ALASKA CALIFORNIA FLORIDA MID‐PACIFIC NORTHEAST NORTHERN ROCKIES NORTHWEST ROCKY MOUNTAIN WASHINGTON, D.C. INTERNATIONAL January 15, 2016 Colorado Roadless Rule U.S. Forest Service, Rocky Mountain Region 740 Simms Street Golden, CO 80401 Via Email: [email protected] Re: Comments of High Country Conservation Advocates et al. on Supplemental Draft EIS on Proposal to Reinstate North Fork Coal Mining Area Exception to the Colorado Roadless Rule (Project #46470) Dear Secretary Vilsack: Thank you for this opportunity to comment on the U.S. Department of Agriculture’s supplemental draft environmental impact statement (SDEIS) on the agency’s proposal to reinstate the North Fork Coal Mining Area exception to the Colorado Roadless Rule. This letter is sent on behalf of the following conservation groups and conservationists, all of whom have a longstanding interest in the protection and wise stewardship of roadless national forest lands and our climate. High Country Conservation Advocates (HCCA) was founded in 1977 as High Country Citizens’ Alliance, to keep Mount Emmons molybdenum mine-free. HCCA’s work now addresses other issues that affect Gunnison County’s clean air, clean water, public lands, and healthy wildlife. HCCA has over 600 members who live, recreate, and enjoy the rural and wild character of Gunnison County and its public lands. The Sierra Club is America’s largest grassroots environmental organization, with more than 2.4 million members and supporters nationwide. In addition to creating opportunities for people of all ages, levels and locations to have meaningful outdoor experiences, the Sierra Club works to safeguard the health of our communities, protect wildlife, and preserve our remaining wild places through grassroots activism, public education, lobbying, and litigation. Sierra Club is dedicated to exploring, enjoying, and protecting the wild places of the Earth; to practicing and promoting the responsible use of the Earth’s resources and ecosystems; to educating and enlisting humanity to protect and restore the quality of the natural and human environment; and to using all lawful means to carry out these objectives. WildEarth Guardians is a Santa Fe, New Mexico-based nonprofit organization with offices throughout the western U.S., including in Colorado. WildEarth Guardians is dedicated to protecting and restoring wild places, wildlife, wild rivers, and the health of the American West and has over 100,000 members. As part of its Climate and Energy Program, Guardians works to combat climate change by advancing clean energy and aiding a transition away from fossil fuels, the key source of the greenhouse gases fueling global warming, particularly on our pubic lands. In doing so, Guardians defends the public interest by safeguarding clean air, pure water, vibrant wildlife populations, and protected open spaces. ROCKY MOUNTAIN 633 17TH STREET, SUITE 1600 DENVER, CO 80202 T: 303.623.9466 F: 303.623.8083 [email protected] WWW.EARTHJUSTICE.ORG HCCA Comment Letter re: 2015 Supplemental Draft EIS on Colorado Roadless Rule Page 2 January 15, 2016 The Center for Biological Diversity is a non-profit environmental organization with 50,400 member activists, including members who live near and recreate in the areas in the Grand Mesa, Uncompahgre and Gunnison National Forests. The Center uses science, policy and law to advocate for the conservation and recovery of species on the brink of extinction and the habitats they need to survive. The Center has and continues to actively advocate for increased protections for species and habitats in the planning area on lands managed by the Forest Service. The lands and waters that will be affected by the decision include habitat for many listed, rare, and imperiled species that the Center has worked to protect including the Colorado pikeminnow, humpback chub, bonytail, razorback sucker, Colorado cutthroat trout, and Canada lynx. Founded in 1947 as Defenders of Furbearers, Defenders of Wildlife is a nonprofit organization dedicated to the protection and restoration of wildlife and plants in their natural communities, with 1.2 million members and supporters nationwide. Defenders’ distinguished record of leadership on America’s conservation efforts includes helping secure final passage of the Endangered Species Act in 1973. Our current priorities include conserving wildlife including the predators that help maintain biodiversity, protecting the Endangered Species Act and other important wildlife conservation laws from political attacks, supporting policies and practices that help wildlife adapt to climate change and advocating for wildlife-friendly renewable energy development. Friends of the Earth fights to create a more healthy and just world. Its current campaigns focus on promoting clean energy and solutions to climate change, ensuring the food we eat and products we use are safe and sustainable, and protecting marine ecosystems and the people who live and work near them. Founded in 1967, the mission of Wilderness Workshop’s (“WW”) mission is to protect and conserve the wilderness and natural resources of the Roaring Fork Watershed, the White River National Forest, and adjacent public lands. WW is a non-profit organization that engages in research, education, legal advocacy and grassroots organizing to protect the ecological integrity of local landscapes and public lands. WW not only defends pristine public lands from new threats, but also helps restore the functional wildness of a landscape fragmented by human activity. WW protects and preserves existing wilderness areas, advocates for expanding wilderness, defends roadless areas from development that would destroy their wilderness character, and safeguards the ecological integrity of all federal public lands in its area of interest. WW has a long history of participation in forest planning on the White River National Forest. WW has approximately 700 members who support its mission and enjoy the lands WW protects and conserves. Rocky Mountain Wild (“RMW”) is a conservation advocacy organization focused on protecting wildlands for wildlife throughout the Southern Rocky Mountain region (Colorado, eastern Utah, southern Wyoming, and northern New Mexico). The organization has around 600 members who are passionate about protecting the biodiversity and ecosystem health throughout the region. RMW advocates for its members’ interests through participating in administrative processes, collaboration, education, and when necessary; litigation. Rocky Mountain Recreation Initiative works to protect Colorado wildlands and roadless areas from high-impact human disturbance so the integrity of these lands remain intact for wildlife HCCA Comment Letter re: 2015 Supplemental Draft EIS on Colorado Roadless Rule Page 3 January 15, 2016 and future generations. RMRI also promotes responsible recreation, working closely with Colorado land management agencies, including the Forest Service and Bureau of Land Management to ensure sustainable trail planning and long-distance motorized trail planning. Founded in 1986, San Juan Citizens Alliance (“SJCA”) advocates for clean air, pure water, and healthy lands – the foundations of resilient communities, ecosystems and economies in the San Juan Basin. SJCA is a membership organization with 650 dues-paying members and over 2,000 supporters that has been active in BLM and National Forest fossil fuel issues in southwest Colorado and northern New Mexico since the early 1990s. Great Old Broads for Wilderness is a national organization, with 5,200 members nation-wide, including 700 members in Colorado. Great Old Broads for Wilderness engages and ignites the activism of elders to preserve and protect wilderness and wild lands. Broads gives voice to the millions of older Americans who want to protect their public lands as Wilderness for this and future generations. Broads brings experience, commitment, and humor to the movement to protect the last wild places on Earth. Environment Colorado is a statewide, citizen-based, environmental advocacy organization that works to protect Colorado's clean air, clean water, and open spaces. 350Colorado.org 350 Colorado (350CO) is a Colorado-based nonprofit organization working locally to help build the global grassroots movement to solve the climate crisis and transition to a sustainable future. 350CO has 10 local teams around the state of Colorado and over 10,000 supporters. As an organization that is working to stop catastrophic climate change that is already wreaking havoc on people and ecosystems worldwide, with terrible impacts on forests across the west through the pine beetle epidemic and record-breaking wildfires, 350CO is extremely concerned about the proposal to open more forest land up for mining of 170 million tons of coal on tax-payer owned land. Wildlands Network is a nonprofit conservation organization with offices and staff across North America, including Durango Colorado, Flagstaff Arizona, Portal Arizona, Salt Lake City Utah and Ogden Utah. We work to halt the 6th Great Extinction. We reconnect wildlife habitats in North America so that animals can live in and move safely through the landscape. Public lands, particularly roadless areas are essential to wildlife, biodiversity and to our mission. Our staff and supporters rely on and use roadless areas for recreation, scientific study and other human uses. We collaborate with partner groups to create wildlife corridors at a large enough scale to meet the needs of wolves, mountain lions, and other native carnivores.