Project Manager, Uncompahgre RMP                                                                                  October 27, 2016

Bureau of Land Management

Uncompahgre Field Office

2465 South Townsend Ave

Montrose, CO 81401

Comments on the Draft RMP/EIS for the Uncompahgre Field Office

Craig Grother, Colorado BHA Central West Slope Regional Director

Thank you for the opportunity to comment on the Draft Resource Management Plan and Environmental Impact Statement (Draft RMP/EIS) for the Uncompahgre Field Office (UFO).  I am a resident of Norwood Colorado and have lived and worked in the area since 1989.  I have worked as a wildlife biologist for the US Forest Service for 33 years on various Ranger Districts in Idaho, Nevada, and Colorado.  For the last 20 years of my career I was the wildlife biologist for the Norwood and Ouray Ranger Districts of the GMUG National Forest.  During that time I was able to work with various staff members of the UFO on cooperative wildlife habitat improvement projects through programs and initiatives such as the Habitat Partnership Program and the Uncompahgre Plateau Project.

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 and as the Regional Director for the Central Western Slope.  Backcountry Hunters and Anglers is a grass roots 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.

Although I have reviewed much of the Draft EIS and Supporting Documents for this RMP, my comments are focused on those Appendices which are of primary concern to Backcountry Hunters and Anglers.  I would appreciate the opportunity to discuss any of these comments with you or BLM staff working on this revision.

Appendix G – Best Management Practices and Standard Operating Procedures

There have been several wildlife habitat improvement projects implemented on the UFO to enhance winter range for big game.  Several of those projects were developed and implemented in cooperation with the US Forest Service and Colorado Parks and Wildlife.  The primary objective of these projects was to enhance existing winter range conditions and encourage elk and mule deer to utilize traditional winter ranges on public lands by improving winter forage and browse condition and production.  These projects in combination with wildfire rehab efforts were largely successful in meeting these objectives.

During that time the Uncompahgre National Forest also developed and implemented a forest-wide travel management plan which includes specific direction and actions to further encourage big game use of these winter ranges through an active program of reducing open road and trail densities through route decommissioning and seasonally closing big game winter range areas to all forms of motorized and mechanized travel from December 1 through April 15.  In combination, these efforts have had a significant effect on seasonal use patterns and distribution of big game.

While the BLM did implement the vegetation projects, there has not been an equal effort to reclaim or manage the existing roads, trails, or fire lines within these areas, or to control use by the public.  This was largely due to the lack of direction in the current RMP, or a comprehensive travel management plan for the UFO.  The effectiveness of the vegetation treatments for big game on BLM lands has been reduced by this lack of travel management.  Over the years of implementing these projects and suppressing and rehabbing wildfires, there has been a steady progression and increase in open road and OHV trail densities which are having a significant impact upon big game habitat effectiveness.

The UFO has made the decision to approach travel management on a watershed or implementation-level scale.  There is a lot of merit to this approach, but there needs to be stronger direction and guidance in the RMP to prevent cumulative effects to wildlife habitat and our remaining unroaded landscapes.  As one recent example, a travel management plan was developed for the Burn Canyon area south of Norwood.  The final decision intends to provide a mix of recreation opportunities for hiking/horseback, bicycle, and OHV recreation.  The Burn Canyon area is located within one of the most heavily used big game winter ranges of the San Miguel watershed.  The decision includes seasonal use restrictions on the BLM roads and trails to mitigate impacts to wintering big game.  Unfortunately, use within the project areas has not gone according to plan.  Bicycles continue to use the horse & foot use only trails in McKee Draw.  Access to BLM lands is provided by a system of county roads which the BLM has no jurisdiction over.  People are using any and all of the trails whenever they physically can, regardless of their seasonal restriction or use designation.  The area attracts more use now that trail systems have been formally developed, and the impacts to big game have increased as a result of the project.

The following comments are specific to some of the resources area BMP’s and SOP’s included in Appendix G that I believe are necessary to provide direction in the RMP.

Vegetation – General and Upland

Retain the following direction to meet landscape objectives and enhance success of treatments:

• Limit authorized use levels and activities where needed to allow vegetation to recover from fire, drought, disease and insect outbreaks
• Incorporate strategies in grazing plans which manage fuel build up to enhance natural fire use.  
• Defer vegetation disturbing activities during severe or extreme drought to allow for vegetation recovery.
• On a landscape scale, maintain a diversity of age classes. Any 100 square mile patch of pinyon-juniper should encompass the full range of seral stages. Preferentially achieve diversity by actions in younger age classes rather than reductions of older stands.
• To benefit species sensitive to habitat fragmentation, maintain unroaded stands or patches no less than 1.2 square miles in size.
• Maintain connectivity between stands of pinyon-juniper, sagebrush, and ponderosa pine by preserving corridors of similar vegetation.
• Reclaim unused or undesired roadbeds in pinyon-juniper woodland, salt desert shrub, and ponderosa pine.
• Place high requirements for justifying creation or retention of roads (or other linear features that fragment the habitat) in sagebrush. Reclaim unused or undesired roadbeds in sagebrush land cover types.

Wildlife – Terrestrial

Retain the following direction to improve habitat effectiveness:

• In all habitat improvements and manipulations, and maintenance of those areas, including projects designed to improve livestock grazing, reduce fuel loading, or otherwise, consider the habitat requirements of native wildlife communities, game and non-game alike, and acknowledge the ecological tradeoffs.
• During severe or extreme drought years, to the extent possible, assure that some pastures retain the maximum herb cover (even standing dead material) possible for ground-nesting birds.

Modify or add the following direction to improve habitat effectiveness:

• “Where winter range areas are not protected by lease stipulations, operations such as construction, drilling, completion, work-overs and other intensive activities will be avoided from January 1 to March 1 to minimize impacts to wintering big game.”   Modify this direction to include seasonal closures on public recreation use to avoid impacts to wintering big game, and change the dates to December 1 through March 1.  These dates encompass the winter season for big game animals, and would be more consistent with seasonal closures on adjacent National Forest lands.
• Manage big game winter ranges to provide habitat conditions and seclusion that will encourage use of public lands by elk and mule deer.

Livestock Grazing

Retain the following direction to meet landscape objectives and enhance success of treatments:

• Grazing will be deferred on new vegetation treatments and rehabilitated burned areas to the extent necessary to comply with BLM Colorado Standards for Public Land Health and Guidelines for Livestock Grazing Management (BLM 1997).
• Seasonal utilization levels on palatable forage species should not exceed 50 percent unless required to meet specific range management objectives as identified in an allotment management plan or other activity plan.
• During any time of the year, livestock use shall not exceed an average of 30 percent on native woody vegetation in riparian areas unless required to meet specific range or riparian management objectives as identified in an allotment management plan or other activity plan.
• Develop rotational grazing strategies, incorporating rest, deferment, and/or other grazing methods to improve rangeland health. All developed strategies that are not during dormant periods should ensure livestock grazing does not occur in the same location during the same time period in any two consecutive years.

Comprehensive Trails and Travel Management

Appendix G currently lacks any direction specific to wildlife.  The following direction should be added to improve habitat effectiveness:

• Recreational trail systems will not be developed in areas identified as big game winter concentration areas, severe winter range, or critical winter range.
• All proposals for the establishment, modification, and funding of recreational trails will be reviewed by local District Wildlife Managers and Biologists with Colorado Parks and Wildlife prior to BLM proceeding with implementation.
• Where effective, the use of seasonal route and/or area restrictions will be in effect from December 1 through March 1 regardless of current weather and snow conditions.
• The analysis of OHV and bicycle trail system proposals will include identification of open road and trail densities and the potential impacts of the alternatives on habitat effectiveness.
• The implementation of travel management plans will include corresponding measures and funding to decommission roads and user-developed routes concurrently with trail development.

Appendix F - Lands with wilderness characteristics

The Draft RMP/EIS identifies a total of eight areas that meet the qualifications for lands with wilderness characteristics.  Lands that qualify for this designation are of primary interest to Backcountry Hunters and Anglers.  They can provide essential habitat and security for wildlife and fish as well as high quality backcountry hunting and fishing opportunities.  In reviewing the analysis and management alternatives for these areas in the Draft RMP/EIS, it is apparent that the BLM recognizes that several of these areas have been severely impacted by roads and trails used for past mining and energy development, utilities, livestock grazing, and OHV use.  We are adamant that the remaining areas that retain their wilderness character be protected from further energy and recreation development and emphasized for the improvement of land health objectives and habitat for terrestrial wildlife. 

The Camel Back WSA Adjacent area includes a total of 8,700 acres of BLM lands that include Monitor and Potter Canyons as well as most of the Monitor Mesa area in between.  According to the BLM’s analysis, at least 6,950 acres still retain their wilderness character.  In combination with the Camel Back WSA and adjacent National Forest lands, this area represents some of the best remaining roadless and backcountry habitat on this portion of the Uncompahgre Plateau.  It provides high quality habitat for a population of desert bighorn sheep as well as winter range for elk and mule deer.  Management of the Camel Back area should emphasize the retention and enhancement of its roadless character and wildlife habitat.  The RMP should acknowledge the resource values of this landscape for wildlife and its primitive backcountry character, and develop a management prescription that is specific to these values.  As a minimum, the RMP should specify that there will not be any motorized or mechanized trail development within this area.  It should also specify that vegetation treatments will be utilized and livestock grazing will be managed to maintain or improve land health objectives while providing residual forage for big game.  The RMP should also specify that domestic sheep grazing will only be authorized and managed to achieve no contact between domestic sheep and desert bighorn to prevent disease transmission.  

The Lower Tabeguache/Campbell Creek area includes 11,060 acres of BLM lands that include Long Mesa, Burro Creek Mesa, Wild Cow Mesa, and Spring Creek Mesa.  This area represents another large block of unroaded backcountry habitat that has escaped the development associated with past uranium mining on this portion of the Uncompahgre Plateau.   This portion of the Uncompahgre Plateau also contains high quality big game winter range and important security from the disturbance of roads and OHV trails.  In order to retain and improve habitat for elk and mule deer, and encourage them to remain on public lands during the winter months, the RMP should include specific direction for this area that will prohibit any development of motorized and mechanized trails.  Some attempts by the BLM and Forest Service have been made to allow OHV and bicycle trail development within big game winter range while mitigating impacts to wildlife through the use of seasonal closures.  Unfortunately this has not prevented use of these trail systems by the public.  If the conditions on the ground are favorable, people use the roads and trails regardless of the seasonal closure.  The agencies do not have the law enforcement presence capable of ensuring compliance.  It is far better to not create a trail system in these areas in the first place.

Shavano Creek includes 6,090 acres of BLM lands in the upper Campbell Creek and West Campbell Creek adjacent to the north side of the Tabeguache SMA.  In combination with the adjacent National Forest lands, this area provides a significant roadless area on this portion of the Uncompahgre Plateau.  The Upper Campbell Creek drainage of the BLM would increase the size of this area if it were not for a county road (U472) going to a stock pond development, presumably for maintenance of this pond.  Other user-developed OHV trails have been created off county road 226 in to Shavano Creek.  Much of this area burned in the Campbell Creek wildfire of 2004 which significantly enhanced habitat conditions on big game winter range, creating a large winter concentration area.  The RMP should acknowledge the resource values of this area for wildlife and its primitive backcountry character, and develop a management prescription that is specific to these values.  As a minimum, the RMP should specify that there will not be any motorized or mechanized trail development within this area, and implement an aggressive decommissioning program to eliminate the user-developed OHV trails.  It should also specify that vegetation treatments will be utilized and livestock grazing will be managed to maintain or improve land health objectives while providing residual forage for big game.  Implementing these management standards would encourage elk and mule deer to remain on preferred habitats on public lands and reduce game damage occurring to adjacent private lands in and around Nucla.

Norwood Canyon contains 5,600 acres of BLM lands along the San Miguel River between Norwood Bridge and Pinyon Bridge.  This part of the San Miguel River canyon provides river rafting, kayaking, and fishing opportunities that are not adjacent to the noise and activities of highway 145 or 141.  River recreation and fishing activities are far less than the section above Norwood Bridge so the area provides opportunities for more solitude and quiet use.  There are currently at least two ways to legally hike into the Norwood Canyon to gain fishing access.  Both access routes are not official “government” trails which further limits activity in this area and provides a high quality backcountry fishing experience.  This situation needs to be maintained by the BLM and the RMP should specify that there will not be any trail development or OHV/bicycle use into or within the Norwood Canyon.  Access on the BLM would continue to be provided by boat and/or hiking the old road on the north side of the river which goes around the Cascabel Ranch private land.

Appendix J – Recreation Management Areas

Appendix J provides a series of tables that outlines goals and objectives for various Recreation Management Areas on BLM lands under various alternatives.  Some of the RMA’s include the entire range of alternatives in the Draft EIS, while others do not.  Presumably the areas that do not include a range of alternatives already have a recently approved travel management plan in place (such as Burn Canyon, Ridgway, Dry Creek). 

One of the primary concerns we have with increased trail development for OHV’s and bicycles on BLM lands is where this development is occurring, and the level to which it is being developed.  Most big game winter range occurs in the lower elevation valleys and foothills, and extends upward in elevation on the drier south and west facing slopes.  Much of the habitat for big game and other species that occurs in the valleys is now developed for our towns and housing in the rural areas surrounding these towns, or for agricultural production.  As a result, extensive areas of winter habitat have been lost to this development and its associated roads, traffic, and other human activities.  This has generally displaced big game to higher elevation winter ranges on the foothills and mesas of the adjacent public lands.  With our increase in human population there is also a tremendous increase in recreation on the adjacent public lands and pressure on the BLM to build and/or authorize more and more OHV and bicycle trails to accommodate this use.  Once a few trails are established, other user-developed trails appear and additional proposals from user-groups come to the BLM for even more trails that reach farther and farther into areas that have provided big game winter range.  The result has been a dramatic increase in the displacement of wildlife off their limited winter range areas and a subsequent decline in the health and productivity of our big game herds. 

This RMP provides an opportunity for the BLM to define which areas are critical for wildlife and should not be developed for recreational use, and which areas can be developed for recreation while still protecting other resource values.  We strongly feel that the BLM should provide this direction in the RMP instead of continuing to react to proposals from user-groups that are only focused on their own goals and activities.

In general, we support the efforts to manage use of the most popular destinations by providing good maps, access to the trailheads, and education for the users of those areas.  However, we are very concerned that there are no Management Actions or Allowable Use Decisions for fish or wildlife in any proposed RMA’s, and request that the BLM include this direction in the Final RMP.  The following are some specific comments on a few of the proposed RMA’s.

Burn Canyon SRMA.  A travel management plan was recently developed for this SRMA and projects are currently being implemented within the planning area.  As previously stated, the Burn Canyon area is located within one of the most heavily used big game winter ranges of the San Miguel watershed.  The decision includes seasonal use restrictions on the BLM roads and trails to mitigate impacts to wintering big game.  Unfortunately, use within the project areas has not gone according to plan.  Bicycles continue to use the horse & foot use only trails in McKee Draw.  Access to BLM lands is provided by a system of county roads which the BLM has no jurisdiction over.  People are using any and all of the trails whenever they physically can, regardless of their seasonal restriction or use designation.  The area attracts more use now that trail systems have been formally developed, and the impacts to big game have increased as a result of the project.

The BLM promised in its decision to monitor use of the area and apply adaptive management to further actions.  The main lessons that should be learned from here is that 1) seasonal restrictions to protect big game winter range are ineffective when the BLM has no jurisdiction over primary access roads managed by the county, 2) overall use of the area increases substantially after becoming a designated RMA, 3) people do not comply with allowable trail use designations, 4) the UFO does not have the resources to monitor and enforce compliance with established regulations for recreational use.

Dolores River Canyon SRMA.  We agree entirely with the management goals and objectives for this SRMA.  We are also aware of several user-developed OHV trails in the area that access the south rim of the Dolores River canyon, as well as go all the way into the bottom of the Dolores River canyon from Sylvia’s Pocket.  Appendix J should also include direction to obliterate these trails to restore the primitive nature of this Canyon.

Dry Creek SRMA.  Management emphasis within this area is primarily for a variety of motorized and mechanized recreation, both trail based and off-trail rock crawling.  The matrix in Appendix J does not have any mitigation measures for wildlife.  There are substantial areas of big game winter range within this SRMA and there is currently a proposal to construct another 50 miles of mountain bike trails.  As stated above, we are concerned with the continued loss of big game winter range to recreation development and the additional trail development proposed in this area would result in an extreme density of trails and associated disturbance.  The BLM needs to develop and include a standard for open route density to alleviate these impacts.  Similar to Burn Canyon, we believe that the presence of county roads and the ineffectiveness of a seasonal closure (if there is one) would not adequately minimize harassment of wildlife or significant disruption of wildlife habitat.

Paradox Valley SRMA.  Zone 3 of this SRMA includes a substantial amount of area that should be included in the Zone 4 management strategy.  Any plans to provide OHV and bicycle trail riding in this area should be limited to existing roads that are managed by the county or that are roads that remain from previous mining activity that are somewhat used and maintained, and would create a logical and safe trail system.  Much of the area near the rim of the Paradox Valley and Dolores River canyon is very primitive in nature, and should be left available for dispersed hiking, hunting, and exploring.  Appendix J only includes one alternative, and the BLM should at least consider and analyze an alternative that retains and enhances the primitive nature of this area for wildlife habitat and undeveloped, dispersed uses.

San Miguel River SRMA.  The San Miguel River is the most significant fishery in the west end of the UFO and provides other river based recreation opportunities such as rafting and kayaking.  The UFO has done an excellent job in providing river access and overnight camping facilities on this portion of the San Miguel.  The San Miguel River above the Cascabel Ranch is also adjacent to public highways and county roads which provide unlimited public access to the river for fishing.  We are opposed to any trail development into the Norwood Canyon below the Cascabel Ranch.  This area is already accessible on foot, and provides an excellent opportunity for more solitude and quiet use.  We also oppose any plans to develop trails into the Beaver Creek and Saltado Creek Canyons, which is compatible with the recreation strategy for zone 2.  These two major tributary canyons also provide excellent opportunities for solitude and backcountry hunting or fishing experiences adjacent to the main river corridor. 

Appendix K – Bighorn/Domestic Sheep Risk of Association Modeling

Rocky Mountain and desert bighorn sheep represent one of the premier backcountry hunts available in Colorado, and are of very high interest to us in the BHA.  We are extremely concerned about the health and productivity of our limited 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.

We appreciate the efforts the BLM and CPW has taken to utilize both the PoI and RoC Risk Assessment Models to evaluate and compare the results for potential risk of contact between wild and domestic sheep within the UFO.  Although we are skeptical of the assumptions utilized in the local PoI model, we do feel that it adds some perspective to the planning-level analysis when compared to the results of the national RoC model.  When the results of both models are examined, it is very apparent that there are allotments where domestic sheep grazing is authorized directly within and adjacent to existing populations of bighorn sheep, and the BLM needs to take action to eliminate this threat to bighorn sheep.  Based upon the current science and professional experience and judgement of range and wildlife managers, we believe the only effective way to achieve this is to prevent physical contact between wild and domestic sheep.  Domestic sheep herd management practices and mitigation measures included in Appendix K have been short term and marginally effective at preventing contact.

The RMP should use the results of the analysis presented in Appendix K to determine the suitability of existing grazing allotments for domestic sheep grazing.  The risk of contact should preclude other suitability criteria such as historic/current use, terrain, forage type, etc.  We believe this is a planning-level decision that is appropriate and missing from the current Draft RMP/EIS.  In addition to a suitability determination, there should be specific direction to remove domestic sheep from allotments that have potential for contact, and that there will be no conversion of class of livestock from cattle to sheep where there is any potential for contact with bighorn.

Implementation of the decisions within the final RMP would occur through subsequent updates and revisions of allotment management plans.  Those updates and revisions should occur in a timely (5 years) fashion and be based upon the suitability determinations in the RMP with input from the CPW and the public.  This could be achieved through the development of an implementation plan for allotment management plans and permit actions.     

Appendix M – Travel Management

The RMP will determine planning level decisions for the UFO, such as which areas are open, closed, or limited to OHV and bicycle use, and which types of uses will be emphasized within those broad allocations (Recreation Management Areas – Appendix J).  We believe the BLM should strive to provide a balance in those allocations, and to recognize the values we place on providing large blocks of undisturbed habitat for fish and wildlife and the opportunity for traditional methods of hunting and fishing in the backcountry.  That balance would include a priority for the retention and enhancement of lands with wilderness characteristics and/or lands with low densities of open routes, lands that currently provide seasonally important big game habitat and migration corridors, and lands adjacent to communities surrounding the UFO that will provide opportunities for quiet use and solitude.

Appendix M includes a description of the process and criteria that will be considered by the BLM when evaluating routes within area-specific travel management plans during implementation of the RMP.  

Within Appendix M we would like to see the BLM include additional management goals and objectives 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 recreation use 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 Appendix M to guide implementation of travel management on the UFO.  These additional Goals, Objectives, and Actions  will also enable the BLM to fully comply with 43CFR 8342.1 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 UFO.

            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.

Appendix O - Areas of Critical Environmental Concern

The Draft RMP/EIS includes analysis of several potential ACEC’s that demonstrate the exceptional biological and environmental resource values of several areas within the UFO (Appendix O).  We at Backcountry Hunters and Anglers support the designation of ACEC’s for the Roubideau-Potter-Monitor, San Miguel River Expansion, and Dolores River-Slickrock Canyon areas of the UFO.  The Draft RMP/EIS does not appear to contain integrated resource management direction under any alternative that would fully protect these resource values.  Designation of these ACEC’s does not preclude livestock grazing, mining, energy development, utility corridors, or recreation emphasis designations such as SMRA or ERMA.  The designation of these ACEC’s should provide further emphasis in the RMP to manage these areas for their unique character and biological resources and substantially reduce and limit impacts to these values from recreation, livestock grazing, and energy development.   

The Roubideau-Potter-Monitor and Dolores-Slickrock Canyon ACEC’s provide crucial habitat for existing populations of desert bighorn sheep.  It is essential that the RMP include clear direction for both wildlife and livestock grazing resources to emphasize the perpetuation of healthy populations of desert bighorn sheep within these ACEC’s and any other occupied habitat areas within the UFO through active vegetation management and the elimination of any potential contact between wild and domestic sheep.  The BLM must utilize the most current science-based information and nationally accepted analysis methods to determine potential contact between wild and domestic sheep on these landscapes, and implement permit actions to resolve the issues associated with disease transmission to these populations.  The RMP should include specific direction to subsequently develop an implementation plan to resolve the conflicts identified in the EIS through permit actions and/or updated allotment management plans within a five year time period.

Both of these ACEC’s also provide critical big game winter range and security areas for elk and mule deer.  The RMP should include clear direction for wildlife, vegetation, and livestock grazing resources to manage vegetation to provide habitat conditions favorable to big game, and to manage livestock grazing use in these areas to provide abundant residual forage for wildlife.  The management prescriptions for recreation included in Appendix J do not adequately address mitigation of the potential impacts of current and future OHV and bicycle use or development within big game winter ranges.  As I stated previously, attempts have been made locally by the BLM and Forest Service to allow OHV and bicycle trail development within big game winter range while mitigating impacts to wildlife through the use of seasonal closures.  Unfortunately this has not prevented use of these trail systems by the public and the impacts from these activities continue to degrade habitat quality and displace big game from preferred wintering areas.  If the conditions on the ground are favorable, people use the roads and trails regardless of a seasonal closure.  The agencies do not have the law enforcement presence capable of ensuring compliance.  It is far better to not create a trail system in these areas in the first place.  Recreation strategies within Appendix J also need to include no motorized or mechanized use in these important wildlife areas.  If there are user-developed routes already in place within these areas, the RMP should also include direction to actively decommission those routes to prevent continued disturbance to wildlife and restore habitat effectiveness.

We also support designation of the San Miguel River ACEC.  It would expand the current ACEC to a total of 35,480 acres, and include the entire river corridor as well as the major tributaries.  The San Miguel River is the most significant fishery in the west end of the UFO and provides other river based recreation opportunities such as rafting and kayaking.  The UFO has done an excellent job in providing river access and overnight camping facilities on this portion of the San Miguel.  The San Miguel River above the Cascabel Ranch is also adjacent to public highways and county roads which provide unlimited public access to the river for fishing.  As previously stated, we are opposed to any trail development into the Norwood Canyon below the Cascabel Ranch.  This area is already accessible on foot, and provides an excellent opportunity for more solitude and quiet use.  We also oppose any plans to develop trails into the Beaver Creek and Saltado Creek Canyons.  These two major tributary canyons also provide excellent opportunities for solitude and backcountry hunting or fishing experiences adjacent to the main river corridor.