September 18, 2013

Thank you for the opportunity to comment on the Draft Resource Management Plan and Environmental Impact Statement (Draft RPM/EIS) and Travel Management Plan for the Dominguez-Escalante National Conservation Area (D-E NCA). I am submitting my comments on behalf of the Colorado Chapter of the Backcountry Hunters and Anglers. I represent our State Chapter as the Habitat Watchman for the Uncompahgre.   Backcountry Hunters and Anglers is a grassroots organization of sportsmen and women who strongly believe in the principals of the North American Wildlife Conservation Model and the value of our public lands for fish and wildlife habitat and the traditional fishing and hunting opportunities that are available to all sportsmen. As a group of sportsmen, we are highly dependent upon our public lands to support the fish and wildlife species we all enjoy. We believe in the conservation and management of fish and wildlife habitats on our public lands, and in providing undisturbed backcountry areas for fish and wildlife and the opportunity for traditional methods of hunting and fishing that challenge us physically and mentally and emphasize the principals of fair chase.

Our membership can also be characterized as families who enjoy undisturbed backcountry for reasons other than hunting and fishing. We cherish the opportunity to venture into areas free of the noise and activity of OHV’s and bicycles to enjoy the peace and solitude of the outdoors with our friends and family on river trips, day hikes, backpacking trips, and horse pack trips.   We also strongly feel that these opportunities should not only be available to us now but to our future generations as well.

We recognize the need for BLM to provide a spectrum of recreational opportunities within the D-E NCA to comply with the Omnibus Act creating the NCA. After reviewing the Draft RMP/EIS it is apparent that the BLM recognizes the values of unroaded, primitive backcountry areas with no motorized use that are managed for wildlife habitat effectiveness and security, backcountry hunting and recreation opportunities, and solitude for people. We appreciate the BLM incorporating these values into the analysis and support many of the management strategies and actions included in the preferred alternative.

I have previously submitted comments to you on May 2 and June 13, 2011 with specific comments on Travel Management within the D-E NCA. After reviewing the Travel Management Plan included in the Draft RMP/EIS it is apparent that you have considered our comments and incorporated many of them into the preferred alternative. This letter provides further comments on the Draft RMP/EIS and Travel Management Plan for the D-E NCA.

The following comments are based upon the analysis provided in the Alternatives Matrix (Table 2.2) for the BLM preferred alternative (Alternative 5)

Management of Resources.

We are in full support of actively managing the vegetation resources within the D-E NCA to meet BLM’s land health standards for the benefit of the biological resources of the area. The BLM has planned and implemented several roller chops and seedings in the Wagon Park and Steamboat Mesa areas of the Plateau. These projects have done an excellent job of restoring big game habitat within the old burned areas, P/J chainings, and other sites to improve vegetation condition, induce mosaics for wildlife habitat, increase forage, and reduce the risk of large-scale wildfires. However, many of these projects have created or reestablished roads and OHV trails into areas that were previously inaccessible by motorized vehicles. During the time I have lived and worked here I have seen a steady progression of user-developed OHV trails become established in areas such as Wagon Park that have opened up large areas that were previously inaccessible with four-wheel-drive vehicles and ATV’s. Leaving these access roads and user-developed trails open completely negates the benefits of the vegetation treatments for wildlife.

The BLM needs to implement an active program of road closures to eliminate these routes and restore the benefits of the vegetation treatments as well as the hunting experience in these areas. The RMP should include Management Goals and Objectives to maintain and improve big game habitat capability within these treatment areas and include Actions specifying immediate closure of fire lines and roads used to suppress wildfires and implement vegetation treatments such as roller chopping and prescribed burns to prevent this route proliferation.

In addition we fully support the BLM proposal to implement seasonal restrictions on lands classified as big game winter range. The seasonal closures are vitally needed to provide solitude for wintering big game herds that can be displaced from preferred habitats by motorized vehicles during the time they are most vulnerable. Vegetation treatments to improve big game winter range would be totally negated without limiting winter activities. The seasonal closures need to be coordinated with the areas currently restricted on adjacent National Forest lands as depicted on the 2008 visitor map for the Uncompahgre National Forest. The seasonal closures must apply to all motorized vehicles including snowmobiles. Big game winter ranges on the National Forest are closed from December 1 through April 15 each year, regardless of snow conditions.

For this reason we support the seasonal restriction language included in Table 2.2 for Alternatives B and C instead of the preferred alternative: Close BLM routes from December 1 to April 30 within mule deer and elk winter concentration areas to public motorized and mechanized vehicles (as mapped by CPW, Maps 3–16 and 3–17). There is no reason to have CPW determine if big game herds are stressed or not on an annual basis as required under the preferred alternative. These mapped winter range areas represent preferred winter range for big game and they will concentrate there if left undisturbed.

Wilderness Resource Management.

We support the concept of managing the Dominguez Wilderness in three management zones to emphasize the various resource values and opportunities for primitive recreation, hunting, and solitude.

The preferred alternative also includes a commitment to protect wilderness characteristics in two of four units (Dry Fork of Escalante and Cottonwood Canyon) outside of the designated Wilderness and WSA. These two areas provide outstanding backcountry habitat and security for wildlife as well as opportunities for backcountry hunting and other quiet use recreation. We fully support the designation of these two areas as non-motorized, non-mechanized SRMA’s that emphasize hiking and equestrian recreation activities.

Two other units with wilderness characteristics occur within the D-E NCA that are not included within the preferred alternative. Wilderness characteristics within the Gunnison Slopes Unit appear to have been largely protected through management of this area as an ERMA that would emphasize equestrian and hiking trail activities and dispersed camping. This management strategy seems reasonable to provide camping opportunities along the Gunnison River to accommodate boating use on the river while maintaining an overall primitive setting.

However, wilderness characteristics within the Dominguez Addition Unit would be highly impacted by the preferred alternative through the inclusion of two ATV trails within the Unit. Both of these ATV trails are currently low-standard two-track roads that extend into the Dominguez Wilderness. The preferred alternative would restrict the use of these roads to ATV’s and the trails would theoretically dead end at the Wilderness boundary. Even if ATV riders did respect the Wilderness boundary, these motorized trails would degrade the wilderness values of the Dominguez Addition Unit. For this reason we are recommending that these two roads (roads 3162/2089/2166, and 2596/2171/2003) be converted to non-motorized trails to provide big game solitude, backcountry hunting, and quiet recreation use opportunities.       

Recreation, Science and Education.

We agree with the BLM’s recreation management strategies included in the preferred alternative. This includes four ERMA’s (Hunting Grounds, Nine-Mile Hill, Escalante/Wagon Park, and East Creek) and five SRMA’s (Gunnison River, Cactus Park, Escalante Canyon, Cottonwood Creek/Dry Creek, and the Gunnison Slopes). We feel that these areas and recreation management strategies will provide a spectrum of recreation opportunities within the D-E NCA, including areas that will emphasize backcountry areas for wildlife and traditional hunting as well as other quiet use recreation outside the Dominguez Wilderness.

Managing the Hunting Grounds area as a mixed-use ERMA makes sense to us due to it’s proximity to Highway 50 and the presence of the Spanish Trail. Development of trail systems for motorized vehicles, OHV’s and mountain bikes would occur within an area that is already highly disturbed and close to a major highway.

Managing the Gunnison River should definitely be done under an SRMA. Use of the river for float boating and camping is rapidly increasing. Permits are not currently required for private trips and dogs are still allowed to accompany us on the river. This is becoming a rare commodity and we appreciate the BLM’s approach to retaining these opportunities while improving management of the river by limiting camping to designated sites, requiring camping permits during the high use season, and mitigating the current conflicts between commercial and private float trips. Basically the BLM would manage the Gunnison River the same way it is managing the Horsethief and Ruby Canyon section of the Colorado River, which is a vast improvement over what has been happening in the recent past.

We strongly support management of the Nine Mile Hill area as an ERMA with emphasis on equestrian and hiking trail activities and dispersed camping. This would provide easy access to an area where we could enjoy family oriented quiet use activities close to Grand Junction. This area also provides important habitat for desert bighorn sheep and managing it as a non-motorized and non-mechanized recreation area with relatively low development would encourage bighorn sheep to remain in the area.

The preferred alternative would manage the Cactus Park area as an SRMA that emphasizes ATV and developed camping activities. This area would provide easy access to an area developed for motorized recreation and developed camping that is also close to Grand Junction. Providing separate areas for motorized and non-motorized recreation should help avoid conflicts between recreationists in the Grand Junction area.

As I mentioned previously we fully support the management of the Gunnison Slopes as an ERMA that emphasizes equestrian and hiking trail activities and dispersed camping. This management strategy seems reasonable to provide camping opportunities along the Gunnison River to accommodate boating use on the river while maintaining an overall primitive setting.

We also support management of the East Creek area along highway 141 as an ERMA that would emphasize auto touring, hiking, climbing, and interpretive education. Providing parking areas for climbers and designating trails or routes to the climbing areas would alleviate some of the conflicts with private landowners in the Unaweep Canyon.

The preferred alternative would manage the Escalante Canyon area as an SRMA that also emphasizes auto touring, hiking, climbing, interpretive education, and kayaking. It would be more intensively managed as an outdoor classroom and watchable wildlife area. We feel this would be a good area for this type of use and support the BLM’s proposal in this area of the D-E NCA.

As I mentioned previously we fully support the management of the Dry Fork of Escalante and Cottonwood Canyon as a non-motorized, non-mechanized SRMA that emphasizes hiking and equestrian recreation activities. These two areas provide outstanding backcountry habitat and security for wildlife as well as opportunities for backcountry hunting and other quiet use recreation. This SMRA will further improve the balance in recreation opportunities within the D-E NCA with easy access from the Delta area.

Under the preferred alternative the Sawmill Mesa and Wagon Park areas would be managed as a mixed-use ERMA that would emphasize motorized, mechanized, and non-motorized recreation, big game hunting, and dispersed camping. The concept of mixing all of these uses in these areas poses some problems in maintaining or improving big game habitat and providing quality hunting and recreational experiences. However, the preferred alternative could be modified to retain and/or improve big game habitat effectiveness and the quality of traditional big game hunting and non-motorized recreation opportunities within these areas. Our route-specific recommendations for these modifications are described under the travel management section below.

Livestock Grazing.

The desert bighorn sheep is identified as one of the two special emphasis species within the D-E NCA that require additional management standards and guidelines beyond those developed for the major habitat types. Desert bighorn sheep represent one of the premier backcountry hunts available in Colorado, and are of very high interest to us in the BHA. There are only three units available to hunt desert bighorn sheep in Colorado, with a total of 11 tags available State-wide. Two of those units contain the D-E NCA. If you are lucky enough to draw a tag and harvest a desert bighorn, this is a once in a lifetime hunt.

We are extremely concerned about the health and productivity of our limited desert bighorn sheep herds. There is an abundance of research and anecdotal evidence to undeniably support the devastating effects of disease transmission between wild and domestic sheep. To prevent this disaster from occurring, the only certain method to avoid disease transmission is to prevent contact between wild and domestic sheep.

Appendix A of the EIS states that currently significant overlap (within high risk areas) occurs between domestic sheep and goats and desert bighorn sheep on BLM lands. We feel that the management strategy included in the preferred alternative is inadequate to prevent interaction between wild and domestic sheep. It relies on mitigation measures instead of complete separation to prevent contact within high risk areas. This strategy would not provide a long-term solution nor protect desert bighorn from possible devastating impacts of disease transmission. Therefore, we support the management strategy outlined in Alternative C where domestic sheep grazing would be prohibited in allotments identified as high probability allotments for interaction between wild and domestic sheep. The high probability allotments would be converted to cattle allotments.

Special Designations.

I have reviewed the Wild and Scenic River eligibility analysis (Appendix O) and ACEC analysis and concur with the BLM’s conclusions. Therefore we support the BLM,s preferred alternative which includes one river segment (Cottonwood Creek) would be identified as suitable for Wild and Scenic River designation, and all other segments would be released from eligibility. Of the areas currently designated as ACECs, the Escalante Canyon ACEC would be carried forward and expanded. One new ACEC would be designated (River Rims) to protect rare plants and paleontological resources. The Hunting Ground area of the D-E NCA would be established as the Old Spanish National Historic Trail Management Corridor and managed for auto-tour interpretive opportunities along Highway 50 and county roads.

Travel Management.

Within the mixed-use area on Sawmill Mesa and Wagon Park we would like to see the BLM include additional management goals and objectives within Table 2.2 for big game habitat capability and effectiveness. We strongly fell there is a need for additional consideration and recognition of the impacts of motorized and mechanized (aka bicycles) upon big game distribution, productivity, vulnerability, and population structure, as well as hunter success in relation to open road/trail density on the landscape. There is a large and growing body of research available that needs to be recognized and implemented by the BLM. We have posted several of the most relevant research studies on our website at backcountryhunters.org:

Literature Reviews of OHV Impacts on Hunting, Fishing and Habitat:

1. ATV Impacts on the Landscape and Wildlife (2011). A white paper by BHA which provides a synthesis of OHV-related articles in three sections focused on the effects of ATV use on: 1) soils, water quality and vegetation 2) wildlife (primarily elk) 3) the habitat and environment that wildlife depend upon.

2. Off Road Vehicle Impacts on Hunting and Fishing. An excellent illustrated literature review by the Isaac Walton League highlighting the impacts that off road vehicle use has on our sporting heritage.

3. Environmental Effects of Off-Highway Vehicles on Bureau of Land Management Lands (2007). A synthesis of literature compiled by the Department of Interior.

4. The Effects of Off-Road Vehicles on Ecosystems. A research review by Texas Parks and Wildlife.

5. Effects of Roads on Elk: Implication for Management in Forested Ecosystems (2005). Research which builds on a large body of research demonstrating the impacts of roads on elk behavior and habitat.

6. Behavioral Responses of North American Elk to Recreational Activity (2008).  A study which found that "activities of elk can be substantially affected by off-road recreation. Mitigating these effects may be appropriate where elk are a management priority. Balancing management of species like elk with off-road recreation will become increasingly important as off-road recreational uses continue to increase on public lands in North America."

7. Reproductive Success of Elk Following Disturbance Following Disturbance by Humans During Calving Season (2011).  A study which shows that cow/calf ratios decease when disturbance increases and therefore "maintaining disturbance-free areas for elk during parturitional periods" is necessary.

There are additional Goals and Objectives and the associated Actions that relate to open road/trail densities, the impacts of bicycle trails and use, and the conservation of our existing backcountry areas that I request the BLM to include in Table 2.2 for the Final RMP. These additional Goals, Objectives, and Actions will also enable the BLM to fully comply with 43CFR 8342.1 b) and c) as stated in the Draft RMP: b) Areas and trails will be located to minimize harassment of wildlife or significant disruption of wildlife habitat, and c) Areas and trails will be located to minimize conflicts between OHV’s and other uses.

Goal/Objective – Locate and manage OHV and mechanized routes and trails to minimize harassment of wildlife or significant disruption of wildlife habitat.

            Action #1 – Limit and reduce motorized and mechanized routes and trails in areas managed for mixed uses. Implement road and trail density standards within these areas that are favorable to big game habitat requirements as defined in current scientific research.

            Action #2 – Motorized and mechanized routes and trails will avoid lands managed for wilderness characteristics, critical wildlife areas, and wildlife emphasis areas.

            Action #3 – No motorized off-route down game retrieval will be allowed anywhere within the D-E NCA.

            Action #4 – Seasonal closures to protect big game winter range will include snowmobiles.

            Action #5 – Routes designated for administrative use within all mixed use areas, lands managed for wilderness characteristics, critical wildlife areas, and wildlife emphasis areas will be closed to public OHV use yearlong.

Goal/Objective – Locate and manage OHV routes and trails to minimize conflicts between OHV’s and other users.

            Action – Same as above (all 5).

            Action #6 – Utilize the basic road transportation system as a multi-use trail system for OHV’s and bicycles as much as possible to avoid duplication of routes and reduce overall open route density.

Comments on Travel Management Plan

The following comments are based upon my review of the Map of Route by Route Designations for Alternative E (Map N-1E) in relationship to the resource management goals and objectives of the NCA.

As previously stated, we are concerned that wilderness characteristics within the Dominguez Addition Unit would be highly impacted by the preferred alternative through the inclusion of two ATV trails within the Unit. Both of these ATV trails are currently low-standard two-track roads that extend into the Dominguez Wilderness. The preferred alternative would restrict the use of these roads to ATV’s and the trails would theoretically dead end at the Wilderness boundary. Even if ATV riders did respect the Wilderness boundary, these motorized trails would degrade the wilderness values of the Dominguez Addition Unit. For this reason we are recommending that these two roads (roads 3162/2089/2166, and 2596/2171/2003) be converted to non-motorized trails to provide big game solitude, backcountry hunting, and quiet recreation use opportunities.

In addition, we request that road 2169/2170 in Palmer Gulch be closed and obliterated. This road closure would greatly enhance big game security and provide solitude for backcountry hunting and quiet use recreation.

We also request that the BLM reconsider leaving road 2181 open to motorized vehicles. We feel that this road in Tatum Ridge should be converted to a non-motorized trail at the junction with road 3096 to provide additional opportunities for backcountry hunting. A trailhead could be designated here at the head of Ridge to accommodate a few vehicles.

Within the Sawmill Mesa and Wagon Park mixed-use areas, we recommend the following modifications to the preferred alternative to improve big game habitat effectiveness and the quality of traditional big game hunting and non-motorized recreation opportunities within these areas.

Close and obliterate spur roads 1782/1768/2602 located on the rim of the Big Dominguez Canyon. This road does not access any wilderness trailheads or serve any other purpose we know of.

We also do not understand why road 1756 was left open half way down the ridge instead of just closing the entire length of the route. This road should be closed at the junction with 1758, and include closure of roads 1593 and 1585 as shown in the preferred alternative.

We would also like to see road 1778/1727 down Wildlhorse Draw closed to motorized vehicles and retained as a non-motorized trail. Closing this route to motorized vehicles would also enhance big game habitat effectiveness and provide a high quality backcountry hunting area.

Within the Sawmill Mesa area we are very pleased to see the establishment of two major horse & foot trails in the area. Route 2243/2244/2248/2249 provides access into the Dry Fork of Escalante Canyon. This canyon provides excellent opportunities for hiking, backpacking, backcountry hunting, horseback riding, exploring, and other quiet use recreation. Route 2377/2376/2353/2354/2399 in the Escalante Rim area also provides opportunities for these activities in an area that provides excellent solitude. We fully support the designation of these routes as being open to horse and foot travel only.

Thank you again for the opportunity to review and comment on the Draft RMP for the Dominguez-Escalante National Conservation Area. I appreciate your attention to my previous written and oral comments and look forward to continuing this dialogue. Please contact me if you have any questions about these comments and add me to your contact list for future meetings or notifications about the D-E NCA.

Craig Grother

Habitat Watchman

Backcountry Hunters and Anglers