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Final Weminuche Landscape Grazing Analysis Draft EIS Comments

March 28 2016

RE:  Comments on Draft EIS Weminuche Grazing Analysis

Please consider the following comments on behalf of the Colorado Chapter of Backcountry Hunters & Anglers in regards to the Draft EIS for the Weminuche Landscape Grazing Analysis, February, 2016.

Backcountry Hunters & Anglers (BHA) is a grassroots sportsmen conservation organization dedicated to serving as the sportsmen’s voice for our wild public lands, waters and wildlife. We support wildlife and wild land management plans that are science-based.   Accordingly, we felt compelled to comment on the current draft EIS concerning grazing in the Weminuche landscape.

 We applaud the Forest’s effort to carefully gather and thoroughly analyze scientific data and to note comments and concerns from a variety of stakeholders including wilderness recreationists, sportsmen, outfitters and livestock industry representatives in this process.  We appreciate this systematic approach as part of a process to make decisions that attempts to balance the science of managing bighorn sheep populations with social/economic demands.

Our comments will primarily address what we consider to be the critical and pivotal wildlife issue in the Draft EIS Weminuche Grazing Analysis – the potential for transmission of contagious respiratory disease from domestic sheep to resident bighorn sheep.  Our comments will highlight the value of bighorns, the Forest Service (FS) responsibilities for protecting the bighorns, and the recent historic, scientific and legal justification for closing all domestic sheep grazing allotments on the Weminuche landscape.

We recognize that the FS has a mandate for multiple-use and that livestock grazing is an allowed use in the Weminuche. However, grazing of Forest Lands is a privilege and not a guaranteed right for any single livestock operator on any specific allotments. 

Bighorns on the Weminuche landscape are truly special and perhaps irreplaceable.  “Rocky Mountain bighorn sheep are native to the Weminuche Landscape.  In North America, bighorn sheep have declined substantially in geographic extent of overall range and population size since European settlement (Cahn et al. 2011, CAST 2008). Carpenter et al. (2014) state current bighorn range may be just 30% of their historic distribution, and populations may be less than 5% of their numbers in the mid-1800s. Substantial declines in abundance and the distribution of herds occurred from the late 1800s through the early 1900s from factors such as over harvest, habitat alteration, competition with domestic livestock, and disease transmission from domestic livestock (Carpenter et al. 2014, Wehausen et al. 2011, CAST 2008, George et al. 2008). Bighorn sheep abundance and distribution have failed to rebound to the same extent as other ungulates whose populations declined during the same time period, due in large measure to recurrent herd-level respiratory disease outbreaks (Carpenter et al. 2014)” (Weminuche Grazing Risk Assessment, 2016 (WGRA) p.6)  

 “The Weminuche Population (DAU RBS-20) is classified by CPW as a Tier 1 population numbering about 425 animals… which is about 73% of the San Juan NF’s estimated total bighorn population of 585 animals…The Weminuche Population is believed to be one of only three herds statewide that has received little or no augmentation of individuals. For that reason the Weminuche Population may represent important historic genetic material for the San Juan Mountains and for the state of Colorado. The Weminuche Population, as a Tier 1 population, is placed in the top priority state-wide for inventory and monitoring, habitat protection and improvement, disease prevention, and research (Weinmeister 2012)”. (WGRA p.139)

Weminuche Bighorns are listed by the FS as a Sensitive Species. “Rocky Mountain bighorn sheep were historically distributed across the mountainous portions of Colorado and much of the SJNF. Their Sensitive Species designation implies there is concern for the long-term viability and/or conservation status of bighorn sheep on FS lands in the Region. This concern is based primarily on potential threats to the long-term viability of bighorn sheep populations, including diseases transmitted from domestic sheep, lack of connectivity between bighorn herds, and/or loss of genetic variability (fitness) due to habitat fragmentation, habitat loss, increased human disturbance on summer and winter grounds, competition for forage with domestic livestock, and predation on small isolated herds (SJNF 2013a, Beecham 2007). Although habitat degradation from fire suppression, highways, livestock grazing, and human disturbance is of concern, the susceptibility of bighorn sheep herds to population declines or extirpation due to respiratory diseases, which can be transmitted by domestic sheep or goats (Besser 2012b, Cassirer 2013), appears to be the greatest concern for bighorn sheep population persistence on the SJNF(SJNF 2013a)”. (DEIS p129)

There is unequivocal evidence that domestic sheep transmit respiratory disease to bighorns and that the only management solution for preventing disease transmission is spatial and temporal separation of the species.  The following is from The Joint Issue Statement of The Wildlife Society and American Association of Wildlife Veterinarians (TWS-AAWV) released March 8th, 2016. “Wild sheep are susceptible to a variety of diseases that affect herd viability. The most important diseases affecting wild sheep populations are respiratory infections that result in pneumonia. Bacteria of the family Pasteurellaceae (Pasteurella multocida, Mannheimia haemolytica and Bibersteinia trehalosi), and Mycoplasma ovipneumoniae are the most frequently isolated respiratory pathogens from wild sheep with pneumonia. Pneumonia caused by these organisms often results in the mortality of a large proportion of

the population (Cox and Carlson 2012) across all age classes (referred to as an all age epizootic or die-off) and is typically followed by enzootic disease with multiple years of lamb mortality from pneumonia (WAFWA WHC 2014). This pattern of pneumonia in wild sheep has been documented in more than 70 peer-reviewed scientific publications…Incidences of pneumonia-related die-offs are frequently associated with the presence of domestic sheep and goats (George et al. 2008, Wehausen et al. 2011). Controlled research studies have confirmed that both Mannheimia hemolytica and Mycoplasma ovipneumoniae are transmitted to wild sheep upon contact with, or proximity to, domestic sheep (Besser et al. 2014, Lawrence et al. 2010, Wehausen et al. 2011)…Management alternatives to reduce the impacts of respiratory disease on wild sheep are limited. There is currently no effective vaccine or treatment for pneumonia in bighorn sheep (Wehausen et al. 2011). Maintaining appropriate and reasonable spatial and temporal separation between wild sheep and domestic sheep and goats is the most effective tool currently available for minimizing risk of disease transmission between species. (WAFWA WSWG 2012)” (TWS-AAWV p.1)

“The policy of The Wildlife Society and the American Association of Wildlife Veterinarians regarding the risk of disease transmission from domestic sheep and goats to wild sheep is to:

  • Accept that peer-reviewed, published science has consistently demonstrated the occurrence of disease transmission from domestic sheep and goats to wild sheep upon contact or proximity.
  •  Recognize that disease transmission from domestic sheep and goats to wild sheep is a significant risk factor for the conservation and restoration of wild sheep populations…
  • Recognize effective temporal and spatial separation of domestic sheep and goats from wild sheep as the only currently available management solution for preventing or minimizing disease transmission and advocate for proactive and cooperative management strategies for achieving such separation…”  (TWS-AAWV pp.1-2)

The FS has a standard that recognizes the threat of disease transmission from domestic sheep. Standard 2.3.39 “Bighorn sheep (Ovis canadensis): during project-level planning on domestic sheep (O. aries) allotments, management options must be developed to prevent physical contact between domestic sheep and bighorn sheep. Actions may include but are not limited to boundary modification, livestock-type conversion, or allotment closures”.

The FS recognizes that foray activity occurs on the Weminuche Landscape on a regular basis and that foray activity increases the risk of disease transmission. “The four forays documented in the past four years and within two active allotments confirm that both short- and long-distance forays are occurring in the landscape on a regular basis. These observations confirm that forays are contacting allotments and bringing bighorn sheep into very close proximity (less than ½ mile) to domestic sheep. These observations confirm the potential for physical contact within active allotments, and therefore the potential for a subsequent disease transmission and bighorn mortality event. These observations therefore confirm the determinations from multiple lines of reasoning that several active allotments in the Weminuche Landscape present “High Risk” for physical contact between the species”. (WGRA p. 128)

Using the current Risk Assessment model and the Risk of Contact tool the FS identifies high risk of physical contact in 3 of the 5 active allotments under Alternatives 2, 3 and 4.  As such, even with design criteria and best management practices in place, considerable risk of physical contact between domestic and bighorn sheep is likely. (See Table 34 and 35 pp. 110-111 of WGRA)

BHA recognizes and applauds FS efforts to gather and analyze pertinent data, to conduct a risk assessment using the risk of contact tool and to establish design criteria (along with best management practices) to try to reduce risk of contact between domestic and bighorn sheep.  The work appears to be thorough and science based. “The Risk of Contact Tool was used to rank the alternatives based on the predicted frequency of contact with allotments by foraying bighorn sheep. The Risk of Contact Tool results confirm conclusions based on other quantitative and lines of reasoning in ranking the order of the alternatives in terms of reducing the risk of physical contact between bighorn and domestic sheep”.  (WGRA p.128)   BHA contends The Risk of Contact tool is probably best used for determining the relative risk of the 3 alternatives that allow continued domestic sheep grazing but the tool is not designed and does not function to accurately predict a single contact event between domestic sheep and bighorns.  In addition, BHA contends that the FS should not rely on as yet unproven design criteria and untested boundary adjustments to “enhance the effectiveness of separation between species."  (WGRA p. 136)

 Although it appears to be very challenging to predict the likelihood of a contact event that results in disease transmission, as long as domestic sheep graze in allotments on the Weminuche landscape frequented by bighorns on forays - a real, known and undeniable threat to the viability of bighorns Forest Wide remains present.  A single transmission event could cause a significant mortality event and/or low reproductive capacity.  Again, “Numerous controlled studies have shown more than 90% mortality in bighorn populations due to respiratory diseases within two months after exposure to domestic sheep”. (The Wildlife Society Fact Sheet, 9/2014).  And, because of the interconnected nature of the meta-population of S-28, S-16, and S-15, up to 73% of the Weminuche Tier 1 herd could be affected.  “Because the Weminuche Population represents nearly three quarters (73%) of the bighorn population and geographic distribution across the planning area, viability across the planning area is closely related to the status and function of the Weminuche Population. A disease event involving the population that represents 73% of the bighorn population on the planning area and roughly half of the geographic distribution across the planning area has potential for being a significant event for viability of bighorn sheep Forest Wide”.  (WGRA p142)  Note, too that a loss of all bighorns in S-28, S16 and S15 represents a potential loss of all of the highly valued Tier 1 population on the Weminuche Landscape.

The FS recognizes that closing all sheep grazing allotments on the Weminuche is the only way to completely prevent contact and disease transmission on the landscape and likely promote bighorn viability. “Alternative 1 is the only alternative that completely prevents physical contact between bighorn sheep and domestic sheep authorized by the Columbine Ranger District to graze on NFS lands in the Weminuche Landscape because this alternative does not authorize domestic sheep grazing in the Landscape. Alternatives 2, 3 and 4 all result in some potential for physical contact between the species because domestic sheep would continue to be permitted to graze some portions of NFS lands within the Landscape”. (DEIS p.3)  “…Alternative 1 provides the greatest likelihood of maintaining bighorn viability across the planning area over the long term (next 10+ years)”.  (WGRA p.147)

Closures of other domestic sheep grazing allotments have been used by the FS to protect the S16 and S15 herds.

“Domestic sheep grazing activities in proximity to S-15 are managed by the Pagosa Ranger District, and by the Divide Ranger District of the Rio Grande National Forest (RGNF). There are no active domestic sheep grazing allotments on NFS lands managed by the Pagosa Ranger District in S-15. A 2010 NEPA decision closed all vacant allotments in S-15 on the Pagosa Ranger District due to concerns for the high risk of contact between domestic and bighorn sheep. Two forage reserve allotments remain available on the Pagosa RD in or immediately adjacent to S-15 (Bonito Crater and Treasure) but intensive surveys would be required before stocking would be permitted. In another recent NEPA decision, the Divide Ranger District on the Rio Grande National Forest vacated the Fisher/Ivy/Goose Allotment in S-15, with concurrence from the permittee, due to concerns for high risk of contact between domestic and bighorn sheep.

There are several domestic sheep and goat grazing allotments on the Divide Ranger District of the Rio Grande NF that overlap or lie adjacent to S-16, but all are currently vacant due in part to concerns for potential for contact with domestic sheep. All domestic sheep allotments on the portions of S-16 and S-28 managed by the Pagosa Ranger District were closedto domestic sheep grazing in 2010 (USDA Forest Service 2010b). Only one sheep allotment in the Weminuche Landscape overlaps S-16 (see Figure 5 at the end of this document, and EIS Figure 1-4), the Pine River Allotment, which has remained vacant since it was last grazed by domestic sheep in 1980.”  (WGRA pp 139-140)

Federal Courts have recently upheld the closure of sheep grazing allotments in Idaho.

Recent closures of domestic sheep grazing allotments as a management tool to prevent disease transmission on the Payette National Forest have been recently upheld by the Ninth Circuit on March 2, 2016.  The courts clearly and unequivocally recognize the science and the threat to bighorns.  "The conclusion was that the scientific consensus is that disease transmission from domestic sheep - by whatever mechanism and involving whatever confounding factors - poses a sufficient risk to bighorn sheep viability to merit separation of the bighorns from the domestic animals," wrote Circuit Judge Marsha Berzon in a 29-page opinion. (Ninth Circuit Court Opinion, March 2016).

Time is of the essence.  There is uncertainty but it is likely that bighorn core herd home ranges and foraging activities will change in the next few years possibly increasing the risk of contact with domestic sheep as the result of habitat changes produced by a spruce beetle epidemic.

“Within the next five years the beetle outbreak is expected to expand down the Pine River and Vallecito Creek drainages, and is expected to increase in the upper Florida River and Missionary Ridge portions of the Weminuche Landscape. Spruce mortality resulting from this beetle epidemic is expected to increase forbs and grasses in the understory of previously closed-canopy stands. For this reason, the beetle epidemic has the potential to substantially alter habitat conditions for bighorn sheep, likely improving habitat connectivity for bighorn sheep in the most heavily affected areas. Beetle epidemics have the potential to substantially open the canopy of mature closed-canopy stands, potentially greatly improving bighorn forage and travel habitats”.   (WGRA p159)  Closing all sheep grazing allotments as soon as possible may prevent an exposure and mortality event made more likely by habitat changes associated with the spruce beetle epidemic.

 The current and potential future economic value of a healthy and growing population of Tier 1 bighorns on the Weminuche dwarfs the economic impact of sheep grazing on the landscape.

“For the six active allotments, annual average use was 1,800 AUM for sheep and 252 AUM for cattle (Canyon Creek only) during the past five years. Using this actual AUM usage information along with agency economic contribution model, the regional economic effects in terms of Social and Economic Specialist Report Page 15 employment, income and GRP are estimated. On an annual average basis, permittee grazing on these allotments contributes approximately $580,000 to GRP, $300,000 in labor income (2014 USD), as well as support/sustain about 11 full and part time jobs in the regional economy”.  (Social and Economic Specialist Report March 2015(SESR).  (pp 14-15)  The actual economic impact of a single permitted domestic sheep operation is unknown but could be reasoned to be a fraction (50-75%) of the numbers above reflecting a lower total economic contribution than noted.

In contrast, a report released by CPW in February 2014 analyzed the economic contributions of outdoor recreation, including hunting and wildlife watching (CPW 2014). The study found that hunting contributes $82 million of economic output annually in southwest Colorado, while wildlife watching contributes $213 million. The Socioeconomic Analysis in the EIS fails to consider the recreational values, both consumptive and non-consumptive, of bighorn sheep populations distributed across suitable habitats in the analysis area, and the economic impact of potentially losing 75% of bighorn sheep in the planning unit under the Preferred Alternative 4. In 2014 hunters submitted 14,838 applications for the opportunity to draw one of 254 Colorado bighorn sheep licenses, and 292 of those were for the 13 licenses available for herds on the San Juan National Forest.  According to the Rocky Mountain Bighorn Society the auction of a single Colorado bighorn sheep license in January 2014 raised $130,000, and the raffle of an additional license raised $78,200. Those funds were put directly into bighorn sheep management programs in the state. 

Likewise the SESR does not determine the potential economic impact of managing the Weminuche bighorn herd in a manner that promoted greater vitality and natural expansion of the herd into all the allotments closed to sheep grazing (Alternative 1).   A significant increase in economic activity from increased hunting and wildlife viewing opportunities would be expected.  Although specific data on the economic benefits of Alternative 1 are not presented in the SESR and may not be readily available, it can be reasoned that this action aligns with a statement from the SESR that “Management of NFS lands is expected to yield positive net benefits for the American public – including the consideration of all benefits and costs.”  Removing domestic sheep from the Weminuche should reduce management costs, reduce the risk of economic losses associated with a bighorn mortality event and encourage the development of bighorn wildlife watching and hunting opportunities for generations of Americans.

BHA recognizes that closing all sheep allotments on the Weminuche Landscape will likely represent a challenging transition for the permittee.  BHA recognizes the history and heritage of sheep grazing in the region.  However, we believe that future generations will thank the FS for having the wisdom to act in a timely and decisive manner to protect the iconic bighorns of the Weminuche.  

BHA recognizes the political nature of this process and impending decision.  In our review of the DEIS we have noted with dismay the significant impact of a joint letter  by Bob Broscheid of Colorado Parks and Wildlife and John Salazar of the Colorado Department of Agriculture (CDA) signed and submitted in the Weminuche Landscape Grazing Assessment EA.(Broscheid and Salazar 2014). That submitted letter, which can best be described as a politically-motivated capitulation by CPW to the CDA under pressure from the Governor’s Office is referred to several times in the DEIS and has had the following end effect in the DEIS:

“CPW Position: This line of information is considered because the CPW biologists are probably the most familiar with the current state of bighorn herds on this landscape, and the risks to those herds. The CPW and CO Department of Agriculture were supportive of an alternative that continues to allow domestic sheep grazing on the Weminuche Landscape in a manner that reduces the risk of contact. They expressed concern about the proximity of domestic sheep grazing on this landscape, and they also expressed that grazing under current conditions posed a low enough risk that grazing could continue. The State also expressed concerns about closing allotments to grazing, and the potential for future limitations on grazing and impacts to the local agricultural economy and community (Broscheid and Salazar 2014).” p.140 DEIS

We found further evidence of this undue political influence in the Weminuche Grazing Risk Assessment (WGRA), published as part of the Documents of the DEIS:

“Memorandum of Understanding (Colorado Parks and Wildlife 2013a): dated October 14, 2013, and signed by USDA Forest Service Rocky Mountain Region, USDI Bureau of Land Management Colorado State Office, Colorado Parks and Wildlife, Colorado Department of Agriculture, and the Colorado Woolgrowers Association.

This document recognizes, among other things, that contact between domestic sheep and bighorn sheep increases the probability of respiratory disease outbreaks in bighorn sheep, but also recognizes that not all disease outbreaks and reduced recruitment in bighorn sheep can be attributed to contact with domestic sheep. The stated goal is to minimize contact by decreasing the opportunities for domestic/bighorn sheep interaction, while still recognizing that some vacant sheep allotments are important to the domestic sheep industry as forage reserves or for other economic or management reasons. The bighorn sheep management concepts specifically agreed to by the USFS are stated in section IV, parts a through h, of the MOU. It is agreed by CPW and Colorado Woolgrowers in section V that closure of active sheep allotments will not be recommended based solely on the potential for interaction between domestic and bighorn sheep. It is also recognized that land management agencies (USFS and BLM) will follow existing regulation and direction regarding closure or modification of active allotments to resolve documented resource conflicts.”  (WGRA p.20)

Based on this research BHA believes that CPW and Forest Service have been unduly politically pressured by agriculture interests and have improperly placed priority on the need to maintain domestic sheep grazing on the Weminuche Landscape.  With the recent Joint Statement of TWS/AAWV and the Ninth Circuit Court of Appeals Opinion, BHA believes there should now be little doubt that closure of allotments is scientifically sound and legally required.

Again, three of the four Weminuche Landscape  DEIS alternatives will continue to put bighorns at risk – even in the face of unequivocal science that clearly warns of risk of significant mortality events.  “Alternative 1 is the only alternative that completely prevents physical contact between bighorn sheep and domestic sheep authorized by the Columbine Ranger District to graze on NFS lands in the Weminuche Landscape because this alternative does not authorize domestic sheep grazing in the Landscape. Alternatives 2, 3 and 4 all result in some potential for physical contact between the species because domestic sheep would continue to be permitted to graze some portions of NFS lands within the Landscape”. (DEIS p.3)  “…Alternative 1 provides the greatest likelihood of maintaining bighorn viability across the planning area over the long term (next 10+ years)”.  (WGRA p.147)

Yet in both the DEIS and WGRA documents and even the public meeting held in Durango on March 12, Alternative 1 is/was presented as mostly untenable.  We think this is wrong.

 In summary, BHA is convinced that vacating and eventually closing all domestic sheep grazing allotments on the Weminuche landscape is the only way for the Forest Service to effectively protect native bighorns against disease transmission from domestic sheep on the landscape.  This limited application of Alternative 1 is scientifically sound, economically justifiable and legally upheld.   Permanently removing domestic sheep from all the allotments will promote a viable, vigorous and expanding population of highly valued Tier 1 bighorns across the Weminuche landscape. 

 Loss of Elk and Other Hunting Opportunities

Finally, in addition to bighorn concerns, we would also like to state that our members have noted the decreased presence of elk in the permitted area both during the permit season as well as during the early rifle seasons.  The presence of domestic sheep and herder camps, particularly new herder camps in recent years near timberline in the Virginia Creek drainage, appear to have pushed out elk herds and decreased hunting opportunities in this area.  This is important elk hunting territory as it provides opportunities for hunting in a Wilderness Area within a day’s hike from the boundary without OHVs and other disturbances present in non-Wilderness Areas.

Thanks for taking the time to consider our input.   Please don’t hesitate to let us know if there is any clarification needed on our comments.   We look forward to being involved throughout the rest of the process.

Sincerely,

Dan Parkinson DVM

Southwest Regional Director

Colorado Backcountry Hunters & Anglers

 

Literature Cited

Broscheid, Bob, and John Salazar. 2014. Weminuche Landscape Grazing Analysis Environmental Assessment. Joint comment letter from CPW and CO Dept Agric. 16 July 2014. (Attached)

MOU. 2013. Memorandum of Understanding for Management of Domestic Sheep and Bighorn Sheep. USDA Forest Service R2, USDI BLM CO, CO Dept. of Agriculture, CO Woolgrowers Assoc., and CO Division of Wildlife. Oct. 2013. 4pp. (Attached)

The Wildlife Society and American Association of Wildlife Veterinarians Joint Issue Statement,

 Domestic Sheep and Goats Disease Transmission Risk to Wild Sheep.  March, 2106

http://wildlife.org/wp-content/uploads/2015/03/WS-DS_DiseaseTransmission_TWS-AAWV_JointStatement_APPROVED.pdf

The Wildlife Society Fact Sheet, Impacts of Disease on Bighorn Sheep Management.   February, 2014.

http://wildlife.org/wp-content/uploads/2014/11/TWS_FactSheet_BighornSheep_FINAL_2014.11.13.pdf

United States Court of Appeals for the Ninth Circuit, No. 14-35445 D.C. No. 1:12-cv-00469-BLW OPINION. March, 2016 https://cdn.ca9.uscourts.gov/datastore/opinions/2016/03/02/14-35445.pdf

USDA, Forest Service. 2015 Weminuche Landscape Grazing Analysis, Social and Economic Specialist Report, San Juan National Forest  March 31, 2015  http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/nepa/83582_FSPLT3_2669829.pdf

USDA, Forest Service.  2016.  Assessment of Risk of Physical Contact between Rocky Mountain Bighorn Sheep and Domestic Sheep in the Weminuche Grazing Analysis Landscape Jan. 27, 2016 Columbine Ranger District, San Juan National Forest http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/nepa/83582_FSPLT3_2718886.pdf

USDA, Forest Service.  2016. Draft Environmental Impact Statement, Weminuche Landscape Grazing Analysis.  February, 2016 Columbine Ranger District, San Juan National Forest  http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/nepa/83582_FSPLT3_2900099.pdf

 

FAQ: Expanding Public Access On State Trust Lands

014777504 640x480 CopyColorado sportsmen are sick of being locked out of our state lands, though our voices are definitely being heard! Colorado Parks & Wildlife and the Colorado state land board have held public meetings on the issue. We’re also continuing to work to advance legislation that would provide the direction and funding needed to expand public access on state trust lands. This fight is far from over!

Frequently Asked Questions:

Isn’t most state trust land in Colorado already open to the public?

No. While every other Western state provides public access to the majority of state trust lands with legal public access (via public road or adjacent to public land), Colorado currently provides access to only about 20 percent (485,000 acres) of its lands. Of the remaining 80 percent, private outfitters, clubs and individuals control recreational access on 5 percent. Recreational access on the remaining 75 percent is controlled by those who lease the state trust lands for other purposes, such as agriculture and energy production. Note that these lease holders are not paying for the exclusive recreational access they currently enjoy. 

BLM Little Snake Field Office Travel Management Area 1 Scoping Comments

Dear Sir/Ma’am:

Below you will find comments from the Colorado chapter of Backcountry Hunters & Anglers (COBHA), a non-profit 501(c)(3) group of sportsmen and women who share the common goal of preserving traditional hunting and angling activities and conserving our wild public lands, waters and wildlife.  Our mission is to ensure America’s outdoor heritage of hunting and fishing in a natural setting through education and work on behalf of wild public lands and waters.  We appreciate this opportunity to provide scoping comments on the BLM Little Snake Field Office’s (LSFO) Travel Management Area 1 planning process.

The TMA 1 planning area encompasses significant habitat for elk, mule deer, pronghorn, mountain lion, greater sage-grouse, and many other species of wildlife.  These wildlife populations are a public resource and represent resources of regional and state-wide significance.  Hunting and angling support a $3 billion per year industry in Colorado and rural communities in northwest Colorado depend on the annual economic benefit provided by hunters and anglers that come here to enjoy the area’s world class wildlife-related recreational opportunities.  

BLM plan may be solution that allows drilling while maintaining unique qualities of Thompson Divide

Thompson Divide Lindberg StevensoilandgasleaseislocatedinmiddleoflakeAs a sportsman who cares greatly about access to our state’s public lands, I support the Bureau of Land Management’s recently issued draft decision that would honor existing oil and gas operations on the land but halt development in undeveloped areas of the Thompson Divide.

These valuable landscapes have attracted generations of sportsmen, including Theodore Roosevelt himself. Limiting development in this fish- and wildlife-rich tract of the White River National Forest is a balanced approach that respects current oil and gas activities while conserving the undeveloped habitat that our fish and wildlife populations need.

BLM State Director Ruth Welch and Colorado River Valley BLM Field Office Manager Karl Mendonca deserve our thanks for listening to the public, which voiced overwhelming support for this course of action during the comment period for this draft decision. Their response shows that they were heeding the calls of citizens who cherish these lands and waters and all they represent.