the largest contributors of bare soil from harvest activities. When correctly engineered, maintained, and properly disconnected from water, timber roads contribute very little sediment to stream courses or other water bodies. Re-opening old road prisms and building temporary harvest roads can create a sharp increase in erosion of soils to water courses, due to an increase in bare soil. Proper application of standard best management practices can mitigate this initial increase in erodible soils as well and ongoing erosion from roads. These impacts decrease over time but do not entirely stop. Additionally, roads that are maintained as part of the haul route are often better maintained than similar roads across the area, and this maintenance can lead to a decrease in sedimentation to lakes and streams by disconnecting those sources. Upon completion of a sale, operators are required by best management practices and project design features to

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install rolling dips to disconnect the road from streams and thus protect water courses from increases in sediment delivery. Leaf litter forms a physical barrier to protect against soil erosion. Standard best management practices require slash to be returned to skid trails, landings, and roads, which help prevent erosion from the area after harvest activities are complete.

Comment SOIL – 2 Typo error on page 158 of the draft environmental impact statement. 3rd paragraph last sentence might want to read “C being the most impactful with about 3,000 more acres each year.” Response This correction has been made.

Comment SOIL – 3 The primary impact to soils is grazing, in terms of compaction, creation of bare ground as well as stream bank instability, yet the environmental impact statement downplays these impacts. Further, the primary impact on soil productivity is grazing, yet grazing is not mentioned. Response Soils are detrimentally impacted when soil function is severely limited or lost. These impairments can be effected through soil compaction, removal of organic matter necessary for nutrient cycling, or soil loss, primarily through erosion. Many practices have potential to cause these issues. Timber harvest using heavy equipment can compact soils and remove topsoil; and recreation sites, including trails, can create areas of compaction, which in turn can lead to increases in erosion and soil loss. Compaction and soil loss from grazing activities typically occurs along trailing routes and stream banks. Hoof action and shear can trample down streambanks, and removal of vegetation can create areas of streambank instability. This instability can lead to soil loss and can diminish soil function. All of the above activities are widespread across the Forest, but impacts are generally localized. Grazing impacts may be the most widespread, but potential for impact is not greater than other sources of soil disturbance. Authorized uses of the Forest generally are prescribed project design features as well as accepted best management practices, which protect and mitigate soils from excessive detrimental disturbance caused by these activities. When areas are identified that are not meeting expected standards and guidelines for resource protection, adjustments are made to aspects of the activity to protect that area from further unacceptable impacts. Examples of measures taken to address resource concerns include grazing timing or a rest rotation system that may be applied to a grazing allotment pasture, or timber harvest that may need to be done only during winter. In addition, the National Best Management Practices monitoring protocol was established to monitor the application and effectiveness of best management practices applied on the Forest. This monitoring protocol ensures that project design features and best management practices are applied correctly from planning documents and are effective on the ground. These sideboards are designed to protect resources from poor practices that will lead to impacts such as soil loss and loss of soil function, but these disturbances cannot be attributed to one source or leading contributor as

134 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments the comment asserts. Detrimental disturbance across the Forest can come from a number of different sources including grazing and vegetation management sources but is addressed through project design features, best management practices, and adaptive management practices.

Comment SOIL – 4 The draft environmental impact statement fails to address the effects of soils on fire behavior from salvage logging, and appears to underestimate likely problems with regeneration (page 122 of the DEIS). Response While not specifically addressed, salvage logging impacts are similar to other vegetation management practices. Management measure 14.2 from the water conservation practices handbook (FSH 2509.25) requires the Forest to “Maintain or improve long-term levels of organic matter and nutrients on all lands.” This is done by establishing minimums for woody debris left for wildlife habitat and ecosystem function as established in Table 5 of the forest plan on a tons per acre basis. Although the amount of fine woody debris may increase after a salvage harvest and increase the potential for fire on the short term, this fuel burns differently than large woody debris. However, conditions that depend on the accumulation of fuels, moisture, and climatic conditions are all integral in determining how a fire burns and therefore do not necessarily increase the fire hazard in relation to soil simply by being present. The environmental impact statement states that coarse woody debris will fall and eventually decay to become part of the soil. Large logs are a component to the nutrient cycling in the system. There is also some discussion of how significance is determined in the environmental impact statement. This page also discusses the contrasting opinions of how important the contributions of coarse woody debris are to the nutrient cycling processes. There are other considerations along with wildlife habitat and fuel loading that are also included in considerations to how much coarse woody debris is left. Forest Service Handbook 2509.25 and the forest plan provide direction for the amounts of debris to be left.

Special Interest Areas and Research Natural Areas (SIA)

Comment SIA – 1 Substantive plan components should be adopted for each special interest area to ensure that the values for which they are established are maintained and enhanced over the life of the plan. These plan components should be analyzed in the final environmental impact statement and included in the forest plan. Response Forest Service regulations allow the Regional Forester to designate special interest areas to protect a wide variety of resource values including botanical, geological, cultural, and historic (36 C.F.R. § 294.1). Drafting plan components that are tailored to each special interest area would significantly increase the complexity of the forest plan. Several

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commenters have urged the Forest to develop a simpler and more workable plan, and Revision Topic 3 noted the need to reduce the complexity of management areas. However, in response to the commenter’s request for additional guidance on management of special interest areas, the forest plan includes a management approach that signals the responsible official’s intention to prepare a management plan for each special interest area to provide focus on management to maintain, enhance, or restore the reason for creating a special interest area.

Comment SIA – 2 The forest plan should describe the primary values of the Spruce Hole/Osier/Toltec Special Interest Area, and specific meaningful desired conditions, standards, guidelines, and management approaches should be included. Response The primary value of the Spruce Hole/Osier/Toltec area is its role in enhancing habitat connectivity for large game species and carnivores. This area would also enhance ecosystem integrity related to the persistence of several species of conservation concern and other federally protected species. The forest plan does not recommend Spruce Hole/Osier/Toltec as a special interest area for a number of reasons. First, the wildlife values represented by the Spruce Hole/Osier/Toltec area are adequately protected through sections of the plan dealing with species of conservation concern; federally listed, proposed, and candidate species; and plants and wildlife. Goal 1 of the forest plan, along with multiple plan components throughout these sections, provides direction that will direct project-level planning and analysis to consider impacts on habitat connectivity. The second reason that the Spruce Hole/Osier/Toltec area was not included in the forest plan is because the creation of additional special interest areas would increase the complexity of management areas in contradiction of Revision Topic 3, which was included in the need for change.

Comment SIA – 3 Several commenters mentioned the proposed Chama Basin Watershed Protection Special Interest Area. Some noted the high potential for oil and gas development, while others urged protection of fish, watershed, and recreation values. Others wanted the area to accommodate vegetation management and motorized recreation. Response In addition to watershed protection, other values represented by the Chama Basin Watershed Protection area include opportunities for high quality backcountry recreation and habitat quality for species of conservation concern such as the Rio Grande cutthroat trout. The forest plan does not recommend Chama Basin as a special interest area. The recreational and fish habitat values represented by the proposed Chama Basin Special Interest Area are protected through multiple plan components. Also, nearly 90 percent of the area is currently designated as Colorado roadless, which the plan incorporates as a management area. This designation provides additional protections for the values represented by the Chama Basin area. Therefore, the values of the area receive additional protection without adding increased complexity in the forest plan. The importance of reducing management area complexity was identified in Revision Topic 3 and mentioned in several public comments. The final

136 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments environmental impact statement took these facts into account, along with the desires expressed by the public, and the responsible official concluded that designation as a special interest area was not necessary or practical to protect the resource values at this time.

Comment SIA – 4 Some commenters urged designation of several proposed special interest areas, including the Jim Creek Special Interest Area and Carnero Creek Special Interest Area to ensure preservation and restoration of the Rio Grande cutthroat trout, which is a management priority. Response The forest plan includes multiple plan components that constrain management activities to ensure the persistence of Rio Grande cutthroat trout. The responsible official concluded that designation of special interest areas in the Jim Creek and Carnero Creek areas is not needed to ensure species persistence and would unnecessarily increase management area complexity in contradiction of Revision Topic 3.

Comment SIA – 5 Oil and gas surface development should not be allowed in special interest areas. The forest plan should have enforceable provisions regarding oil and gas surface development to protect water and wildlife. Response The forest plan at SUIT-MA 4.1-3 makes special interest areas available for oil and gas leasing with no surface occupancy. This provision will limit impacts to water and wildlife on the surface of special interest areas. The forest plan also includes many other components that protect water and wildlife from negative impacts associated with management activities, including oil and gas development.

Comment SIA – 6 Please see the attachment for additional insight supporting the expansion of the Summer Coon La Ventana proposal. Response Please refer to the response for SIA-15.

Comment SIA – 7 The Summer Coon area should be protected from target practice to prevent further damage to archaeological resources. Response Target practice a use that is permitted on the Forest when it is not impacting public safety or causing resource damage. The Forest recognizes the importance of protecting and preserving archaeological resources. Closures or prohibitions are determined on a case-by-case basis and

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are therefore best considered at a site-specific level, versus in a strategic document such as the forest plan.

Comment SIA – 8 More should be done in the Summer Coon area to educate the public about local cultural resources like rock art, stone structures, ancient campsites, and the Old Spanish Trail. Response The Forest is committed to connecting the public with cultural resources, and recognizes the values within the Summer Coon area. Goal 3 of the Forest Plan notes the need to provide interpretive opportunities to increase public knowledge, provide historical background, and promote connection of the current people to the past and their land. This goal is carried over in a desired condition for cultural resources.

Comment SIA – 9 See attachment for a proposed Half Peak SIA. Response Public comment included designation of the Half Peak Research Natural Area. The comment identified this as one of only two occurrences for stonecrop gilia (Alicella sedifolia). The comment addressed the need to designate this area to “ensure that appropriate and necessary management actions would occur in order to protect this species and its known and potential habitat.” Stonecrop gilia is designated as a species of conservation concern by the Regional Forester. Forest plan direction associated with species of conservation concern for ecological conditions is necessary to maintain a viable population of the species in the plan area and does not limit taking any management actions to enhance or protect the species or its habitat. Appendix C identifies vulnerability to changes in temperature and precipitation regimes due to the loss of alpine habitat as the greatest threat to the species. The proposed area is within designated Colorado roadless and is afforded protections based on that designation as well. Creating a new research natural area on top of Colorado roadless is not consistent with Revision Topic 3 to reduce overall complexity of the forest plan.

Comment SIA – 10 Revision Topic 1: Special Designations is inaccurate, as it does not relate the need to consider special designations back to the additional areas submitted by the public. Response In the final environmental impact statement, Revision Topic 1 notes that public comments regarding changes to designated areas were addressed in the need for change. Special designations was included as a revision topic. During the plan revision process, special designations were considered based on internal staff recommendations and public comment during development of the need for change. The action alternatives in the final environmental impact statement considered a wide range of possible designations, with alternative D including the largest amount of special interest areas.

138 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment SIA – 11 No acreage is given in Table 28 of the DEIS on page 84 for the Cumbres and Toltec National Historic Landmark SIA. Response There are a total of 4,733 acres in the Cumbers and Toltec National Historic Landmark Special Interest Area corridor. This total has been added to the documents.

Comment SIA – 12 Please consider expanding the Elephant Rocks Special Interest Areas to the entire 22,000 acres submitted by the SLVEC to include the entire Summer Coon Volcano System. Response The boundary of the Elephant Rocks Special Interest Area was adjusted to include the Natural Arch/La Ventana geologic feature as an area of tribal importance. The Elephant Rocks Special Interest Area was expanded to include Natural Arch in the proposed action. The expanded area was largely based on tribal comments. The Ute and Jicarilla Apache consider the area sacred. The area considered covers the geologic feature and provides habitat for neoparrya (Astragalus cerussatus) as well as nesting habitat for peregrine falcons.

Comment RNA – 1 The Forest should address the Little Squaw proposed RNA from the 1996 Forest Plan. Response The Little Squaw proposed research natural area was analyzed for the 1996 forest plan revision process but not included in the 1996 Revised Forest Plan. The area is in the Weminuche Wilderness, which already provides for additional protections of the resources there. Designating a research natural area in wilderness would add complexity and is therefore not consistent with Revision Topic 3, which identified the need to simplify management areas.

Comment RNA – 2 The forest plan needs to be clear on how motorized use will be managed in Management Area 2.2; Table 12 differs from 2.2-S-1. Motorized use should be prohibited or restricted to designated routes to protect sensitive resources in these areas. Response Revisions have been made to the forest plan to clarify that motorized and mechanized use is prohibited in research natural areas, except when necessary for research or education access.

Vegetation (VEG)

Comment VEG – 1 A protective designation is needed for Ripley's milkvetch.

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Response The 1996 forest plan designated a special interest area for Ripley’s milkvetch in the southwestern portion of the Forest. Project-level analysis and surveys showed that the species was distributed in a much larger area than simply this special interest area. Ripley’s milkvetch is designated as a species of conservation concern and is covered by G-SCC-2: To maintain viability of species of conservation concern, roads and other permanent ground- disturbing structures and activities should not degrade vegetation within 100 feet of where plants that are listed as species of conservation concern are known to occur. Such barren or rocky areas include, but are not limited to, alpine fell fields, alpine cushion plant communities, talus slopes at any elevation, rock fields, boulder gardens, cliff faces, recently disturbed soils, exposed shale, gypsum, volcanic, or adobe soils, and other sparsely vegetated areas within other ecosystems. (Forestwide) This Forestwide direction will continue to maintain viability in the absence of a designated special interest area or other protective designation.

Comment VEG – 2 Plan components are not adequate to restore and maintain ecological integrity for the sagebrush ecosystem associated at-risk species. Gunnison sage-grouse, a threatened species, and Brewer’s sparrow, a potential species of conservation concern, require this habitat. Response The forest plan has several plan components that address ecological integrity of the sagebrush ecosystem and these associated species. These include: DC-TEPC-1: Maintain or improve habitat conditions that contribute to either stability or recovery, or both, for threatened, endangered, proposed, and candidate species. (Forestwide) G-TEPC-1: To avoid or minimize adverse effects to listed species and their habitat, management actions should be designed with attention to threatened, endangered, proposed, or candidate species and their habitats. (Forestwide) DC-SCC-1: Structure, composition, and function of sagebrush ecosystems meet the needs of associated species, including species of conservation concern. (Forestwide) G-SCC-3: To maintain viability of species of conservation concern, reduce habitat fragmentation and maintain structural conditions of sagebrush ecosystems through design of management activities. Patch sizes should not be less than 5 acres. (Forestwide)

Comment VEG – 3 The term “planning unit” is not defined in either glossary in the draft Plan or DEIS, or in the 2012 Planning Rule. This term has been used previously to mean the national forest unit for which a plan applies, like the Rio Grande National Forest. This needs to be clarified, but if the criteria in Table 5 in the plan are meant to apply to the entire Rio Grande National Forest, the direction is meaningless at the project level. The term "planning unit" should be "treatment area" and further defined as to the meaning.

140 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments There is a need to clarify what "planning unit" means, to offer rationale for this change in scale, and to add this to the comparison of effects of each alternative. There is a need to include justification for increased snag and down wood retention amounts. There is concern that even though it states the amounts are to be calculated as a per-acre average over a project area, that it will be implemented on only those acres that are treated (as was the case on the Conejos Peak Salvage project). Clarify and perhaps give an example on how these retention amounts will be calculated. DC-VEG-1. In Table 5 (Draft Plan at 37), we note the bracketed detail under the title of the table, "Quantities are based on an average per acre basis across the planning unit." What "planning unit" means must be specified. Does this mean across the plan area, the entire Forest or project area or different unit or scale? Desired distributions must be in the plan and should be applicable to project implementation. We disagree with some of the snag targets in Table 5. See Appendix 2: Snags and Downed Wood Targets. DC-VEG-1 - Snag and down wood retention amounts should apply to the harvest unit not just the planning unit. Response The direction previously included as DC-VEG-1 is now a guideline – G-VEG-1. A “planning unit” is defined as the area planned for treatment as identified in a project-level decision document. This term has been added to the glossary of the plan. “Planning unit” was deliberately used as it best addresses the concern regarding snags. As described in the final environmental impact statement (pp. 88-89), the average number of large snags has increased over time, especially since the spruce beetle outbreak started, and the Forest also has a large volume of downed woody material. As stated in the final environmental impact statement, although the snag and downed wood retention in alternatives B, B Modified, C, and D applies to the planning unit instead of the smaller project area (as in alternative A), the additional snag and downed wood plan components and generally higher snag retention amounts in the action alternatives, as well as determinations made at the project level, would help ensure that large openings created during salvage have sufficient amounts of snags and downed wood.

Comment VEG – 4 Table 12 on page 38 of the Terrestrial Ecosystems Assessment should also include downed wood requirements by density. A standard or guidelines must be developed to constrain vegetation management activities that impact snag and downed wood retention. The desired condition for retaining a minimum amount of snags and downed wood should be a standard or guideline. There should be a designated minimum amount of dead wood remaining for each area with timber harvested. Snag recommendations are insufficient for species such as American marten and boreal owl. Response Snags and downed wood retention are addressed in the forest plan direction at G-VEG-1 and Table 8. This table lists the minimum requirements for snags and downed wood that need to

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be maintained when implementing management activities. Assessments were used to inform these final documents. As described in the final environment impact statement (pp. 88-89), the average number of large snags has increased over time, especially since the spruce beetle outbreak started, and the Forest also has a large volume of downed woody material. We understand your suggestion to include downed wood requirements by density to mean that you would like additional downed wood retention requirements in terms of pieces per acre, as this was an additional metric used in the assessments. Comments were received suggesting that the draft forest plan components are too complex or difficult to implement, and adding additional downed wood requirements such as this would exacerbate that concern. Wildlife biologists and vegetation managers consulted the best available science in determining the amounts presented. The direction in the forest plan provides guidance that can be exceeded at the site-specific level following on-the-ground analysis and determinations. For instance, project-level analysis for vegetation management projects may include additional design features related to snags and downed woody material when needed.

Comment VEG – 5 There needs to be a guideline providing for the establishment of limitation on how much of any forest product can be removed, per person and/or per time period, to reduce adverse effects on ecosystems and to ensure the product is available to everyone. Response Forest products are managed by Forest Service Manual 2430, Rio Grande Supplement 2400- 2011-1. This supplement limits how much one person and/or household can remove of a particular Forest product on a yearly basis. Most forest product removal is authorized under a permit system that also tracks the amount of forest products sold. Each product may have a different limitation for amount or value. As an example, the Rio Grande Supplement allows for permitting personal use firewood up to 20 cords or $200 in value per year per person or each household can be permitted up to 5 Christmas trees per year.

Comment VEG – 6 The draft environmental impact statement fails to consider alternatives that would reduce the area suitable for timber production to provide additional protections for watersheds and ecosystems. Response The area suitable for timber production varies among the four alternatives. Appendix B in the final environmental impact statement and Appendix C in the forest plan provide details on the process used to determine lands suitable for timber production. Table 39 in the final environmental impact statement shows a range of land that is suited for timber production, from 320,567 acres in alternative A to 480,683 acres in alternative C. These values range from 64 percent to 96 percent of the lands that may be suited for timber production. This also equates to 17 to 27 percent of the total Forest land base. This is a reasonable range of area allocated to timber production for consideration.

142 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Plan components that protect watersheds can be found in the Watershed section, and all of these apply Forestwide. Plan components that protect ecosystems can also be found in several other sections, such as the Vegetation and Soils sections. Project-level analysis for timber harvesting and other vegetation management projects will consider site-specific concerns and may offer additional protections for watersheds and ecosystems. For example, site-specific projects often include design features or project-specific mitigation measures to reduce environmental impacts.

Comment VEG – 7 The long-term sustained yield quantity is much too high and violates the letter and intent of Forest Service Handbook 1909.12 chapter 60. The levels of timber harvest proposed in all the alternatives is excessive. Response The calculation of long-term sustained yield is readily available and disclosed in the analysis and follows Forest Service Handbook 1909.12 Chapter 60. The forest plan standard S-Veg-7 presents the sustained yield limit value of 737,490 CCF per decade. This timber volume is based on the lands that may be suited for timber production (499,936 acres), as described in Appendix C. This is an estimated 14.7 cubic feet per acre per year of volume accrual on average. Timber volume yield determinations have been studied extensively for many years. Several prior publications were consulted to determine if the 14.7 CF per acre per year value is comparable to values presented in those studies. Meyer, Yield of Even-aged Stands of Ponderosa Pine, USDA Technical bulletin 630, October 1938 Table 10 (forest plan) shows cubic foot volume per acres, including stump and tip but not bark, of trees 6.6 inches and more in diameter, on the lowest site (40) and at age 200 averages 16.5 cubic feet per acre. In Stage, Renner, and Chapman (1988), Selected Yield Tables for Plantations and Natural Stands in Inland Northwest Forest, Research Paper, INT-394, Table 1-Yields of naturally regenerated stands in the grand fir cedar-hemlock ecosystem, for the lowest site (40) at age 150 the average merchantable volume is 12.78, at site 50 it is 31.38. In Table 7-Yields of grand fir plantations having 500 trees per acre surviving 5 years, no thinning, the average volume yield at 10 50 onsite 50 is 78.3 merchantable cubic feet per acre. In Alexander and Edminster, 1980, Management of Spruce-Fir in Even-Aged Stands in the Central Rocky Mountains, Research Paper RM·217 Rocky Mountain Forest and Range Experiment Station from Table 1.-Estimated total cubic-foot volume production per acre of spruce-fir In relation to growing stock level, site index, rotation age, and cutting cycle, with a clearcut option the average volume production for site index 50, growing stock 40 at age 160 is 20.65 cubic feet per acre per year. And in Meyers 1967, Yield Tables for Managed Stand of Lodgepole Pine in Colorado and Wyoming, USDA Forest Service Research Paper RM-26, Table 5-Yields per acre of

143 USDA Forest Service managed, even-aged stands of lodgepole pine in Colorado and Wyoming, site index 40 at age 120 an average final volume of 14.4 merchantable cubic feet per acre/year after removals. All of these sources show that an average volume growth of 14.7 cubic feet per acre per year for the sustained yield limit is the capability of the lowest site timber lands and that the sustainable yield limit is well within the expected volume production of these lands. The level of timber harvest is within the wood producing capabilities of the forested landscape. The proposed harvest levels are less than those described in the 1996 forest plan as shown in Figure 1 below.

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Figure 1. Comparison of annual forest products production estimates between the 1992 plan, 2017 DEIS, and 2019 FEIS

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Comment VEG – 8 The proposed salvage in the first decade is unrealistically high. Response The rate of deterioration of the standing dead spruce has been higher than initially expected. The estimated salvage volume for alternative B Modified incorporated this, with the estimated salvage program lasting only 5 years, rather than 6 to 10 years, and with the estimated salvage volume reduced overall.

Comment VEG – 9 The landscape level challenges reported in the recent Colorado State Forest Service report must be addressed with landscape level management. Response The 2016 Report on the Health of Colorado’s Forest (https://csfs.colostate.edu/media/sites/22/2017/03/CSU_304464_ForestReport-2016- www.pdf) is assumed to be the report being cited. The 2017 report was released after the close of the draft environmental impact statement and draft forest plan comment period. The executive summary discloses that portions of the report were prepared using data jointly gathered by the U.S. Forest Service and the Colorado State Forest Service. These data are available to the forest plan revision team and were used in the preparation of the forest plan and associated environmental impact statement. The challenges presented in the 2016 Report: Wildfire, Insect and Disease outbreaks and Water need to be addressed during the planning process. The plan includes various components about these challenges throughout the document starting at the highest level. Goal 2 – Protect and restore watershed health, water resources, aquatic ecosystems and the systems that rely on them and Goal 1 – Maintain and restore sustainable, resilient terrestrial ecosystems guided the development of more specific plan components. Desired conditions for fire management are concerned with landscape-level wildfire concerns. Direction related to management of insects and disease is dispersed throughout the forest plan. Watershed desired conditions are also designed to address landscape-level water management.

Comment VEG – 10 Management direction must be focused on the major challenges for the Forest to address the issues; no new management standards should make timber management more difficult or impossible. In consideration of the impacts of restrictive management on the pine beetle response, restrictions on active management of Rio Grande resources must be questioned.

146 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response Management direction needs to be focused on the challenges that the Forest faces as well as designing in flexibility to address unknown challenges that will occur in the future. The importance of vegetation management regarding its role in managing fire risk and watershed health and contribution to the local economy is also recognized. Given comments on the draft forest plan, plan components were simplified, combined, or deleted. Some were added. Alternatives B, B modified, C, and D all have areas suitable for timber production that are larger than those in the 1996 forest plan. The environmental impact statement discusses the active vegetation management in the Forest Products section of Chapter 3. About 72 percent of the Forest is withdrawn from timber production due to legal or technical factors, such as areas in designated wilderness or areas where there is no reasonable assurance that the lands can be adequately restocked. Other restrictions in the forest plan were included based on an interdisciplinary approach incorporating the best available science to create and maintain healthy forested ecosystems and necessary to meet the ecological integrity and other requirements of the 2012 Planning Rule.

Comment VEG – 11 All efforts must be made to mitigate the dead biomass that has resulted from extensive die- offs for forest health, economic benefit, and future access. Response Goal 3 of the forest plan states that the Forest contributes forest products that are important to local economies. Alternatives B, B modified, C, and D all have areas suitable for timber production that are larger than those in the 1996 forest plan.

Comment VEG – 12 Designation of “may be suitable for timber production” land in alternative B will invite big corporations to come and destroy the area. Response The Forest recognizes that the timber industry is a valuable partner in important work with multiple benefits including fuels reduction, watershed protection, and wildlife habitat creation. The National Forest Management Act (1976) requires designation of lands that are suited for timber production. The analysis process determined lands that may be suited for timber production to ensure that only those lands that are physically capable of sustaining commercial timber production without deleterious effects to the environment are included. Specific details are in Appendix C of the forest plan. Forest plan components along with Forest Service handbooks and manuals and watershed best management practices guide project design and implementation to avoid harm and mitigate damage. Project-level analysis for timber harvesting and other vegetation management projects will consider site-specific

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concerns and may offer additional protections. For example, large projects often include design features or project-specific mitigation measures to reduce environmental impacts.

Comment VEG – 13 Convert DC-VEG-2 to a Guideline. Critical for ecological foundation and ecosystem integrity but a Guideline would also provide flexibility. Deviation range is already built into Table 6. Response This plan component has been deleted from the Vegetation section, but the concept of timber harvesting meeting multiple objectives appears in other sections. For example, a management approach in the Scenery section, states “Management practices are designed to produce forest composition, structure, and patterns similar to those that would have occurred under natural disturbance regimes, where feasible.”

Comment VEG – 14 This was a Standard in the original VEG S7 agreed to by USDI Fish and Wildlife Service. No need to repeat if it gets back in there, otherwise convert to a Guideline. Response We believe this is in reference in DC-VEG-4 in the draft forest plan. This desired condition has been deleted. Some similar language is included in the lynx management approaches (During salvage project design, late-successional forest patches that are expected to remain green or mostly green in the next 15 years are identified for retention during project implementation. Foresters and wildlife biologists determine the optimal landscape heterogeneity objectives that include retention, opening patch size, and configuration. Project objectives should be considered at a watershed or sub-watershed scale, using the best available science.)

Comment VEG – 15 Convert DC-VEG-5 to a Standard or Guideline. Range and flexibility is already built into Appendix A table. Response This direction repeated other direction and has been removed.

Comment VEG – 16 Convert DC-VEG-8 to a Guideline. This is essential for ecosystem integrity, diversity, connectivity, and habitat in many aspects. Response This plan component and associated table describes the desired distribution of structural stages. The 2012 Planning Rule states that “a desired condition is a description of the specific social, economic, and/or ecological characteristics of the plan area, or a portion of the plan area, toward which management of the land and resources should be directed. (36 CFR

148 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments 291.7(e)(1)(i). As written, this plan component is appropriate as a desired condition rather than a guideline.

Comment VEG – 17 Add second sentence to DC-VEG-9, "Refer to applicable species guidelines for best available science." to reference. DC-VEG-18 - This provision is not described in a way to allow an assessment of progress toward its achievement during monitoring. It is not clear if this desired condition applies to riparian management zone only or to other areas and ecosystems of the forest. This desired condition is written like a standard, and it should be a standard because it provides a constraint on activities, e.g., vegetation management, that impacts necessary snag elements of forest ecosystems. See Appendix 2: Snag and Downed Wood Targets and Appendix 3: Salvage Logging Impacts. Response Given other concerns, plan components were deleted, simplified, or combined. Some new plan components were added based on public comment. Desired condition DC-VEG-9 has been deleted. However, G-VEG-1 provides direction for snags.

Comment VEG – 18 Regarding MA-VEG-2, along with the information coming out of the lynx study, existing FS VEG data indicate that there already is a tremendous conversion to aspen occurring underneath Spruce-Fir. There will soon be an excess of aspen. That needs to be mentioned and considered somewhere. Response This issue is not specifically incorporated into the forest plan through a plan component. However, the distribution of cover types will be monitored over time (see Monitoring Question 7 (MQ7)), and this monitoring will identify whether there is an excess of aspen across the Forest.

Comment VEG – 19 Convert MA-VEG-6 and MA-VEG-7 to a Guideline. It is essential for ecosystem integrity, SCC, and numerous goals stated elsewhere in the plan. Response The desired amounts of various structural stages, including old forest, are incorporated into desired conditions. This, in combination with these two management approaches, provides sufficient direction for and maintenance of this resource. In addition, a management approach in the Threatened, Endangered, Proposed, and Candidate Species section states “During salvage project design, late-successional forest patches that are expected to remain green or mostly green in the next 15 years are identified for retention during project implementation.”

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Comment VEG – 20 S-VEG-5 seems like methodology, it would be better written as a management approach. S-VEG-5 is not written in a way that complies with plan direction for standards in the planning rule. The plan requires a desired condition linked to this standard. The set of plan components pertaining to clearcutting should: define “optimum method,” describe the conditions for which clearcutting would be appropriate, and references the “desired conditions for vegetation, wildlife habitat, scenery, and other resources” so the linkages are clear. The DEIS must address the potential conflicts between clearcutting and other uses, including at-risk wildlife and plan recovery and viability. Response Forest plan standard S-VEG-5 is a required standard in the 2012 Planning Rule, as described at 36 CFR 219.11(d)(5) and in the Land Management Planning Handbook - FSH 1909.12, Chapter 60, sections 64.22 and 64.23. Language has been clarified in this plan component to include “following interdisciplinary review” and it now states: S-VEG-5: Clearcutting may be used where it has been determined to be the optimum method, and other types of even-aged harvest shall be used only where determined to be appropriate following interdisciplinary review. Determinations shall be based on site-specific conditions and the desired conditions for vegetation, wildlife habitat, scenery, and other resources. (Forestwide) Language in standard S-VEG-5 indicates that these determinations shall be based on site- specific conditions, following interdisciplinary review, and are more appropriately handled at the project level. Given that this is a programmatic analysis, a detailed examination of this issue and the associated cost is not warranted for the responsible official to make a reasoned choice among alternatives.

Comment VEG – 21 Third bullet in S-VEG-6: inform the public how salvage treatments apply to this Standard regarding openings. The reference for the definition and size of created openings needs to be included. Please be specific about the intent of this standard. Response Forest plan standard S-VEG-6 is a required plan component under the 2012 Planning Rule, as described at 36 CFR 219.11(d)(4) and in the Land Management Planning Handbook - FSH 1909.12, Chapter 60, section 64.21. “Created Openings” are defined and described through a management approach in the Vegetation Section. This management approach states “Management-created openings are no longer considered openings when the trees reach a height and density that meet management objectives. The default criteria are when the minimum stocking standards for the forest vegetation type on suitable lands are met and average height is 6 feet or greater with at least a 70-percent distribution for conifer species, and 10 feet or greater with at least a 70-percent distribution for aspen. The criteria is validated and may be modified in accordance with local conditions.” Salvage treatment openings larger than 40 acres may be created as they are

150 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments harvested as a result of natural catastrophic conditions. This exception is described at 36 CFR 219.11(d)(4) and in the Land Management Planning Handbook - FSH 1909.12, Chapter 60, sections 64.21c.

Comment VEG – 22 Add information on how timber management activities have the potential of introducing invasive species and the associated cost. Response The final environmental impact statement recognizes that alternatives that propose increased amounts of timber harvest and any associated road construction or reconstruction would increase the amount of nonnative species present on the Forest (pp. 161, 163). Project-level analysis for timber management activities will consider site-specific concerns and may offer additional protections for invasive species. For example, projects may include design features or project-specific mitigation measures such as washing equipment. Given this is a programmatic analysis, a detailed examination of this issue and the associated cost is not warranted for the responsible official to make a reasoned choice among alternatives.

Comment VEG – 23 Clarify the criteria used to determine old forest. Please include the “local knowledge and judgment” used for the Old Forest Criteria and the justification for any changes. Response The criteria used to determine old forest is found in the Plan, Appendix A. This criteria is based on the regional guidelines, which were originally based on Mehl (1992), and incorporated some slight modifications based on local expert opinion. The regional guidelines are shown in Table 6 and were taken from Appendix D of the R2 FSVEG Spatial Tool 5 User Guide – Calculate Old Growth Attributes and Status from CSE Tree Data (dated 3/1/16).

Table 6. Regional guidelines for old forest criteria

Rotten Cull Criteria Age Qmd Large Trees and Dead Snags Layers Tops Local Type Ponderosa Pine >= 200 >= 16 inches >= 10 per acre >= 1 / acre >= 2 / acre Not Used Mixed Conifer >= 200 >= 16 inches >= 10 per acre >= 1 / acre >= 2 / acre >= 2 / acre Spruce/Fir >= 200 >= 16 inches >= 10 per acre >= 1 / acre >= 2 / acre >= 2 / acre Aspen >= 100 >= 14 inches >= 10 per acre >= 1 / acre Not Used Not Used Lodgepole Pine >= 150 >= 9 inches >= 10 per acre >= 1 / acre >= 2 / acre Not Used

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Laurie Swisher, Regional Vegetation Applications Program Manager, indicated that these guidelines were adjusted to reflect conditions on the San Juan National Forest (email communication). The changes made on the San Juan were to change the minimum dbh from 18 to 16 inches for both mixed conifer and ponderosa pine. Also, for ponderosa pine, the Front Range criteria, rather than Southwest criteria, were used, which included a 16-inch minimum dbh and minimum age of 200 years. The Forest agreed with the change in minimum dbh to 16 inches for ponderosa pine and mixed conifer, but used a minimum age of 175 years, a value in between the values in Mehl (1992) for Front Range ponderosa pine (200) and Southwest ponderosa pine (160). The Rio Grande National Forest also added minimum downed wood values for spruce-fir and mixed conifer. In Mehl (1992), it is indicated that old growth forest in these two vegetation types has some downed wood, but it doesn’t list specific amounts. The Forest, based on the professional judgement of the interdisciplinary team members, assigned a minimum of 10 tons per acre for spruce-fir and 5 tons per acre for mixed conifer. Finally, the criteria was for pinyon-juniper, which had not been included in the regional guidelines, based on the information in Mehl (1992). The final old forest criteria, as indicated in Appendix A of the forest plan, is listed in Table 7.

Table 7. Criteria used to determine old forest

Ponderosa Mixed Minimum Attributes Spruce/Fir Aspen Pinyon-Juniper Pine Conifer Age 175 200 175 100 200 12 (diameter at root DBH (inches) 16 16 16 14 collar) 30 (diameter at root Large trees/ac >= DBH 10 10 10 10 collar) Rot + dead/broken tops per 1 1 1 1 1 acre Snags per acre 2 2 2 n/a 1 Layers (#) n/a 2 2 n/a n/a Downed Woody Material n/a 10 5 n/a n/a (tons/acre)

Comment VEG – 24 DC-VEG-5: This desired condition must describe the necessary conditions to sustain the at- risk species, and those species must be articulated. The conditions must be measurable, and based on the best available scientific information. Appendix A is over 25 years old, and contains an important note on the first page of the report on the Forest Service’s webpage to which the report is linked (https://www.fs.fed.us/rm/pubs_series/rm/gtr/rm_gtr213.pdf), which states, This is a legacy archive publication from the former Intermountain Research Station or Rocky Mountain Forest and Range Experimental Station. The content may not reflect current scientific knowledge, policies, or practices. This statement indicates that the old growth criteria listed in the report may not reflect best available scientific information. The Forest must justify and document why this report is considered in the best available scientific information and not newer information. This report includes 22 chapters; from which chapter(s) did Appendix A's recommendations come from?

152 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response Desired condition DC-VEG-5 has been removed in the forest plan. Desired conditions for late-successional and old forest habitat are described in Table 7. The criteria for old forest are described in response to comment VEG-24. As stated in Forest Service Handbook 1909.12 – Land Management Planning Handbook – Zero Code, 07.12, “The Preamble of the planning rule makes clear that there is a range of information that can be considered to be the best available scientific information, with specific reference to expert opinion, panel consensus, or observations: In some circumstances, the best available scientific information would be that which is developed using the scientific method, which includes clearly stated questions, well-designed investigations and logically analyzed results, documented clearly and subjected to peer review. However, in other circumstances the best available scientific information for the matter under consideration may be information from analyses of data obtained from a local area, or studies to address a specific question in one area. In other circumstances, the best available scientific information also could be the result of expert opinion, panel consensus, or observations, as long as the responsible official has a reasonable basis for relying on that scientific information as the best available.” (77 FR 21192 (April 9, 2012)) As described in a previous comment response, the old forest criteria is based on the regional guidelines, which were originally based on Mehl (1992), and incorporated some slight modifications based on local expert opinion. Mehl (1992) is the 12th chapter in the referenced GTR – GTR-RM-213. This chapter is titled “Old-Growth Descriptions for the Major Forest Cover Types in the Rocky Mountain Region” and starts on page 106.

Comment VEG – 25 Plan, pg. 39 – Table 6 – We support use of this kind of table for identifying desired forest vegetation conditions. We request that you also include a description of how current conditions were measured, how the Desired Condition percentage was developed, and how that compares to the natural range of variation. Clarify the rationale behind the desired amounts of and the difference between late- successional and old forest conditions. There is a need to clarify rationale behind desired amounts/conditions of late-successional forest. The plan documents must clearly document the BASI that supports the desired conditions presented in Table 27 (DEIS at 74). Response Current conditions were estimated based on the corporate spatial vegetation data layer (FSVEG Spatial) in March 2017. Consistent with the terrestrial ecosystem assessment, late-successional forest is defined as structural stages 4B and 4C (with the exception of pinyon-juniper, in which case there is no 4C). Habitat structural stage class 4B corresponds to areas with mature trees (9 inches and larger) with 40- to 70-percent canopy cover. Habitat structural stage class 4C corresponds to

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areas with mature trees (9 inches and larger) with more than 70-percent canopy cover. Old forest is defined using the criteria in Appendix A of the forest plan. The desired condition amounts of late-successional forest (FEIS table 27, plan DC-VEG-4 and Table 7) were based on modeling done as part of the terrestrial ecosystem assessment to examine the natural range of variation. The desired condition amounts in some cases were based on values found in the San Juan National Forest plan and the professional judgement of the team members, especially in cases where no assessment modeling results were available. Adjustments were made, rather than model results used exactly, in some cases to factor in a desire for more open, less dense, stands for higher resilience to climate change. Cool-dry mixed conifer was adjusted to account for the species and drier, less productive conditions found there. As stated in FSH 1909.12 – Land Management Planning Handbook, Chapter 10, 12.14a, while a description of the natural range of variation provides insight into the temporal dynamics and key characteristics of an ecological system and provides context for assessing whether an ecosystem has integrity, the natural range of variation does not represent a management target or desired condition. As stated in FSH 1909.12 – Land Management Planning Handbook – Zero Code, 07.12, “The Preamble of the planning rule makes clear that there is range of information that can be considered to be the best available scientific information (BASI), with specific reference to expert opinion, panel consensus, or observations.

Comment VEG – 26 Appendix C – Timber Suitability and Analysis – Table 20 – we request that you show more details on how suitable acres were calculated for each alternative. Response The details regarding how the suitable timber acreage was determined for each alternative are described in Appendix C of the forest plan. The first part of the process is to determine the lands that may be suited for timber production. During this step, lands not suited for timber production based on legal and technical factors are identified and these acres are removed from suitability. This includes lands on which timber production is prohibited and lands withdrawn from timber production, as well as lands on which technology to harvest timber without causing irreversible damage is not currently available, lands on which there is no reasonable assurance of adequate restocking within five years of the final regeneration harvest, and nonforest lands. Areas identified as not suited for timber production in this step are outlined on the first page of Appendix C. The second step removes from suitability lands where timber production is not compatible with the desired conditions and objectives for an area. Areas identified as not suited for timber production in this step are outlined near the end of Appendix C.

Comment VEG – 27 The Forest has not consistently used the same classifications for ecosystem types, and this is confusing. We're concerned that the different units of analysis have resulted in multiple findings that are difficult to interpret.

154 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Draft forest plan, pg. 36, VEG write-up, first paragraph. Aspen ranks way up there and is much higher acreage than Pinyon-Juniper or mixed conifer. Edit the text to reflect this. Response The understandable confusion in this case is that the ecosystems used in the assessments did not include aspen as its own category, but as a component of other ecosystems such as spruce-fir forest mix and mixed conifer-wet. Two tables have been added to the plan that better describe the ecosystems used in the assessments and how they crosswalk to the cover types in the Forest Service corporate vegetation data.

Comment VEG – 28 Draft forest plan, Pg. 93, BASI, 1st paragraph - Accuracy of our Forest Inventory and Analysis data is variable by system. For example, only spruce-fir correctly attains adequate snag samples. Ponderosa pine does not. Need to note this using our own data to demonstrate using best available scientific information. Response Forest Inventory and Analysis data were used to assess snag levels in the Terrestrial Ecosystem assessment. Information regarding the specific number of Forest Inventory and Analysis plots by vegetation type is found there.

Comment VEG – 29 We recommend including information on the new Trinchera Forest Products mill on p. 128. This drastically increases capacity in the area. Response The Trinchera Ranch sawmill is captured in the Timber (Including Non-Timber Forest Products) section of the Multiple Uses and Ecosystem Services section. As noted there, “A new mill in Costilla County (currently utilizing timber from within their own property) was also included due to its potential to utilize timber from the Forest in the future.” The new mill referenced in this section is the Trinchera Ranch sawmill. Therefore, no updates have been made.

Comment VEG – 30 Draft environmental impact statement Table 21 should include the amount of “snow, rock, or other non-vegetated cover.” It is confusing that the Table does not add up to the entire acreage of the Forest. Response The footnote on Table 21 clearly indicates that the total acreage listed does not include areas with snow, rock, or other non-vegetated cover. The total acreage of the Forest is approximately 1,837,000 acres. Snow, rock, or other non-vegetated cover makes up about 6 percent of this, as echoed in Table 23 of the final environmental impact statement.

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Comment VEG – 31 There is a need to clarify the definition of resilience used and ensure it matches planning directives. The draft environmental impact statement states, “Resistance and resilience of vegetation are important concepts as they relate to integrity and sustainability of the ecosystem in the face of future uncertainties” and then goes on the use a definition of resilience provided by Holling (1973) (DEIS at 62). The planning directives include a definition for resilience (FSH 1909.12, Ch. Zero Code, 05). What is the justification for the Forest choosing an alternative definition? This is one of the many ways the draft plan deviates from the planning rule and directives that we find perplexing. Response The forest plan is consistent with the requirements of the 2012 Planning Rule. Adjustments to better align with the Rule have been made between the draft and final; many of these were suggested through public comment.

Comment VEG – 32 Draft environmental impact statement, chapter 3, we recommend including language in paragraph 1 on p 91 that given the fact that the Forest only manages about 17-27 percent of the Forest, there is incredible opportunity on those acres to achieve desired conditions. In some places, the managed acres may provide not only the best habitat, but also safety for communities and protection of watersheds. Response The language in this paragraph is sufficient as is. It highlights that progress toward the desired conditions in some vegetation types, such as mixed-conifer and ponderosa pine, will be highest in alternative C, since this alternative has the highest level of planned vegetation management in these types, but also emphasizes that while planned management is different across the four alternatives, the distribution and diversity of vegetation structural stages across the Forest is predominantly determined by ecological succession and disturbances such as fire, insects, and disease, rather than by planned management activities.

Comment VEG – 33 Draft environmental impact statement, chapter 3. Recommend including language on the conditions that have allowed the current spruce beetle epidemic to grow as big as it has (ex. monoculture of spruce with very little age and size diversity). Response There are benefits to having age and size diversity, and we feel that the benefits of having diverse vegetation are adequately discussed. For example, the final environmental impact statement on page 75 states “Diversity of vegetation – Maintaining a diversity of ecosystems and structural types provides the various habitats needed by the many species that use the Forest and will help ensure resiliency in the face of environmental disturbances and changes.”

156 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment VEG – 34 We recommend that you delete “All vegetation management is sustainable” in the 3rd paragraph on page 70. We are big advocates for sustainable forest management in green forests, but that concept simply does not apply to a dead forest. We recommend you change the last sentence in paragraph 2 on p. 70 to “Vegetation is managed for wood production and to benefit other resources.” Response We believe you are referring to the last two paragraphs of the General Forest Geographic Area Management Approach Summary (pg. 70 of the draft forest plan). These paragraphs are not included in the forest plan.

Comment VEG – 35 The proposed changes in lynx direction are unclear. The rationale, effects, and best available scientific information for these changes need clarification. Response The proposed changes in lynx direction have been updated based on the preliminary results of a new research study (FEIS pg. 16). The latest direction can be found in the Threatened, Endangered, Proposed, and Candidate Species section of the plan.

Comment VEG – 36 We cannot find any sources of best available scientific information that supports vegetation management plan components in any planning documents. The effects analysis related to insects and disease does not distinguish between forest ecosystem types to enable an understanding of the different impacts of management (or no active management) on different forest types. Pollinators should be considered. Response Vegetation management activities such as thinning, regeneration harvests, and prescribed fire will be applied and governed by plan components, including, but not limited to, those in the Vegetation and Fire sections. Impacts to pollinators when applying pesticides is covered by guideline G-SCC-1: G-SCC-1: To maintain ecological conditions to support a viable population of species of conservation concern insects and plants, minimize negative impacts to pollinators when applying pesticides. (Forestwide) Management approaches in the Species of Conservation Concern section describe application of pesticides: Forest programs mitigate impacts to insect species that are listed as species of conservation concern and their habitat, or that are necessary to those species as pollinators or as food, from applications of insecticide or other pesticides. To inform project-level planning on avoiding impacts to these species, the range and

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distribution of at-risk insect species (threatened, endangered, proposed, or candidate species and species of conservation concern) is assessed. Forest programs mitigate impacts to plant species that are listed as species of conservation concern and their habitat, or that are necessary for those species as food (including grazing, forage, and nectar for pollinators) or cover, from herbicide or other pesticides). A management approach in the Wildlife section discusses pollinator-friendly best management practices and mitigating impacts to pollinator insects when applying insecticide. Federal statutes applicable to forest management include the Federal Insecticide, Rodenticide, and Fungicide Act, as listed in Table 25 of the forest plan. These activities are adequately governed by plan components and other plan direction. In addition, project-level analysis will consider site-specific concerns and may offer additional protections.

Comment VEG – 37 The draft environmental impact statement and additional plan documents have explained that the science cannot provide certainty regarding whether or not the spruce beetle outbreak has pushed the spruce-fir forest type outside the natural range of variability. The Forest acknowledges that tree stress and mortality from insect and disease is natural and important for maintaining the ecological integrity of forested systems. Despite this, the draft environmental impact statement seems to be making the assumption that not actively managing forest systems puts them at “risk,” given the language in the draft environmental impact statement pg. 99 - “Alternatives that increase the amount, extent, or tree density of mature development stages would generally increase the risk of insect outbreaks or widespread disease. As a result of lower management rates, alternative D would have a greater likelihood of an increased amount and extent of mature, dense forest, and would therefore result in a slightly greater risk for insect outbreaks, or widespread disease, than other alternatives.” Does this mean at risk of losing resilience or something else? This needs to be clear. Perhaps the statement should use the term "probability" instead of "risk." Regardless, the analysis of effects is inadequate. Response The Terrestrial Ecosystem Assessment recognized that “While these insects and diseases are natural disturbance agents beneficial to the creation and maintenance of many ecological functions for wildlife species, high amounts or outbreaks may be damaging to other habitat components.” It also noted that the susceptibility of stands to insects and disease such as spruce beetle, mountain pine beetle, and Douglas-fir beetle is dependent on stand structure attributes such as size and density. The Final environmental impact statement (p. 77) recognizes the challenge that insects and disease outbreaks pose to forest management, with statements such as “Insect and disease outbreaks are major ecological processes that shape forest conditions. Without the influence of “change agents” such as fire, insects, and disease, forest vegetation would stagnate and eventually become homogeneous, which would decrease biodiversity and resilience to

158 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments disturbance. These change agents are an integral part of forest ecosystem processes, but still pose a challenge to forest management.” In addition to the section referenced in your comment, this topic is also expanded upon in the final environmental impact statement (p. 114): “Given integration of insect or disease management with silvicultural prescriptions for vegetation management to meet a variety of goals and objectives, impacts across the alternatives would correspond closely with acres thinned, harvested, or burned, especially those acres managed within the mixed-conifer and ponderosa pine type. These acres do vary by alternative, but are small in context with the total area in these vegetation types. The effects from insects or disease would tie more closely with forest conditions and affecting factors than from actual management activities. The forest condition and affecting factors include: 1) amount, extent, and susceptibility of host habitat, 2) insect or disease levels (extent and populations/infection rates), 3) climate, and 4) disturbance.”

Comment VEG – 38 The draft environmental impact statement (at 100) states, “Action alternatives reduce the minimum stocking levels for ponderosa pine and Douglas fir from alternative A. The lower density values are more aligned with the natural range of variation for these species and increase resilience to stressors such as climate change, insects, and diseases. Silvicultural systems by cover type were also expanded in alternatives B, C, and D. Other plan components that are applicable to the action alternatives are contained in the Rio Grande National Forest Draft Revised Land Management Plan. All alternatives include guidance that should produce conditions similar to those that occurred under natural disturbance regimes …” The analysis is based on an assumptive leap not supported by best available scientific information in the planning documents. The analysis suffers from the other similar problems discussed elsewhere (e.g., no assessment of the effects of plan components). Response One change in the action alternatives is a reduction in the minimum stocking levels for ponderosa pine and Douglas fir. These lower density values are also more aligned with the NRV of these species, which were often found in more open conditions due to the more frequent fire regimes of these types. Two relevant references include in the Terrestrial Ecosystem Assessment include Romme et al. 2009 and Fulé et al. 2009: Romme, W. H., M. L. Floyd, D. Hanna. 2009. Historical range of variability and current landscape condition analysis: South central highlands section, southwestern Colorado and northwestern New Mexico. Report produced by the Colorado Forest Restoration Institute at Colorado State University and Region 2 of the U.S. Forest Service. Fulé, P. Z., J. E. Korb, and R. Wu. 2009. Changes in forest structure of a mixed conifer forest, southwestern Colorado, USA. Forest Ecology and Management 258:1200–1210. As described in the final environmental impact statement, under all alternatives there is guidance that management practices should produce conditions similar to those that occurred under natural disturbance regimes, with the exception that openings larger than 40 acres are not allowed unless one of the exceptions is met, making mimicking of very large

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disturbances more difficult. Examples of this forest plan direction in the action alternatives includes a desired condition (DC-FIRE-2: Natural ignitions play a natural role in ecosystem dynamics when and where there is no threat to human life or property. (Forestwide)), a management approach in fire (Suppression actions are taken to mitigate effects of wildfire to public safety, communities, and unique resource values while allowing unplanned ignitions to play a natural role in fire-dependent ecosystems.), a management approach in scenery (Management practices are designed to produce forest composition, structure, and patterns similar to those that would have occurred under natural disturbance regimes, where feasible.), and a management approach in the Vegetation section (Treatments generally avoid alteration of the edge of natural openings.). Desired condition DC-VEG-4 regarding the desired structural stage distribution of the forested terrestrial ecosystems. The associated desired amounts in Table 7 were based on modeling done as part of the terrestrial ecosystem assessment to examine the natural range of variation, with some modifications based on local expert opinion.

Comment VEG – 39 Referring to Goal 2, the draft environmental impact statement needs to more clearly demonstrate how we are "maintaining and restoring sustainable, resilient terrestrial ecosystems," particularly regarding spruce-fir and tied to the key ecosystem characteristics. Response Two of the key ecosystem characteristics are diversity of vegetation and snags and downed woody material. Maintaining a diversity of ecosystems and structural types provides the various habitats needed by the many species that use the Forest and will help ensure resiliency in the face of environmental disturbances and changes (FEIS p. 75). The desired diversity of structural stages is described in DC-VEG-4. As discussed in the final environmental impact statement (p. 105), in some of the spruce-fir salvage areas, tree planting in currently understocked stands would speed forest recovery toward the desired conditions for this type. Tree planting in spruce-fir may also speed recovery to mature forest conditions and provide for future snags and downed wood (FEIS pg. 112).

Comment VEG – 40 Old forest and/or late-successional forest should be identified and managed outside of the suitable timber lands. Response The desired amount of late-successional forest and old forest is described in DC-VEG-3. This desired condition states the desire for all development stages of the forested terrestrial ecosystems to be well-represented at the landscape scale and occur Forestwide within the specified ranges. Management approaches regarding old forest or late-successional stage forest include the following: Presence of old forest is determined during project-level planning based on criteria in Appendix A. The habitat is assessed for quality and distribution and retained as necessary for vegetative diversity.

160 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Old forest, or late-successional stage forest, is often deferred from harvest to maintain biotic diversity across the landscape. The following is considered in selecting old forest stands to be retained: • Older stands that have not been manipulated are more desirable than younger ones. • Stands with limited use and access are better suited to maintain old forest conditions. • Stands that provide habitat for threatened, endangered, or proposed species, species of conservation concern, or Colorado Natural Heritage Program Species of Special Concern. • Stands exhibiting a variety of attributes such as diverse canopy layers, decadence in live trees, standing or downed dead, or both, and patchiness. We feel these management approaches provide appropriate yet flexible direction on assessing and retaining old forest habitat.

Comment VEG – 41 We are concerned with the amount of future timber harvest and the cumulative operational restrictions that have been built into the draft plan. As written, alternative B proposes to treat significantly less than alternative C in both the first and second decade, likely causing a wood shortage for the existing businesses. Plan components (DC-VEG-4, G-SCC-3, G-WLDF-1) are too limiting and will likely further reduce the amount of acres of treatment that can be implemented. Response Projected volume has been updated and included for alternative B Modified. Total projected volume under alternative B Modified is slightly higher than alternative B. However, a high rate of deterioration of standing dead spruce has been observed and, as a result, alternative B Modified also incorporates a faster transition from a salvage program to a green timber program. We understand the concern regarding cumulative operational restrictions. In some cases plan components have been deleted or simplified. Forest plan guideline G-WLDF-1 has been deleted, but replaced with a management approach that states “When raptors are known to occur in a project area, consult the Colorado Parks and Wildlife raptor guidance.” Desired condition DC-VEG-4 has been deleted, but there is language in the lynx management approaches that states “During salvage project design, late-successional forest patches that are expected to remain green or mostly green in the next 15 years are identified for retention during project implementation. Foresters and wildlife biologists determine the optimal landscape heterogeneity objectives that include retention, opening patch size, and configuration. Project objectives should be considered at a watershed or sub-watershed scale, using the best available science.”

Comment VEG – 42 Draft forest plan, page 39, Table 6 should be updated with more recent FS Veg data between draft and final.

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Response The current condition information in the table referenced was updated based on FSVEG Spatial data layers in March of 2017 and is sufficiently current for programmatic analysis.

Comment VEG – 43 We recommend condensing this DC-VEG-1 down to about 2 sentences plus Table 5. There is no need to go into explanations or rationale as part of a desired condition. Since late successional forest conditions are covered in DC-VEG-4 and 5, there is no reason to discuss late-successional and old forest conditions in DC-VEG-1, and we recommend you delete the first sentence on p. 37. Response Plan direction has been simplified, with references to late successional and old forest conditions deleted.

Comment VEG – 44 Insects and Disease – we recommend having specific plan components for this section, rather than just management approaches. After carefully reviewing the other sections that were identified as having specific plan components for insects and disease, we did not find any that were actually specific to insects and disease or measurable. With the current and ongoing insect epidemics, it is critical that plan components be developed. Response Management approaches provide sufficient direction regarding insects and disease. Project- level analysis will consider site-specific concerns and may offer additional direction regarding insects and disease.

Comment VEG – 45 MA-VEG-1 – 10 – there are some good concepts in these MAs, but they are generally too vague to be useful. We recommend that you either rewrite them as general description for Vegetation Management or as Plan Components. Management Approaches are not Plan Components, and cannot be used as Plan Components. We do not support the use of Administrative Changes to change Management Approaches as a way to get around public involvement. Response These management approaches were re-worded, in some cases simplified, and moved to the beginning of each resource area section, which reinforces that they are not plan components. The adaptive management section of the final environmental impact statement in Chapter 4 discusses how changes will be made through interdisciplinary analysis and will include public involvement. It discusses how Forest staff will annually post proposed changes and the rationale for the changes on the Forest website in conjunction with a stakeholder meeting to discuss the changes proposed and will be followed by a comment period.

162 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment VEG – 46 DC-VEG-3: The purpose of this desired condition is not clear. The text, "irregular, unscheduled timber harvest program" deviates from the rule (see 219.11(c)). Harvest activities must meet plan direction. Response This desired condition was clarified. It now reads: DC-VEG-2: Commercial timber harvest occurs on lands identified as not suitable for timber to meet multiple use objectives and for safety and health. These harvests are not part of the regularly scheduled harvest program. These activities meet management direction and desired conditions and may provide other services and benefits. (Forestwide)

Comment VEG – 47 MA 5.13 – Forest Products - It’s impossible for us to tell how Integrated Desired Conditions will be interpreted or implemented. For example, the second paragraph contains the following – 1) landscape diversity is similar to natural conditions, including consideration within a spatial context, 2) all succession stages are represented, and 3) mature stands are identified for old growth characteristics. We are concerned that the first desired condition will require analysis and determination of “natural conditions” – since most of the RGNF is currently dead as a result of a “natural” spruce beetle epidemic that could mean manage for dead trees. We are concerned that the second desired condition is meaningless, since “all succession stages” will always be represented in some proportion. We are also concerned that the third desired condition could be interpreted to require management of all “mature stands” as old growth. We want to see this direction better thought-out and articulated in the Plan, and recommend you go back to the drawing board to get that done. Integrated Desired Conditions for MA 5.13 are in conflict with wildland fire management zone goals. We recommend language along the lines of the following (from the Shoshone NF forest plan) be added for MA 5.13 and any other MA that contains suited timberlands – “The initial response to unplanned ignitions in the management area generally favors consideration of managing fires to accomplish resource protection objectives, but opportunities to manage fire for resource benefits are possible. Key values within the management area warrant fire management responses that mitigate the effects or prevent losses from fire. Potential values at risk include suitable timber lands and forage, infrastructure and developments, wildland urban interface, utility corridors, and other investments. In some situations, resource benefit objectives can be achieved using wildfire, but the use of wildfire is secondary to meeting protection objectives for other values within the management area.” Response Management Area 5.13 and the associated integrated desired conditions are not a part of the preferred alternative, alternative B Modified. However, some of this language is included in the desired conditions for management area 5 – General Forest and Rangelands. This

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language ensures a balanced approach and consideration of multiple uses, as directed by the Multiple Use and Sustained Yield Act of 1960 (MUSYA), as well as supporting ecological integrity, as directed under the 2012 Planning Rule. Language for the Wildland Fire Management Zone: Resource Protection and Benefit, which Management Area 5 is a part of states: “Wildfires that burn in this zone may benefit natural resources under certain conditions. All lightning-caused wildfires in these areas will be assessed on an individual basis for the most appropriate response based on values at risk and potential benefits to natural resources from wildfire. All human-caused unplanned wildfires are managed using a full suppression strategy commensurate with the values at risk.” This language captures the dual goals of protecting values at risk, including suitable timberlands, and the potential ecological benefits from allowing wildfires to burn.

Comment VEG – 48 DC-VEG-8 - Ecosystem types should have their own sets of plan components, including desired conditions for structure at various ecological scales (i.e. landscape, patch, and stand), in order to provide sufficient specificity regarding how diversity is to be achieved. We are concerned that the structural stages on Table 6 do not account for the periodicity of natural disturbance processes, and indicate a need for an overly rigid management regime. Response Draft forest plan Table 6 is Table 7 in the final forest plan. Table 7, while tied to a single plan component, outlines different desired conditions for each terrestrial ecosystem. An overly rigid management regime is undesirable and this table is sufficiently specific. Project-level analysis will consider site-specific concerns regarding diversity.

Comment VEG – 49 G-VEG-1: To operationalize this guideline, there would need to be a desired condition for fire behavior. There must be a desired condition linked with point d). Point e) allows for clearcutting outside of suitable lands, and there is a need to define the condition for “protecting and restoring multiple use values,” which the current plan does not adequately do. The intention of point c) is unclear. Response Forest plan guideline G-VEG-1 is a required plan component, as described at 36 CFR 219.11(d)(7) and in the Land Management Planning Handbook - FSH 1909.12, Chapter 60, section 64.26. Forest Service Handbook 1909.12, Chapter 60, section 64.26 clearly identifies that these limitations do not apply to thinning or other stand improvement treatments and uneven-aged systems that do not regenerate even-aged stands, salvage or sanitation harvesting of timber stands that are substantially damaged by fire, wind throw, or other catastrophe, or that are in imminent danger from insect or disease attack, and harvesting of trees on lands not suited for timber production because the type and frequency of harvests are driven by the need to protect multiple use values other than timber production. Forest Service Handbook 1909.12, Chapter 60, section 64.26 also indicates that a plan may provide for exceptions to the culmination of mean annual increment requirement for expected situations where even-aged regeneration harvest at less than culmination of mean annual increment

164 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments would contribute to the plan’s desired conditions or objectives consistent with other plan components.

Comment VEG – 50 Including a desired condition for old forest conditions is necessary for species such as the northern goshawk, but the plan must also include related standards and guidelines to assure that desired conditions are compliant with the planning rule and can be met. For example, standards should be written that assure, for example, that criteria for retaining: old trees and large trees, etc. The plan must be specific about what spatial scale these criteria apply. Response In addition to DC-VEG-3, the plan has G-VEG-5 that address old forest conditions and the criteria for retaining old and large trees: Presence of old forest is determined during project-level planning based on criteria in Appendix A. The habitat is assessed for quality and distribution and retained as necessary for vegetative diversity. Old forest, or late-successional stage forest, is often deferred from harvest to maintain biotic diversity across the landscape. The following is considered in selecting old forest stands to be retained: • Older stands that have not been manipulated are more desirable than younger ones. • Stands with limited use and access are better suited to maintain old forest conditions. • Stands that provide habitat for threatened, endangered, or proposed species, species of conservation concern, or Colorado Natural Heritage Program Species of Special Concern. • Stands exhibiting a variety of attributes such as diverse canopy layers, decadence in live trees, standing or downed dead, or both, and patchiness. The forest plan also includes a management approach regarding late-successional conditions in the Canada Lynx section: During salvage project design, late-successional forest patches that are expected to remain green or mostly green in the next 15 years are identified for retention during project implementation. Foresters and wildlife biologists determine the optimal landscape heterogeneity objectives that include retention, opening patch size, and configuration. Project objectives should be considered at a watershed or sub-watershed scale, using the best available science. This provides sufficient forest plan-level direction regarding old forest and late-successional conditions. Project-level analysis for timber management activities will consider site-specific concerns and may offer additional guidance regarding retention of old forest conditions. In addition, the monitoring plan (see MQ3) address the status and trend of key ecosystem characteristics associated with at-risk and other species and includes as a landscape-level indicator the distribution of old-forest/late-successional conditions.

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Comment VEG – 51 OBJ-VEG-1: Clarification is needed. Does 100 acres annually apply to all forest types combined or does this mean 100 or 1,200 acres for each forest type, e.g. spruce-fir and/or mixed conifer? Response This objective was updated to match the projected timber program under alternative B Modified. In the final forest plan OBJ-VEG-1 reads: Diversify the structure class distribution for various forest types by managing 800 acres annually in years 4 and 5 of the planning period and 1,200 acres in years 6 through 20 of the planning period, to work toward or maintain the desired conditions in Table 7. (Forestwide) The annual acres estimates apply to all forest types combined.

Comment VEG – 52 OBJ-VEG-2 and 3: There must be a desired condition for species composition and landscape pattern that is linked to the objective. Response OBJ-VEG-2 is linked to DC-VEG-4. OBJ-VEG-3 is linked to Goal 3.

Comment VEG – 53 OBJ-VEG-5: The objective must be linked to a specific desired condition. Response This objective has been deleted.

Comment VEG – 54 Forest plan standard S-VEG-4 is too vague to provide clear direction to project planners. It offers almost complete discretion to project managers and provides no actual constraint(s) on management activities. Response Standard S-VEG-4 is a required plan component, as described at 36 CFR 219.11(d)(5) and in Forest Service Handbook 1909.12, Chapter 60, section 64.15.

Comment VEG – 55 OBJ-VEG-1 and OBJ-VEG-2 – we recommend that you increase the number of acres diversified or restored to at least the number of acres to be managed annually through the timber sale program, as outlined in OBJ-VEG-3. The low number of acres listed isn’t enough to make any difference at a landscape level. Response Objective OBJ-VEG-1 was updated to match the projected timber program under alternative B Modified. This objective is specific to the green timber program and the acres were increased in years 4 through 10. OBJ-VEG-2 was not changed as it pertains specifically to

166 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments dry mixed-conifer and ponderosa pine areas and not to the program as a whole. OBJ-VEG-3 is specific to the salvage program.

Comment VEG – 56 OBJ-VEG-3 – we recommend that you add a volume to this Objective, specifically 90,000 ccf annually, and that you broaden the purpose to include forest management benefits as well, as stated in MA-VEG-10. Response Objective OBJ-VEG-3 was changed to focus on volume, rather than acres. It now reads: OBJ-VEG-3: Salvage harvest approximately 62,800 CCF (hundred cubic feet) of spruce-fir annually for the first 3 years of the planning period. (Forestwide). The volume in this objective is based on the projected timber program under alternative B Modified.

Comment VEG – 57 OBJ-VEG-4 AND OBJ-VEG-5 – we recommend that you clarify the difference between these. Response In the draft forest plan, OBJ-VEG-4 was focused on the projected timber sale quantity while OBJ-VEG-5 was focused on the projected wood sale quantity. These are defined in the glossary of the final environmental impact statement and in Forest Service Handbook 1909.12, Chapter 60 as follows: Projected timber sale quantity The estimated quantity of timber meeting applicable utilization standards that is expected to be sold during the plan period. As a subset of the projected wood sale quantity, the projected timber sale quantity includes volume from timber harvest for any purpose from all lands in the plan area based on expected harvests that would be consistent with the plan components. The projected timber sale quantity is also based on the planning unit’s fiscal capability and organizational capacity. Projected timber sale quantity is not a target nor a limitation on harvest, and is not an objective unless the responsible official chooses to make it an objective in the plan.

Projected wood sale quantity The estimated quantity of timber and all other wood products that is expected to be sold from the plan area for the plan period. The projected wood sale quantity consists of the projected timber sale quantity as well as other woody material such as fuelwood, firewood, or biomass that is also expected to be available for sale. The projected wood sale quantity includes volume from timber harvest for any purpose based on expected harvests that would be consistent with the plan components. The projected wood sale quantity is also based on the planning unit’s fiscal capability and organizational capacity. Projected wood sale quantity is not a target nor a limitation on harvest, and is not an objective unless the responsible official chooses to make it an objective in the plan.

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Comment VEG – 58 S-VEG-1: There needs to be independent plan direction for those values in non-suited lands in order to guide these harvest activities. The plan must describe and define these values, habitat, etc. This statement does not provide any direction. Response Standard S-VEG-1 is included as the 2012 Planning Rule requires that plan components ensure that no timber harvest for the purpose of timber reproduction may occur on lands not suited for timber production (36 CFR 219.11(d) and –in Forest Service Handbook 1909.12, Chapter 60, section 64.1). The forest plan must also have appropriate plan components that establish permissible reasons for timber harvest for purposes other than timber production in order to protect multiple use values on lands not suited for timber production (36 CFR 219.11(c) and the –Forest Service Handbook 1909.12, Chapter 60, section 63).

Comment VEG – 59 Clarification is needed as to how DC-VEG-8 and OBJ-VEG-1 apply to the spruce-fir ecosystem. The draft environmental impact statement indicates that the “abundance” of young forest vs mid- and mature-closed forest in the spruce-fir ecosystem is undesirable (DEIS at 87-88). In spruce-fir forest, how does the Forest propose to bring structural conditions back in line with its approach to Natural range of variability analysis and the interpretation of results? Response All options for treatment are available unless otherwise stated in forest plan direction. Site- specific analysis would clarify and describe planned treatments.

Comment VEG – 60 The management implications of Table 6 (draft forest plan at 39) and vegetation management changes to the draft forest plan do not square with conclusions from the Terrestrial Assessment (at 18) and statements in the draft environmental impact statement (pages 72 through 73), which acknowledge the difficulty in determining whether the spruce-fir ecosystem is outside the natural range of variation based on structural stage proportions. The Terrestrial Assessment and draft environmental impact statement also acknowledge the lack of scientific consensus noted on page 18 of the Terrestrial Assessment between peer-reviewed published science and the results of the vegetation modeling the Forest commissioned. Of particular importance is that the model did not include large beetle outbreaks that may be within natural range of variation (an also included the lodgepole pine). The issue is captured in this statement in the Terrestrial Assessment (at 18). Response As stated in Forest Service Handbook 1909.12, Chapter 10, 12.14a, while a description of the natural range of variation provides insight into the temporal dynamics and key characteristics of an ecological system and provides context for assessing whether an ecosystem has integrity, the natural range of variation does not represent a management target or desired condition. A description of the natural range of variation alone is not sufficient to determine whether there is ecological integrity.

168 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments While the Forest does recognize the difficulty in determining the natural range of variation for the spruce-fir ecosystem and whether the current conditions are within or outside of that. Desired condition DC-VEG-3 and Table 6 provide direction in support of the goals of the plan and, as stated in the final environmental impact statement, maintaining a diversity of ecosystems and structural types provides the various habitats needed by the many species that use the Forest and will help ensure resiliency in the face of environmental disturbances and changes.

Comment VEG – 61 DC-VEG-4: This desired condition requires some revision. It is written like a standard, and standards and/or guidelines should be included in the plan to support implementing this direction at the project level. We recommend that this be a forestwide desired condition. What are the "species habitat-related goals? List them or reference where these exist in the plan. We are guessing that this is pertinent to Canada lynx, maybe marten, and possibly others, and this should be clarified in plan documents and referenced in the desired condition. What is the BASI rationale for the 60 percent threshold? What are the conditions where green or mostly green patches would be “considered integral”? The statement leaves too much uncertainty. Response This desired condition has been deleted. Some similar language in included in the lynx management approaches (During salvage project design, late-successional forest patches that are expected to remain green or mostly green in the next 15 years are identified for retention during project implementation. Foresters and wildlife biologists determine the optimal landscape heterogeneity objectives that include retention, opening patch size, and configuration. Project objectives should be considered at a watershed or sub-watershed scale, using the best available science.) This language does not discuss “species habitat- related goals” or the 60-percent threshold.

Comment VEG – 62 DC-VEG-2: There must be a desired condition for historical succession and disturbance regimes. The following questions must be answered to develop a desired condition or multiple desired conditions that meet rule requirements. What are the desired conditions for the disturbance factors, which are described in Terrestrial Assessment, that occur on the forest regardless of vegetation management strategies? What is the natural range of variation for each disturbance process for the identified ecosystem? Succession and disturbance regimes are different from spruce-fir and dry mixed conifer forest types, for example. What are the "vegetation management strategies referred to in this desired condition? Does "vegetation management" necessarily mean active management? What are the "other land management objectives" referenced by this desired condition; are those specific objectives in the draft plan or other objectives? This provision is not described in terms specific enough to allow progress toward its achievement. The statement reads more like a guideline. We recommend "consistent with" be replaced by "maintain or restore" to reflect planning rule language and to establish that natural succession and disturbance based on natural range of variation is desirable.

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Response Desired condition DC-VEG-2 has been removed. However, there is language regarding disturbance regimes and succession in several of the management area desired conditions. Management area 1, Wilderness has a desired condition that states: Natural succession, influenced by natural processes and disturbances, occurs in all vegetation types. Structure, composition, function, and spatial distribution of vegetative types are the result of natural succession. Where no natural disturbance has occurred, vegetation is mostly in late- successional stages. Management area 1.1a, Recommended Wilderness has a desired condition that states: These areas are characterized by a natural environment where ecological process such as natural succession, wildfire, avalanches, insects, and disease function with limited human interaction. Management area 3 Colorado Roadless Areas has a desired condition that states: Landscapes in these areas are predominantly natural appearing and relatively undisturbed by humans. Natural processes within the context of the range of natural variability (insects, disease, and fire) are generally allowed to occur with minimal human intervention. Management area 5 General Forest and Rangelands has a desired condition that states: Landscape diversity is similar to natural conditions (composition, structure, and function) and includes consideration within a spatial context—for example: what species, what kind of stand structure, and what kind of landscape patterns are natural, by ecosystem. All succession stages are represented, including old forest. Mature stands are identified for old- forest characteristics (See Appendix A).

Comment VEG – 63 S-VEG-6 – the first two sentences contradict each other; we recommend that you rewrite the Standard along the lines of “Openings will not be created larger than 40 acres, regardless of forest type, unless one of the following is true: …” Response The language in the S-VEG-6 plan component has been clarified and is responsive to this suggestion.

Comment VEG – 64 We recommend that you add a guideline along the lines of the following: “Stands that have been historically managed and regenerated should be intensively managed to maximize timber production.” There are a lot of stands that have regenerated nicely from previous management, and those should continue to be actively managed. Response While we understand the desire for intensive management and maximization of timber production, the Multiple Use and Sustained Yield Act of 1960 provides the agency with a multiple-use mandate. We feel adding the guideline suggested would put a focus on a single resource and make balancing the multiple uses across the landscape more difficult. This guideline has not been added.

170 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment VEG – 65 DC-VEG-2, DC-VEG-4, DC-VEG-5, and DC-VEG-8, should all be combined into a single DC that includes regeneration, ‘the next forest,’ and the desired conditions in Table 6 (as modified per our other comments and recommendations). Response Comments were received that plan components should be simplified, clarified, deleted, and combined. Desired condition DC-VEG-2 was deleted, although there is some similar language in a management approach in the Scenery section. Forest plan direction DC-VEG-4 was deleted, although there is some similar language in the lynx management approaches. DC-VEG-5 was deleted. DC-VEG-8 was re-labeled as DC-VEG-4.

Comment VEG – 66 DC-VEG-9 – snags are covered adequately in DC-VEG-1. We recommend that you delete this one. Some commenters suggested that more snag direction be included in standards or guidelines instead of relying too much of desired conditions and management approaches. Response The direction previously included as DC-VEG-1 is now a guideline – G-VEG-1. This guideline will help to maintain ecosystem conditions for viable populations of many different species of conservation concern.

Comment VEG – 67 We are very concerned that “areas have been deferred from harvest due to the presence of high quality lynx habitat, and this amount has varied by project.” If harvest is allowed by the Southern Rockies Lynx Amendment, then there is no reason to defer that harvest. The Southern Rockies Lynx Amendment direction is onerous and restrictive, and the Forest should be implementing salvage and restoration to the fullest extent allowed. Response The lynx direction in the final forest plan is based on preliminary results of a research study (FEIS p. 16) and is different than both the direction in the draft plan and the original Southern Rockies Lynx Amendment direction. The Southern Rockies Lynx Amendment direction is important for the conservation of Canada lynx. The lynx direction in the final forest plan provides direction for the dead spruce-fir habitat that is not addressed in the original Southern Rockies Lynx Amendment direction. The cap on disturbances within the lynx 95 percent high-use areas may seem restrictive, but it is important to maintain suitable habitat for the species.

Comment VEG – 68 Support for thinning of young spruce-fir stands - We are concerned with the fact that “there is an abundance of spruce-fir in the young 1T/2T class, yet proposed management activities list on p 88 state “while not anticipated in green spruce-fir, a small amount may be treated through uneven-aged management over the life of the plan.” In order to have productive

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advance spruce-fir stands in the future, it is critical that some of the 1T and 2T stands are thinned. Response The Forest also sees a need to thin some 1T and 2T stands to have more productive stands in the future. Current forest conditions focus on salvage operations, with the anticipation of moving toward a green tree program in the future. Program priorities for timber are evaluated and adjusted, usually on an annual basis, and may not be captured in the forest plan.

Comment VEG – 69 We support aggressive salvage during the first decade of the Plan, and we agree that deterioration of the dead spruce will lead inevitably to less spruce salvage in the second decade. We interpret the second paragraph (page 69) as an intent to only harvest green timber in mixed-conifer and other non-spruce forest types. We do not support that approach. We recommend allowing management and harvest in green spruce stands where possible, and that you develop Plan Components that will facilitate that. The suited timberlands are a small component of the forest, only 26 percent for alternative 3, and we want to see continued active forest management on the suited timberlands. Response We believe you are referring to the second paragraph of the General Forest Geographic Area Management Approach Summary (p. 69 of the draft forest plan). Geographic areas are not part of the preferred alternative. The final environmental impact statement (p. 102) discusses proposed vegetation management activities. While not a dominant part of the planned timber program, this section makes it clear that a small amount of vegetation management in green spruce-fir may occur, stating “While not anticipated in green spruce-fir, a small amount may be treated through uneven-aged management over the life of the plan for reasons other than timber management.”

Comment VEG – 70 Recommendation that the Forest continue a salvage program into the second decade, for house logs and other products that can be made from the dead trees. One of the primary users of wood from the Forest is a log home manufacturer who depends solely on standing dead volume. There will always be dead and dying trees in the forest and we recommend you always actively salvage this material. Response A high rate of deterioration of standing dead spruce has been observed and was incorporated into alternative B Modified. This alternative focuses on salvage for the first 3 to 5 years of the planning period and incorporates a faster transition from a salvage program to a green timber program than the other alternatives. However, if there are dead and dying trees after this time period, there is nothing that specifically limits the ability to salvage those areas at that point in time. Many plan components have specific exceptions for salvage or sanitation harvesting when areas are substantially damaged by fire, windthrow, or other catastrophe, or that are in imminent danger from insect or disease attack.

172 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment VEG – 71 Support for timber management in the Chama Basin area. Support for timber management in the Spruce Hole/Osier/Toltec Connectivity special interest area. Timber management in this area will provide some habitat or wildlife benefits to the area by removing the dead stands of spruce and helping to regenerate the forest. Response Differing opinions about these specific areas were submitted by commenters. While some comments indicated support for timber management in the Chama Basin and Spruce Hole/Osier/Toltec areas, other comments indicated a desired for these areas to have a protective designation, such as a special interest area or watershed protection area. The alternatives were developed to reflect this difference, with alternative D including both the Chama Basin Special Interest Area and the Spruce Hole/Osier/Toltec Special Interest Area and the other alternatives not including special designations for these areas. Regardless of whether or not they are included in a special interest area, timber management may be limited, with portions of these areas not suitable for timber production, such as the portions included in Colorado roadless areas.

Comment VEG – 72 Support for timber management/harvest of beetle-killed trees, with recommendation to update alternative B with a higher volume for the second decade. Recommendation to accelerate the salvage program up to the fiscal year 18 target of 90,000 ccf/ year for at least the next three years and potentially up to five years depending on the level of mortality, before tapering off to a lower level. With an estimated sustained yield of 73,749 ccf per year, treatment numbers within alternative C are very conservative in the next years, before the wood deteriorates and is no longer. We recommend updating alternative C to show up to 90,000 ccf of salvage for at least the first three years, and possibly up to five years if the mortality continues to spread, before tapering down. The 2018 timber target for the Forest is 90,000 ccf. The increased target is a direct response of the Rocky Mountain Region (Region 2) prioritizing funding in order to facilitate critical salvage operations prior to the wood deteriorating. Due to the abundance of beetle kill, I would like the timber outputs of our Rio Grande National Forest to be maximized, recognizing that sooner is better for harvest and salvage. This would accomplish thinning as well as looking to an uncertain future of possible drought, warmer temperatures, and wildfires. Response The Forest is working to maximize salvage harvest in the first 3 to 5 years of forest plan implementation. A high rate of deterioration of standing dead spruce has been observed and this information was incorporated into the projected timber harvest levels of alternative B Modified. This alternative focuses on salvage for the first 3 to 5 years of the planning period and incorporates a faster transition from a salvage program to a green timber program than the other alternatives. The planned timber program under alternative B Modified is 70,000 CCF annually for the first 3 years, which balances the desire to maximize salvage with other

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concerns heard, such as that the proposed timber harvest levels are excessive. It also reasonably factors in the high deterioration seen in the standing dead spruce.

Comment VEG – 73 We encourage harvest of beetle killed timber and realize the habitat improvement value throughout the forest. Response A management approach in the Vegetation section of the plan describes this - In areas suitable for timber production, dead or dying trees due to fire, insects, or disease are salvaged to recover the economic value of the wood while providing for ecosystem function. This will be the primary focus of the timber program for the first 3 years of the planning period. There are also two objectives related to salvage harvest: OBJ-VEG-3: Salvage harvest approximately 62,800 CCF (hundred cubic feet) of spruce-fir annually for the first 3 years of the planning period. (Forestwide) OBJ-VEG-4: Salvage harvest an estimated 20,000 CCF of spruce-fir annually during years 4 and 5 of the planning period. (Forestwide)

Comment VEG – 74 The draft plan components and alternatives based on geographic and management areas enable a significant amount of diversifying forest structure through logging and other active vegetation treatments, and the best available scientific information does not fully support this. Given the scientific uncertainties, especially related to the spruce beetle outbreak, we urge precaution and an analysis of an alternative that proposes plan components that offer a clear passive, low, or limited vegetation management approach. Response Alternative D offers the suggested low vegetation management approach. Under this alternative, the projected volume for the first decade is 25,000 CCF annually, with the majority of that coming from salvage harvest. The projected volume for the second decade is 11,200 CCF annually, with the majority of that coming from fuelwood sales (7,200 CCF). This alternative emphasizes less active management of resources and would increase the number of acres proposed for wilderness (FEIS pg. 38).

Comment VEG – 75 In assessing the direct and indirect effects of the alternatives on vegetation diversity, the Forest has made determinations about current conditions and desired conditions based on natural range of variation information that it acknowledges cannot be substantiated empirically. Based on the management proposals in the draft environmental impact statement (at 88-91), it appears as though particular decisions are made about the types of management to be applied in the different ecosystems when the plan should be proposing this direction instead.

174 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response The environmental impact statement analyzes the effects of implementing the plan but does not make decisions. The plan is a programmatic document that requires subsequent analysis before any ground-disturbing activities can occur.

Comment VEG – 76 Plan, at page 93 best available scientific information, first paragraph, last sentence - I guess this is fine. Some don't really meet planning rule specifics for "focal species". Would have been good to have been consulted on this first as I don't believe we've taken a hard look at what key ecosystem characteristics are being covered by these species and which are not. Response The original sentence referred to in the comment was “While data on breeding bird occupancy and density is important for understanding trends associated with individual species, the Forest is also proposing to use a suite of birds as “focal species,” identified in consultation with experts at Bird Conservancy of the Rockies, which can be used to infer changes in the structure, function, and composition of terrestrial forest ecosystems.” This sentence was updated, with the reference to focal species removed. It currently states “In consultation with Bird Conservancy of the Rockies, the Forest identified a suite of bird species for monitoring that can be used to infer changes in the structure, function, and composition of forest ecosystems.”

Comment VEG – 77 Draft environmental impact statement, chapter 3 - We recommend including regeneration as a key ecosystem characteristic in addition to the ones already listed. Young forests play a very important role, especially for the Canada lynx and other species that rely on regeneration. With the current spruce beetle epidemic and the previous large wildfires, the future forest depends on adequate regeneration. While young forests/regeneration is likely considered under “Diversity of Vegetation,” we feel it is important enough to be a stand- alone key component. Response The key ecosystem characteristics were defined in the Terrestrial Ecosystem Assessment. While regeneration is not a stand-alone key characteristic, we agree that it is already included as part of the “Diversity of Vegetation” key characteristic. Standard S-VEG-3, describes restocking and the minimum restocking levels, as well as desired condition DC-VEG-4, which describes the desired amount of young forest.

Water (WA)

Comment WA – 1 Alternative D should be selected because it ensures that high-value resources are protected from potential impacts associated with altered hydrology and deposition of sediment. This is

175 USDA Forest Service particularly important given existing watershed concerns related to water quality, riparian and wetland vegetation, and soils. Response All alternatives were developed to protect resources; the various alternatives may provide a different focus.

Comment WA – 2 The analysis should include examples of Watershed Conservation Practices Handbook and National BMPs that may be required to protect water and soil resources. The Watershed Conservation Practices Handbook should be incorporated into the forest plan. A standard is needed that incorporates the Watershed Conservation Practices Handbook into the forest plan. Response Forest Service Handbook 1909.12, Section 22.1 (2(i) specifically states that “2. Plan Components: (i) should not simply repeat Agency policies applicable to all National Forest System units.” The plan explains that all higher level direction is incorporated by reference and applies to implementation.

Comment WA – 3 To complement the draft environmental impact statement Table 45, the final environmental impact statement should include a map of the impaired waterbody segments within or downstream of the planning area. Response As part of the Clean Water Act, States establish water quality standards for waters within their borders. States must update and resubmit impaired waters lists every two years. The State maintains the list. Publishing the list in the forest plan would require undue updating and correction over time; instead, the environmental impact statements refers to the State’s list as posted by the Colorado Department of Public Health and Environment. Regulation #93 contains Colorado’s Section 303(D) List of Impaired Waters and Monitoring and Evaluation List.

Comment WA – 4 The Forest should identify five Priority Watersheds, which is the maximum allowed under the 2012 Planning Rule, to assist stakeholder groups in proposing projects, seeking grants, and maximizing partnerships for restoration. More than three priority watersheds should be identified. To protect water and fish resources, the forest plan needs to identify five priority watersheds including a merger of Upper Chama and Archuleta Creek, which share a majority of the same resource concerns and would benefit from a joint watershed restoration plan. The commitment to active management of watershed health and water resources should be more of a major focus for the Forest.

176 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response Three priority watersheds have been identified. This is a logical approach at this time.

Comment WA – 5 The terms “heathy and functioning watersheds” and “watershed health” need to be defined. Response Definitions of these terms have been added to the final documents.

Comment WA – 6 To complement the existing goals, there needs to be goals added for aquatic ecosystems, water quality, and water quantity. Response The forest plan goals have been reordered. Forest plan Goal 2 specifically addresses aquatic ecosystems, water related topics, watersheds, and watershed health. Desired conditions address topics including water quality and quantity.

Comment WA – 7 The objectives in the Watershed section need to be written to be positive and measureable. Objectives should consider how other management can help reach the goals and desired conditions in the Watershed section. Response Objectives for water have been updated in the forest plan to be concise, measurable, and time-specific statement(s). (36 CFR 219.9 (e)(1)(i))

Comment WA – 8 The monitoring plan should use a finer scale than HUC-12 watersheds because Rio Grande cutthroat trout are rarely found at a HUC-12 watershed level. Inventories should be done by stream reach because at this scale, native Rio Grande cutthroat trout and other native fish can be found in the isolated headwaters and smaller stream sections on the Forest. These metrics can be excellent sources of reference when examining habitat for fish species of conservation concern. Riparian management zone metrics and analyses should be incorporated into the watershed and species health monitoring, particularly beaver presence, when conducting monitoring and in the biannual updates. Response The HUC-12 analysis scale was chosen to be consistent with Forest Service national direction found in the Watershed Condition Framework. This is suitable for programmatic- level analysis. At the project level, specialists (fish biologists etc.) make recommendations to the responsible official on an analysis scale based on a variety of factors, including the presence of native fish.

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Comment WA – 9 The watershed direction should be rewritten so it is measurable, condensed, and able to be monitored. It should also be condensed. The Watershed objectives should be rewritten to be specific about the work to be accomplished. Response Objectives for water have been condensed into two objectives that have been updated in the forest plan to be concise, measurable, and time-specific statement(s). (36 CFR 219.9 (e)(1)(i))

Comment WA – 10 Edit the first and second paragraphs on page 180 of the draft environmental impact statement, which discusses potential flow increases associated with timber harvest, to clarify that because virtually all of the current and projected timber harvest is in dead trees, there should be very little difference on stream flows associated with timber harvest. Response Changes in paragraphs noted by the commenter in the Effects on Watershed Resources from Vegetation Management section have been made.

Comment WA – 11 The draft environmental impact statement discusses the potential for sedimentation from roads (page 182) but does not include the benefits of Best Management Practices, design, construction, or maintenance techniques used to keep sediment at natural levels; the results of monitoring sedimentation; the role of timber sales in road maintenance and keeping drainage structures functional; and monitoring results of Colorado silviculture Best Management Practices. Response While best management practices mitigate the undesirable effects of sedimentation from roads, they are not a cure-all. Impacts are still realized even when implementing best management practices. Colorado Forestry Best Management Practices Field Monitoring Reports have been completed for 2008, 2012, and 2014. These reports analyzed best management practices implementation and effectiveness for 236 best management practice sites on federal lands and found that: • In 1.7 percent (4 out 236) of cases, best management practices effectiveness was judged as having yielded improvements relative to pre-project conditions. • In 223 of 236 cases (94.5 percent), the best management practices were judged to have provided adequate protection. • In 9 of 236 cases (3.8 percent), the best management practices were judged to have allowed minor or temporary impacts. Programmatic assessment of the Forest Service national best management practices data from the 2013-2014 phase-in period show that:

178 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments • 13 percent of mechanical vegetation management best management practices were rated as not effective or marginally effective. • 46 percent of road management best management practices were rated as not effective or marginally effective. Analysis of 2015-2016 best management practices monitoring in Region 2 of the Forest Service shows that: • 22 percent of mechanical vegetation management best management practices were rated as not effective or marginally effective. • 60 percent of road management best management practices were rated as not effective or marginally effective. Given the large body of data from best management practices monitoring in the last decade, it can be concluded that while best management practices are successful at mitigating some impacts of vegetation management and the associated road management activities, the activities analyzed under the forest plan revision will almost certainly generate erosion and sedimentation impacts to watersheds that are above natural levels. References Cited: Carlson, J., Edwards, P., Ellsworth, T., and Eberle, M. 2015. National best management practices monitoring summary report. Program phase-in period fiscal years 2013-2014. FS-1070. Washington, DC: U.S. Department of Agriculture, Forest Service. 36 pp. Colorado forestry best management practices forest stewardship guidelines for water quality protection 2008: Field audit report. Colorado forestry best management practices forest stewardship guidelines for water quality protection 2012: Field audit report. Colorado forestry best management practices forest stewardship guidelines for water quality protection 2014: Field monitoring report.

Comment WA – 12 The riparian management zone delineation in Appendix F is overly complex and leaves opportunity for wider than necessary riparian management zones. Simplify the process to a standard 100 feet or the mean height of mature dominant late-seral vegetation water influence zone as stated in Forest Service Handbook 2509.25 Chapter 10, p. 8. Response The relevant portion of the Forest Service Handbook 2509.25 (see below) does not set a “standard 100 feet or the mean height of mature dominant late-seral vegetation.” The greater or 100 feet, or mean height of dominant late-seral vegetation is the minimum that is allowed to be buffered. By definition the water influence zone includes the geomorphic floodplain (valley bottom), riparian ecosystem, and inner gorge. In cases where these three components total less than 100 feet, or are less than the mean height of the dominant late seral vegetation, then the greater of these two metrics is applied as the defined water influence zone.

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In the water influence zone next to perennial and intermittent streams, lakes, and wetlands, allow only those actions that maintain or improve long-term stream health and riparian ecosystem condition. (FSH 2509.25, section 12.1 – Management Measure (3)) The water influence zone includes the geomorphic floodplain (valley bottom), riparian ecosystem, and inner gorge. Its minimum horizontal width (from top of each bank) is the greater of 100 feet or the mean height of mature dominant late-seral vegetation. The water influence zone protects interacting aquatic, riparian, and upland functions by maintaining natural processes and resilience of soil, water, and vegetation systems (Reid and Ziemer 1994).

Comment WA – 13 Reconsider the overall impacts from alternative C; none of the benefits (such as road maintenance, wildfire risk reduction, etc.) are even considered. The benefits should be discussed in the “Effects on Watershed Resources from Vegetation Management” section as well as the “Effects on Watershed Resources from Roads and Trails” section. Alternative D analysis does not include any of the ramifications of less management in consideration of wildfire. Less management does not equal less impacts. Response The following discussion pertains to the salvage in the subalpine zone of Engelmann spruce that has been killed by the ongoing beetle epidemic. While other forms of vegetation management will also occur, they are relatively minor compared to the anticipated salvage, and are relatively constant across alternatives (draft EIS, Table 11). Watershed impacts and wildfire risk reduction: Engelmann spruce, the dominant vegetative type proposed for salvage, occurs in the subalpine zone. In this vegetation type fire suppression has not significantly altered the historic fire regime and while there has been some alteration of stand structure and composition, most stands are still within the their natural range of variation in terms of stand density and fuel loading (McDonald and Larson 2009). Recent analysis of the West Fork Fire that occurred on the Forest concluded that “Contrary to the expectation that bark beetle infestation alters subsequent fire severity, correlation and multivariate generalized linear regression analysis revealed no influence of pre-fire spruce beetle severity on nearly all field or remotely sensed measurements of fire severity.” The work further asserts that the conclusion “…that beetle infestation did not alter fire severity is consistent with previous retrospective studies examining fire activity following other bark beetle outbreaks and reiterates the overriding influence of climate that creates conditions conducive to large, high- severity fires in the subalpine zone of Colorado.” (Andrus et al. 2016). Additional research on the West Fork Fire (Carlson et al. 2017) determined that salvage logging of spruce-beetle-killed forests would be unlikely to mitigate the compound impacts for fire and beetles for a variety of reasons, including: failure to remove ground fuels, the short period of increased fire likelihood following tree mortality, and the random nature of fire. The paper concludes that while there are social and economic benefits to salvage, “salvage Logging with the goal of averting the impacts of beetle-wildfire interactions is not a logical management action.”

180 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments These two papers conclusions, focused specifically on fire within the area covered by this land management plan revision, combined with prior work showing that subalpine forests are at a lower risk from post-fire flooding and erosion (McDonald and Larson 2009), indicate that efforts to salvage dead Engelmann Spruce in order to improve watershed condition via a reduction in wildfire risk are unlikely to yield positive impacts to watershed resources. References Cited: Andrus, R.A., Veblen, T.T., Harvey, B.J., and Hart, S.J. 2016. Fire severity unaffected by spruce beetle outbreak in spruce-fir forests in southwestern Colorado. Ecological Applications. 2016 Apr 1; 26(3):700±11. PMID: 27411244 https://esajournals.onlinelibrary.wiley.com/doi/epdf/10.1890/15-1121 Carlson, A.R., Sibold, J.S., Assal T.J., and Negro ́n, J.F. 2017. Evidence of compounded disturbance effects on vegetation recovery following high-severity wildfire and spruce beetle outbreak. PLoS ONE 12(8):e0181778. https://doi.org/10.1371/journal.pone.0181778 McDonald, L.D., and Larson, I.J. 2009. Effects of forest fires and post-fire rehabilitation: A Colorado, USA case study. Land Reconstruction and Management Series, Volume 5: Fire Effects on Soils and Restoration Strategies. http://journals.plos.org/plosone/article/file?id=10.1371/journal.pone.0181778&type=pr intable Watershed Impacts and Road Maintenance Associated with Vegetation Management: Roads associated with the salvage of beetle killed Engelmann Spruce in the subalpine zone can be broadly broken into three types: use of existing open National Forest System roads; reopening of previously used harvest roads that are currently closed; and construction of new temporary roads that will be decommissioned upon completion of salvage operations. Reopening of closed roads: In most cases of reopening previously used harvest roads, the roads have been closed to vehicle traffic and allowed to revegetate for a significant period of time, often decades. In the case where the roads have stabilized and revegetated, the reopening will generate both immediate and long-term sedimentation rates that are in excess of those observed under the closed condition (Foltz et al. 2009). References Cited: R.B. Foltz, N.S. Copeland, and W.J. Elliot. 2009. Reopening abandoned forest roads in northern Idaho, USA: Quantification of runoff, sediment concentration, infiltration, and interrill erosion parameters. Journal of Environmental Management 90; 2542–2550. https://www.fs.fed.us/rm/pubs_other/rmrs_2009_foltz_r001.pdf Maintenance and use of open National Forest System roads: While there certainly benefits to well-maintained roads, there is a substantial amount of scientific literature showing that road maintenance can increase erosion, and that sediment generation is proportional to vehicle traffic and vehicle weight, even on well-maintained roads. The anticipated increase in traffic over baseline conditions is likely to increase erosion and sedimentation from open National Forest System roads.

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Reference Cited: Chapter Four, Forest Service Northern Research Station General Technical Report NRS-165, October 2016. Effectiveness of Best Management Practices that Have Application to Forest Roads: A Literature Synthesis. Construction of New Temporary Roads with Subsequent Decommissioning: Construction of new temporary roads is proven to increase erosion and sedimentation relative to the undisturbed forest condition. Even with appropriate mitigation measures, impacts will occur. Subsequent decommissioning will result in short-term spikes of erosion and sedimentation followed by rapid declines over time. The net impact is to increase erosion and sedimentation relative to the undisturbed condition. References Cited: Rocky Mountain Research Station General Technical Report RMRS-GTR-231, January 2010. Cumulative watershed effects of fuel management in the Western United States. Pacific Northwest Research Station General Technical Report PNW-GTR-509, May 2001. Forest roads: A synthesis of scientific information.

Comment WA – 14 The final environmental impact statement and forest plan should incorporate the decree, the negotiated restrictions on management of suitable and eligible stream segments as well as the prohibition against additional reserved water rights. The final forest plan more fully discloses the negotiation and impacts of the water decree. Specifically, Colorado Division of Water Resources requests that the following items be included in the discussion of this case: 1) the significant negotiations and cooperation that went into the development of these water rights, and which resulted in a stipulated decree without the need for litigation; 2) what the reserved water rights provide to the Forest in terms of beneficial uses of the water; 3) the fact that the instream flows decreed to the United States in this case satisfy fully any need for instream flows in the Gunnison and Rio Grande National Forests in Water Division No. 3; 4) the prohibition against claiming additional appropriative instream flow water rights in Colorado Water Division No. 3 for National Forest purposes; 5) that the decree allows the development of water projects on RGNF land, provided that there were decreed existing absolute or conditional water rights for those projects as of December 31, 1998. Response The 81CW183 Decree is a legally binding agreement that the United States has entered, there is no need to restate the conditions of the Decree as forest plan components. The Forest Service acknowledgment of the 81CW183 Decree is contained in the Record of Decision.

Comment WA – 15 The primary impact to water quality, in terms of biological, nutrient, as well as sediment is livestock grazing. Currently, very little water quality monitoring takes place on the Forest and what has been done shows major exceedances of fecal coliform, so to characterize water quality as "generally good" is misleading and disingenuous.

182 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response No reference to specific studies or water quality outcomes from the Forest is provided. Based on the Colorado Department of Public Health and the Environment 2018 303(d) listings, the water quality on 100 percent streams within the Rio Grande National Forest boundary fully supports recreational and agricultural uses. Water quality is sufficient to fully support aquatic life on greater than 80 percent of analyzed stream miles.

Comment WA – 16 It is not likely that the plan direction [for groundwater-dependent ecosystems] will provide for the integrity of fens and other groundwater-dependent ecosystems nor the species that depend on them for persistence. Desired condition for fens in the “especially pristine” condition should be established so that conditions can be maintained. Response The forest plan includes standard S-GDE-1: Do not authorize management actions that alter the hydrology of groundwater-dependent habitat features. (Forestwide) In the professional experience and judgement of the interdisciplinary team that the plan components related to the protection of groundwater-dependent ecosystems (including fens) are sufficient to protect these areas. These areas will also be identified in site-specific analysis and potentially have additional project-level mitigations applied.

Comment WA – 17 The draft environmental impact statement fails to effectively analyze the effects of the forest plan on groundwater dependent ecosystems. The reader has no idea whether the draft plan direction will provide for the ecological integrity of these system types, nor the viability of the species that depend on them. Response In the professional experience and judgement of the interdisciplinary team, the plan components related to the protection of groundwater-dependent ecosystems (including fens) are sufficient to protect these areas. Direct and indirect effects on watershed related resources, including groundwater-dependent resources such as fens, were covered in the draft environmental impact statement at pp. 174-184 and 187-190.

Comment WA – 18 Based on information in the Aquatics Assessment, there is a need for the forest plan to include plan direction to 1) maintain excellent/good condition in areas with that condition and 2) protect and restore integrity to low elevation seeps and springs threatened by water diversions, trampling etc. Response In the professional experience and judgement of the interdisciplinary team, the plan components related to the protection of groundwater-dependent ecosystems (including springs) are sufficient to protect these areas.

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Comment WA – 19 The environmental impact statement should provide plan components that address the low integrity of low elevation aquatic systems and whether negative effects are likely to continue, and whether the plan is likely to provide for viability of associated species of conservation concern. Response The environmental impact statement analyzes the effects of implementing the plan components. In the professional experience and judgement of the interdisciplinary team, the plan components in the forest plan related to the protection of aquatic systems are sufficient to protect these areas.

Comment WA – 20 The environmental impact statement can only rely on plan components to determine the effects of the plan. (DEIS, page 167) Plan direction does not "prescribe extensive measures"; the draft environmental impact statement must document all of the measures and let the reader decide if they are extensive and prescriptive. There is no basis for the assumption that measures will be implemented and will be effective. The plan depends heavily on desired conditions to meet the rule. Response The draft and final forest plans list the applicable plan components. The environmental impact statement analyzed the applicability of plan components (and higher level law, regulation, and policy) on the identified alternatives and resource areas. All plan components included in the selected alternative will be applied to all subsequent projects in accordance with the requirements of the National Forest Management Act.

Comment WA – 21 More explanation on the applicability of the cited 1980 study is necessary to support the conclusion that the plan provides for the integrity of watersheds. The draft environmental impact statement then discloses site-specific concerns for “certain sensitive watersheds” but that impacts to those watersheds is considered on a project-by-project, site-specific basis. For years, the Forest Service has been avoiding addressing broad-scale effects during project analysis by saying that they are “beyond the scope” of that analysis. Now that it is time to consider those effects at the forest plan level, we expect the Forest Service to take a serious and rigorous look at the choice of plan components that will drive future projects and their impacts. Response Broad-scale impacts to watersheds have been considered in the analysis. There are numerous plan components that address watershed characteristics. Because the plan does not authorize specific activities that would affect watershed condition, the analysis at the plan level relies on the application of the plan components across the alternatives in the environmental impact statement.

184 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment WA – 22 The implications for watershed integrity on the assumption that forest plan direction is “typically effective” need to be expanded, along with the analysis supporting the generalized conclusion that “In general, fuels treatments would not be expected to result in measurable impacts to water yield because such treatments…primarily target the understory and small- diameter trees; therefore, they may not measurably alter basal area” (DEIS p. 179). Describe in more detail what is meant by “alternative C would be expected to have the most watershed impacts from timber harvest” (DEIS at 179). This analysis should be done within the context of the rule requirements for watershed integrity. Response Please refer to the response to Comment WA – 13.

Comment WA – 23 While the adaptive management strategy is a positive step, any condition that might trigger a new management opportunity should be weighed against the impacts to the water resources and its dependents in the region. Response Any changes brought forward as a result of the adaptive management strategy will include public involvement. This will help weigh the impacts.

Comment WA – 24 Support for Goal #1, the original premise of national forests as a tool to protect watershed and water quality for user health and environmental protection. Response Note: Forest plan goals were reordered between issuing the draft and final documents. Goal #2 specifically addresses water-related topics, watersheds, and watershed health. Desired conditions address topics include water quality and quantity.

Comment WA – 25 At desired condition DC-WA-1, the plan should identify how the physical channel condition will be measured, what the natural ranges of discharges and sediments are, define the most probable form, define correct function mean in this context, and describe the Forest’s interpretation of “minimal effects” to hydrologic processes. Response Due to variation in channel condition, this is best described at the site-specific level of analysis. The intent is to move toward the best resource conditions that are described in higher level direction, which is not to be repeated (FSH 1909.12 § 22.1). A management approach has been added that describes some of the variability within the watershed.

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Comment WA – 26 Regarding desired conditions DC-WA-2, 3 and 4, identify how the conditions will be evaluated. When plan components simply repeat the requirement for natural resource variability (or other requirements of the Planning Rule) it means that someone implementing the plan has total discretion to determine what is needed for ecological integrity. This violates the requirement in the Planning Rule that plan components do so planning documentation, using the effects analysis within the environmental impact statement, must demonstrate that ecological integrity of each ecosystem is restored and maintained. This will require a determination of natural resource variability and a comparison to the projected future conditions. Response See response to comment WA – 25.

Comment WA – 27 The forest plan should define natural conditions (DC-WA-6) so they can be measured and evaluated. The term “especially” implies that plan direction will be implemented inconsistently. Response FSH 1909.12, Section 23.12 subscribes language from higher level direction that is to be included in the forest plan. Higher level and forest plan level direction is applied indiscriminately.

Comment WA – 28 Desired condition DC-WA-7 sounds like a good goal statement. Desired conditions should be measurable and define what “clean” and “safe” mean for planning purposes. Response Forest Service Handbook 1909.12, Section 23.12, subscribes language from higher level direction that is to be included in the forest plan. Higher level and forest plan level direction is applied indiscriminately.

Comment WA – 29 The forest plan should have a desired condition for condition class to support implementation of OBJ-WA-1. The water condition framework is a useful tool to support forest planning for watershed integrity. Its indicators of ecological, hydrologic, and geomorphic condition should be used to develop forest plan components for watershed integrity, not just for the three priority watersheds identified in the plan. Response Condition classes are described in other direction and not repeated here.

186 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment WA – 30 Regarding objective OBJ-WA-2, the forest plan should identify the implications of the water decree on watershed/ecosystem integrity planning and management under the current instream flow quantification scheme. The forest plan (OBJ-WA-3) should identify the implications of the information on watershed/ecosystem integrity planning and management. Response The 81CW183 Decree is a legally binding agreement that the United States has entered. The Forest Service acknowledgment of the 81CW183 Decree is contained in the Record of Decision. These objectives have been combined. A determination on moving quantification points may be made at a future time based on a site-specific need. This is not currently within the current fiscal capability of the unit.

Comment WA – 31 Direction should be included in the forest plan and not referenced elsewhere (S-WA-1). Response Forest Service Handbook 1909.12, Section 22.1, directs that plan components should not “merely repeat existing direction from laws, regulations, or directives.”

Comment WA – 32 Guidelines G-WA-1 and G-WA-2 do not conform to the definition of guideline and should be rewritten. Response Guidelines are described in the 2012 Planning Rule as “a constraint on project and activity decision-making that allows for departure from its terms, so long as the purpose of the guidelines is met. Guidelines are established to help achieve or maintain a desired condition or conditions, to avoid or mitigate undesirable effects, or to meet applicable legal requirements” (36 CFR 219.7(3)(1)(iv)). G-WA-1 has been revised to include project constraints applicable to the Clean Water Act.

Comment WA – 33 Guideline G-WA-1 should explain what “long-term degradation” means in the context of rule requirements and define “particular attention.” Response We believe this comment refers to forest plan G-WA-2. Particular attention means that we will provide a greater focus on waters that provide water to public water supplies, sole source aquifers, and source water protection areas. Often managing resource causes short-term reductions in water quality and quantity. The intent of guidelines G-WA-2 is that resources would not be degraded over the long-term. Management measures that maintain or improve long-term stream health and riparian ecosystem condition are further defined in Forest

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Service Handbook 2509.25, in section 12.1. Short-term in this context was considered up to five years after implementation, while long-term is anything greater than five years. Implementation of G-WA-2 could reduce site-specific mitigations that would reduce any negative impact to water quality or quantity, particularly in areas with public water supplies, sole source aquifers, and source water protection areas.

Wilderness (WILD)

Comment WILD – 1 Some commenters stated that the Forest needs to protect and increase the amount of wilderness areas, while others pointed out that additional recommended wilderness creates barriers restricting multiple uses and limits the ability of managers to address challenges and capitalize on opportunities in a timely manner. Response The final environmental impact statement contains detailed analysis of five alternatives with a variety of recommended wilderness acreages. These alternatives ranged from zero acres of recommended wilderness in alternatives A and C, to 284,853 acres of recommended wilderness in alternative D. The selected alternative and record of decision recommend an additional 40,052 acres of wilderness. This recommendation represents a compromise between the protections afforded by wilderness and the management flexibility that is retained in non-wilderness management areas. The decision to recommend an additional 40,052 acres was informed by the wilderness inventory and evaluation process, in which the Forest identified potentially suitable areas, evaluated their wilderness characteristics, and analyzed the impacts of potential wilderness designation in the environmental impact statement. It was the conclusion of the responsible official that, on these 40,052 acres, the benefits to be obtained through wilderness designation outweigh any additional limitations on management options. The final environmental impact statement considered the impact of additional recommended wilderness on a wide variety of resource areas. The analysis notes potential benefits from recommended wilderness in the form of increased carbon sequestration, maintenance of aquatic ecosystem integrity and watershed resources, and positive impacts for species of conservation concern. Increased wilderness also provides additional opportunities for primitive recreation and solitude. On the other hand, the environmental impact statement also acknowledges that additional acres of wilderness could lead to increased costs to grazing permittees, reduced opportunities for energy development projects, and restrictions on the ability to improve lynx and other habitat. Access for multiple use and opportunities for expanded motorized and mechanized recreational use would also be reduced. The responsible official’s decision accounts for all of these likely impacts of wilderness designation and recommends the 40,052 acres with a high degree of wilderness character and, due to their remote and inaccessible nature and adjacency to existing wilderness, a lower probability of conflicting with other management goals and multiple uses. Consultation with tribal governments also informed the decision, which will increase protection for Mt. Blanca, which is sacred to the Navajo, Ute, and Jicarilla Tribes.

188 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments The impact to management flexibility from this recommendation is tempered by the fact that more than 12,000 of the 40,052 acres recommended for wilderness designation are currently Colorado Roadless areas, which are subject to management restrictions. In addition, despite the recommendation for increased wilderness acres, the forest plan also represents an increase of about 150,000 acres suitable for timber production. Increased protection for the 40,052 acres of recommended wilderness are balanced by an increase in management flexibility achieved through additional acres suitable for timber production. In sum, the decision to recommend additional acres of wilderness was based on a careful consideration of public preferences, and the social, economic, and environmental impacts associated with wilderness designation.

Comment WILD – 2 Mountain bikes should be excluded in wilderness. Response The Forest Service manages wilderness areas under the authority of the Wilderness Act of 1964 and the regulations and policies enacted in accordance with that law. Section 4(c) of the Wilderness Act prohibits any “form of mechanical transport.” In accordance with the Wilderness Act, mountain bike use is not authorized in any wilderness area.

Comment WILD – 3 Any new wilderness areas should not allow grazing, and grazing should be limited in existing wilderness areas, such as along the Saguache Creek drainage. Response The Forest Service manages wilderness areas under the authority of the Wilderness Act of 1964 and the regulations and policies enacted in accordance with that law. The Wilderness Act, and the regulations adopted under the authority of the Wilderness Act, allow for grazing to occur in wilderness areas where it existed prior to the designation of the area as wilderness. (36 C.F.R. § 293.7). Permittees are required to adhere to the terms and conditions set forth in the permit and the forest plan, both of which are designed to minimize impacts to National Forest System lands.

Comment WILD – 4 A buffer should be implemented between residences and recommended wilderness on Snowshoe Mountain. Response Federal wilderness designations do not identify buffer. Wilderness buffers are also not authorized in the Colorado Wilderness Act of 1980. The Wilderness Act establishes the boundary as the buffer and specifically says not to provide additional buffer unless adding wilderness area.

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Comment WILD – 5 Some commenters expressed concerns related to the impact that additional wilderness could have on important infrastructure such as ditches and SNOTEL sites. These commenters were particularly concerned with infrastructure owned by other agencies, organizations, and individuals. They stressed the importance of retaining the ability to efficiently repair infrastructure, especially in light of anticipated changing conditions. Response The Forest recognizes the importance of maintaining key infrastructure, especially in light of anticipated changes in climate that could increase stress on these resources. This is true whether the infrastructure is managed by the Forest Service or by neighbors and agency partners. The potential impacts of wilderness on the ability to maintain infrastructure were considered in the wilderness inventory and evaluation process and the final environmental impact statement. Ditches and SNOTEL sites were identified during the wilderness inventory and evaluation process and noted in the evaluation report. Presence of infrastructure was also considered during the analysis phase and included in Appendix A of the environmental impact statement. The Barbara Tobler Ditch and the Ridenour Ditch intersect proposed wilderness in alternatives B and D. The Paradise Ditch No. 1 intersects wilderness in alternative D. The presence of infrastructure was considered during the inventory, evaluation, and analysis phases of the wilderness process. Along with many other social, economic, and environmental factors, the responsible official took into account the potential impacts of additional wilderness on the ability to maintain infrastructure, and the recommendation in the final forest plan represents a balance between protecting the values associated with wilderness and maintaining flexibility for access, use, management, and maintenance.

Comment WILD – 6 Recommended wilderness near Bear Town and in the Conejos watershed could limit the ability to correct water impacts from historic mining. Response Information on historic mining activity was taken into account in the analysis. Potential limitations on the ability to remediate water impacts related to historic mining were one of several factors considered in the decision to not recommend this area for wilderness designation in the forest plan and record of decision.

Comment WILD – 7 Adding to the Sangre de Cristo, La Garita, and South San Juan’s with recommend wilderness in Antora Meadows, and Saguache Creek would protect these areas from oil and gas development and protect water, wildlife, and other resources. Choosing alternative D would increase protections for Canada lynx and boreal toad.

190 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response The final environmental impact statement considered many different factors in the analysis of potential impacts of wilderness designation. These factors included benefits to water, wildlife, and other resources related to increased protection under the Wilderness Act of 1964. Ultimately, the responsible official balanced these along with public support, and other considerations such as social and economic impacts of wilderness designation, in his decision to recommend an additional 40,052 acres of wilderness in the Sangre de Cristo area. It is important to note that wilderness designation is not the only mechanism for protecting sensitive areas and at risk species, and it is not always the most appropriate. In some cases, active management that would not be possible in wilderness areas may be necessary or helpful to maintain or restore habitat. The forest plan includes many plan components that are designed to protect at risk species like Canada lynx and boreal toad, and not just in designated and recommended wilderness areas.

Comment WILD – 8 Oil and gas development should not be allowed in recommended wilderness, special interest areas, or important fish and wildlife habitat. Response The regulation of mineral resource activities varies across the Forest, depending on the management area in which it occurs. These activities are guided by the forest plan, along with other laws, rules, and regulations. Under the Wilderness Act of 1964, new mineral leases are not permitted in designated wilderness areas. Recommended wilderness areas are treated differently because they have not been officially designated by Congress. The 2012 Planning Rule requires national forests to draft plan components for the management of recommended wilderness areas that will “protect and maintain the ecological and social characteristics that provide the basis for their suitability for wilderness designation.” (36 C.F.R. § 219.10(b)(iv)). As the environmental impact statement notes, recommended wilderness areas are not withdrawn from mineral entry and are available for new leases or claims as long as the social and ecological characteristics that provide a basis for wilderness designation are maintained and protected. The forest plan captures this approach with standard S-MA-1-1, which requires the Forest to preserve wilderness character in areas recommended for wilderness. This means that, prior to permitting oil and gas development at the project level, the Forest must account for any potential impacts to the wilderness character of a recommended wilderness area that could arise due to the activity. Special interest areas are a separate management area in the forest plan, with a different approach to management of oil and gas resources. The forest plan, through land suitability SUIT-MA 4.1-3, makes special interest areas “available for oil and gas leasing with no surface occupancy.” Restricting surface occupancy in these areas creates an additional layer of protection for the unique resources they contain, while still allowing for multiple use access. Important fish and wildlife habitat could occur throughout the Forest, and management of oil and gas resources will vary depending on the management area in which the habitat occurs.

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Regardless of the management area, the forest plan protects fish and wildlife habitat with Forestwide plan components designed to minimize impacts to these resources from other activities. In addition, some management areas, such as MA 1, 3, 4.1, and 4.2 include additional management constraints that will provide a high level of protection for fish and wildlife habitat. Potential impacts from mineral resource activities on fish and wildlife habitat were considered in detail in the analysis of the forest plan.

Comment WILD – 9 Recommended wilderness should be identified and discussed as a separate management area. Management direction should not be the same for designated wilderness as for recommended wilderness. Only Congress can designate wilderness, and the Forest Service does not have the authority to manage non-wilderness as a wilderness. Existing wilderness characteristics should be maintained but existing uses, even those prohibited in designated wilderness, should be allowed to continue in recommended wilderness areas. Response The 2012 Planning Rule, written under the authority of the National Forest Management Act, requires forest plans revised under the 2012 rule to include plan components for areas recommended for wilderness designation. These plan components, including standards and guidelines, must “protect and maintain the ecological and social characteristics that provide the basis for their suitability for wilderness designation.” (36 C.F.R. § 219.10(b)(iv)). The Land Management Planning Handbook, Chapter 20, notes that “the responsible official may provide one or more management or geographic areas” to organize plan components applicable to existing or recommended wilderness areas. As identified in the draft forest plan, there were two separate management areas for wilderness (MA 1.1) and recommended wilderness (MA 1.1a). The draft plan assumed that plan components in a wilderness management area would largely be applied to recommended wilderness. In the final forest plan components for recommended wilderness are better defined and appear with the designated management area (MA 1.1a). Managers are required to maintain wilderness characteristics identified that qualified the area for recommended wilderness. Enforcing direction associated with wilderness ensures that these characteristics are maintained.

Comment WILD – 10 The positive benefits of the continental Divide National Scenic Trail should be included in the wilderness evaluations and NEPA assessments. Response The final environmental impact statement notes the overlap between the Continental Divide National Scenic Trail and areas analyzed for recommendation as wilderness. Some users may prefer to hike through a wilderness area, but the plan components related to management of the Continental Divide National Scenic Trail have been designed, in cooperation with the public and other stakeholders, to ensure that the values for which the trail was designated are maintained or enhanced, and that all users experience the trail as Congress intended.

192 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment WILD – 11 The Como Lake Road should be cherry stemmed out of any wilderness designation. Response Roads were identified during the wilderness inventory and evaluation process. These will be considered on a case-by-case basis as the recommendation process moves forward. The Como Lake Road was cherry-stemmed out of the recommended wilderness area.

Comment WILD – 12 Existing special use permits should be disclosed with discussion of how new permits would be granted. Response Non-conforming uses were identified during wilderness inventory and evaluation. Existing special use permits will be identified and evaluated as wilderness recommendations move into the legislative process.

Comment WILD – 13 Sawlog, Snowshoe Mountain, Willow Mountain, and Pole Creek are all good choices for recommended wilderness. The southeast side of Snowshoe Mountain should be included in any recommended wilderness designation not the whole area north and west of Lime Creek road. Response Chapter 70 of the Land Management Planning Handbook gives discretion to the responsible official to determine areas from the wilderness evaluation to bring forward for analysis. Sawlog and Snowshoe Mountain were analyzed for wilderness recommendation under alternative D of the final environmental impact statement. The forest plan recommends 40,052 acres of additional wilderness adjacent to the Sangre de Cristo Wilderness. The final environmental impact statement considered a broad range of social, environmental, and economic impacts related to the designation of additional wilderness areas, and the responsible official selected alternative B modified, which struck a balance between wilderness values and the need to provide for multiple uses and retain management flexibility.

Comment WILD – 14 The Forest should inventory mountain bike trails before reaching a decision, the likelihood of developing new trails after recommending more wilderness is slim. Many of the areas recommended have potential for mountain bike use. Response The forest plan authorizes the construction of bicycle trails in four management areas (3, 4.21, 4.34, and 5), which constitute over 1.4 million acres.

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While mountain bike trails cannot be constructed in wilderness areas, the forest plan retains the flexibility to construct mountain bike trails in nearly 75 percent of the total forest area. The analysis considered the impact on different recreational user groups that would be caused by the varying levels of wilderness recommended in the five alternatives, and the responsible official’s selection of alternative B Modified represents a balance between mechanized and motorized uses and the desires of Forest visitors for solitude and a primitive experience.

Comment WILD – 15 The discrepancy in the number of acres recommended for wilderness needs to be corrected in the draft environmental impact statement. On page 29, alternative B recommends 59,000 acres, but on page 303, alternative B recommends 52,860 acres. Response Acres in the analysis are rounded, these numbers have been corrected.

Comment WILD – 16 The narratives in Appendix A of the draft environmental impact statement do not consistently address the need to expand ecosystem representation within wilderness, such as landscape connectivity, the larger context of landscape, lynx linkage areas, or landscape conservation. These important supplemental values should be documented in the area descriptions. Specifically, the contributions of the Antora Meadows/Bear Creek area, Elkhorn Peak area, Saguache Creek-Four Mile Creek-Taylor Canyon, North Fork Rock Creek, Sawlog, Snowshoe Mountain, Wannamaker Creek-Deep Creek, Wason Park addition, Sangre de Cristo–Pole Creek–Crestone–Cotton Creek–Hot Springs–Miller Creek–Butterfly additions to the Sangre de Cristo Wilderness, and Blanca Peak area should be considered for enhancing ecosystem representation within the National Wilderness Preservation System. Low elevation areas should be considered for recommended wilderness. Areas to include are Polygon 12 (Saguache) and North Fork/Rock Creek, which would increase the biodiversity of the wilderness system. Response Forest Service Handbook 1909.12, Chapter 70, provides guidance on the information that should be shared with the public from the analysis phase of the wilderness evaluation process. According to the direction in Chapter 70, the analysis should include a brief description of the general geography, topography, and vegetation of the recommended area; a brief description of the current uses and management of the area; a description of the area’s wilderness characteristics and the ability to protect and manage the area to preserve these; a brief summary of the factors considered and the process used in evaluating and developing the areas recommended; and a brief summary of the ecological and social characteristics that would provide a basis for the area’s suitability for inclusion in the national wilderness system. The information provided in Appendix A of the final environmental impact statement meets the standard set by the Forest Service Handbook. Analysis of potential areas is not confined to Appendix A of the final environmental impact statement. Other potential benefits of additional wilderness to forest resources were addressed throughout the analysis. For example, the Wildlife and Plants section of the final

194 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments environmental impact statement includes discussion of the potential benefits to Canada Lynx from wilderness designation. The wilderness inventory and evaluation was conducted in accordance with the Wilderness Act of 1964, the 2012 Planning Rule, and Forest Service Handbook 1909.12. During the inventory phase, all areas of the Forest were analyzed, regardless of supplemental values such as potential to enhance ecosystem representation within the wilderness preservation system. Likewise, during the evaluation phase, all areas of the inventory were evaluated using criteria from the Wilderness Act of 1964 to assess suitability for inclusion in the National Wilderness Preservation System, regardless of other supplemental values. Additional criteria such as contribution to ecosystem representation or connectivity are best considered in the analysis phase. Both Polygon 12 and the North Fork/Rock Creek areas were analyzed in alternative D of the final environmental impact statement, and Appendix A notes these and other unique qualities of the areas. The final decision on wilderness recommendation represents an analysis of these, and many other factors, to determine which areas on the Forest are most appropriate for wilderness recommendation.

Comment WILD – 17 The Pole Creek- Sheep Mountain area in Appendix A of the draft environmental impact statement is larger than the area that we submitted; the acreage should be the area that we had submitted to meet the planning rule requirement for ecological integrity and species diversity. Response The final environmental impact statement analyzed additional acreage in the Pole Creek area in response to the information derived from the inventory and evaluation process and as a result of comments received during scoping. Recommended wilderness areas were often adjusted to increase manageability by making them align with man-made and natural features.

Comment WILD – 18 Commenters suggest improvements to the narratives in Appendix A of the environmental impact statement. Additional details on Beartown-Indian Ridge, Cumbres-Elk Creek, and Tobacco Lakes-Gold Creek-Cascade Creek would enhance the analysis and the public understanding of benefits and unique features offered by these areas, such as the potential for enhanced experience on the Continental Divide National Scenic Trail. Response Forest Service Handbook 1909.12, Chapter 70 lays out the content that should be made available to the public in support of the analysis of any wilderness areas brought forward by the responsible official. (FSH 1909.12, Ch. 73). Appendix A of the environmental impact statement tracks closely with the language of the handbook and all of the information required by the Handbook is provided for each area analyzed under the five alternatives. The description, in Appendix A, of the Beartown-Indian Ridge area notes the presence of the Continental Divide National Scenic Trail. Some users may prefer to hike through a wilderness area, but the plan components related to management of the Continental Divide

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National Scenic Trail have been designed, in cooperation with the public and other stakeholders, to ensure that the values for which the trail was designated are maintained or enhanced, and that all users experience the trail as Congress intended.

Comment WILD – 19 Forest planners must avoid artificial elevation of issues as a result of political pressures and concerns that are not based on issues seen. Response The forest planning process, including wilderness inventory and evaluation, was developed consistent with law, regulation, and policy. All letters and comments were reviewed for issues. Public input informed decision-making and helped establish a range of alternatives to analyze. A wide range of proposed wilderness acres was analyzed in the environmental impact statement.

Comment WILD – 20 Visitor use statistics do not reflect a need for additional wilderness. Response The 2012 Planning Rule requires all national forests undergoing plan revision to conduct a wilderness inventory and evaluation to determine whether additional areas on the forest should be recommended for addition to the National Wilderness Preservation System. Visitor use statistics are not specifically identified by the Wilderness Act of 1964, 2012 Planning Rule, or Forest Service Handbook as a factor that should be considered during the wilderness evaluation process. However, during the analysis phase, it is appropriate for the responsible official to consider a number of social, economic, and environmental factors to determine whether additional acres should be recommended for wilderness designation. In the final environmental impact statement, the Forest addressed the range of wilderness included in the five alternatives and discussed how those alternatives might affect different classes of Forest visitors and recreational users. Throughout the process, the Forest has heard from organizations and individuals wishing to see more wilderness, and commenters who have expressed the opposite sentiment. The Wilderness Act of 1964 identifies the need for wilderness areas where people can find opportunities for solitude. By its nature, and in keeping with the intent of Congress, recreational use in wilderness is unlikely to be as intensive as in other areas of the national forest. While visitor use and demand for different recreational services is one factor to consider in an analysis, it does not, by itself, answer the question of whether it is appropriate to recommend additional acres for wilderness designation.

Comment WILD – 21 Research shows a correlation between wilderness and impacts from invasive species. Response Analysis of the forest plan considers a number of potential tradeoffs from wilderness designation, including impacts stemming from reduced management flexibility. For example, the final environmental impact statement acknowledges that wilderness designation typically

196 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments provides a high level of protection for many natural resources, but it can also prevent or limit some necessary natural resource management practices such as the use of motorized equipment to treat nonnative invasive plant species. The decision to recommend additional acres of wilderness accounted for these potential impacts to management flexibility, and the forest plan includes some guidance on addressing nonnative invasive species in wilderness areas. The desired conditions for the wilderness management area describe a system composed of native plant species, where populations of nonnative invasive species are limited and ongoing management activities control existing populations and eradicate new species before they become established. The 2016-2019 Invasive Species Action Plan also contemplates a programmatic minimum required tools analysis that would facilitate treatment in designated wilderness if necessary.

Comment WILD – 22 The current acreage and location of wilderness is sufficient compared to the size of the Forest. The amount of wilderness in the Forest is well balanced at this time. The recommended Pole Creek Wilderness is not necessary, the area is already balanced with the Weminuche Wilderness nearby, and the area around Bear Creek, Pole Creek, and Finger Mesa is well balanced with uses and do not warrant wilderness recommendations. Areas with new wilderness (Bear Town, La Manga, and Crestone) need to retain access so trails can be reached by vehicle. Response The 2012 Planning Rule requires national forests undergoing plan revision to “identify and evaluate lands that may be suitable for inclusion in the National Wilderness Preservation System and determine whether to recommend any such lands for wilderness designation. Forest Service Handbook 1909.12, Chapter 70, outlines the steps that national forests should take to meet this requirement of the planning rule. The Forest conducted a wilderness inventory and evaluation in accordance with the regulation and policy of the planning rule and the handbook, and that process indicated that several areas met the criteria for recommendation for inclusion in the National Wilderness Preservation System. Forest Service Handbook 1909.12 does not direct national forests to consider the amount of existing wilderness in or near national forests during the inventory and evaluation stage. However, the balance between competing land uses and the amount of wilderness existing on the national forest are relevant topics for the evaluation stage, which is documented in the environmental impact statement. The final environmental impact statement noted many of the tradeoffs associated with the recommendation of additional wilderness, and potential impacts on multiple use access and management flexibility. The forest plan, which includes a recommendation for 40,052 additional wilderness acres, reflects an informed decision of the responsible official that accounts for all social, economic, and ecological factors, including the amount of existing wilderness in the area. Access roads to trailheads were considered and remain outside of recommended wilderness areas.

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Wildlife (WLDF)

Comment WLDF – 1 Plan components that protect the value and functionality of production areas, transitional habitats between summer and winter range, and migration routes need to be added for wildlife species. Response There is no requirement for the plan to provide components at this level of specificity for all wildlife species. The revision process identified species of conservation concern and the plan provides coarse and fine filter plan components to maintain ecological conditions that support viable populations. In addition to species of conservation concern, other species are also evaluated. The plan includes wildlife plan components, including desired conditions for habitat connectivity and home ranges, seasonal movements, and long-distance movements across boundaries (DC-WLDF-3); habitat conditions for spatial arrangement of forage, cover, and security for mule deer, pronghorn, bighorn sheep, and elk (DC-WLDF-4); and for limits to motorized and non-motorized recreation that will trend toward maintaining and improving migration routes and corridors (DC-WLDF-5). Other plan components in other sections also contribute to protection of breeding and production areas. Bighorn sheep are addressed in other sections of the plan, particularly in the Range and Species of Conservation Concern sections.

Comment WLDF – 2 Continued coordination with the Forest Service is welcomed and encouraged. Response The forest plan supports maintaining existing relationships and fostering new collaborations. The agency actively coordinates with multiple groups already, including Colorado Parks and Wildlife, The Natural Resource Conservation Service, The Colorado Water Conservation Board, and the State of Colorado Departments of Natural Resources and of Public Health and Environment. Those partnerships are structured through Memorandums of Understanding (MOU) that are described in Appendix H. Management approaches included in the forest plan provide focus on maintaining ongoing relationships with other agencies and fostering new ones. Continued coordination with other agencies and partners is also addressed in Comment WLDF – 69.

Comment WLDF – 3 The draft forest plan lacks direction to achieve the specified desired conditions. Response In response to internal and external comments received, plan components, including desired conditions, objectives, standards, and guidelines, have been revised to better meet the intent and direction of the 2012 Planning Rule (36 CFR 219) and its implementing direction (FSH 1909.12). The intent of the direction did not change; rewrites combined like direction, added

198 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments clarity, and added specificity. Much of the implementation of the forest plan will require subsequent analysis to be completed. This analysis will show how resources are moving toward or away from desired conditions. The monitoring and adaptive management process are intended to show where the forest plan needs to be adjusted to better move resources toward desired conditions.

Comment WLDF – 4 Motorized trail density in production areas, winter concentration areas, severe and critical winter range for big game should be 1 mile/square mile or less. Response Management Area 5 sets a desired condition of “1 mile per square mile provide for critical wildlife needs, in areas used for winter concentration, critical winter range, calving areas, and transition habitat.” Forest plan direction, G-WLDF-1 does allow for seasonal closures (Dec. 1 through March 31), as needed, to protect wildlife on winter range.

Comment WLDF – 5 The forest plan should address constraints of wilderness management on wildlife management tools and provide opportunities to permit wildlife management tools and activities to occur in wilderness. Response Because tools, such as the Minimum Requirements Decision Guide, are available and have been used in the past to evaluate and authorize such activities, further forest plan direction is not needed at this time. In addition, the plan restricts stocking to native fish in wilderness. This is primarily accomplished through aerial stocking.

Comment WLDF – 6 Big game movement between Colorado and New Mexico is important and the Spruce Hole/Osier/Toltec Connectivity Special Interest Areas is needed. Response Big game movement is important and has been accommodated in the forest plan direction. The intent of the plan direction and management areas was to accommodate energy and genetic flow across the landscape, including big game movement. Goals have been reformatted, and Goal 1 focuses on connectivity. Numerous other plan components address connectivity at different scales and provide flexibility to allow managers to maintain and restore connectivity. Lynx management direction also includes multiple components relating to connectivity. Although geared toward lynx, such connectivity may also benefit other wildlife species as well. Component DC-WLDF-5 directly addresses this issue, as does S-RMZ-1 and G-RMZ-1.

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Comment WLDF – 7 Recommendations in the 2012, "Recommendation for Domestic Sheep and Goat Management in Wild Sheep Habitat" should be used in refining forest plan standards. Response Wildlife staff are familiar with the 2012 WAFWA document, which is commonly cited for the development of a risk assessment tool for bighorn sheep. The document is used extensively in project-level analysis and management.

Comment WLDF – 8 Edit plan, page 88, MA 5.41 paragraph 7, 2nd sentence to read "Grazing systems are managed to provide the quantity and quality of forage for use by big game species." Response The statement has been corrected and is included in MA 5.

Comment WLDF – 9 The environmental impact statement and the monitoring section should address how species lists will be updated. Response Updates to the species of conservation concern list will be done according to agency policy and procedures. Needs to update the list should be informed by plan monitoring and monitoring from other partners.

Comment WLDF – 10 The first bullet on page 7 of the draft environmental impact statement needs to be updated to say that the black footed ferret is not in the Forest so the actual number is 7. Response The black-footed ferret occurred on the Forest historically. Although the species has been extirpated for several decades, the Forest still provides potential habitat. Under the 2012 Planning Rule, the U.S. Fish and Wildlife Service determines which threatened, endangered, and candidate species the Forest Service needs to analyze. Although the black-footed ferret has not been present in the plan area for many years, the Forest Service is still mandated to examine impacts to potential habitat and to the potential for the species to repopulate, even if there are no plans to reintroduce the species.

Comment WLDF – 11 Lynx direction needs to be addressed consistently throughout the draft environmental impact statement. In some cases it says that alternatives B and D include revised direction and that A or C do not but others say all action alternatives (B, C, and D) include revised management.

200 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response The different consideration of direction by alternative is intentional to show a range of effects for the responsible official. The information has been corrected.

Comment WLDF – 12 Wildlife corridors between roadless areas need plan direction protecting them. Response Big game movement has been accommodated in the Forestwide plan direction in the forest plan. Many roadless areas are connected to designated wilderness areas, which extends protection for movement into those protected lands. Plan direction and management areas to accommodate energy and genetic flow across the landscape, including big game movement. Habitat connectivity is highlighted in Goal 1, as well as in desired condition DC-WLDF-3.

Comment WLDF – 13 Seasonal travel closures need to be expanded and implemented. Response Seasonal closures are developed at the project level based on site-specific conditions. However, several proposed plan components acknowledge a potential need for seasonal closures with primary examples associated with watershed and wildlife protection.

Comment WLDF – 14 The plan should include strong standards to protect pure Rio Grande cutthroat trout, fens, and high quality lynx denning habitat. Response The current plan components address these important resources. The Forest commits to continuing to support the recovery and conservation efforts for the Rio Grande cutthroat trout as structured through the Conservation Agreement for that species. Goal 2 of the Forest Plan also focuses on aquatic species, including the Rio Grande cutthroat trout. Fens are addressed in the Management Approaches for Wildlife and Plants, and in Management Approaches for Groundwater-Dependent Ecosystems. Component DC-GDE-1 specifically addresses the protection of fens, as does DC-WA-4. The plan includes significant direction and multiple components relating to Canada lynx, as described in both the Threatened, Endangered, Proposed, and Candidate Species (TEPC) section as well as in Appendix E.

Comment WLDF – 15 The forest plan should protect key species, such as boreal toad and Canada lynx.

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Response The boreal toad is recognized as a species of conservation concern. Plan components are included to address boreal toad habitat as well. Much of the management direction in the Southern Rockies Lynx Amendment has been incorporated into the forest plan as well (see Appendix E). In addition, the forest plan has included new plan components to address the protection and management of lynx habitat in existing spruce-fir habitat.

Comment WLDF – 16 The direction on pollinators is confusing and should be deleted. Response In response to internal and external comments received, plan components, including desired conditions, objectives, standards, and guidelines, have been revised to better meet the intent and direction of the 2012 Planning Rule (36 CFR 219) and its implementing direction (FSH 1909.12). The intent of the direction did not change; rewrites combined like direction, added clarity, and added specificity. Pollinator direction has been included in the Wildlife section of the forest plan.

Comment WLDF – 17 The desired conditions need to be rewritten to conform to the definition of Desired Condition in the 2012 Planning Rule so they are measurable and able to be monitored. Response In response to internal and external comments received, plan components, including desired conditions, objectives, standards, and guidelines, have been revised to better meet the intent and direction of the 2012 Planning Rule (36 CFR 219) and its implementing direction (FSH 1909.12). The intent of the direction did not change; rewrites combined like direction, added clarity, and added specificity.

Comment WLDF – 18 Management approaches cannot be used in lieu of plan components, many of them should be removed. We do not support the proposed use of Management Approaches for wildlife. Management approaches are not plan components and cannot be used in lieu of Plan Components. When you rewrite the Management Approaches as Plan Components, we recommend that you simply delete about 50 percent of them. Response Management approaches are described in Forest Service direction (FSH 1909.12 §22.4) as optional content that could facilitate transparency and give the public and governmental entities a clear understanding of the plan and how outcomes would likely be delivered. Management approaches can describe strategies and program priorities that the responsible official intends to employ to carry out projects and activities. In response to external and internal comments, management approaches have been revised in format and content to meet the direction in Forest Service Handbook 1909.12.

202 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment WLDF – 19 The Big Game Winter Range Management Areas (MA 5.41) should include suitable timber lands and not limit winter vegetation treatments which are critical. Paragraph 3 states that “Disturbance is limited during the primary winter use period,” while paragraph 4 states that “Vegetation treatments occur during the winter.” Flexibility for winter logging is crucial for forest products companies, and we recommend you rewrite that direction to provide flexibility for winter operations. Response In response to public comment, management areas have been simplified and reduced in numbers. The big game winter range areas are included in the suitable timber base. The forest plan recognizes and allows flexibility for potential habitat improvement using various vegetative treatments in big game winter range but also recognizes the potential need to restrict management activities during the critical winter use period to provide security habitat for big game species. The needs will be addressed on a site-specific basis at the project level.

Comment WLDF – 20 The Forest should not rely on the health of one herd (the Sangre de Cristo herd) as an appropriate approach to ensuring persistence. Response In response to internal and external comments, the Regional Forester has added bighorn sheep to the list of species of conservation concern. Coupled with this, components were changed to strengthen protections for the species, such as changing standard S-SCC-1 from the draft to the final version of the forest plan by changing the action from “mitigating impacts” from activities to “not authorizing” activities detrimental to bighorn sheep.

Comment WLDF – 21 Plan direction to protect habitat by reducing fragmentation should be addressed by decommissioning and obliterating roads and removing obsolete fencing. Response Road management decisions including closing, decommissioning, and obliterating road mileage are accomplished at the project level. The forest plan recognizes this need in association with riparian zones and watersheds and with security habitat for wildlife.

Comment WLDF – 22 The following comments on the off-road game retrieval direction were received: • The outdated practice of motorized game retrieval should be discontinued; each of these tracks offer a potential trail to follow. • Off-road motorized game retrieval should not be allowed.

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• There needs to be a standard protecting the Forest and limiting off-road game retrieval allowed. Such activity creates new “roads” that are then used more and more and ultimately tear up the landscape. Response Forest plans do no restrict activity by the public, they direct activities conducted by the agency. The Rio Grande is one of the few forests that allow for off-road game retrieval during certain times of the day. This activity is restricted to open motorized roads shown on the motorized visitor use map and is only applicable in Management Area 5. The management approach presents time and conditions when this activity would be acceptable.

Comment WLDF – 23 Colorado's population is projected to increase from 5.5 million to 8.3 million by the year 2050. Visitor education and enforcing the use of all-terrain vehicles on authorized trails only for all purposes, including game retrieval, is necessary to avoid fragmentation of wildlife habitat as visitor use increases. Response Access is an important and value-laden consideration in managing the national forests. Off-road game retrieval during certain times of the day is an authorized use in Management Area 5.

Comment WLDF – 24 The forest plan is not in compliance with Forest Service Manual 2621.2 by failing to develop or implement effective conservation strategies for sensitive species. Response Forest Service Manual 2621.2 (now 2670.22 Objectives for Sensitive Species) direction instructs national forests to develop and implement conservation strategies for sensitive species and their habitats, in coordination with other Forest Service units, managing agencies, and landowners. In association with the Forest Service Rocky Mountain Regional Office, the Rio Grande National Forest has implemented these objectives based on species needs, funding, priorities, and other considerations. Upon completion of the forest plan, the Forest will no longer address Regional Forester sensitive species. Final handbook direction is still being completed. Handbooks undergo public review and input before being finalized.

Comment WLDF – 25 The draft environmental impact statement and forest plan fail to address multiple occurrences of ecological conditions for sensitive species so that not all occurrences could be eliminated by one catastrophic event. Response The forest plan addresses ecological conditions Forestwide. The forest plan ensures ecological conditions to maintain persistence of species of conservation concern.

204 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment WLDF – 26 The draft environmental impact statement and forest plan fail to address requirements specified in the Federal Register (77 FR 21217, April 9, 2012). Plan components that provide for ecological conditions to maintain a viable population of species must keep in mind the definition of population found in the preamble to the 2012 Planning Rule and whether there is sufficient distribution in the context of the species natural history and historical distribution. The analysis does not provide documentation of how plan components will ensure the needed ecological conditions, or whether plan components are adequate versus needing species- specific components. Meaningful plan components are not presented for at-risk species, the plan cannot rely on monitoring to meet diversity requirements. The analysis and methods section needs to clarify if habitats is synonymous with ecosystems, not much information is associated with the various habitats. The Forest appears to be attempting to use a “proxy on proxy on proxy” approach to addressing viability in this case, where an ecological condition is analyzed to determine the effects on habitat for a group of species, which is used to determine effects on habitat for an individual species, which is then ostensibly used to determine viability of the species population. This involves establishing major assumptions about the relationships of individual species populations to their habitat, and of those habitat requirements to the groupings used in the analysis. The best available scientific information used as a basis for these assumptions must be documented. The at-risk species that desired conditions are targeting are not identified which makes it difficult to know if they meet the requirements for snag and downed wood dependent species. Response Appendix D addresses how plan components address ecological conditions for species of conservation concern. The assessments, forest plan, and environmental impact statement all include lists of references considered. This is in addition to other scientific information that was reviewed and not cited. In response to internal and external comments received, many of the plan components have been clarified. Five desired condition components were added to the Species of Conservation Concern section, as was one new guideline, in addition to bighorn sheep-related components that were moved from the Wildlife section into the Species of Conservation Concern section. The ecological conditions required by species of conservation concern are included in plan components, but reference to individual species were removed from components in an effort to ensure that such components are more broadly protective of any and all species that require such habitats, rather than being limited to species of conservation concern.

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Comment WLDF – 27 The environmental impact statement should tie to the conditions from the assessments and list plan components designed to provide that condition as well as assess effects of plan implementation on the conditions. Response The conditions in the assessment provided the basis for the analysis. The draft version of the plan linked many plan components to species. This final version of the forest plan removed the linkage to ensure that such components could be understood to apply to all species that use such habitats and not be limited to species of conservation concern.

Comment WLDF – 28 New Lynx Analysis Unit analyses must be prepared to account for the beetle impacts, the Forest must also incorporate updated information from the Squires et al. study. Response Habitat baseline conditions involving lynx habitat on the Forest were updated in February 2018, including the delineating of Lynx Analysis units. Information from the Rocky Mountain Research Station Lynx Study (Squires et al. 2018) has been incorporated into the forest plan.

Comment WLDF – 29 The analysis does not provide enough information on how maximizing habitat connectivity in alternative D contributes to ecosystem integrity and species persistence. Response Programmatic level analysis does not provide on-the-ground level analysis of effects but rather addresses effects at a much higher level than the project-level analysis.

Comment WLDF – 30 The lack of information on the current condition of Gunnison sage-grouse habitat limits the ability to analyze the effects of plan components; there is no assessment of the current habitat conditions and potential recovery habitat. Response This habitat makes up a very small portion of the planning area. Plan components address overall maintenance and improvement of the existing habitat. Site-specific analysis would address more specific habitat components and outcomes.

Comment WLDF – 31 The analysis does not provide any assessment of effects for Mexican spotted owl, southwestern willow flycatcher, western yellow-billed cuckoo, and wolverine; federally recognized species must be addressed if they "may be present" in the plan area (50 CFR 402.12(c)(1)(d)).

206 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response The Biological Assessment includes a detailed analysis of these species for the selected alternative. Section 7 consultation requirements with the U.S. Fish and Wildlife Service incorporate information into forest plan direction.

Comment WLDF – 32 The environmental impact statement did not state which alternative was preferred. Response Upon release of the draft environmental impact statement, no preferred alternative was identified. Section 1502(e) of the National Environmental Policy Act requires that the environmental impact statement “identify the agency’s preferred alternative if one or more exists, in the draft statement, and identify such alternative in the final statement…” If the agency has a preferred alternative at the draft environmental impact statement it must be identified “If the responsible federal official in fact has no preferred alternative… a preferred alternative need not be identified…” (NEPA’s Forty Most Asked Questions, CEQ). The preferred alternative in the final environmental impact statement is alterative B Modified.

Comment WLDF – 33 The maintenance of motorized game retrieval would help facilitate wildlife management objectives. Response Motorized or off-road game retrieval is included in the forest plan direction for Management Area 5. The motorized visitor use map defines where that use is allowed, defines restrictions on when it may occur, and requires that it be done in a manner that not damage resources including soils and vegetation.

Comment WLDF – 34 The effects analysis related to forested ecosystems and associated at-risk species is consistent with problematic patterns found throughout the draft environmental impact statement. For example, the analysis presents no accounting of effects of plan components on the Forest’s natural values and resources (including at-risk species). It provides weak and relative comparisons of the effects of the alternatives on the key characteristics selected to assess ecosystem integrity. It is not always clear which scientific and other information was selected as the Best Available Scientific Information driving decisions, and given the array of information such as modeling results and peer-reviewed science that sometimes offer conflicting findings, providing documentation that explains which information is considered the Best Available Scientific Information is essential. It’s not always clear the assessment findings are driving decisions, and the draft environmental impact statement must document when and why this is justified. The effects analysis related to forested ecosystems fails to assess effects from livestock grazing, mining, energy development, climate change, roads, and possibly other sources of effects influenced by draft plan proposed management

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direction, and these could have significant adverse effects; this is a deficiency. The assessment of impacts from recreation is insufficient. Response See response to Comment WLDF – 29. Assessment findings were used as a basis for the analysis. The analysis is based on changes from the current forest plan (alternative A) that can be meaningfully analyzed. The best available scientific information was used throughout the planning process. References include information that was considered and helped develop plan components and analysis.

Comment WLDF – 35 There are no plan components that restore or maintain habitat connectivity across ecosystems. Response Not specifically. The suite of plan direction provided is designed to manage energy and genetic flow across the entire landscape of the Forest. Goal 1 emphasizes connectivity at multiple scales, including across jurisdictional boundaries and between habitats.

Comment WLDF – 36 The forest plan must include the best available science for all species. Reliance on outdated direction and science, such as the Lynx Conservation Assessment and Strategy, will avoid application of outdated direction. Response The analysis represents the use of best available science. One example would be incorporation of the finding of the Squires et al. (2018) lynx study. The study was taken into consideration in developing the new direction for lynx in spruce-fir habitat.

Comment WLDF – 37 The draft environmental impact statement contains no discussion of connectivity and lynx movement between the Carson and Rio Grande National Forests. Response The biological assessment includes a detailed analysis of the existing condition for all federally listed species, including the Canada lynx.

Comment WLDF – 38 The Forest Service needs to clarify what definition is being used for the various statistics related to lynx. Response The comment letter was not clear on what definitions are not clear.

208 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment WLDF – 39 The Forest is ignoring information provided in its wolverine overview prepared for the assessment, which lists sightings in 1911, 1973, 1978, 1992, and 1997. Response The biological assessment addressed the existing conditions for all federally listed species and proposed species, including the wolverine. Sightings of wolverine on the Forest after 1911 are not confirmed, and there is no confirmation that the species is currently present in the plan area.

Comment WLDF – 40 The forest plan should have plan components to protect and restore beaver to the forest, and retain beaver as a focal species to monitor integrity of aquatic and riparian habitat. Response The protection and restoration of beaver are included in plan components associated with the riparian management zone and watershed health considerations.

Comment WLDF – 41 What is meant by the statement on page 234 of the draft environmental impact statement, "Some bird species may only be hunted with hawks and falcons." Response Colorado Department of Parks and Wildlife defines bird species that may be hunted using hawks and falcons. The Forest Service does not regulate what species may or may not be hunted because that is a function of State governance. This includes falconry and other forms of privately owned raptors (the comment in the draft environmental impact statement is not a reference to predation by wild hawks and falcons).

Comment WLDF – 42 Lynx guidance is in conflict with the 2013 Lynx Conservation Assessment Strategy. Response The 2013 Lynx Conservation Assessment Strategy was reviewed in relationship to potential lynx conservation needs in the forest plan. Only one section was incorporated into the draft forest plan that recommends an update to Southern Rockies Lynx Amendment Standard VEG S-1.

Comment WLDF – 43 Failure to consider the LCAS (Lynx Conservation Assessment and Strategy) direction squanders the work and relationships that went into preparing that analysis.

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Response See response to Comment WLDF – 42. The Lynx Conservation Assessment and Strategy was considered and one section is incorporated into the plan.

Comment WLDF – 44 The premise that large animals, particularly deer and elk, are sensitive to traffic and road activity is not supported by published scientific research. Response Considerable science exists that describes how large big game species, particularly deer and elk, respond to road and traffic activity, including open road densities and various motorized and mechanized vehicles.

Comment WLDF – 45 Alternative C would cause more fragmentation and put herbivores most at risk. Habitat areas are treated as static in alternative C. Response Alternative C provides flexibility in determining habitat based on actual conditions on-the- ground. Not placing lines where we think the habitat occurs allows for more factual determinations of use and animal movements. If plan direction and best management practices are applied as intended, more fragmentation would not be the result.

Comment WLDF – 46 Winter range for big game should not be subject to commercial timber production. Response Big game winter range is included in the timber base to ensure that forest vegetation management can be used as a tool to improve habitat conditions for big game. Because these winter ranges are often associated with lower-elevation dryer forest types, a lot of commercial timber harvest is not anticipated. However, the use of forest management as a tool for habitat maintenance and restoration is a desired management option. Multiple plan components ensure that such timber harvest has little to no direct impact on wildlife.

Comment WLDF – 47 Seasonal closures of travel routes need to be adjusted: bighorn sheep Nov 1 to Apr 15; production areas Apr 15 to June 30; deer and elk winter range Dec 1 to Apr 15; and elk production areas May 30 to June 30; and included in the plan so they will be enacted. Response Based on input received, the timing restrictions have been adjusted in the forest plan direction.

210 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment WLDF – 48 DC-WLDF-3 uses the term “Sufficient” which is a subjective term that provides no direction if it is not defined. What are the specific ecosystem conditions required by at-risk species for which habitat connectivity is an essential requirement, such as lynx and American marten? Response Based on internal and external comments plan components, including desired conditions, objectives, standards, and guidelines, have been revised to better meet the intent and direction of the 2012 Planning Rule (36 CFR 219) and its implementing direction (FSH 1909.12). “Sufficient” no longer appears in the direction.

Comment WLDF – 49 "Adequate" is a subjective term used in DC-WLDF-7 that provides no direction if it is not defined. It is not clear where, among plan documents, the information about the current and desired distribution and patterns of wood legacies, or snag components exists; without this, there is no way to achieve such a desired condition. Providing wood legacies, including snags, needs to be a standard. The previous plan has a standard for retention of snags and down wood. Response This specific direction has been incorporated into the snag direction in G-VEG-1, which includes specific recommendations by forest type. Snag and down wood retention guidelines do not restrict activities as a standard would. Stating this direction as a desired condition allows managers to apply restrictions or tools to meet or move toward the desired condition.

Comment WLDF – 50 DC-WLDF-4 and -5 should apply Forestwide not just on big game winter range. Response These desired conditions are to be applied Forestwide.

Comment WLDF – 51 The concept/criteria needs to be further developed as a Guideline, which is important to meeting connectivity requirements. Response Connectivity is addressed throughout the plan in goals, desired conditions, management areas, and plan components. The plan is document that integrates resources, therefore, components that help protect habitat connectivity might be contained in other sections. For example, the eligibility of wild and scenic rivers provides protections to riparian stream corridors that have benefits to wildlife habitat connectivity through these protection corridors.

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Comment WLDF – 52 DC-WLDF-8 can be deleted as it is a repeat of an existing Guideline in Appendix G. If desired, it could be rewritten to encompass other aspects of providing for long-term persistence of goshawk. Response This direction has been moved to a guideline.

Comment WLDF – 53 DC-WLDF-9 should be a standard instead of the desired condition, and require compensatory mitigation to offset developments that cause the 1 mile/square mile to be exceeded. Response The desired condition has been deleted but similar and more restrictive direction found in the desired conditions for Management Area 5 - General Forest and Rangelands: “Prescribed road densities of 1 mile per square mile provide for critical wildlife needs, in areas used for winter concentration, critical winter range, calving areas, and transition habitat.”

Comment WLDF – 54 DC-WLDF-10 should be specific about the direction for identifying lands "as a key component in maintaining the integrity of seasonal movements by wildlife." Response This is more appropriate at the project-level analysis.

Comment WLDF – 55 Rewrite DC-WLDF-11 to include information from Colorado Parks and Wildlife and the Colorado Natural Heritage Program. Response DC-WLDF-11 has been revised (now DC-WLDF-3) and addresses habitat connectivity in a more general way. Ongoing partnerships with Colorado Parks and Wildlife and Colorado Natural Heritage Program will continue to help us achieve mutual goals for wildlife.

Comment WLDF – 56 There are no standards or guidelines to support DC-WLDF-11 and 13. Response In response to internal and external comment, plan components have changed. A full set of plan components (desired conditions, objectives, standards, and guidelines) is not required, and connectivity is now addressed by desired condition DC-WLDF-3, which has been revised to be more all-encompassing.

212 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment WLDF – 57 Convert DC-WLDF-11 to a guideline it is important for connectivity and ecosystem integrity. Response Guidelines restrict activities to move resources toward desired conditions. Projects are designed to move resources toward desired conditions, and we feel this is better suited as a guideline. This desired condition included in the draft environmental impact statement has been combined with DC-WLDF-3, which is more general and all-encompassing.

Comment WLDF – 58 DC-WLDF-12 needs to provide more information on where dense, interior riparian willow habitat is needed; suitable nesting habitat conditions for the target species; including measurable parameters for edge, need to be described. Response The desired condition has been revised and simplified to better reflect a programmatic scale of analysis and is now listed as DC-WLDF-6. The land management plan is programmatic in nature and does not typically address this level of detail. Project impacts (positive or negative) will be analyzed at the project level.

Comment WLDF – 59 S-WLDF-1 is too vague for us to support. Avoiding or minimizing disturbances “as much as possible” could easily be interpreted as prohibiting any disturbances from April 15 to July 1. It is crucial that purchasers and loggers be able to operate close to year-round; we recommend you delete this standard. Response The direction has been clarified. It has been moved to Management Area 5 with exceptions for contractual obligations.

Comment WLDF – 60 Regarding S-WLDF-2, we do not support a Standard that requires adherence to “current regional guidance,” especially when the details of that regional guidance are not disclosed or could change. We recommend that you delete the reference to “current regional guidance” and that you review overlap between this Standard and S-WLDF-5. Response The Forest will continue to follow regional guidance on many different resource areas as it is developed. Regional guidance is often issued to address needs in a more nimble way than through plan revision. Higher levels of guidance do not necessarily need to be repeated at the forest plan level (although sometimes it is; usually to add emphasis to a topic). It can be problematic when regional guidance is updated, and the forest plan has a standard or guideline to follow it. Sometimes it is not clear that the intent of the standard or guideline was meant to be updated along with updates to the regional guidance. In this case we have

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reviewed it and decided to remove it based on your suggestion, and suggestions of others to simplify management in the plan and remove redundant and overlapping direction. In addition to the existing regional guidance, the plan also adds other plan components that protect bats and other species.

Comment WLDF – 61 The dates to provide protection from disturbance for wintering big game (pronghorn, mule deer and elk) on winter ranges is December 1- April 15. Access restrictions and seasonal closures are necessary to help big game survival. For bighorn sheep lambing (production area) should have seasonal restrictions from April 15-June 30, and a winter restriction from Nov 1-April 30. Please modify these dates in the final land management plan. We recommend that you delete the requirement for “security habitat;” if you decide to keep the “security habitat” requirement, you need to define “security habitat” and how the requirement would be implemented. It is crucial that purchasers and loggers be able to operate close to year-round; therefore, we recommend that you minimize timing restrictions and that any timing restrictions be qualified with “Unless otherwise agreed in writing by the District Ranger …” Response The dates for big game winter range have been adjusted to December 1 through March 31 (G-WLDF-1). Bighorn sheep have been added to the species of conservation concern, due to comments raised by the public regarding persistence concerns. Plan components for bighorn sheep can now be found in the Species of Conservation Concern section. These include timing restrictions to protect important breeding and reproductive periods.

Comment WLDF – 62 We question the need for this Standard, and we recommend that you delete it. Even if it is retained, it is too vague, and should be rewritten to identify specific requirements. Make S- WLDF-4 a Guideline. Response Conditions for bat habitat will be applied at a project level consistent with higher level direction. The Forest will continue to protect bats and bat habitat, but will do so following Rocky Mountain Regional Office planning directives, which apply across all Forests in the Rocky Mountain Region. As such, plan components for individual national forests are not needed and would be redundant. The direction has been removed from the forest plan.

Comment WLDF – 63 We question the need for S-WLDF-5; it is not discussed in the draft environmental impact statement, and, therefore, we recommend that you delete it. It is crucial that purchasers and loggers be able to operate close to year-round. Even if it is retained, it is too vague, and should be rewritten to identify specific requirements. Response The direction has been removed, it is stated in higher level direction and will be analyzed as necessary at the project level. See response to comment WLDF-63.

214 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment WLDF – 64 Make S-WLDF-8 a guideline. Response This direction has been revised and is now S-WLDF-1.

Comment WLDF – 65 There is no discussion in the wildlife report regarding a need for “screening cover.” There is also no discussion of what constitutes “screening cover” and how it would be accomplished. We recommend that you delete S-WLDF-9. Make S-WLDF-9 a guideline. Response The component has been removed in the forest plan. Screening cover for big game will be addressed at the project level as appropriate.

Comment WLDF – 66 S-WLDF-12, the dates to provide protection from disturbance for wintering big game (pronghorn, mule deer and elk) on winter ranges is December 1- April 15. Access restrictions and seasonal closures are necessary to help big game survival. For bighorn sheep lambing (production area) should have seasonal restrictions from April 15-June 30, and a winter restriction from Nov 1-April 30. Please modify these dates in the final land management plan. Response The dates have been adjusted. See response to comment WLDF – 62.

Comment WLDF – 67 Regarding G-WLDF-1, we do not support a Forest inventory for raptor nests – that is an expensive and unnecessary commitment. Any protective measures for raptor nests and nest areas belong in Plan Components, not in an Appendix. We are very concerned about the cumulative effect of timing restrictions on operations. It is crucial that purchasers and loggers be able to operate close to year-round; therefore, we recommend that you minimize timing restrictions and that any timing restrictions be qualified with “Unless otherwise agreed in writing by the District Ranger …” Response G-WLDF-1 from the draft plan has been replaced in the final version of the plan with a management approach to consult with Colorado Parks and Wildlife on the issue. That guidance contains a variety of protective measures and avoidance dates for various species and situations. The Forest can consider this guidance during implementation of site-specific analysis to determine the impacts that proposed projects may have on raptors, and to craft protective measures and stipulations for such proposed projects.

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Comment WLDF – 68 Regarding MA-WLDF-3, we recommend identifying specific management needs in Plan Components instead of referencing recommendations or plans from other organizations or agencies. Response Collaboration among agencies is an ongoing process that will continue under the new forest plan. Reliance on species experts and recommendations is integral to our work. The Forest Service has always collaborated with other agencies and has multiple cooperative agreements and memorandums of understanding in place to structure that cooperation. Additionally, the Forest Service participates in many interagency working groups for a variety of issues, from sage grouse, to Colorado River fishes, to bats and white-nose syndrome. As such, the Forest Service contributes to the products and guidance issued by these groups, including the Colorado Bat Working Group, which currently includes a Forest Service biologist on its board. The Forest will continue to protect bats and bat habitat. A management approach in the final version of the plan solidifies the forest’s intent to maintain an early detection program for white-nose syndrome in bats, follow guidance from the Forest Service Rocky Mountain Regional Office, and continue to coordinate with partners and other agencies to protect bats from white-nose syndrome.

Comment WLDF – 69 We recommend that: • MA-WLDF-6 be a guideline; • MA-WLDF-12, MA-WLDF-13, and MA-WLDF-14 become standards; • MA-WLDF-17 be converted to a standard or guideline; • MA-WLDF-18 be a standard; • MA-WDLF-23, 24, 26 and 27 become guidelines applied Forestwide otherwise it will be difficult to ensure that these get implemented at the project level to maintain and sustain ungulate protection; • 5.41-S-1 should be edited to ensure that logging equipment is not include in the “off- road” travel restriction. Response In response to comments received, direction has been combined, clarified, changed, or removed. Specific to MA-WLDF-6, the direction does not restrict activities; therefore, it is not suitable as a guideline. Collaboration with outside agencies will continue. See response to comment WLDF – 69. Bighorn sheep has been added to the species of conservation concern list and is subject to plan components pertaining to species of conservation concern.

216 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Specific to MA-WLDF-17, because no activities are restricted, this is an appropriate management approach. Collaboration and compliance as appropriate with Colorado Natural Heritage Program will continue. Specific to MA-WLDF-18, impacts to bats and bat habitat will be addressed in project-level analysis. See response to WLDF-63. MA-WDLF-23, 24, 26, and 27 all describe ongoing program operations that will continue during implementation of the forest plan. MA-23, 26, and 27 have all been reworded to focus more narrowly on TEPC species and to match riparian management zones described in Appendix F. MA-24 has been deleted. 5.41-S-1 has been moved to Management Area 5 and revised to allow for meeting contractual obligations.

Comment WLDF – 70 Convert MA-WLDF-27 to a Guideline unless MA-LYNX-4 becomes a Guideline, in which case this could remain a MA as Spruce-Fir systems are the primary need for this approach. Response Forest plan direction should not prescribe how analysis is conducted. This has been removed.

Comment WLDF – 71 Native Animals and Plants – Pollinators - S-PLTRl-1- this standard should be rewritten to clearly specify what actions are being constrained for which specific species, and how those will be implemented and monitored. S-PLTR1-1 should be labeled as S-PLTR-1, assume this is a typo. Also, replace "Mitigate" with "Avoid or minimize." Response Pollinator direction has been moved to wildlife. The typo has been corrected. Pollinators are addressed in site-specific analysis.

Comment WLDF – 72 MA-PLTR-2 should be a guideline not a management approach. Response Pollinators are a focus of ongoing program management as pollinator decline is an emerging worldwide issue. Because no activities are restricted, the direction presented is appropriate as a management approach.

Comment WLDF – 73 Regarding G-TEPC-1, there is no measurable desired condition for the abundance and distribution of willows and riparian/wetland integrity to measure reduce impacts in G-TEPC-1.

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Response Maintenance and restoration of willow habitat is monitored across the Forest. Project analysis would include any monitoring data as well as desired habitat conditions. Recovery plans for the southwestern willow flycatcher and yellow-billed cuckoo contain more specific objectives for the management of willow and riparian vegetation in general as pertains to those two listed species. Site-specific projects that have potential to impact those two species will undergo consultation under Section 7 of the Endangered Species Act. This will describe and limit impacts to riparian willow as a function of flycatcher and cuckoo habitat relative to the best available scientific information and the recovery plans.

Comment WLDF – 74 Direction for Gunnison sage-grouse in G-TEPC-3 paraphrases the rule requirements for ecological integrity, the direction as written will not effectively conserve Gunnison Sage Grouse habitat. The analysis does not describe how the plan components will provide conditions for sage- grouse recovery or change the current fire regime, the fuels direction is included at G-TEPC- 3 is unclear, and no new science is provided to justify a change in the fuels treatment approach. Response The Forest has only a small amount of Gunnison sage grouse habitat. Any project implementation proposed would follow the Endangered Species Act and species-specific direction as determined through Section 7 consultation with the U.S. Fish and Wildlife Service.

Comment WLDF – 75 Adjust to a Standard. This relates to persistence of an endangered species and existing responsibilities under ESA Recovery Plans. Response The Forest is required to follow applicable recovery plans and direction therein. Any proposed action or project that has the potential to impact federally listed species must undergo Section 7 consultation; the Forest Service has no discretion otherwise. Due to the lack of Forest Service discretion in this matter, the direction does not need to be restated in the forest plan. This is covered under DC-TEPC-1.

Comment WLDF – 76 The effectiveness of direction in G-TEPC-5 cannot be determined without knowing the ecological conditions that contribute to southwestern willow flycatcher recovery. Response This direction is now incorporated into DC-TEPC-1. Applicable recovery plans and higher level direction would be followed. See response to WLDF-76. Additional information on this species is contained within the Wildlife Report that is part of the project record.

218 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Comment WLDF – 77 All at-risk species do not require the same habitat conditions. Management actions that are beneficial to one species may be detrimental to another. Response This direction has been addressed in DC-TEPC-1. Higher level direction in the Endangered Species Act will be adhered to. See response to WLDF-76. Comment and issues surrounding bighorn sheep are being addressed separately.

Bighorn Sheep (BHS)

Comment BHS – 1 Bighorn sheep should be considered as a species of conservation concern for the following reasons: The presence of domestic sheep on and adjacent to bighorn sheep habitat shows a clear concern for persistence. Early forest plan documents and assessments acknowledged bighorn sheep as a species of conservation concern. Sometime between September 2016 and September 2017, they were excluded without publically accessible, written rationale or public input. The conclusion reached was not based on the facts found in the Rio Grande national Forest’s own documentation of best available scientific information. Bighorn sheep are listed as a species of conservation concern on the San Juan National Forest and there is inadequate scientific analysis and justification given for not including them as a species of conservation concern. Current and potential management is not one of the criteria for identifying species of conservation concern. Because of significant declines in the population of the Trickle Mountain bighorn sheep herd and other populations. The rationale for not including them is inadequate. Lack of separation from domestic sheep and goats has been decimating bighorn sheep herds in Colorado for decades, therefore they need to be a species of conservation concern with species specific direction. Response Rationale is presented in Appendix D of the environmental impact statement. The documents submitted for comments in the fall of 2017 represented draft analysis and forest plan components. No decision had been reached yet; the information was being released for public comment. In response to comments received, the Regional Forester has determined that bighorn sheep are being considered as a species of conservation concern. The final documents will include this change.

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Comment BHS – 2 Changes to grazing management that would improve the viability to bighorn sheep herds has not occurred to provide persistence of the species in the future. Response The Forest has made changes, including vacating allotments due to high risk of contact between domestic sheep and bighorn sheep in project-level analysis. The risk of contact will continue to be assessed at the site-specific level and addressed as needed in the future.

Comment BHS – 3 The analysis does not update knowledge gained over the past seven years related to disease transmission, risk of contact, and bighorn sheep movement on the unit. Response Project analyses present a clear record of refinement as best available scientific information has become available. The information is readily disclosed in project-level decisions.

Comment BHS – 4 Management of hunting pressure by Colorado Parks and Wildlife will not restore the ecological conditions required for bighorn sheep persistence. Periodic augmentation will also not restore ecological conditions, and Colorado Parks and Wildlife is rarely doing augmentations because of concerns about novel pathogen transfer/movement. Response Management of hunting pressure and periodic population augmentation programs are State management tools that are not specifically directed at restoring ecological conditions required for the persistence of bighorn sheep. If bighorn sheep movement is a concern because of the proximity of domestic sheep, the listed activities are often considered a management tool for reducing potential interactions between domestic sheep and bighorn sheep. The success of this action as a management tool varies depending on a variety of factors such as distance between species, disease history, bighorn sheep population levels, herd movement and dynamics, and other factors.

Comment BHS – 5 The forest plan needs to include direction that balances management actions to address bighorn sheep and domestic sheep grazing to ensure that both uses are supported. Response Forest plan direction is aimed at providing balance. Project-level decisions will still be reliant on the analysis of the area at hand.

Comment BHS – 6 Forest plan standards can be ignored or interpreted to get around the strict wording that standards are designed to ensure. A viability assessment is critical to long-term persistence of bighorn sheep on the unit.

220 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response Forest plan standards are mandatory to be followed unless the analysis considers an amendment of plan direction. In that case, the analysis will display the effects of the changes for that particular project and circumstance. Table 22 of the forest plan (Table 122 in the environmental impact statement) lists the rationale for consideration of species as species of conservation concern. Several risk of contact assessments have been completed on the Forest allowing planners to ascertain information on Forestwide impacts. This information and comments received have prompted the Regional Forester to include bighorn sheep as a species of conservation concern.

Comment BHS – 7 Management Area 5.42 that was included in the 1996 forest plan should be retained. Eliminating this management area does not address the primary concern for bighorn sheep a focus on core herd home range. The strong standards for protecting bighorn sheep and their habitat from adverse impacts from projects and activities as well as ensuring separation between bighorns and domestic sheep should be retained. Management Area 5.41 is inadequate in addressing summer domestic sheep grazing. Bighorn sheep areas need to be identified to ensure herd viability. Response Management Area 5.42 was created because of limited information regarding bighorn sheep in the 1996 forest plan. The area primarily focused on known lambing areas. It would be impractical to incorporate all of the mapped summer source habitat and potential core herd home range areas into a new management area for bighorn sheep. Instead the direction addressing these areas is applied Forestwide to increase the protections. Management areas have been reduced and simplified between the draft and final versions of the plan.

Comment BHS – 8 Implement management to restore and improve habitat quality on important bighorn sheep lambing areas, winter concentration areas, migratory routes, and movement areas to reduce the potential for disease transmission from domestic sheep. (p.26) What bighorn sheep habitat characteristics are in need of restoration and improvement? How will habitat restoration reduce the potential for disease transmission? The need for habitat restoration and improvement are unrelated to disease transmission. Quality winter habitat for bighorn sheep is already addressed by DC-WLDF-4. Delete DC-WLDF-13 and expand the scope of DC-WLDF-4 so that it is not limited to winter habitat (delete “on mapped winter range” from the end of the sentence). Response Habitat characteristics in need of restoration and improvement vary across the Forest. Separation between domestic and bighorn sheep is a high priority. Habitat maintenance and restoration are a priority when aligned with other proposed projects. The direction has been reviewed and revised as appropriate.

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Comment BHS – 9 S-WLDF-10, maintain effective separation to minimize the risk of disease transmission between domestic sheep and bighorn sheep on active grazing allotments. Effective separation is defined as spatial or temporal separation between bighorn sheep and domestic sheep, resulting in minimal risk of contact and subsequent transmission of respiratory pathogens between animal groups. (p.27) Respiratory disease is not transferred between the animal groups. Pathogens can be transferred, though respiratory pathogens are likely endemic in many of the bighorn and domestic sheep herds. As stated above, Forest Service direction states that management be effective in supporting both uses. Standards in the forest plan must have the flexibility that allows managers to provide for both uses. Elimination of risk of interaction is not a realistic goal. Minimizing the potential for interaction through best management practices should be the objective. Proposed wording: “Manage for effective separation between bighorn sheep and domestic sheep to minimize the risk of interaction between animal groups. Effective separation is defined as spatial, temporal, or anthropogenic (i.e. herd management) separation that minimizes the potential for interaction between bighorn sheep and domestic sheep.” Response The standard has been rewritten to “…reduce the likelihood of disease transmission…”

Comment BHS – 10 Amend S-WLDF-11 as follows: Do not authorize projects, activities, and uses to bighorn sheep production areas that may result in disturbance or displacement of bighorn sheep during critical reproductive periods (generally April 15 to July 1). (Forestwide) Response The direction now reads: Do not authorize projects that will result in a disturbance or displacement of bighorn sheep during their reproductive period (generally April 15 to July 1).

Comment BHS – 11 Amend S-WLDF-13 as follows: Prohibit the use of recreational pack goats in all bighorn occupied habitat to eliminate potential interactions between pack goats and bighorn sheep. (Forestwide) Response Bighorn sheep have been added to the species of conservation concern and specific protections are offered in that section of the plan. Please note that many plan components have changed or are now in different sections of the forest plan. S-SCC-3 prohibits the use of recreational pack goats in the Sangre de Cristo Mountains to eliminate potential interactions between pack goats and bighorn sheep. Additionally, the Species of Conservation Concern section includes a Management Approach that states the Forest intends to provide education and awareness information regarding potential disease transmission between recreational

222 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments pack goats and bighorn sheep at entry points to areas of known bighorn sheep use. The Management Approach also states the intent for areas of overlapping pack goat and bighorn sheep use is observed over time.

Comment BHS – 12 Amend S-WLDF-14 as follows: Do not authorize the use of domestic goats for vegetation management in bighorn occupied habitat to minimize risk of contact between animal groups. (Forestwide) Response Bighorn sheep have been added to the species of conservation concern, and have fine filter protections in the plan.

Species of Conservation Concern (SCC)

Comment SCC – 1 The analysis does not provide documentation of how plan components will ensure the needed ecological conditions. The analysis does not document whether plan components are adequate or if species-specific plan components are necessary. There is no direction related to maintaining or restoring ecosystem conditions to maintain the viability for potential Species of Conservation Concern plants. Response A table has been added to Appendix D to show how plan components tie to species of conservation concern.

Comment SCC – 2 Plan components for Species of Conservation Concern need to be rewritten to conform to the 2012 Planning Rule direction. The Desired Conditions need to be rewritten to include enough specificity that they can be measured and progress toward their achievement can be monitored. Neither of the Objectives are measurable and time-specific. All of the Plan Components need to be rewritten to conform to their respective definitions, so they are concise, specific, measurable, and able to be monitored. Response In response to internal and external comments received, plan components, including desired conditions, objectives, standards, and guidelines, have been revised to better meet the intent and direction of the 2012 Planning Rule (36 CFR 219) and its implementing direction (FSH 1909.12). The intent of the direction did not change; rewrites combined like direction, added clarity, and added specificity.

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Comment SCC – 3 There are many concerns with the Species of Conservation Concern process. The list identified species with no occurrence and species with no substantial concern for persistence. Response Table 21 and 22 in the forest plan are the same as tables 122 and 123 in the environmental impact statement. These tables list occurrence data for each species present in the plan area and provide a synopsis of what drives the concern for persistence for each. Additional documentation for such factors is also included in Assessment 5 and in the individual species overviews that were released earlier in the process.

Comment SCC – 4 Public involvement in the Species of Conservation Concern process did not occur before changes to the list were proposed. Response Many meetings have been held throughout the revision process. The comment period on the draft forest plan and environmental impact statement is also an opportunity for public involvement. The assessments that preceded the draft environmental impact statement and forest plan included Assessment 5 which addresses at-risk species. Those assessments went out for public review, and the comments from that review led to revision of the species of conservation concern list. Comments on the draft environmental impact statement led to further revision, with the addition of bighorn sheep to the list.

Comment SCC – 5 Management Approaches have no regulatory basis or requirement so there is no Forest Service accountability for the direction. Response Management approaches are described in Forest Service direction (FSH 1909.12 §22.4) as optional content that could facilitate transparency and give the public and governmental entities a clear understanding of the plan and how outcomes would likely be delivered. Management approaches can describe strategies and program priorities that the responsible official intends to employ to carry out projects and activities. In response to external and internal comments, management approaches have been revised in format and content to meet the direction in FSH 1909.12.

Comment SCC – 6 Boreal toad, Rio Grande chub, Rio Grande cutthroat trout, and Rio Grande sucker should be listed as species of conservation concern. Response The species of conservation concern list has been evaluated and analyzed. All four species mentioned in the comment are on the species of conservation list in the forest plan. The final

224 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments list is not static; species may be added or removed depending on the concern for long-term persistence.

Comment SCC – 7 A desired condition of undisturbed grass cover is unrealistic. Response The desired condition is changed to reflect on-the-ground conditions. Any herbivory, either wild or domestic, creates disturbance.

Comment SCC – 8 Having so many species of conservation concern with limited plan components tied to their management will make implementing projects difficult. Response Please see response to comment SCC – 1. Many of the species of conservation concern-listed plants and animals are at-risk precisely because they occupy very small, limited habitats. As such, many projects would have no risk of impacting these species because the projects would not impact that small portion of the plan area occupied by species of conservation concern. Other areas where species of conservation concern are present are already subject to a wide array of protective measures, such as protections for riparian, wetland, and alpine habitats. As such, protective measures and habitat restoration activities would only be adding to an existing suite of protective measures and habitat goals, adding precision to what is already generally occurring. This may not be a dramatic change from current management.

Comment SCC – 9 The species of conservation concern analysis is insufficient and does not support conclusions of viability. Response According to Forest Service Handbook 1909.12, a species of conservation concern is a species, other than federally recognized threatened, endangered, proposed, or candidate species, that is known to occur in the plan area and for which the Regional Forester has determined that the best available scientific information indicates substantial concern about the species’ capability to persist over the long-term in the plan area. The 2012 Planning Rule requires that the plan have plan components to provide ecological conditions necessary to maintain a viable population of each species identified in the plan area.

Comment SCC – 10 The draft environmental impact statement is deficient in assessing plan impacts on species of conservation concern. Response Please see response to comment SCC – 1. Without specifics it is challenging to respond.

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Comment SCC – 11 The Plan should provide the rationale for including plan components for some species but not others. Response Please see response to comment SCC – 1. Generally speaking, plan components related to species of conservation concern manage the habitat and environmental conditions required by the species. In many cases, this happens as a simple byproduct of good forest management, and in such cases, the component may not have been crafted with species of conservation concern in mind and would likely make no mention of any specific species. Every species of conservation concern is managed by at least one standard or guideline, in addition to desired conditions, goals, and management approaches.

Comment SCC – 12 Plan components (standards and guidelines) need to be in place to protect habitat refugia areas. Response The plan was designed to ensure the entire that the Forest continues to be a refugia and connect habitats over time through included plan components. This does not preclude short- term disturbance associated with operations associated with landscape designated for management under a multiple-use mandate.

Comment SCC – 13 The Forest must meet the requirements at 219.9(b)(2), however the draft EIS (at p. 191) indicates that the Forest does not have the capability or authority to maintain viable boreal toad populations. Response The environmental impact statement identifies several species that are beyond the ability of the Forest Service to maintain with certainty. This is to be expected when many of these species face threats that cannot be eliminated by forest management, such as chytrid fungus, which is very easy to spread from one location to another, and once present in the environment, cannot be eradicated. In such cases, the Forest Service must document the reasons that the species remains at-risk, as per chapter 20 of the Land Management Planning Handbook. The final version of the plan includes a management approach in the Species of Conservation Concern section stating the Forest’s intent to provide boreal toad education and outreach materials regarding chytrid fungus. And, where the fungus has been detected, the Forest intents to determine the need to implement decontamination procedures to protect boreal toads and other amphibians.

Comment SCC – 14 Burrowing owl needs added to the species of conservation concern list because it has a connection to prairie dog colonies.

226 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Response Rationale for not including burrowing owl is included in Table 22 of the forest plan.

Comment SCC – 15 The number of occurrences for flammulated owls needs to be updated. Response Thank you, we will consider updating the information.

Comment SCC – 16 The justification in the species of conservation concern list should be updated to say "Removed from species of conservation concern list due to taxonomic lumping. No concern for persistence." Response Your suggestion has been considered. Updates have been made to the list and rationale.

Comment SCC – 17 Many Species of Conservation Concern plants were included with insufficient information about a substantial concern to persist. Response Rationale for not including species is included in forest plan Table 22. If a plant is not known to occur on the Forest, that is sufficient rationale for not adding the species to the list.

Comment SCC – 18 A standard that prohibits shooting prairie dogs needs to be included. Response This is outside of the jurisdiction of the Forest Service. Hunting is regulated by the Colorado Division of Parks and Wildlife. The Forest Service has no statutory authority to prevent Colorado Division of Parks and Wildlife from allowing such activity for species not addressed through additional federal regulation (such as the Endangered Species Act, or the Bald and Golden Eagle Protection Act, or other such federal laws). There are no federal laws that are specifically protective of prairie dogs.

Comment SCC – 19 The Plan has not successfully provided specific, detailed, and enforceable coarse- and fine- filtered plan components tiered to the habitat needs and threats to viability and recovery of at-risk, Species of Conservation Concern, and listed species. Response At-risk species include federally recognized threatened, endangered, proposed, and candidate species AND species of conservation concern. See above response as well. Plan components

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address coarser scale ecosystem level approach first and species specific second. If a plan component at an ecosystem level provides the protections, no other components are needed. See also response to comment SCC – 1. A table in the forest plan lists which habitat standards and guidelines manage which species. Fine filter plan components are not needed if the coarse-filter components sufficiently address the risk factors and/or habitat requirements for a given species of conservation concern.

Comment SCC – 20 The analysis must disclose the effects of implementation to the new lynx provisions on other at-risk species. Response This is included in the analysis.

Comment SCC – 21 Pika should be listed as a Species of Conservation Concern because it is very sensitive to increases in temperature and could serve as an indicator for the effects of climate change on the Forest. Response Rationale for species is included in Tables 21 and 22. Although American pika may be sensitive to climate change, they are rated as secure and common both globally and at the State level, with a NatureServe Ranking of G5S5. As of 2008, historically referenced relatively low-elevation pika populations in and around the plan area were still populated. Despite its well-known affinity for habitat that may be threatened by climate change, American pika itself appears to not be at risk.

Comment SCC – 22 Woodsia neomexicana Windham (New Mexico cliff fern) should be on the SCC list. This species is S1, state critically imperiled, and there are only two known occurrences on the RGNF. Response Rationale is provided in Table 22. The Forest Service was unable to identify any specific threats to this species habitat on the Rio Grande National Forest. The species is very rare, but otherwise appears to not be at-risk on the Forest.

Comment SCC – 23 The measures to protect boreal owls and flammulated owls need to be corrected; the direction should be standards, not guidelines. Response In response to internal and external comments received, plan components, including desired conditions, objectives, standards, and guidelines, have been revised to better meet the intent and direction of the 2012 Planning Rule (36 CFR 219) and its implementing direction (FSH 1909.12). The intent of the direction did not change; rewrites combined like direction, added

228 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments clarity, and added specificity. Boreal and flammulated owls are both managed for by a combination of standards and guidelines.

Comment SCC – 24 Changes need to be made to desired conditions for species of conservation concern. Desired condition DC-SCC-2 should be a guideline. It is okay as a desired condition if something is added as a guideline about New Mexico meadow jumping mouse as a threatened and endangered species. This can be verified with crosswalk table. Aquatic species, specifically Rio Grande cutthroat trout, should be included as a desired condition as they are greatly impacted by streambank grass cover, consider protecting them under DC-SCC-2. Desired condition DC-SCC-9 should be a standard, not a desired condition. Response Plan direction was rewritten between release of the draft and the final forest plan. The desired conditions for species of conservation concern now are generally addressed at the ecosystem level, which we think aligns better the definition of desired conditions. It was incorrect to include an SCC plan component in the draft plan for New Mexico jumping mouse, because it is a federally listed species, and we are not sure it occurs on the Rio Grande National Forest. Although we have no records of the New Mexico jumping mouse detected in the planning area, we do know it has been detected on the Grand Mesa, Uncompahgre, and Gunnison National Forests. New Mexico meadow jumping mouse is not included as a species of conservation concern, because it is an endangered species protected under the Endangered Species Act, and is protected by federal law. The forest plan identifies a desired condition (DC-TEPC-1) to maintain or improve habitat conditions that contribute to either stability or recovery of ESA species, as well as a guideline to constrain projects to avoid or minimize adverse effects to listed species and their habitat (G-TEPC-1). The US Fish and Wildlife Service has identified final critical habitat for this species, but the Forest is outside of this designation. Rio Grande cutthroat trout are a species of conservation concern and are protected by multiple plan components (S-GDE-1, G-GDE-1, S-RMZ-1, G-RMZ-1, G-RMZ-2, S-WA-1, G-WA-1, G-WA-2, G-FISH-1, G-FISH-2, G-FISH3, and G-MIN-1). Based on feedback during the comment period, DC-SCC-9 was revised into DC-SCC-5. A guideline has been added to constrain projects to maintain ecological conditions to support alpine-related species of conservation concern (G-SCC-4).

Comment SCC – 25 OBJ-SCC-1 and 2 should be standards, not objectives. Response The comment correctly identifies that OBJ-SCC-1 and 2 were not consistent with definition of an objective. Instead of adding these to standards, we have added them to management

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approaches in the forest plan. A guideline was added to maintain ecological conditions to support a viable population of species of conservation concern insects and plants and minimize the negative impacts to pollinators when applying pesticide. Specific mitigation of impacts is often more appropriate at project-level analysis, depending on aspects of the project.

Comment SCC – 26 Standard S-SCC-1 should be rewritten. It is too broad and removes any requirement to demonstrate causality or significance before imposing restrictions on an activity that causes disturbance. Any disturbance “might” be considered a threat to species viability. Change “might” to “would.” The direction should be rewritten to be more specific about the intent and definition of “avoid disturbance” for project design and implementation. Response Thank you for your comment. The standard has been removed and other standards and guidelines have been added to more specifically address ecosystems and species for SCC. S- SCC-1 was too broad and more specific plan components were added that will be easier to implement, and easier to understand. As written, SCC-1 left too much open to interpretation. This has now been corrected. Forest plan Table 23 links species of conservation concern to relevant plan components.

Comment SCC – 27 Standard S-SCC-2 should preclude new impacts within one-half mile of known breeding sites. And not allow any impact within 600 feet of documented field sightings. Merely considering management actions to protect boreal toad movement is not adequate to provide necessary conditions for persistence. This standard should include protecting of winter hibernacula from September 30 to May 15. Response Forest plan standards and guidelines that will provide for ecological conditions in many different aquatic habitats for viability of boreal toad in the forest plan include S-GDE-1, G- GDE-1, S-RMZ-1, G-RMZ-1, G-RMZ-2, S-WA-1, G-WA-1, G-WA-2, G-FISH-1, G-FISH-2, G-FISH-3, G-MIN-1. Since many of these apply year-round, seasonal restrictions are not needed; but may be applied at the project level if appropriate. Although these components are not specific to the boreal toad, they provide coarse filter protections for maintaining habitat conditions. Boreal toads also benefit from beaver habitat; beaver is included as a focal species and will be part of the monitoring program. The standard and guideline for groundwater dependent ecosystems, which provide toad habitat, prohibit any management actions that alter the hydrology of those systems. These help implement a desired condition for groundwater dependent ecosystem to provide habitat for species of conservation concern (DC-GDE-1).

Comment SCC – 28 G-SCC-3 needs to be written as a desired condition with measurable indicators (number of owls).

230 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Table 6 says 49 percent of ponderosa pine is in mature-open structural stage, if that is not adequate the desired condition should identify the desired percentage. Response G-SCC-3 was removed between draft and final versions of the forest plan in an effort to simplify plan direction and remove redundancy, where other direction sufficed. Coarse filter plan components provide habitat conditions for Flammulated owl include G-VEG-1, G- VEG-5, S-VEG-4 and S-VEG-5. Snag direction was contained as a desired condition in the draft forest plan (DC-VEG-1), but was elevated to a guideline in the final version that include snags and downed wood downed wood quantities on an average per acre basis across five major forest types. Snags, and the existing condition of dead trees, should benefit the Flammulated owl, and other owl species. The Flammulated owl are known to uses nesting cavities vacated by woodpeckers, and also utilize brushy understory. Desired conditions for structural stages of terrestrial ecosystems are found in Table 6, and provide ranges of desired condition, as well as the current condition, by forest vegetation type.

Comment SCC – 29 There is no best available scientific information identified that supports the idea that grazing benefits prairie dogs, please remove “livestock grazing” as a bullet in G-SCC-5. Also remove "avoiding the use of poison to control or eliminate prairie dogs." Instead, provide a standard that prohibits poisoning. In the second bullet, replace "Livestock grazing" with an active term similar to other bullets and add species to read: "Utilizing native ungulate and livestock grazing." Response G-SCC-5 was removed between draft and final versions in response to the need to simplify the plan. Gunnison prairie dog will benefit from the coarse filter guideline that reduces habitat fragmentation and maintains structural conditions of sagebrush ecosystems (G-SCC- 3). Range plan components also contribute to ecologically sustainable grazing and wildlife benefits (DC-RNG-4) and provide an objective to restore 150 acres of upland ecosystems.

Comment SCC – 30 Regarding the following management approaches. • MA-SCC-: populations of threatened, endangered, and proposed candidate species across the Forest do not need to be mapped. • MA-SCC-1: Awkward wording, rewrite as “The Forest intends to assess the range and distribution of…” • MA-SCC-2: should be moved to threatened, endangered and proposed candidate species. Response Revisions made between releasing the draft and final forest plans have addressed these comments. Some management approaches were deleted, many were combined with others

231 USDA Forest Service when there was overlapping intent. Note that management approaches in the forest plan do not have a coding system like they had in the draft, this was largely because of public comment that indicated confusion of management approaches with other traditional plan components.

Wild, Scenic, and Recreational Rivers (WSRR)

Comment WSRR – 1 According to the Colorado Natural Heritage Program reports Deadman Creek is better suited for special interest area designation. Response The 2012 Planning Rule requires all national forests undergoing plan revision to “identify the eligibility of rivers for inclusion in the National Wild and Scenic Rivers System, unless a systematic inventory has been previously completed and documented.” (36 C.F.R. § 219.7 (c)(2)(vi)). The Forest conducted an eligibility evaluation of rivers that were not considered during the 1996 plan revision in accordance with planning regulations and Forest Service Handbook 1909.12, Chapter 80. The eligibility evaluation resulted in a conclusion that Deadman Creek is eligible for inclusion in the National Wild and Scenic Rivers System because it is free flowing and possesses outstandingly remarkable values, including scenery, fisheries, historic and cultural, and botanical. Rivers determined to be eligible for inclusion in the National Wild and Scenic Rivers System must be managed to maintain free-flowing character and the outstandingly remarkable values that made the stream eligible. The upper portion of Deadman Creek occurs within a research natural area and is within the Sangre de Cristo Wilderness; therefore, additional protections are being applied. Where overlapping management occurs, the most constraining management would be applied. The final environmental impact statement also analyzed potential changes and additions to special interest areas on the Forest, and the responsible official concluded that recommendation for wild and scenic river designation was appropriate for Deadman Creek. This decision was based, in part, on existing research natural area and wilderness designations in the area and the effort to simplify management areas as described in Revision Topic 3.

Comment WSRR – 2 Some commenters argued that wild, scenic, and recreational river eligibility is supportable within the conditions of Forest Service Federal Reserved Water Rights, decreed in case 81CW183, while others urged the Forest to withdraw all eligible and suitable rivers in recognition of the decree in case 81CW183. Response The Forest acknowledges the decreed water rights agreed upon in Case No. 81-CW-183, and values the collaborative approach that led to the settlement. The management of wild, scenic, and recreational rivers is supportable and consistent with all existing decreed water rights, including those decreed in case 81CW183. The Rio Grande National Forest conducted eligibility evaluations and suitability determinations in accordance with the Wild and Scenic Rivers Act (Section 5(d)(1)) and planning regulations. In response to these comments, the language of the management approaches for MA 4.34 (Eligible and Suitable Wild, Scenic,

232 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments and Recreational Rivers) was modified to explicitly acknowledge the decreed water rights in Colorado Water Division 3 (81CW183), and to engage with the community on the subject of water rights and wild, eligible, and suitable river segments. Apart from minor revisions to some lengths based on updated hydrography, no changes have been made and all eligible or suitable segments from the 1996 plan have been carried over to this revision; details are contained in Appendix B. Management of these segments has been consistent with the decree in case 81CW183.

Comment WSRR – 3 Support for including Deadman Creek in Wild, Scenic, and Recreational River recommendation. Response Deadman Creek was evaluated for eligibility in accordance with the 2012 Planning Rule and Forest Service Handbook 1909.12, Chapter 80. Under the evaluation, Deadman Creek was found to be eligible for inclusion in the National Wild and Scenic Rivers System with a classification of scenic.

Comment WSRR – 4 Additional river segments need to be analyzed under the Wild and Scenic Rivers Act, and a more thorough review of the outstandingly remarkable features needs to be done. Response The 2012 Planning Rule requires all national forests undergoing revision to “identify the eligibility of rivers for inclusion in the National Wild and Scenic Rivers System, unless a systematic inventory has been previously completed and documented, and there are no changed circumstances that warrant additional review.” (36 C.F.R. § 219.7 (c)(2)(vi)). During the 1996 revision of the forest plan, the Forest engaged in a systematic inventory and eligibility evaluation for all rivers flowing on the Forest that were labeled on USGS 7.5-minute quadrangle maps. The 1996 plan included management areas and direction to preserve the outstandingly remarkable values of each eligible river. Each of these eligible segments (with the exception of Medano Creek and Little Medano Creek, which are now managed by the National Park Service), have been carried forward in the current plan revision. When the current plan revision was initiated, the responsible official concluded that no changed conditions existed and decided to limit the extent of the study process to those river segments that were not previously considered. The Forest conducted a review to identify any river segments that had been missed during the 1996 study and identified 31 river segments that would need to be considered during the current plan revision. A list of those streams is provided in Table 19 of Appendix B in the forest plan. After identifying the 31 new rivers, the forest evaluated the free-flowing condition and the presence of outstandingly remarkable values for each one. Table 19 in Appendix B of the forest plan represents a systematic review of each stream segment and the presence of all potential outstandingly remarkable values, as required by Forest Service Handbook 1909.12, Chapter 80. This evaluation led to the

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conclusion that one additional river, Deadman Creek, was eligible for inclusion in the National Wild and Scenic Rivers System as a scenic river.

Comment WSRR – 5 Elk Creek , Rio Colorado, South Elk Creek, Alamosa River headwaters, Bitter Creek, Cascade Creek, Cataract Creek, Iron Creek, Gold Creek, Prospect Creek, Treasure Creek, East Ute Creek, Middle Ute Creek, West Ute Creek, Ute Creek, Benito Creek, Halfmoon Creek, Machin Creek, headwaters of Middle Fork Saguache Creek, headwaters of South Fork of Saguache Creek, Spring Creek, Twin Peaks Creek, Wannamaker Creek, Whale Creek, Adams Fork, North Fork Conejos, Rito Azul, Mesa Creek, Rito Hondo, Spring Creek, Willow Creek, Bear Creek, Pole Creek, the Rio Grande above Rio Grande Reservoir, and West Fork Pole Creek should all be reviewed for consideration for wild and scenic eligibility because of the very high numbers of likely fens. Response All of the river segments mentioned in the comment were evaluated as part of the systematic inventory concurrent with the 1996 forest plan revision and/or were already recommended as part of the Conejos Wild and Scenic River Study from 1982 (North Fork Conejos and Rito Azul). As part of the eligibility evaluation for each of these river segments, Forest specialists considered outstandingly remarkable values, which includes outstanding geologic or other values and unique or rare features such as fens. It is important to note that, according to the Wild and Scenic Rivers Act and Forest Service Handbook 1909.12, river segments should not be considered eligible unless they possess a unique, rare, or exemplary feature that is significant when compared with other rivers at a regional or national scale. As the analysis notes, recent survey results indicate at least 17 fens across the Forest. Though this feature is uncommon in the Southern Rocky Mountains and plays an important ecological role, the presence of a fen does not, by itself, elevate a river to the level of outstandingly remarkable.

Comment WSRR – 6 All streams containing Rio Grande cutthroat trout should be evaluated for wild and scenic eligibility. Response All named streams on the Forest have been evaluated for wild and scenic eligibility, either through the 1996 evaluation or the updated analysis of changes in which forest specialists evaluated 34 additional stream reaches and identified a segment of Deadman Creek as eligible. As part of the eligibility evaluation for each of these river segments, Forest specialists considered outstandingly remarkable values, which includes outstanding fish habitat or fish populations, which would include the Rio Grande cutthroat trout. It is important to note that, according to the Wild and Scenic Rivers Act and Forest Service Handbook 1909.12, river segments should not be considered eligible unless they possess a unique, rare, or exemplary feature that is significant when compared with other rivers at a regional or national scale. As the final environmental impact statement notes, Rio Grande cutthroat trout occupy about 154 miles in 30 streams on the Forest. Though the presence of

234 Rio Grande National Forest Land Management Plan Final Environmental Impact Statement Volume II: Appendix D Public Involvement and Response to Comments Rio Grande cutthroat trout is surely a unique asset for any stream on the Forest, it does not, by itself, rise to the level of outstandingly remarkable. The presence of Rio Grande cutthroat trout is a factor that was considered in the determination that Deadman Creek is eligible as a scenic river, but it is not the only factor that led to that conclusion.

Comment WSRR – 7 Reconsider wild and scenic eligibility for Lake Fork Conejos River. Response The 2012 Planning Rule requires all national forests undergoing revision to “identify the eligibility of rivers for inclusion in the National Wild and Scenic Rivers System, unless a systematic inventory has been previously completed and documented, and there are no changed circumstances that warrant additional review.” (36 C.F.R. § 219.7 (c)(2)(vi)). During the 1996 revision of the forest plan, the Forest engaged in a systematic inventory and eligibility evaluation for all rivers flowing on the Forest that were labeled on USGS 7.5-minute quadrangle maps, including Lake Fork Conejos River. The 1996 plan included management areas and direction to preserve the outstandingly remarkable values of each eligible river. Each of these eligible segments has been carried forward in the current plan revision. When the current plan revision was initiated, the responsible official concluded that no changed conditions existed and decided to limit the extent of the study process to those river segments that were not previously considered.

Comment WSRR – 8 Corrections should be made to the management area prescriptions for Saguache Creek, which was classified by the 1996 plan as wild. Response Table 18 in the final environmental impact statement has been updated to reflect the fact that Saguache Creek is eligible for inclusion in the National Wild and Scenic Rivers System with a classification of ‘wild.’

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United States Department of Agriculture Forest Service Rio Grande National Forest 1803 W. Highway 160 Monte Vista, CO 81144 www.fs.usda.gov/main/riogrande/