THE WILDERNESS SOCIETY, HIGH COUNTRY CONSERVATION ADVOCATES, WESTERN COLORADO CONGRESS, CONSERVATION COLORADO, GREAT OLD BROADS FOR WILDERNESS, SHEEP MOUNTAIN ALLIANCE, ROCKY MOUNTAIN WILD, SAN JUAN CITIZENS ALLIANCE, ROCKY SMITH, RIDGEWAY OURAY COMMUNITY COUNCIL, WESTERN ENVIRONMENTAL LAW CENTER, WEST SLOPE CONSERVATION CENTER Forest Planning Team GMUG National Forest 2250 Highway 50 Delta, CO 81416 January 22, 2018 Dear GMUG Planning Team, Please accept these comments on the draft wilderness inventory from The Wilderness Society, High Country Conservation Advocates, Western Colorado Congress, Conservation Colorado, Great Old Broads for Wilderness, Sheep Mountain Alliance, Rocky Mountain Wild, San Juan Citizens Alliance, Rocky Smith, Ridgeway Ouray Community Council, Western Environmental Law Center, and Western Slope Conservation Center. The Grand Mesa-Uncompahgre-Gunnison National Forest (GMUG) posted the draft inventory online1 on January 8, 2018 and set January 22, 2018 as the deadline for submitting comments. We want to thank you for contacting us before you released the draft inventory, and taking the time to answer our questions during this two-week period. This letter is divided into two sections. The first section discusses the draft wilderness inventory criteria2 that the GMUG used to identify wilderness inventory polygons, and the second section provides feedback on specific polygons. To the degree we were able, we have provided photographs, google earth screen shots, and other pieces of evidence to support our comments. I. Feedback on the Wilderness Inventory Criteria A. Size criteria Page 2 of the draft criteria document describes how the ‘size’ criteria were applied: Areas to be included in the Inventory must be federal lands and must meet one of the following size criteria: 1. The area contains 5,000 contiguous acres or more. 2. The area contains less than 5,000 contiguous acres, but is of sufficient size as to make practicable its preservation and use in an unimpaired condition, including but not be limited to areas contiguous to an 1 https://www.fs.usda.gov/detail/gmug/landmanagement/planning/?cid=fseprd500301 2 Available at https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd568465.pdf 1 existing wilderness, primitive areas, administratively recommended wilderness, or wilderness inventory of other Federal ownership. 3. For areas less than 5,000 acres that are not adjacent to already designated areas, the Responsible Official will need to consider and determine whether such areas could be preserved in an unimpaired condition. (No areas that meet this size criteria are yet included in the inventory; this criteria will apply if such smaller, isolated areas are recommended by the public). Subsection 3 is unnecessary (it describes a subset of situations under section 2) and it is confusing because it appears inconsistent with the language in section 2. Subsection 2 directs the GMUG to look at areas less than 5000 acres that are of sufficient size to make practicable their preservation and use in an unimpaired condition, including when they are contiguous to existing wilderness or wilderness inventory areas under other Federal ownership, while subsection 3 refers to areas contiguous to existing designated wilderness only. Recommendation: Delete subsection 3. In addition, after listening to the informational webinars offered by the GMUG on the wilderness inventory, we got the sense that the GMUG may have not comprehensively applied the adjacency filter. Subsection 2, which echoes the language in FSH 1909.12, chapter 70, section 71.21(2), directs the agency to include polygons that are less than 5,000 acres in size and adjacent to designated wilderness, primitive areas, administratively recommended wilderness, or wilderness inventory of other Federal ownership. Emphasis added. It was our sense from the conversation on the webinar that the GMUG may have only looked at polygons adjacent to designated wilderness and may have not considered polygons adjacent to wilderness inventory areas of other federal units. These include Bureau of Land Management (BLM) lands of wilderness characteristics and wilderness study areas, as well as wilderness inventory areas on adjacent national forests (Rio Grande, White River, Pike-San Isabel, and San Juan). While we are sure more exist, here is one example where acreage was inappropriately left out of the inventory for failure to look across the boundary. Inventory polygon 61 (Matterhorn) inappropriately excludes Sunshine Mountain on the south side of the North Fork Henson Creek, apparently because it appears to be an isolated fragment less than 5,000 acres in size. However, this portion of the inventory polygon is adjacent to the BLM’s American Flats Wilderness Study Area (WSA), which itself is contiguous with the Uncompahgre Wilderness. The boundary for inventory polygon 61 should align with the Colorado Roadless Area (CRA) boundary and include all lands adjacent to the BLM WSA. An excerpt from the BLM’s Montrose 1:100K surface management quad is attached below that depicts the relationship of these units. 2 Additionally, there is an inventory polygon under 5,000 acres that has recently been pending in wilderness legislation introduced in Congress, most recently in the Colorado Wilderness Act of 2015. This is the western portion of Horsefly Creek, which would be part of inventory polygon 18 other than for a transmission line, and is included within the proposed Norwood Canyon wilderness unit on adjacent BLM lands in the legislation. See Exhibit 4 for a map and additional details. Recommendation: We request that you ensure that the adjacency filter is comprehensively applied so that polygons less than 5,000 acres and adjacent to wilderness inventory units or in pending wilderness legislation under other federal management are included in the wilderness inventory. As a first step, you should check to make sure that CRA acreage is not excluded from the inventory, and if it is you should check to make sure that the exclusion is not due to a failure to apply the adjacency filter appropriately. B. Substantially noticeable improvements i. Application of the definition of substantially noticeable improvements is not adequately rigorous. The hardest part of developing the inventory of lands that may be suitable for wilderness is identifying with rigor, accuracy, and replicability the substantially noticeable improvements. While we like the definition of substantially noticeable improvements proffered on page 4 (“An improvement is substantially noticeable when it creates a noticeable difference in form, line, color, texture and pattern in the surrounding natural landscape at a size, scale, or concentration that contrasts with the surrounding natural landscape. To be substantially noticeable, the improvement or concentration of improvements must be more dominant than the surrounding natural landscape scene.”), we are concerned that the criteria and data sets that the GMUG used to evaluate whether improvements meet the definition are deficient, and inadequate or inappropriately utilized, respectively. The Wilderness Society has developed inventories in several forests using the criteria set forth in the Forest Service Handbook 1909.12, chapter 70, and has found that it is necessary to utilize digital spatial data 3 with sufficient detail and attribution so that substantially noticeable and substantially unnoticeable impacts can be distinguished, and complement digital data with field surveys. We are concerned that the GMUG developed the inventory using digital data only and without sufficient rigor such that the resultant inventory inappropriately excludes qualifying acreage from the inventory. Below, we describe exactly how the GMUG inventory is deficient, and offer recommendations on how the GMUG might address the deficiencies. 1. Vegetation treatments and timber harvests The criteria document states that all vegetation treatments beyond the removal of a single tree are considered substantially noticeable and are excluded from the inventory. If the vegetation treatment involved tree removal beyond single tree removal, it is considered substantially noticeable and has been excluded from the draft inventory.9 Other types of vegetation treatment, i.e., weed treatment, are included in the Inventory. Footnote 9 states that: Vegetation treatment activities considered substantially noticeable, and/or are typically associated with harvest activities: Commercial thin, coppice cut, disease control, fill-in or replant trees, fill-in seed or reseed trees, fire line construction, fuel break, group selection cut, improvement cut, insect control, over story removal cut, patch clear-cut, permanent land clearing, piling of fuels (hand or machine), plant trees, pre-commercial thinning for visual, pre-commercial thin, range control vegetation, salvage cut, sanitation cut, seed-tree cuts, Shelterwood establishment cuts, single-tree selection cut, site preparation for natural regeneration (mechanical), site preparation for planting (mechanical), stand clear-cuts, thinning for hazardous fuels reduction, tree encroachment control, tree release and weed, watershed resource non-structural improvements erosion control, wildlife habitat (activities, create corridors, create openings, intermediate cut, mechanical treatment, non-structural improvements, pre- commercial thinning, and regeneration cut).” Draft Wilderness Inventory Criteria, page 5. Similarly, the draft criteria documents states that all timber harvest