mil i ii mi i imi i n Him w nun iiiiiiii ii 1 1 iiMWiMi—iiiimiiiM BLM LIBRARY 88063983 Final September 1988 // J I *, >a. "#•! "A1 \J *« *** *yt" >'*<& l4B& UNCOMPAHGRE BASIN Resource Management Plan and Environmental Impact Statement .'$> *J IwflihiH ftitJi Mil wWi* ,r»r K4"> I^^^L SUA 7 V " ^'•^■'iV ,' ,'.Wfcr tesJ? , ' SD 428 .C6 G88 1988 n<^±F* ~,!i.' i.f< 'tiff/, «5?'™>*- 1 * ''Ji^. * t? " 'M // , ,m Department of the Interior ;au of Land Management ltrose District, Colorado ompahgre Basin Resource Area f United States Department of the Interior BUREAU OF LAND MANAGEMENT MONTROSE DISTRICT OFFICE 2465 SOUTH TOWNSEND MONTROSE, COLORADO 81401 TAKE PRIDE IN, AMERICA IN REPLY REFER TO: Dear Reader: Enclosed for your review is the Proposed Resource Management Plan (RMP) and Final Environmental impact Statement (BIS) for the uncompahgre Basin Planning Area. The Proposed Resource Management Plan, hereinafter referred to as the Proposed Plan, is a refinement of the Preferred Alternative in the Draft Uncompahgre Basin RMP/EIS, with consideration given to public comment analysis, corrections, and rewording for clarification. The Proposed RMP and Final EIS is published in an abbreviated format and is designed to be used in conjunction with the Draft Uncompahgre Basin RMP/EIS which was released in June 1987. The Proposed Plan is the Bureau of Land Management's proposed action, with the exception of the recommendations for the Camel Back, Adobe Badlands, and Gunnison Gorge Wilderness study Areas, all parts of this Proposed Plan may be protested in accordance with the planning regulations, 43 CFR 1610.5-2. Protests shall be in writing and sent to the Director (760), Bureau of Land Management, Room 909, Premier Building, 1725 I street, N.W., Washington, D.C. 20240, within 30 days of the date of publication of the Notice of Availability by the U.S. Environmental Protection Agency in the Federal Register. The protest shall include the following information: The name, mailing address, telephone number, and interest of the person filing the protest. A statement of the issue or issues being protested. A statement of the part or parts of the plan being protested. A copy of all documents addressing the issue or issues that were submitted during the planning process by the protesting party, or an indication of the date the issue or issues were discussed for the record. A concise statement explaining why the proposed decision is believed to be wrong. At the end of the 30-day protest period, and after the Governor's consistency review, the Proposed Plan, excluding any portions under protest, shall become final. Approval shall be withheld on any portion of the Proposed Plan under protest until final action has been completed on such protest. The Record of Decision and Final Resource Management Plan will then be published. Sincerely, Ltxa^i) Bureau of Reclamation Subject: Review of Bureau of Land Management Draft Environmental Impact Statement for Uncompahgre Basin Resource Management Plan and Wilderness Technical Supplement CDES 87/20) Our office has reviewed the subject do- nts and has prepared the attached 97 91 88 Comments on Uncompahgre Basin Resour Management Plan and EIS General Recent unpublished studies associated with the Uncompahgre Hydropower Project indicate that the range and population si the endangered plant Erioijontim pe linonhilum, may be greater than studies are published we will ndlcated in Table 2-n. When urnish the information to the Bureau Land Management C BLM) . Cu Table 2-11 it is not clear what ^rs to. The same comment applie nison River Sa.l and No. 2" and "Gunnison River No. 3" the terms "Smith fork ompahgre River No. 4". Contlnuat ic Withdrawals: The management of the power site withdrawals is currently handled by BLM on Crystal and Dominguez. The Crystal power 3ite withdrawal should be turned over to the Bureau of Reclamation (Reclamation). The Dominguez power site withdrawal should be kept by BUM ior future development as Reclamation is relinquishing its withdrawals on the Dominguez Project at this time. If there are any questions on withdrawals or rights-of-way, please contact Steve Schiesswohl or Bill Ellison in our Grand Junction Projects Office at FTS 322-9217. Off-Road Vehicle Designations: The off-road vehicle designation for all Reclamation lands (withdrawn or .therwise) is that the lands are closed to off-road use and off-road vehicles unless specifically opened. It would enhance management of Reclamation project withdrawals if they were so designated on BLM maps. Management Alternatives of Current Management Alternatives -An 128 93 Map "A": Livestock Grazing: Grazing permits that involve withdrawn lands should be reviewed and in most cases adjusted to restrict grazing on developed Reclamation facilities and recreation areas. This should be handled on a case by case basis. Any Considerations below are listed separately by Reclamation project proposed disposal of lands that are withdrawn by Reclamation and Reclamation intends to retain under the withdrawal Review program, should not be disposed of unless the BLM wants to dispose of them to Reclamation. If the disposal is to Reclamation, absolute Fee title would be required to protect project features from mining activities. Most comments have been accompanied by the "proper legal description. In some cases, however, we have not included a description because of the length. Descriptions for all Reclamation lands are available from Reclamation Withdrawal Review reports or from Reclamation's Grand Junction Projects Office. Al. The Reclamation withdrawals between the Black Canyon and Curecanti area in Sections 4, 9, 10, II, 14, and 23, T49N, R7W, are not properly marked on the map. These lands were withdrawn for the Uncompahgre Project and the Aspinall Storage Unit of the Colorado River Storage Project (CRSP). The withdrawal in Sections 10, 11, 14, and 23 are for the CRSP and the withdrawals in Sections 4 and 9 are for the Uncompahgre Project. A2. The Reclamation withdrawal on Fruitgrowers Reservoir should be shown to Include the water surface. This withdrawal is not subject relinquishment. Reclamation al; Fruitgrowers Reservoir. 89 87 has title to the reservoir i A3. The 40 acres in the NW4SW4 of as withdrawn for the Dallas Ci eccion 34, T&6N , R8W should also be shown ek Project. On the Paonia Project, lends are withdrawn in the SE'iN'W4NE4 of Section 18, T13S, R90W, but are not shown as withdrawn. In the S2NE4SE4 and the NE4NE4SE4 of Section 13, TJ4S, R93U, the withdrawal Is not plotted correctly. The tracts identified for disposal in T14S, R93W, Section 22; and T14S, R92W, Sections 3 and 17, are not subject to relinquishment and disposal is not compatible with project purposes. The.SW4Sw4 of Section 3, TL4S, R92W, is questionable as to being public land. Reclamation acquired an easement from the private owner (Overman, H.E.) in about 1950, and if the land is In fact private, the RMP maps need to be changed. If the land is public, Reclamation will be requesting a linear withdrawal to match the dimensions of our existing easement. A withdrawal would be consistent with our other land Status agreements with the BLM on the Fire Mountain Canal. As both the Dominguez and Fruitland Mesa Projects are being proposed for relinquishment in their entirety, we did not review the plotting or disposal recommendations for parcels withdrawn for these projectB. cted on the A6. The withdrawals for the Uncompahgre Project need map as follows: The following parcels should be shown as withdrawn: The NE4NE4SE4 of Section 13, in TI5S, R95W, (It may be shown this way, but the map scale makes it hard to see); the 5 acre tract of the SW4SW4NU4SE4, the SE4SF.4NE4SW4 , the NE4NE4SE4SW4 , and the NW4NW4SW4SE4 of Section 36, T15S, R95W; the 10 acre tract of the SW4NE4NW4 of Section 30, T51N, R9W; the 15 acres of the E2W2E2NE4SW4 and the E2E2NE4SW4 of Section 36 of T50N, R11W. Also, the lands next to the Inside the Black Canyon National Monument need to be added as mentioned in item Al above. Certain withdrawals on the South, West, Montrose and Delta canals were Inadvertently relinquished without Reclamation retaining a linear withdrawal for project facilities. Measures to correct this problem are being worked on In the interim, any land disposals should retain a linear awal foe all structures, canals, diversion dams, la Pat this I withdra laterals such as 87 Lthe CQ lateral on the Montrose and and right-of-way for all laterals. slta system, or other major facilities, 50 90 92 93 PRODUCTION ALTERNATIVE (ALTERNATIVE "B") All recommendations made under the Withdrawal Review are to remain the same with the exception of approximately 130 acres at the far west end of the Paonia State Recreation Area which Reclamation is in the process of proposing for relinquishment. The Dominguez and Fruitland Mesa withdrawal reviews are proposed to be completed this fiscal year. Visual resource objectives for all Reclamation recreation areas including the entire proposed Curecanti National Recreation Area; the Ridgway, Crawford and Paonia State Recreation Areas: and the Fruitgrowers area should all be high scenic quality and high sensitivity. The proposed Curecanti National Recreation Area, Paonia, and Fruitgrowers areas should be added to Table 2-16. The withdrawals section on page 2-21 indicates chat Reclamation withdrawals segregate the lands from the general mining laws. It was the intent and practice of all Reclamation withdrawals to segregate the lands from all of the public entry laws. Under the FLPMA Withdrawal Review program, Reclamation is relinquishing all but the bare necessity of its withdrawn lands, and those lands being retained will be managed with the intent to restrict all surface occupancies that are contrary to Reclamation project purposes. The withdrawal table on page 2-22 should be changed to include all Reclamation purposes such as recreation, flood control, soil and moisture conservation, or state only "Reclamation purposes". As it now reads It may be construed to mean the listed purposes are the only Reclamation purposes and this is not 39 Map "B" Considerations below are listed separately by Reclamation Project name. Any proposed disposal of lands that are withdrawn by Reclamation and that Reclamation intends to retain under the Withdrawal Review program, should not be disposed of unless the BLM wants to dispose of them to Reclamation. If th disposal is to Reclamation, absolute Fee title would be required to protect project features from mining activities. ~B1. The Reclamation withdrawals between the Black Canyon and Curecanti areas in Section 4, 9, 10, II, 14, and 23, T49N, R7W, are not properly marked on the map. These lands were withdrawn for the Uncompahgre Project and the Aspinall Storage Unit of the CRSP. The withdrawal in Section 11, 14, and 23 are for the CRSP and the are for the Uncompahgre Pt proposed for disposal i approved for disposal. thdrawals in Sections 4 and 9 me portion of Section 8 that is planned for relinquishment and is therefore 57 89 85 87 89 85 93 89 82. Comments same as A2. H3. The 40 acres in the W4SW4 of Section 34, T46N, R8W should also be shown as withdrawn for the Dallas Creek Project. Lands shown tor disposal in T47N, KBW in Ouray County north of Cow Creek are important big game winter range and should not be disposed of unless to the Colorado Division of Wildlife. These lands are in the vicinity of lands acquired for wildlife habitat replacement under the Dallas Creek Project. B4. Comments same as M. Also, the disposal recommendations for the following parcels are not compatible with project purposes unless a linear withdrawal is first granted: T14S, R92W, Section 3, NE4SE4; T14S, R92W, Section 17, S2SW4NW4; and TUS, R93W, Section 22, about 55 acres. B5. Comments same as A5. B6. Comments same as A6 . In addition, the recommendations for disposal on the following tracts should be changed to retention: The 5E4NW4 of Section 26, T49N, R8W; the J1W4HW4 of Section II, T48N, R10W; the two tracts in Section 12, T48N, R8W; and the apparent disposal ^ (the lands to the east are actually marked) of Section 36, T50N, RllW^ CONSERVATION ALTERNATIVE HAP "C" Considerations below are listed separately by Reclamation Project name. Any proposed disposal of lands that are withdrawn and that Reclamation intends to retain under the Withdrawal Review program, should not be disposed of unless the BLM wants to dispose of them to Reclamation. If the disposal is to Reclamation, absolute Fee title would be required to protect project features from mining activities. CI. Comments same as Al . C2. Comments same as A2 . C3. The 40 acres in the NU4SW4 of Section 34, T4&N, R8W should also be shown as withdrawn for the Dallas Creek Project. C4. Comments same as A4. C5 . Comments same as A5 . Qb . Comments same as A6. 93 89 87 89 85 United States Department of the Interior GEOLOGICAL .SURVEY RESTON, VA 22(W2 In Reply Refer To: WCS-Matl Stop 423 DES 87/20 To: Bureau of Land Manage: Montrose, Colorado OCT I 9 Uncompahgre Basin Resource Area, From: Assistant Director for Engineering Geology Subject: Review of draft management plan/environmental statement for the Uncompahgre Basin planning area, Colorado 49 71 PREFERRED ALTERNATIVE Map "D": Considerations below are listed separately by Reclamation Project name. Any proposed disposal of lands that are withdrawn and that Reclamation intends to retain under the Withdrawal Review program, should not be disposed of unless the BLM wants to dispose or them to Reclamation. If the disposal is to Reclamation, absolute Fee title would be required to protect project features from mining activities. Dl . Comments same as Al D2. Comments same as A2 D3. Comments same as B3 D4 . Comments same as B4 D5. Comments same as A5 D6. Comments same as Bo Comments on Uncompahgre Basin Wilderness Technical Supplement Designation of the Gunnison Gorge Wilderness Study Area as Wilderness could affect certain management practices and these effects should be discussed in the final EIS. First, helicopters, small airplanes, and outboard motors are used as inventory tools by the Colorado Division of Wildlife for managing the Gunnison River fishery and waterfowl populations. Secondly, rescue operations are occasionally conducted in the canyon by helicopter. On page 3-13, the minimum flow that Recla 300 cfs rather than 200 cfs. .tlon attempts to maintain is On page 4-13 it is stated that there is approximately 750,000 acre-feet of water available from Blue Mesa Reservoir. The correct figure Is 50,000-60,000 acre-feet annually. United States Department of the Interior BUREAU OF MINES P- O. BOX :'S(1«6 BUILDING 20. DENVER t EOERAL CENTLR DLNVLR. COLORADO 8022S Intermountain Field Operations Center We have reviewed the statement as document. cquested In the lett included In the 39 38 The analysis should indicate criteria to be used In permitting mining and disposal of mineral materials on alluvial vall'ey floors and flood plains. Mitigation of related impacts should be addressed- The analyses of cumu- lative impacts should include long-term effects of aquifer mixing and accidental release of saline formation waters into freshwater aquifers. Such contamination may occur long after oil and gas test and production wells are abandoned as well as during operations such as hydraulic fracturing, injection of formation waters, and enhanced recovery. Ground-water impacts to be avoided during secondary and/or enhanced recovery methods involving injection and well pressurizing should be included in the analysis. tlH James F. Devine Copy to: District Chief, WRD, Lakewood, Colorado 35 October 21, 19P7 To: Robert S. Vecchia, RMP Team Leader, Bureau of Land Management, Uncompahgre Basin Resource Area, 2505 South Townsend Avenue, Montrose, Colorado 81401 From: Chief, Intermountain Field Operations Center Subject: Review of the Draft Resource Management Plan/Environmental Impact Statement for the Uncompahgre Basin Resource Area, Delta, Gunnison, Mesa, Montrose, and Ouray Counties, Colorado As requested, Bureau of Mines personnel have reviewed the subject documents regarding proposed management of 483,077 acres of Federal land and 755,923 acres of subsurface federal mineral estate, including three wilderness study areas (WSA's) (41,865 acres), in western Colorado. Our comments pertain to the discussion of mineral resources and assessment of impacts under the plan. Four multiple-use management alternatives are presented In the DEIS. Differ- ences between the four proposals vary considerably in the amount of acreage open to mineral entry and to oil and gas, coal, and geothermal leasing. From a mineral-development standpoint, the Production Alternative is the more favorable of the plans described. In comparison to the Preferred Alternative, it makes about 30,000 more acres available to mineral entry and about 196,000 more to oil and gas and geothermal leasing; the acreage open to coal leasing Is the same under both alternatives. In the "Affected Environment" section, the discussion of oil, gas, and geo- thermal resources (p. 2-3 of the main document) assumes that the lack of paBt or present production of these commodities implies a low probability for future discoveries. We believe that such an assumption may not be valid because seismic work and exploration drilling have been limited in the resource area. We suggest the Affected Environment Section of subsequent versions of the document be modified to better explain the relationship between the assumption of low productivity of future discoveries and the lack of explora- tion activity in the area. 58 71 The geology and mineral resource descriptions in the Wilderness Technical Supplement tend to discuss only the surface geology of the WSA's- We believe that formations at depth should be discussed as well. For example, the Adohe Badlands WSA Is underlain by the Morrison and Chinle Formations, both of which are major hosts for uranium deposits in other areas. Uranium, however, is no; discussed in the Mineral Resources section (p. 3-10). We believe that the lack of a discussion of the uranium potential in the Morrison and Chinle Formations is an oversight that should be corrected in future versions of the document. The Bureau of Mines currently is conducting a mineral land assessment study Of Gunnison Gorge WSA, hut has no current study of either Adobe Badlands WSA or Camel Back WSA. for the opportunity to coi Dent on this document. ■fo^Jilliam Cochran United States Department of the Interior pfiwic AMEXKAh NATIONAL PARK SERVICE „ ROCKV MOUNTAIN RFGIONaI 0 12795 W. Alameda Parl*ua\ P.O. Bm 25287 Denver. Colorado 80225-021(7 L7619 (RMK-PP) OCT 2 9 1987 Robert E. Vecchia, Resource Management Plan Team Leader, Bureau of Land Management, Montrose, Colorado Associate Regional Director, Rocky Mountain Region Planning and Resource Preservation, Subject: Review of Draft Uncompahgrc Basin Resource Management Plan/ Environmental Impact Statement and Draft Uncompahgre Basin Planning Area Wilderness Technical Supplement (DES 87/20) 68 17 Our comments on the subject draft Resource Management Plan/Environmental Impact Statement (RMP/EIS) follow. Review of the document was made relatively easy due to several factors: 1. The draft RMP/EIS Is very well written. 2. The number of alternatives (four) and the orderly presentation of material made it convenient to compare impacts of alternatives. 3. The three alternatives other than the proposed plan are analyzed as thoroughly as the Preferred Alternative. We recognize the Bureau of Land Management's (BLM) multiple-use approach to land management, but we would like to see more concern for National Park Service (NFS) Interests in specific portions of the Preferred Alternative. 1. The Preferred Alternative appears to reflect a concern for wilderness values-- both on BLM-administered lands and on lands administered by the MPS- We note that the Gunnison Gorge Wilderness Study Area (WSA) would be recommended for designation as wilderness; the Adobe Badlands WSA would Qot be recommended for designation, but there would be restrictions on surface-disturbing activities and no Off-Road Vehicle use there. However, we believe that the Adobe Badlands WSA is deserving of wilderness status and should not be rejected for designation because of plans to implement salinity control measures. Efforts to reduce salinity should be concentrated in the agricultural areas where increased salt loading is caused by agricultural practices. 2. Some BLM-administered lands near the northeast and northwest boundaries of Black Canyon of the Gunnison National Monument are designated as potential exchange tracts under the Preferred Alternative. As the draft RMP/EIS is 17 16 revised, uld like to see these lands ; have provision for sceni ither deleted as potential ;ement language that would exchange tracts or have provision for scenic easement language that would ride with the deed(s) conveying the exchange tracts. These BLM-administered lands form an important backdrop to the viewsheds looking north from the monument's south rim. 3. The four land status maps included with the draft RMP/EIS, after page 43 of the Appendix, need to be revised to show correct NPS boundaries. The maps show the Black Canyon of the Gunnison National Monument boundaries as they existed years ago; the monument boundaries have since expanded. The maps fail to show the considerable portion of Curecanti National Recreation Area that occurs in the Uncompahgre Basin Planning Area. As a good reference for correcting the maps, we recommend the BLM Edition (1985) of the Paonia Quadrangle topographic map. Thank you for the RMP/EIS. Richard A. Strait ipp. irtunity to review the generally well-prepared draft ffFTvS United States \!ek/ Department of ^-— Agriculture Grand Mesa, Uncompahgre and Gunnison National Forest Phone: (303) 87^-7691 2250 Highway 50 Delta, Colorado 81*116 Heply to: 1950 Date: 108 ■NOV - 2 1987 Mr. Robert E. Vecchia, RMP Team Leader Bureau of Land Management Uncompahgre Basin Resource Area 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia: We have reviewed the draft Resource Management Plan for the Uncompahgre Basin Resource Area. As you can see from the comments of the District Rangers which follow, we are unsure of where the fire management strategies are to be applied. Consequently, we are unable to determine if they would be compatible with fire management efforts on adjacent National Forest System lands. We recommend that some additional coordination be done in thl3 respect. Paonia Ranger District In reviewing the above referenced plan, we found the proposed management units compatible with ours, both in terms of location and management emphasis/direction. The only concern we surfaced dealt with the application of the three proposed wildfire suppression strategies. From the information available for review, it was not possible to determine the geographical locations at which the various strategies would be applied and whether or not they were compatible with fire management efforts on adjacent FS lands. I suggest we review the proposed fire management with the BLM at the Forest level just to be sure we do not have any significant Inconsistencies . Ouray Ranger District BLM's management areas D1, D2 and D3 are adjacent to our management prescriptions 4B and 5A on the Uncompahgre Plateau. Management emphasis and direction are compatible. None of the access acquisition proposals on the Plateau would have an effect on NF lands. Closing Potter Creek will have no effect. Dry Fork Escalante Road will not be closed according to Gene Vecchia. BLM's D9 management areas and emphasis are compatible with our 9A prescriptions although our map doesn't have them Identified. 59 15 C BLM's D10 Management area in the Cimarron Ridge country is adjacent to 2A, l)B, 5B and 6B. These appear to be compatible also- The access to High Park would improve access to the NF. Storm King Ski Area would not have an effect on NF as it would be located in the northernmost unit. The D15 management area adjacent to NF on High Mesa would be open to ORV's. This is adjacent to a restricted travel area on N.F. The location of the BLM's proposed three fire management strategies also need to be identified on this end of the Forest. DEPARTMENT OF THE AIR FORCE MR FORCE REGIONAL CIVIL ENGINEER CENTRAL I 1 Id COMMTWCE * Other than the fire management item, we have not identified any significant additional concerns. Me appreciate the opportunity for this review. rXr. RAYMOND J. EVANS Forest Supervisor ec: Regional Forester Chief (Director, Environmental Coordination) (FWE) MEMORANDUM United States Department of the Interior FISH AND WILDLIFE SERVICE Fish and Wildlife Enhancement 529 25*i Road, Suite B-113 Grand Junction, Colorado 81505 November 5, 19B7 57 [ Mr. Robert S. Schmidt Montrose District Manager Bureau of Land Management Montrose District Office 2465 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Schmidt This is in response to your request for comments on the Draft Planning Area Uilderness Technical Supplement for the Uncompahgre Basin Planning Area located in southwest Colorado. We continue to support the overall wilderness area concept. While actual conflicts between Air Force flying areas/routes and the proposed wilder- ness area do not exist at the present time, routes and airspace require- ments of the military do change frequently. Mission requirements, fuel costs, and environmental constraints all act on the decision to locate a military training activity. In particular, low altitude high speed flight, because of general aviation and population pressures, has been relegated to those areas least accessible and sparsely inhabited. For this reason, it is requested that you give full consideration to the extent to which a wilderness designation might adversely effect or restrict use of low altitude airspace by the Air Force. If restrictions are placed upon these military overflights, the negative impact on train- ing and readiness will force the Air Force to object to that wilderness designation. Ue hope this information is useful in your planning process. We thank you for the documentation previously provided and look forward to continued communication with your office. Our staff project officer is Mr. Raymond Bruntmyer, telephone (214) 653-3341. Sincerely — [ JOHN A. MILLER, Lt Colonel, USAF ^"Director Environmental Planning Division Copy to: HQ USAF/LEEV I i 11 To: RMP Team Leader, Bureau of Land Management Uncompahgre Basin Resources Area , Montrose . Colorado From: Acting State Supervisor, Fish and Wildlife Enhancement Fish and Wildlife Service, Grand Junction, Colorado Subject: Draft Uncompahgre Basin Resources Management PI an /Environmental Impact Statements and the Draft Uncompahgre Basin Planning Area Wilderness Technical Supplement General Comments We have reviewed the referenced Resources Management Plan/Environmental Impact Statememt and related Wilderness Technical Supplement. The Endangered Species Act (Act) requires that an action agency consider possible impacts to proposed and listed species and their critical habitats to determine if any proposed plan may effect such species or habitat areas. Should the Bureau of Land Management make a "may affect" determination, then formal consultation should be initiated. Management proposals identified in the plan seem, at this time, too general to make a "may/may not affect" determination for any species with certainty. It is our suggestion that informal consultation continue as specific actions are planned for the resources area rather than trying to make a blanket determination for the broad Resources Management Plan. By consulting on a case -by -case basis, we will know exactly what action is being considered and will have the advantage of the latest biological knowledge for the species involved, as well as important habitats such as wetlands and riparian zones. Specific Comments Page 2-10, Table 2-6. Endangered, threatened, candidate, or sensitive plant 3pecies. The habitat descriptions for the spineless hedgehog cactus and Uinta Basin hookless cactus are reversed. Based on new locations discovered by Jim Ferguson last field season the habitat description for the Delta lomatium should be expanded to include mid-altitude mancos shale in association with pinyon- juniper . The Wetherill milkvetch ( Astragalus 85 99 wetherillii) , a plant on State List 3 and which will be added as a federal candidate in the next update, should be added to Table 2-6. Its habitat is clay hills in association with pinyon- juniper and sagebrush. Estimated populations include four collections from the Uncompahgre Resources Area, and the estimated acerage of occurence is unknown. Page 2-12. Table 2-B. Endangered, threatened, and candidate animal species. The river otter, Lutra candensis sonorae, is a federal candidate species . Page 3-30. Disposal of public lands. We recommend that public wildlife values be considered prior to any disposal of public lands. Page 3-31, 37. Oil and ga3. The Service would appreciate involvement in any variance to seasonal stipulations on lands used by bald eagles for hunting habitat. Page 4-50. Impacts on riparian zones. The Service would appreciate involvement prior to the approval of any disturbances to riparian zones. Page 4-51. Impacts on threatened and endangered species. The Service would appreciate involvement prior to any mineral resources management that might affect wintering bald eagles. Appropriate consultation may be necessary if offroad recreational vehicles use affect the Uinta Basin hookless cactus or if the disposal of public lands affects any threatened or endangered species. P4-52. Impacts on terrestrial wildlife. The Service would appreciate notification of the potential loss of any raptor nesting habitat. 60 USEZ< UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION VIII 999 16th STREET-SUITE 500 DENVER, COLORADO 80202-2405 Thank you for the opportunity to provide our comments prior to completion of the draft. Again, we would appreciate the opportunity to comment when specific actions are completed. NOV 05 1987 X.J f. /*«•? / cc : AWE-Denver FKE-SLC Reading File Official File DGober:dm:ll-5-B7 (blmuncom F:user 5) Robert E. Vecchia, RMP Team Leader Bureau of Land Management Uncompahgre Basin Resource Area 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia: Draft Uttcompahgre Basin Resource Mangement Plan and Environmental Impact statement (rmp/eiS) , and Wilderness Technical Supplement In accordance with the National Environmental policy Act (NEPA) and our responsibilities under Secticn 309 of the Clean Air Act, the Region VIII office of the Environmental Protection Agency (EPA) has reviewed the referenced documents. The EPA appreciated the opportunity to meet with you and other BLM staff at Montrose in March, 1985. The meeting was followed up by EPA's scoping concerns for the project which were sent on May 3, 1985. In addition to environmental conditions and effects, our review is also focused on the RMP as a "framework for managing and allocating public land resources" and it's importance in establishing "management direction" (page 1-1). our enclosed detailed comments are intended to make a constructive contribution to the management direction. Based en our concerns and the criteria EPA has established to rate adequacy of draft ElSs , we have rated this draft EIS as category EC-2 (environmental concerns - insufficient information). A summary of our EIS ratings definitions is enclosed. We commend the inclusion of management units; initiatives on aquatic and riparian monitoring; and the emphasis on salinity, riparian, and aquatic systems. However, our enclosed comments address insufficiencies and recommendations that we feel are appropriate at the RMP level of planning, regarding: o the description of consistency with water quality standards (existing/designated beneficial uses, use protection criteria and antidegradation requirements) and the Federal/State water quality management programs, o the framework of measures, criteria, and indices that would be used, e.g., physical measures (such as channel and streambank stability), chemical criteria, and biological indices, for implementing water quality standards (WQS) /aquatic resource protection under the Clean Water Act (CWA) and Federal Land Policy and Management Act, o consistency of analysis of effects on aquatic resources/beneficial uses in relation to applicable statutes, o a framework for CWA/WQS monitoring, o additional guidance and documentaticn for protection of riparian and wetland values, o planning of range management to support multiple rangeland values under applicable statutes, o need for consistent Areas of Critical Environmental Concern (ACEC) recommendations by alternative, and plans for ACECs that are adequate to assure resource protection, o compliance with the Endangered Species Act, o and inclusion of more specific plans for coordination and implementation, among other items, in an implementation chapter or appendix. Several features of the conservation Alternative are identified, that would also help provide a stronger, more aggressive resource management program. A statewide antidegradation policy is an important part of State WQS. EPA's WQS regulation requires that, at a minimum, state policy ensure that existing instream uses and the level of water quality necessary to protect the existing uses be maintained and protected (40 CFR Part 131.12). This prevision applies to all waters of the state. Furthermore, the state policy must establish additional measures for protection of certain high quality waters (waters where ambient quality exceeds that needed to protect the "fishable/swimmable" uses) and waters which may constitute outstanding national or state resource waters. At present, there is a difference in the way the federal and state regulations and guidance identify high quality waters, under the current state regulation (5CCR 3.1,8 (3)), High Quality Class II waters "... shall be maintained and protected at their existing quality unless the Commission chooses, after full intergovernmental coordination and public participation, to allow lower water quality as a result of necessary and justifiable economic or social development", in Colorado, this level of protection is applied only to water designated by Colorado's Water Quality Control Commission (WQCC) as High Quality Class II waters. EPA's regulation would not distinguish between those waters designated High Quality Class II by the state and those that are, by definition, high quality. EPA has approved the current state antidegradation standard in the past. However, based on changes embodied in EPA's new water quality standards regulation, the WQCC has begun a review of the present standards arid expects to complete the review process in mid 1988. we encourage the BLM to be part of this process and be aware of the applicability of any new requirements that may apply to BLM streams. The State of Colorado contact person is Dennis Anderson in Denver (331-4571) and the EPA contact is William Wuerthele (FTS 564-1586 or commercial 293-1586) . We would appreciate the opportunity to discuss with the BLM its proposed responses and RMp/EIS revisions relating to EPA concerns prior to the RMP/Final EIS. Based on experience reviewing these documents, such a coordination process would be beneficial in helping address our concerns. Please contact Douglas Lofstedt of my staff as needed for further EPA coordination at 303-293-1717 or FTS 564-1717. Sincerely, Robert R. DeSpain, Chief Environmental Policy Branch Policy and Management Division Neil F. Morck, Colorado BLM State Director David Williams, Office of Planning and Environmental Coordination, BLM Washington Office Jon Scherschligt, Colorado Department of Health Rick Krueger, USFWS, Grand Junction Laurie Mathews, Colorado Department of Natural Resources William Dickerson, EPA Office of Federal Activities 61 EPA DETAILED COMMENTS ON THE BLM DRAFT UNCCMPAHGRE BASIN RESOURCE MANAGEMENT PLAN AND ENVIRONMENTAL ...IMPACT STATEMENT (RMF/EIsTT AND WILDERNESS TECHNICAL SUPPLEMENT" Aquatic Resources, Watershed Management Our review of plans tor water quality and aquatic resource integrity is based on consistency with: o Colorado's water quality standards (WQS) and water quality management program, o Executive Orders (EQs) 11752 and 12088 and Clean water Act Section 313 requirements for Federal agency leadership to "protect and enhance the quality of . . . water . . . resources" (£0 11752) through meeting applicable standards, o requirements for RMP consistency with "officially approved or adopted resource related plans, and the policies and programs contained therein, of other Federal agencies. State and local governments" in 43 CFR Part 1610.3-2: o Federal Land Policy and Management Act (FLPMA) policies to "protect the quality of ecological, environmental, . . . and . . . water resource . . . values" (Section 102(a)(8)), to meet applicable State and Federal "pollution control laws" and water pollution "standards or implementation plans" (Section 202(c)(8)), and "to prevent unnecessary or undue degradation of the lands" (Section 302(b)). o the Clean water Act (CWA) objective to "achieve and maintain physical, chemical, and biological integrity of the nation's waters" (Section 101(a)), O and "NCWPQINT SOURCE CONTROLS AND WATER QUALITY STANDARDS" guidance (August 19, 1987) from Chapter 2 of EPA's Water Quality Standards Handbook . The draft RHP /EI S proposes impacts to aquatic resources frcm several activities. 1) Lccatable mineral activities could "result in water quality degradation", "increase sediment and salinity loads in local surface waters", and "could result in heavy metal contamination frcm mine water discharge and spoil-pile runoff" (page 4-49). 2) Oil and gas activities "would increase sediment and salinity yields in local surface waters" (page 4-49). 3) "Road construction and extraction of mineral materials would increase sediment and salt loads in local surface waters", and could alter "natural stream channels" and "surface water flows" (page 4-49). >uld leave aquatic habitat areas "subject to degradation" 73 74 23 79 71 78 77 44 8? What are at least the general aquatic life/habitat standards and/or objectives to be achieved (page 3-44)? One management concern is to "Identify high potential fisheries requiring improvement and mangement" (page 1-7), Consistency with the CWA should be provided since the CWA does not distinguish between degree of aquatic life potential (Section 101(a)). Fisheries improvement plans should: correlate to impairments of WQS; include consultation with the Colorado Department of Health (CDOH) [since it administers WQS); and be consistent with CDOH priorities, if "existing condition" is maintained "on the balance of the aquatic habitat" (page 4-53), will any existing WQS violations be perpetuated? We like the strong approach to managing the riparian aquatic resources presented in Management units C-4 and C-18 (pages 3-20, 26, and 27) . The intent to improve "Aquatic habitat, . . . streambank stability, and water quality . . . for fair to good condition " in the Camel Back WSA appears commendable (Wilderness Technical Supplement page S-l) . What are the measures for "good" condition under the CWA/WQS? It is not clear how results under non-wilderness management would be better or equal to that under wilderness management. Sources of drinking water from BLM lands are mentioned on page 2-6. What are the existing drinking water problems (if any), potential impacting activities, and water quality improvements needed? Numerous references to impacts to "local surface waters" are made. What is "local"? Protection under the CWA and FLPMA should be referenced. We suggest that oil and gas management requirements be included for Management Unit D-9 (page 3-38). Control of soil erosion remains another concern. Of the 94,110 acres with erosion data, over 85,000 acres have either moderately or severely '"accelerated erosion" (page 2-4). Several areas have severe gully erosion (page 2-5). However, BLM proposes to have erosion control projects "if compatible" with livestock grazing and woodland production activities (page 3-43). This proposed policy is exemplified, for example, by plans to manage grazing to "increase sediment and salinity yields far above normal" for some areas (page 4-50). A reference to CWA compliance is not made. We believe that providing erosicn and sedimentation control is a basic land stewardship responsibility even if it conflicts with grazing, timbering, and other uses. We ask that the RMP/Final EIS contain a more clearly defined action plan to address areas of accelerated erosion and to prevent new erosion problems. This action plan should also specify more detailed direction for erosion control priority in new and existing allotment management plans (AHPs) . Also, it is not clear why erosion control projects would not be compatible with wildlife winter range and riparian management (page 3-43). We found that the disclosure of impacts on aquatic habitat from soil resource management to be insufficient on page 4-53 (only in-channel structures are briefly discussed). 4) Forest management activities "could cause increased sedimentation, bank degradation, and water temperatures, and decreased streamback cover" (page 4-54) . 5) ORV management i (page 4-54} . The Preferred Alternative would also require "Measures designed to minimize erosion and water quality deterioration" and "minimize site-sp*ci£ic riparian and aquatic deterioration" would be in plans for surface disturoing activities (page 3-29) . In response to these potential effects and/or violations of WQS, we found that the RMP/EIS provides an insufficient framework of planning, management, and monitoring requirements to implement CWA and FLPMA requirements. What measures, criteria, and indices will be used, e.g., physical measures (such as channel and streambank stability), chemical criteria, and biological? What does "minimize" mean? BLM's policy for managing activities, including mining under the 1872 Mining Law, to meet WQS/benef icial uses needs to be clearly defined in the text. Consistency with the State water quality/nonpoint source (NPS) control program should be addressed (the discussion on page 2-6 only addresses BLM coordination in locating and identifying NPS pollutants). Similar concerns are raised by plans to prohibit utility projects "which would have long-term adverse effects on riparian/aquatic systems" [page 3-38), and to have "short-term sediment yield increases" frcm vegetation treatments (page 4-49). What are allowable Short-term impacts? how long? The methods to be used in the activity plan NEPA documents to predict effects on WQS/beneficial uses should also be decribed in the RMP/EIS. There are several other questions of RHP/eIS consistency with the above (even though compliance with federal and state water quality standards was a planning criterion (page 1-5)). we would like to see the affected environment chapter establish more clearly the existing WQS, including designated beneficial uses and antidegradation requirements, and status and trends (to the extent of available information) similar to the discussion of air quality standards. Also, we suggest that Chapters Two, Three, and Four address water quality, WQS, and aquatic systems/habitat in an integrated maimer in aquatic resource sections. The aquatic resource requirements of the CWA and FLPMA should be described as part of the planning framework and objectives. we commend the BLM for including aquatic habitat conditions (page 2-14) and plans for intensively managing 70 miles of stream "to restore and protect aquatic habitats" (page S-6) . Does the amount of planned improvement conflict with the amounts stated in Chapter Four? For example, 40 miles of improvement is planned under tie riparian program and 60 miles is planned under the grazing management program (page 4-53). [ 80 33 82 118 62 It is unclear why livestock grazing use would be resticted on only 39,410 acres (page 3-45). Apparently, plans to implement AMPs contain questions on adequacy Since erosion rates would be reduced "if" AMP objectives are net (pages 4-4Q and 49). The RMp/EIS should include guidance for. correcting readily observable problems that do not require long-term monitoring. The Conservation Alternative seems to be more sensitive and aggressive for range stewardship. We ask that the coal unsuitability report be included in the RHP/EIS. The draft RMP/EIS discusses the significant aquifers and provides a qualitative review of the water quality of each zone (page 2-7). Since the alternatives analysis addresses only surface water, it appears that trends and projected effects are not considered to be of major importance under the RMP. We encourage much more site-specific detail for the appropriate projects. Riparian Areas and wetlands The draft RHP/EIS appears to provide a strong, general basis for the riparian area/wetland management program by: 1) continuing to inventory and monitor riparian areas, 2) improving the vegetation conditions on 6,320 acres of land "by implementing special protective and restorative measures" (page 3-43), and 3) by maintaining or improving "riparian zones in the remainder of the planning area" (page 3-43). We have several concerns that we would like to have addressed in order to achieve more detailed management guidance in the RMP. We suggest a thorough description of how vegetation condition meets: 1) the BLM Riparian Area Management Policy "to achieve a healthy and productive ecological condition for maximum long-term benefits"; 2) the riparian values noted in the Policy's background statements; and 3) the Executive Order 11988 an 11990 (Floodplain Management and protection of wetlands, respectively) requirements to preserve, protect, and restore the natural functions of such areas. What are the specific standards/guidelines for improvement and protection of condition? How are the objectives consistent with cwa/WQS objectives? Are there to be any demonstration areas? Also, we ask that the Water Quality Control Division of the CDOH be informed of the priority areas of treatment so they can be incorporated into the CWA Section 319 NPS assessment report. The Preferred Alternative either would or could allow various activities in areas of ripar ian/wetland/ aquatic systems. o "Approximately 4,000 acres of riparian zones would be opened to mineral exploration" with lifting of existing mineral withdrawals (page 4-50). Associated surface disturbance "would lead to increased sedimentation and streambank instability on 25 stream miles of aquatic habitat" (page 4-53) . o Some riparian areas would apparently be left "open to ORV use" and "would be subject to degradation" (page 4-54). o coal development could be considered (page 3-38) . o Forest management activities would take place with up to 60 to 100 acres of riparian vegetation being degraded (page 4-51). 1 24 75 Consistency of the above management direction with existing policies and executive orders should be documented. We found the draft RMP/EIS to lack sufficient criteria and standards for WQS/aquatic resource protection (under the CWA and FLPMA) to be applied to management of the above activities. Without such criteria and standards, for example, we support the Conservation Alternative which would withdraw riparian zones from mineral entry (page 4-32). Formulation of mitigation measures for impacts of coal development is mentioned on page 3-38. The final EWP/EI5 should state BlM's mitigation policies, e.g., avoidance, restoration, compensation, etc., for riparian/wetland/aquatic resource impacts, It appears that leaving some areas open to ORV use contradicts the Preferred Alternative direction on page 3-43 under which most riparian areas would be improved with at least maintenance of existing condition for the rest. The action alternatives rely heavily on intensive grazing management to improve riarian areas. We request more documentation of actual planned grazing management tools. This documentation should include more information en experience in using grazing management without riparian fencing to achieve adequate improvement and protection of multiple riparian values. Table 2-5 lists 1,034 acres of riparian vegetation type. Much larger amounts of riparian zones are mentioned elsewhere. What is the correct amount of riparian area? Monitoring and Evaluation The draft RMP makes several references to monitoring. RMP implementation will be monitored (page 1-1). "Water quality . . . would be inventoried and monitored" (page 3-29). The riparian zones would have intensive "aquatic habitat" monitoring (page 3-38). While we commend these planned initiatives, we request that the document go farther in describing the comprehensive CWA monitoring program in an appendix or monitoring chapter. The monitoring program (not plans for each activity) should include such information as: (1) goals and objectives, (2) types of surveys (ambient, intensive) or assessments to be used, (3) parameters to be monitored, (4) management and environmental indicators (e.g., aquatic habitat, sediment delivery) , (5) monitoring methodologies, (6) mechanisms for monitoring implementation and adequacy of best management practices; (7) the person/position responsible for monitoring, and (8) the feedback loop to achieve timely modification to activities. Refer to our scoping letter for other components. It would provide the basic framework for CWA monitoring (including WQS/benef icial uses) in the Resource Area. However, there is no assurance that this monitoring framework has been established. Groundwater monitoring should also be included as needed. The other agencies and public should be able to review and comment on this framework in the FKp/ElS. The imp direction would then be applied in site-specific detail. The RMP monitoring program would help meet 43 CFR Part 1610.4-9 requirements that the "proposed plan" establish "intervals and standards" that "shall provide for evaluation to determine whether mitigation measures are satisfactory", we could not find the "intervals and standards". What is the early warning system to document existing violations or risk of potential violations of the CWA? Are there going to be reference streams? When are the water quality inventories and monitoring to be done (page 8-3)? How are they designed to document protection of wqs beneficial uses, status, and trends? 75 25 The new Clean Water Act amendments were passed in February 19B7. a primary concern is the new NPS control program (Section 319). BLH cannot match other Federal (EPA) dollars, but allottees, private land owners, and private organizations can and do plan to participate in the program. Seme of this work may be done on BLM lands. How will BLM participate in work on "mixed-ownership watersheds to improve water quality? BLM is asked to provide an assessment of condition of their water bodies to the State as part of the assessment phase of the Section 319 management program. Additionally, the State will be identifying in its Section 319 management program the Federal programs/projects that it plans to review under Executive order 12372 for consistency with the State's NPS management program. BLM involvement in this process should be described. The State of Colorado contact person for the MPS program is Greg Parsons in Denver (331-4756). We suggest that the implementation chapter or appendix list the specific inventories, assessments, and management plans/projects to be done (in priority order) along with anticipated costs and schedule for completion. Of particular concern to EPA to have included are: WQS/aquatic life assessments; watershed and related management plans; salinity control plans; cooperative management plans; wetland and riparian area inventory and management plans; and groundwater studies. We feel that the MP/EIS should address the commitment of the Resource Area office to annually request the funds needed to implement these projects. What is the linkage of the budgeting process to implementation of RMP-identified projects? Extensive site-specific project planning and impact analysis/disclosure under NEPA will be done tinder this broad rmp/eiS. We believe that there will be a continuing need for public and other agency involvement in planning some of these projects (rather than just having the analyses available in the BLM office). The stategy for this involvement remains unclear and should also be addressed in more detail in an implementation chapter or appendix. b yg Even though compliance with MJS is a planning criterion (page 1-5) not clear what is inducted in implementation monitoring reqardinn aa/M .mpli compliance, and aquatic resources. monitoring regarding CWA/WQS 101 102 27 Areas of critical Environmental ceneem (ACECs) The RMP/EIS alternatives contain different ACEC recommendations (Table 3-8). It is our position that the ACECs should be the same (area and size) for all action alternatives. Either they are or are not valid ACECs under FLPMA regardless of what the RMP/EIS alternative is. Management practtces may vary by alternative, however, in order to reach the same ACEC protection objectives. Consequently, consistency with FLPMA requirements to give priority to the designation and protection" of ACECs (Section 202(c'. (3))is not clear. If areas where watershed, soils, W2S, wetlands, riparian areas, or municipal water supply concerns were considered what management requirements will substitute for ACEC designation? we would like to see an appendix that describes all potential ACECs recommended by BLM staff or others, reasoning for not recommending any particular area (if any) in the BMP/EIS, and any special management the area(s) may need. Also, we believe that management plans (including inter-agency and public review) are needed _for all ACECs; however, it is not clear that such plans are to be done. Threatened and Endangered Species The preferred alternative would have a commendable intent to "Require measures to protect T s E species, individuals, and habitats in plans for all surface disturbing activities" (page 3-43). However, this intent appears to be contradicted in chapter Four where statements are made that the preferred alternative would "seriously accelerate destruction of the ointa Basin hockless cactus" (a threatened species) in the North Delta ORV area, and result in a "loss of 10,000 acres of potential habitat for the ointa Basin hookiess cactus and Delta lomatium due to recreational ORV use" (pages 4-51 and 52). we would like to see additional direction/documentation for the RMP action alternatives for compliance with Endangered Species Act requirements for doing everything possible to conserve such species (Sections 2(c)(1) and 3(3)). we would like to see the impact analysis address in more depth both indirect and cumulative impacts under 40 CFR Parts 150S 7 and 8 (with a distinction between the two). For example, the section en cumulative impacts briefly addresses impacts to potential habitat, rather and existing species and their habitat. Also, what is the basis for determining priority of ORV use over protecting riE and/or candidate or sensitive species? Other concerns 75 The BLM states that there is seme coordination with the state in locatinq and identifying NPS "water pollutant sources", and that input to the state's biennial water quality assessment under CWA Section 319 is made. We would like to see an RMP/EIS implementation chapter or appendix recognize action to be taken in response to existing/potential impairments identified in the 305(b) assessment, and the inter-agency coordination and consultation strategy for WOS-related programs. The RMP should identify procedures that will be used to ensure consistency with water quality management plans for the area STATE Of COLORADO ROT ROMER, Go.ocnor DEPARTMENT OF NATURAL RESOURCES 13 13 Sherman SL, Room 716. Derwai. Colorado 60203 S66'33 November 5, 1987 Robert E. Vecchla Bureau of Land Management 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchla: State agencies have completed the review of the Draft Uncompahgre Basin Resource Management Plan and Environmental Impact Statement. We offer the following comments on the management alternatives and their effects on the Important resources of the area. midlife From the perspective of wildlife and wildlife recreation, the Division of Wildlife prefers the Conservation Alternative. This alternative would best conserve and protect wilderness, wildlife habitats, watersheds and recreational areas. This high level of natural resource conservation Is Justified 1n light of the significant economic values of wildlife and recreation 1n western Colorado. The Division, 1n cooperation with the Bureau of Land Management (BLM), has a bighorn sheep relntroductlon program currently underway In the Gunnison Gorge. The two agencies should make arrangements to continue and enhance this program. The Gunnison Gorge area 1s a Gold Medal fishery which should be maintained and enhanced. Protection of the surrounding watershed and associated resources are necessary to protect the fishery. The Conservation Alternative emphasizes this protection; however, other management options are available and should be considered 1f this alternative Is not selected. Protection of the most critical wildlife habitats 1n the Uncompahgre Resource Area, riparian areas and big game winter range, 1s essential. The proximity of BLM public lands to private lands at the lower elevations maximizes available opportunities to enhance these critical wildlife ranges. The Conservation Alternative will not consider disposal of public lands. Rather, private land exchanges would be emphasized to obtain crucial big game winter ranges, riparian zones, and waterfowl areas. Public access to public lands would be acquired. 83 85 63 24 The Importance of riparian habitat warrants Its careful analysis 1034 erativ ™ The DEIS lists the principal proposed riparian restoration management actions as: 1) limit forage utilization to 35% on 6320 acres (4-51); 2) "intensive" grazing management on 5125 acres(4-51); 119 53 67 3) removal of grazing from March 1 to Hay 15 (4-54); and 4) reduction of livestock allocation by 200 AUHs on several grazing allotments (4-54). The EIS should describe how each of these measures would contribute to the restoration of riparian areas. For example, how will the reduction of 200 AUHs on seven allotments Improve riparian areas? "Grazing should be restricted in all riparian areas at all times of the year, since recruitment of native woody vegetation will be nonexistent in riparian improvement areas unless grazing 1s removed. Minerals and Energy Resources The state has no significant disagreement with the preferred alternative with regard to mineral and energy resource development. The Mesa Verde coals In the Paonla area will ultimately be the most economic to produce. The preferred alternative allows mining to occur In this area. The Dakota coals which are thin and have not been economic to date are also reserved for future production 1f conditions warrant. Reservation of the Gunnison Gorge area for wilderness will not significantly affect the ultimate coal production of the area. There has been limited oil and gas exploration in the area to date. There 1s methane potential in the Muddy Creek area near Paonla. The preferred alternative allows development of these resources when feasible. Finally, sand and gravtl In the Mancos shale area 1s surface minable in the Adobe Flats area and the preferred alternative allows production of this resource In the future. Recreation n The discussion on recreation Is very general and does not Include Information on the types and levels of current recreation use. This information would assist in assessing how well the preferred alternative "responds to multiple use demands. Under the preferred alternative, 82 percent of the resource area 1s open to offroad vehicle use. The plan should describe the demand for this use and tailor access to the area accordingly, rather than allowing virtually unrestricted use and corresponding Impact throughout the entire area. 136 28 94 37 Wilderness We support the recommendation In the plan of 21,038 acres of Gunnison Gorge for wilderness designation. This land is a geologic continuation of the Slack Canyon of the Gunnison containing spectacular waterfalls and offering outstanding fishing, hiking and river boating chal lenges . The Camel Back wilderness study area also has outstanding wilderness attributes. Its colorful deep canyons and mesas create vast panoramic vistas and extensive recreation opportunities. As the DEIS states, mineral development in the area Is unlikely over either the short or long term. This area appears deserving of designation although the Division of Wildlife is concerned that access for management and recreation purposes be provided. At the same time, the proliferation of roads similar to that which has occurred 1n nearby areas should be avoided. We would like to see this issue cooperatively worked out to allow eventual designation of the Camel Back area. Special Management Areas The EIS should present Information on remnant or relict plant communities In the resource area. Including those suitable for special management consideration. Recent data Indicate the presence of high-quality riparian vegetation along the Uncompahgre River (T47N R8WS 32 NE1/4 SE1/4) and upland vegetation 1n Wells Gulch (T4S R 3L, portions of sections 18,19,20,30 and T14S R 93W, portions of sections 26 and 35). The Colorado Natural Areas Program will work with BLM to Identify and evaluate appropriate high quality vegetation sites for special management consideration. We recommend that each special management area contain Information and management provisions on all relevant alternative uses of the sites: 1) grazing, 2) ORV use, 3) camping-public access, 4) utility corridors and 5) mineral entry. This is necessary to protect Important features of each area. For example, livestock use in the proposed Escalante Canyon ACEC has severely degraded Sclerocactus qlaucus (federal-threatened) populations, yet no special provisions for grazing are presented. The RHP should include discussion of the 1986 recommendations of the BLM Geologic Advisory Group. Recommendations Included the designation of 1800 acres of Chukar Canyon and recognition of the Ute Indian fault zone within the proposed Gunnison Gorge recreation Area. The EIS should indicate the proposed change 1n status for Needle Rock from a BLM Research Natural Area to an Outstanding Natural Area as supported by the advisory group. 36 [: Water Any impact of coal management, locatable minerals management or oil and gas management which would injure an adjudicated water right, will have to be mitigated by a plan for augmentation approved 1n Water Court prior to the occurrence of the Injury. 38 100 104 27 109 I [Rules requiring casing of oil and gas wells and mineral test holes would help minimize aquifer mixing and ground water degradation. Plugging and capping of test holes are governed by the Colorado Mined Land Reclamation Rules and Regulations. Threatened and Endangered Species Lands having populations of federally threatened or endangered plant species should not be released from federal ownership. Populations of clay-loving wild buckwheat have been documented at both disposal tracts mentioned specifically on page 4-52. Descriptions of additional disposal tracts (3,890 acres) should be made available for review. Potential habitat for endangered plant species should be surveyed before oil and gas or mineral resource development occurs and avoidance stipulations applied to known populations. Threatened or endangered species 1n livestock or ORV areas should also be monitored to assess grazing impacts and loss due to ORV use or collecting. In particular, the document should discuss how development of the North Delta ORV use area will Impact critical habitat for the Uinta 8as1n hookless cactus and potential habitat of clay-loving wild buckwheat and Delta lomatlum. Management practices should be Implemented which enhance habitats for special Interest species which have been historically Impacted by agricultural development in the Frultland Mesa area, such as sage grouse. The Division of Wildlife will assist 1n Identifying such management practices. We appreciate the opportunity to review your draft management plan and look forward to continued cooperation with BLH as decisions Implementing these plans are made. STATE OF COLORADO COLORADO NATURAL AREAS PROGRAM r Colorado 80J0J ^> v/^A/^H) DENNIS W. DONALD Acting Executive Director DWD:nsh:7753 State Agency Reviewers 103 December 23, 1987 Mr. Gene Vecchla >M Bureau of Land Management ^Zttwi 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Gene: I want to correct and clarify the comments submitted by the Colorado Department of Natural Resources in the November 5, 1987 letter for the Colorado Natural Areas Program on the draft Uncompahgre Resource Area Management Plan and Environmental Impact Statement. Information contained in the special management areas section on page 3, paragraph 3 1s erroneous -- legal descriptions are wrong and the specific reference to Wells Gulch should be deleted. The first paragraph In the special management areas section should read as follows: The EIS should Indicate that a systematic survey for relict or remnant plant communities has not been conducted in the Uncompahgre Resource Area. A number of areas, including several riparian sites, may qualify for future special management consideration. The Colorado Natural Areas Program will work with BLH to Identify and evaluate appropriately qualified vegetation sites for special management. I hope that this clarifies any confusion concerning our recom- mendations. I apologize for sending you Incorrect Information. Please call me 1f you have any questions on our revised recommendations. Best wishes for the new year. Director Colorado Natural Areas Program DWK:dat:8441 COLORADO NATURAL AREAS COUNCIL 04 |OHN R. KAPPA Attorney a! Law P 0 8o» 790 Montrose, CO 8)40? (303)249 4631 10 November ^ , 1Q87 Mr. Robert IS. Vecchia BMP Team Leader Bureau of Land Management Uncompahgre Basin Resource Area 2505 3. Townsend Avenue Montrose, CO 8l401 RE: Draft Uncompahgre Basin RMP/EIS and WTS 54 71 Gentlemen: The City of Delta hereby submits the following comments concerning the draft RMP/EIS and WTS for the Uncompahgre Basin Planning Area. 1. Generally the documents fall to adequately Identify and discuss the development of hydro power resources on the Gunnison River and In the Gunnison Gorge as a specific resource or planning issue. 2. The description in the discussion of the Gunnison Gorge WSA on page 2-20 Is devoid of any analysis of potential power projects. 3. The Wilderness Technical Supplement Is totally Inadequate and inaccurate concerning its analysis of hydro electric projects within the Gunnison Gorge by making the following unsubstantiated and erroneous assumptions. A. Economic feasibility of these hydro projects is low. B. The projects will not be developed. C. The Impact due to precluding development Is negligible. D. If the projects are developed, positive impacts will be negligible . ft. The failure to analyze the social and economic impacts of wilderness designation is erroneous. Preclusion of hydro power and water projects will have a dramatic adverse economic effect. DEL 2/15 71 Mr. Robert Vecchia Page 2 November i) , 1987 5- The discussion of City of Delta water rights decrees on the Gunnison in the Gorge on pages 3-15 and f-lfi of the WTS is incomplete because It does not recognize that the City's decree is also for consumptive uses for municipal and Industrial purposes. 6. The discussion on page 3-16 of the WTS concerning the alternative proposals for development Is misleading. Such proposals are being considered in consideration with the legislation to create a Black Canyon National Park and Wild and Scenic River. Under the Wild and Scenic Rivers Act, the City of Delta is entitled to Just compensation for what amounts to a taking of Its water rights. The City has been willing to discuss alternatives to development of Its project In the context of the Black Canyon National Park proposal because It recognizes that other benefits will accrue to the City from that proposal. The amount of water proposed to be traded to the City as compensation clearly demonstrates (understated as it is) the considerable value of the City's water rights. 7. The conclusion on page ft-12 of the WTS that the impact of not being able to develop hydro electric power projects is negligible is totally erroneous for the following reasons: A. Notwithstanding the exception for presidential action, wilderness designation will preclude any possibility of developing the projects. B. Wilderness designation will make it virtually impossible for the City of Delta to perform the necessary due diligence work in order to keep its conditional rights in the Gorge. This will result in substantial detrimental economic effects. C. The City of Delta will lose the many thousands of dollars it has Invested already In these water rights and will lose the potential benefits from the eventual development of its project. D. The conditional water rights in and of themselves are very valuable. Loss of these rights will allow projects such as the City of Aurora's Transmountaln Diversion Project to obtain decrees for unappropriated water which otherwise may not be available. This will result in all of the very substantial Impacts related to such a transmountaln diversion project. DEL 2/15 10 11 71 10 Mr. Robert Vecchia Page 3 November H, 19*7 E. Such conditional rights have value to developers of water rights who might want to develop other projects but need to promote the priority of their rights by purchasing rights such as the City of Delta and thereafter abandoning them to the stream or transferring them. Such value Is eliminated by the Wilderness proposals. 8. The documents also Ignore the fact that development of hydro electric power would not carry with it many of the adverse environmental effects associated with coal or nuclear power. Robert E. Vecchia, RMP Team Leader BLM, Uncompahgre Basin Resource Area 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia, Very truly yours, CITY DELTA JRK/vl DEL 2/15 13 68 136 67 3 102 30 The Montrose District Advisory Council submits the following two resolutions (as adopted October 29, 1987) for your consideration in the RMP process. RESOLUTION 1; The BLH should recommend that the Gunnison Gorge be nade a Wilderness Area to be administered by the BLM. RESOLUTION 2: The BLM should adopt the preferred alternative after reviewing and resolving the following issues: A. The plan should identify specific management measures for riparian areas, and should better define riparian zones. B. Camelbaek and Adobe Badlands VSAs should be reconsidered to wilderness recommendations. C. More attention should be focused on managing future increases in off-road vehicle use. D. The RMP should identify trade-offs and show economic data dealing with land and water management proposals. [ Study areas {natural, undisturbed ecosystems) should be established. The location of the proposed right-of-way corridor should be given a closer look. Sincerely, V, - JO*** | Clay V/Bader, Chairman Montrose District Advisory Council 65 12 13 601 Conyon Boulder, Colorado 60302 303'449'5595 121 (Su^J- ^yu^rUr^ (Lot, /rU~«^ w^2^ 13 68 136 I feel that the DLH needs to reconsider their recommendations that the Camel Back and Adobe Badlands as a non- wilderness area. Thank You 68 136 SIERRA CLUB SOUTHWEST OFFICE September 17,1987 Gene vecchia RMP Team Leader Bureau of Lanr Management 2505 S. Towns^nd five. Montrose, CO 81401 Dear Mr. Vecchia, 1 have read your wilderness recommendations for three desert roadless area which is contained in your draft Uncompahgre Basin Resource Management Plan. I would like to thank you for recommending all 21,038 acres of the Gunnison Gorge Wilderness Study Area for Wilderness protection. This will help increase the chances of the Gunnison River to be considered as a Wild River under the Wild and Scenic Rivers act. Because this area will be protected as a wilderness, thousands of visitors will still be able to enjoy the beauty and the recreational benefits of this area in the future. I do feel that the BLM needs to reconsider recommendations for Camel Back and Adobe Badlands as a wilderness. I do not understand the BLM's approach to their ideas ofmanaoement of a shrinking resource such as wilderness. Camel Back and Adobe Badlands are just a few of the potential wildernesses left on the plateau. According to BLM's reports, there are absolutely no resource conflicts with wilderness designation in these areas. In Camel Back, BLM has mentioned that there are no timber or mineral conflicts. There are four dry oil and gas wells which has bean drilled nearby Adobe Badlands, which indicates a low potential for minerals. Both areas contain many species of plants and animals which are considered endangered under old mangement. There is no telling how many more species will become endangered in the near future if nothing is done to protect them. 14 . * hi //statute? John Bradley jf Internship * Southwest Office 136 66 s^v. ^ mi (\mP Team Ve.c.6er rncnVro* , Co %-^c\ Ob X LuiW \x urcibV \o cAW^ ^W coiQ\zm\x~ p^Vh Y\eor\r>a ce.qo.cci>nc> uA&r- Urn cocY-iocx^qa. ^bin (Vbouote. Or*ona c^rnnV OorVuruVj Vo CCrrim^V On VK oWn • FirbV X_X- \M<. fe VYmW \Vx o'V-nn ■for f^cocrvcntricvaci a\\ Q\oyi acnib cr P\ct & -fcr Ujv \cicroe. sO /rc^cVion^ &etcn tsy "1 ojaj\ci W ^3 rea^n^Y \Vx,\ C&maA (oc.l^ C^cu\ot c\t&w C&nu&^h a\b0 V> cVeS.c^ckc Cfo U-'AilTO«.Sfc. "\V^5 jA&W> uxx^\V Wki?V WUroA encWnemA ^Vn\ fe^aAs Ob u*\n ew Vc, comt WS^ ^W %> YV^ ^^ ^^ <~V HLbOjTC i. c ,ia^ CrtMfrvi"* 136 L 68 69 124 125 14 VtQ'pCn U>iu -VYu^ GrtC\ sVioA^kvA W ^d - on VYi*. SVorm Wnq &Hi arte, &hb i b \cMi Co\oracbG POcxnVa^ C\m.Vj Ccn^TLA-Vi on On Cm r ■fur Vna Loe^Vrn 'hXcot 15 THE COLORADO ARCHAEOLOGICAL SOCIETY 123 124 October 20, 1987 Gene Vecchia RMP Team Leader Bureau of Land Management 2505 S. Townsend Ave. Montrose, CO 81401 Dear Mr. Vecchia, I represent the Chipeta Chapter of the Colorado Archaeological Society, and presented verbal comments on the BLM's Draft RMP for the Uncompahgre Basin at the September 29, 1987 hearing in Montrose. 1 won't repeat verbatim what I said that evening since it is part of the official record, but would like to make additional comments on several key points. The members of the archaeological community in the Montrose area are extremely concerned about the current rate of destruction of:archaeological resources. The law enforcement approach to cultural resource management has limited value. Innovative approaches must be developed, and public education concerning cultural resource appreciation and preservation should receive high priority. The Draft RMP, Preferred Alternate takes the right, first step, but much more can be done. Some recommendations are listed below. 1) Conduct an intensive archaeological resource survey on BLM lands _ between Highway 90 and Roubideau Creek. 2) Publish a booklet that interprets the prehistory of the Uncompahgre Basin based on archaeological studies. done In the area, jhe booklet should be easy-to-read, well-illustrated, include reasoning for 15 resource preservation and be sold for a nominal fee to cover the cost of printing. 3) An interpretive prehistory display should be assembled with repre- sentative types of artifacts from the basin and include photographs, charts and resource preservation information. The display could be housed at the ute Museum, Montrose County Historical Museum or .other high-profile facility. 4) Develop presentation that could be shown to tourists, local civic groups and schools on archaeological topics. 5) Actively pursue mitigation of damaged archaeological sites. 6} Involve local groups interested in prehistoric and historic resources with the implementation of the above recommendations. 7) Patrol areas that contain high site densities and monitor site * damage and conditions. 8) Restrict ORV use in high site density areas to existing jeep roads and close jeep roads that aren't necessary. In conclusion, I would like to emphasize that the BLM has a timely oppurtunity to address the cultural resource management problem. Your decisions concerning the RMP will set the tone for future generations and hopefully preserve the unique cultural resources of the Uncompahgre Basin. Sincerely, 16 Colorado environmental coalition 2239 E. Collax Ave Denver CO 80206-1290 393-0J65 Robert E. Vecchia RMP Team Leader Bureau of Land Management Uncompahgre Basin Resource Area 2505 South Townsend Avenue Montrose, Colorado 81401 October 23, 1987 22 32 33 Dear Mr. Vecchia , I would like to make comments on behalf of the Colorado Environ- mental Coalition in regards to the Uncompahgre Basin Resource Management Plan. The Colorado Environmental Coalition was formed in 1965 to work for protection of Colorado's environment. The organization has 40 member groups with a combined membership of over 35,000 people. Overall, we found the plan to be very vague. It did not really quantify the impacts. The plan uses subjective terms, such as "substantial," "potentially improve," etc. instead of quantifed data. We view these subjective comments on impacts as being poorly conceived and we want actual numbers to allow the public to better understand the impacts. Coal One of the most disturbing aspects of the preferred alternative's coal leasing proposal is the area open to coal leasing. 83,334 acres are open to further leasing consideration. Under the current management alternative, which we would more readily support, the acreage open to coal leasing would be 20,737 acres. This is a much more realistic figure considering current and foreseeable market trends. This would also allow for better protection of the environmental quality of the North Fork Valley because the BLM could select the areas, which would be the least harmed by coal production, for further consideration. The Plan found only 569 acres of land out of the 83,396 acres in the coal planning units to be unsuitable for further leasing consideration using the unsuitability criteria. This is obvious- ly a very narrow interpretation of the unsuitability criteria. Substantial acreage in the North Fork drainage should be found unsuitable on the Scenic Areas criterion alone. Alluvial valley floors are also located in the coal leasing area. It would seem to be appropriate that the EIS devote a section or an appendix to the lands that have been eliminated from further consideration 67 16 119 under the unsuitability criteria, and explain the methodology used for determining unsuitability. This is one of the few RMPs where the reader is not provided with this basic information. A good example of where an area should have been found unsuitable under the Scenic Areas criterion is the higher elevations of the Adobe Badlands WSA. This badlands area is obivously one of the most scenic areas in the uncompahgre Basin Resource Area. A reevaluation of the unsuitability criteria obviously needs to occur in the Pinal EIS. The plan inadequately addresses multiple-use trade-offs. The only discussion of multiple-use trade-offs occurs on page 1-9, stating "These multiple-use trade-off determinations are made during the RMP-EIS process." It appears that the only multiple- use trade-offs made were by letting uses other than coal produc- tion occur on lands that did not contain producable coal re- serves. An example of a BLM Resource Management plan that did examine multiple-use trade-offs is the North Dakota RMP and EIS. We recommend that you take a close look at this document when preparing the final EIS. The Federal Coal Management Program EIS of 1979 also requires that thresholds be established on impacts to a variety of other- resources. Since this concept was not superceded by anything in the 1984 Supplement to the EIS, it is still in effect. We maintain that the RMP must address thresholds particularly for wildlife and socioeconomic capabilities of the surrounding area. "The Secretarial Issue Document of 1986 requires that the RMP assess the coal development potential of the area. The reason that this should be covered in the RMP is so that leasing levels can be in line with demand levels. The Uncompahgre Basin RMP states on page 4-44 that "The possible leasing of up to 5, 730 million tons of coal would far exceed demand over the life of this plan as the 1985 coal production from Delta and Gunnison counties was 2.2 million tons and optimistic annual coal production forecasts for this area range from 4.5 to 7.35 million tons for the years 1990 to 2000. " The plan continues on page 4- 45 to state that "this [preferred] alternative is not anticipated to impact coal production levels over the life span of the plan." The Plan blatantly ignores the realistic coal development potential of the area, and needs to be reworked. The Secretarial Issue Document (1986) also requires the BLM to give "increased emphasis" to six criteria that other agencies, the OTA, and public interest groups wanted added to the 20 un- suitability criteria. Among these other criteria are effects coal mining will have on wetlands/riparian habitat, sole-source aquifers, lands adjacent to Class I air quality areas, 16 adequate criteria for determining tract disposal. The Grand Junction RMP included 17 criteria which would automatically warrant retention of the tract. The criteria are as follows: 1. Wilderness areas and wilderness study areas 2. National conservation areas 3. Wild and scenic rivers and wild and scenic study rivers 4. National or historic trails 5. Natural or research natural areas 6. Designated areas of cultural or natural history 7. Designated areas of critical environmental concern 8. Designated wild horse preserves 9. Other congressionally designated areas 10. Threatened or endangered species habitat areas 11. Riparian habitat areas 12. Valuable recreation areas 13. Wetland Areas as defined in Executive Order 11990 5/77 14. Flood plain areas (100 year) as defined in Executive Order 11988 5/24/77 15. Large blocks of land that are suitable for multiple use management 16. Lands containing water sources with valid existing water rights held by the BLM 17. Critical big game winter range There are also criteria for areas with high mineral potential. We maintain that the criteria used in the Grand Junction RMP is much more useful and thorough than the 5 criteria used in the Uncompahgre RMP presented on page 1-6. Changes in Management prescriptions We recommend the following changes in the mandates for the pre- ferred management prescriptions, in addition to the comments made through the rest of the letter: The D-6 management prescriptior should include a recommendation to acquire land in Red Canyon in order to have a more logical and ecologically sound boundary for the proposed Gunnison Gorge wilderness Area. We commend the BLM on realizing the significance of the Riparian areas within the Resource Area, but feel the agency has not gone far enough in insuring the protection of riparian areas in the plan. The D-9 prescription needs to allow the agency to imple- ment a policy which will improve the quality and vitality of ri- f~parian areas. We support stricter limits for livestock use in these fragile areas, since livestock is probably the single greatest cause of deterioration of riparian habitat. The Plan, 16 45 69 28 nd buffer 2ones around National Park Service these criteria were examined thoroughly in the the plan only briefly mentions riparian areas and ing statement in regards to aquifers on page 4- of coal and loca table minerals could result in d irreversible loss of ground water though diver- nce," which we find totally unacceptable. Ba- needs to conduct not only a much more thorough to these six criteria, but also into the entire ement program in the Resource Area. 47 85 reclaimability a; areas. None of Plan. In fact, makes the follow 63, "The mining the permanent an< sion and subside sically, the BLM investigation federal coal man Oil and Gas "The section on oil and gas impacts is inadequate. The court case of Connors v. Burford states "comprehensive analysis of cumula- tive impacts on several oil and gas activities must be done before a single activity can proceed." The Preferred Alternative of the Plan dedicates only seven paragraphs to the impacts of oil and gas leasing and only one of those paragraphs deals with cumulative impacts. No leasing was recommended only for the Gunnison Gorge, an area recommended for Wilderness. No Surface Occupancy was recommended for the Needle Rock Outstanding Natural Area. It appears that the BLM has chosen to ignore its legal mandate under Connors v. Burford. Another section of judge's decision is applicable here, stating that federal agencies "have intiated a pattern of procrastination, not examination of envi- ronmental concerns." The BLM is capable of doing an adequate job of assessing impacts, so why not do it? The Plan should also mandate that all ACECs and other natural areas receive for a minimum No Surface Occupancy stipulations. Tract Disposal The BLM has not outlined sufficient criteria for determining tracts available for disposal. This can be seen through some of the tracts slated for disposal such as the West Dallas Creek tract (T.44 N. R. i W. Sections 4 fi 9). This area receives heavy recreational use and is located on a county highway. The tract is located on one of the main access points to the Mt. Sneffels Wilderness Area, and obviously should be slated for retention. Another poor selection as a disposal tract is the Baldy Peak Area (T.45 N. R. 8 W. Section 36). Baldy Peak is a former Wilderness Study Area, which has the potential to be a future addition to the Big Blue Wilderness Area. The Muddy Creek tracts above Paonia Reservoir also have heavy recreational use. The tract provides important public access points along Colorado Highway 133. Obviously, the Uncompahgre Basin Resource Area has not devised 16 however , must address the site specific impacts of coal develop- ment on riparian and aquatic areas as required in the Secretarial Issue Document (1986). Mineral development can also have signi- ficant impact of riparian areas , thus this mineral development ( including oil and gas as well as coal ) should be minimized. We oppose the ski area proposed for Storm King Mountain under the D-10 management prescription. The D-10 area should be managed for elk habitat, and timber harvesting should be prohibited. Storm King is not only fantastic elk habitat, it is also an important scenic vista for much of the upper Uncompahgre Valley. The natural character of the area should also be maintained for this reason. We have serious concerns for the resource uses which would be permitted in the D-12 and D-13 management prescriptions. Escalante Canyon is being recommended for an Area of Critical Environmental Concern and Fairview is being recommended for a Research Natural Area because of their outstanding biological characteristics. It is amazing that the BLM realizes the signi- ficance of these areas, but allows potentially destructive ac- tivities to these lifeforms to occur in the areas. The BLM should prohibit grazing in all ACECs, RNAs , and ONAs. Livestock have the ability of destroying the rare plants that are found in these areas. A Mineral withdrawl should also be placed on the areas to prevent potentially destructive mining and the possible converting of important lands to private lands using the claim and patent system. A No Surface Occupancy stipulation should placed on all oil and gas leases which may cover the area to _protect the areas from damage due to oil and gas development. The BLM should also strictly control recreation especially in the Escalante Canyon ACEC. Camping and bathing should be banned. Uncontrolled recreational use can also damage the endangered plant species. WilderLess The Colorado Environmental Coalition supports the designation of the Camelback, Adobe Badlands and Gunnison Gorge as wilderness. All three areas easily quali f y for Wilderness protection and are deserving of designation. Gunnison Gorge The Gunnison Gorge is one of the premiere primitive recreational areas in the state. The area receives substantial boating , hiking and fishing use. Gunnison Gorge is immediately downstream from the Black Canyon of the Gunnison National Monument ' s Wilder- ness area , and would make an excellent addition to this area. 68 16 68 The Gunnison River has also been recommended for Wild River designation under the Wild and Scenic Rivers Act through the Gorge. The Gunnison Gorge is obviously one of the highest candi- dates for wilderness protection in the state of Colorado. Adobe Badlands These Mancos Shale badlands, located just a few miles Delta, are among of the most scenic places in the res The badlands provide excellent vistas and are habitat endangered Uinta Basin bookless cactus. Since four o wells have been drilled near Adobe Badlands and all h dry, the area also has low oil and gas development po Other conflicts with wilderness designation are also BLM states m the plan that it intends to prohibit of vehicle use in the area. If designated as wilderness Badlands would diversify Delta's recreational opportu improve its tourist economy. The BLM does not really rationale for not recommending the Adobe Badlands for _and needs to reevaluate this decision. Camelback north of ource area. for the il and gas ave been tential. low. The road Adobe ities and have a wilderness , 136 Camelback has absolutely no conflicts to Wilderness designation Wilderness designation would be compatible with the current management of the area. The Dncompahgre plateau is one of the major landforms of western Colorado, but not one acre of it has been designated Wilderness. Although officials of the BLM have often claimed that Dominguez Canyon proposed wilderness to the north of Camelback is almost identical to Camelback, we have found the areas to be quite different. Camelback has a much greater diversity of rock formations that are not present in Dominguez Canyon, making the areas look much different Camelback contains habitat for the endangered spineless hedgehog cactus and the rare Grand Junction milkvetch. The area is being considered for desert bighorn sheep ^introduction and for im- provement of its riparian habitat in this plan. Both of these 67 its recommendation of Camelback and should support the area for Wilderness designation. ORV Use The BLM has not effectively dealt with Off Road Vehicle (ORV) use in the plan. The prospect of having 82* of the resource area open to uncontrolled ORV use is frightening. We support substan- 17 1 860 Lincoln Street, Suite 404 • Denver, Colorado 80295 303/860-0099 October 29, 1987 Mr. Robert Vecchia RHP Team Leader Uncompahgre Basin Resource Area Bureau of Land Management 2502 South Townsend Avenue Montrose, CO 81401: Dear Mr. Vecchia: Hlt.V'nfV.r M "le,?0c^ M™tam 011 and Gas Association (RM0GA), I would Ike to offer the following comments on the Draft Uncompahore Basin [,,» Management Plan (RMP) and Environmental Impact Statement EISIRMOGA Is f of? ann"^1"10," "I*.* h"nar"" °f members "'° ««OU»TfoV more 'than 90 Of the oil and gas exploration, production and transportation activities 1n the Rnrkv dBt.™i„. Wwf;h C?"hSequent,^ Ke review all draft plans ntniwegton^ resource!. ey Pr°V'de e<"j1tab,e and reasonable treatment of mineral Drafter, J 1rV° UT? the BLM on 1ts Proration of a clear, concise 2rLr..lf™ WE be,,eve the p,an « proposed represents a balanced SJfS h » management planning which adheres to the multiple-use concept "ZM.SJ"™*!! P° Hy- »<>™™<: '"« BLM's decisions are readily displayed and are easily understood by the reader. The use of oil and gas simulations rn protect other resource values appears to be reason b?e Unbiased and no? designed to unduly constrain oil and gas activities In favor of other values. We are disturbed by the lack of Information displayed In the DEIS reoardlnn oil and gas activities. We believe that in order to have a totalis defensible 2L1 aas activities are conducted on public lands. Specif leal lv the e Lnln^9"1"10^ "^ 1ndustr' and the BLM ™!t comply with ega'rd easing exploration and production activities should be generally discussed 1 the document Itself, or In an appendix. Such discussion Informs the pub c ZJZV] K?d.9iS act1vnies are allowed to occur on public lands, an the process by which such activities are mitigated and approved. 67 27 94 104 IS tial reductions in the amounts of land, where ORV use would be permitted. It is especially disturbing to see the D-8 management prescription (geared to ORV use) being located in habitat for the endangered Uinta Basin hookless cactus. This is obviously in violation of the Endangered Species Act. The plan admits that ORV use will have substantial adverse impact on soils, water, and vegetation. Much greater restraints must be implemented for ORV use. Utility Corridors Although existing utility corridors were described in the plan (p. 2-24), no information was provided on where new utility corridors would be permitted. We support delineation of where ultility corridors would be permitted. Restriction should be placed on all wilderness Study Areas, Outstanding Natural Areas, Research Natural Areas, and Areas of critical Environmental Con- cern prohibiting utility corridors. Threatened and Endangered Species It appears from the lack of information in the plan that the BLM has not conducted a survey of its lands to identify areas which contain threatened and endangered species. The BLM should in- clude in the plan a mandate for conducting a study for not only threatened and endangered species habitat but also to identify Remnant plant communities. Provisions should be made to amend the plan when this information has been collected. We appreciate this opportunity to comment on the plan, and hope that the agency will be responsive to our suggestions. Dramatic changes need to occur in order to make this plan acceptable. Kirk Koepsel Public Lands Coordinator 17 October 29, 1987 Mr. Robert Vecchfa RMP Team Leader Uncompahgre Basin Resource Area Bureau of Land Management page two In conclusion, RMOGA supports the Preferred Alternative as proposed by the *"*,!r; ™ b.e'?",,t ,sHcr,t'«> «>r the BLM to adopt our rec™endat n trtuit .!. .«*!! <"scuss1on of what takes place during oil and gas activities, and the procedures by which these activities are allowed to occur. We appreciate the opportunity to provide our comments, if you have anv Se"tateSto°rcontact"s: " """" "" ^^ '" «""" dSta" ' ?"»•"' S Sincerely, Jess Cooper * Executive Vice Presldt 69 ^fVlEC 43 56 MINERALS EXPLORATION COALITION In PvDI'C Policy Mailing Address Box 195 757 South Xenon CouH Lokowood. Colorado B02. (303J 232-J3J0 18 Lane 1*000. Colorado LC LN Washington flep'fi sen It livr L. Courilund Loo MM WesrSMut tanOoter, Maryland 20?&5 (301) 322-5762 October 29, 1987 Robert E. VeccMa RMP Team Leader Bureau of Land Management Uncompahgre Basin Resource Area 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia: The following comments constitute the response of the Minerals Exploration Coalition (MEC) to the Uncompahgre Basin Resource Management Plan and Draft Environmental Impact Statement (DEIS). The MEC represents companies and individuals engaged in exploration for locatable minerals on the federal lands. The MEC supports the management goals of multiple use, giving consideration to all renewable and nonrenewable resources, including minerals. We do not believe that sufficient minerals data has been collected or weight given to mineral resources to allow fair consideration of minerals in the management plan. Without a complete set of data on the mineral re- sources showing the location and extent of past and current mineral pro- duction and potential for future exploration and production, the importance of these minerals to the citizens of Colorado and the United States cannot be recognized . While the areas of past mineral production and areas with potential for future production are mentioned in a general way on pages 2-3 and 2-4 a map showing location and extent of these areas was not prepared. No rating of the mineral potential Is shown for areas outt.Lde the WSAs. Within the WSAs, maps showing the location of the areas rated is lacking. The absence of mineral data in comparison with the data on other resources is particularly evident when one considers the economic data shown in Table F-l, Appendix F, page A-19. This table shows that , except for government, minerals provide the largest source of personal income to the citizens of the region. Detailed information for some resources is included in the appendix but not for minerals. How can the largest source of non-government income be omitted? The Minerals Exploration Coalition opposes the inclusion of areas of high and moderate mineral potential in wilderness areas because the opportunity to explore for and produce minerals is prohibited in wilderness areas, except where prior existing rights can be shown. The boundaries of the wilderness Study areas that include moderate of high mineral potential should be changed to exclude the mineralized areas or the WSA should not be recommended for wilderness designation. Page 2 October 29, 1987 BLM IS 56 43 The Ceology, Energy and Minerals (GEM) reports are cited as the basis for the determinations of mineral potential in the WSAs in the wilderness supplement. No reference is made to the required mineral surveys conducted by the U. S. Geological Survey and U. S. Bureau of Mines. The USGS-USBM minerals information should be available before wilderness decisions are made. To show that mineral activities will be allowed on most (generally in ex- cess of 90 percent) of the land, thereby implying that most of the miner- alized land will open, is misleading when considering the lands to be with- drawn under the various alternatives. Minerals are unevenly distributed, therefore, without specific information on the location of the minerals one cannot determine the impact on the mineral industry of these proposed withdrawals. Ue have not made a select of our preferred alternative because without adequate minerals we cannot make an intelligent choice. Thank you for the opportunity to comment on this plan. Sincerely, John D. Wells, President ^ 68 136 137 19 19 tu AUDueoN socioVy^WjT Of Western \_o\o-rodo *| 4\ Robert E. Vecchld RMP Team Leader Bureau of Land Management 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Sir: The Audubon Society of Western Colorado appreciates the opportunity to comment on the Uncompahgre Basin RMP and EIS. We offer the following comments and suggestions: 1 . We Del i eve the conservation alternative rather than the preferred alternative would better serve the national interest in almost every detail. We applaud your decisions which incorporate elements of the conservation alternative into the preferred alternative. 2. The conservat ion alternative recommends a wi 1 derness cesi gnat ion for the Adobe Badland WSA and for the Camel Back WSA. but the preferred alternative does not include this recommendation. We believe this omission is a mistake. We support any action which will enhance the preservation of wilderness values, as this designation would. The economic advantages gained by not designating these areas as wilcerness are short-term and negligable in comparison. 3- If the Camel Back area is not to be aesignated as wilderness, eff-roao vehicle use in the area should be pronibited nevertheless. The EIS states that 0RV use would be the primary cause of decline in wilderness values unaer the preferred alternative. This alternative provides enough area for ORV use without allowing such use to destroy the wilderness value of the Camel Back WSA. 137 130 68 The preferred alternative also a:ms to "minimize di sturoance" in this area to enhance habitat for Introduction of bighorn sheep; allowing ORV use would cer ta i n I y hamper this goa I , Further . although the preferred alternative provides for bighorn habitat management, It fai Is to al locate forage for these animals. This fal lure could easily lead to the failure of the re- lntroduct 1 on . 4. The preferred alternative for the Came 1 Back area is confusing. The map for this alternative seems to label the area " D- 1 , " wh i ch " wou Id be managed to improve vegetat i on conditions and forage ava i 1 abi 1 i t y for 1 i vestock graz i ng. " The description of Management Unit D-l . under the sub-heading "Soils ana Water Resources." states that "non-conf 1 ict ino erosion control objectives, projects and mitigating measures would be incorporated." The " Compar ison of Alternatives" chart , however , states that the plan is to "manage the Came ! 3a ck area with emphasi s on r tpar i an/ aquat 1 c system managemen t, wildlife habitat anc livestock grazing." We hope that the real priority is that described in this chart (if a wilderness designation is not forthcoming). At any rate, the designation needs to be c i ar i f ied. 5. The preferred alternative takes the second-best approach to managi ng the Adobe Badl ands area north of De 1 ta . It is wise to put soil erosion control as the primary objective. Wilderness designation for the WSA within the area, however, would also meet that objective and would protect wilderness values as well, 6. The Wilderness Technical Supplement states that "the Proposed Action is based on an overall evaluation of wi 1 derness values, analysis of conflicts with other resources , consideration of soci a 1 and economl c factors, and consistency with other plans." None of these evaluations, ana 1 yses , or consi derat i or.s are di scussed in the RMP. It is impossible for the public to provide adequate input on RMP decisions when the bases for these decisions are unknown. An analysis of the alternatives, such as that prov ided i n the USFS RARE II EIS, would be most helpful. Because the Uncompahgre Basin pi an con tains no such analysis, it seems reasonabl e to request an amendment that i nc 1 udes thl S information and time for the public to respona to It. Si ncere 1 y yours , Richard Levad Conservation Committee Audubon Society of Western 70 ^Hlv Sierra Club 20 Cocky Mountain Chapter Utf Ccva p«.V\CN-, 8")Vcu Dtar SvV : TUt-ifLliA^i^ CpWi*^eL^ oia U^aW ou.aUt~ /Scnls /v~ipa.v-uaw\ <2tpc:ots criUi Uv\a»~paUa«- B'Tn.'H fi.nPo.KA £15 an. v^oJjl. o^ ItcraV? of 1W fc>eK Uo-».t*i'* ClAapTtr. TWi5 ^.v-Q.r+ 4°cu«e-^.t correcitw iwjiicaics tVt pav-ts, ot (%tf"£j "tW t^csott/ca. ^r«d-av<. pu>.aueal lou *v\»cLevati To Set/eve- Soi.l e.roiU>*: \eo.£^A \o asu^itaitnl c©w.t«T.t4«t|j)v, to saloM.+M ItUtU i* "ta. Upper Lo\Dtu-aJ> rai/cv- GaSmjflS uje[.l O.S Siji^e^t. ~\W JLouwe^t CoVvMotk shi-fc-i tWt" oJoo^t Wl'T Ai'M'm, aiissol^eat a.^ Sujp9v^oUc$. UwitCf poU.ut"a^ Li d.u* To Wu.>Ma* a^tii^itics p^t- icu.Ura ct*.c es j f*\*\\** t a*<£ O^l/itst.. TU/. foicaeJ} \^\pocfci> ©A uo.W Tisouvois 0T%-i. r^e-W^ &LW.\£ki/« also appte.»r-|-0 lae ca^ta Ai^ot Corve^a ItUouaW -^^ ^iscas\si«~» o^ t^t. v~\pftc£*. i ** tUi TcjcV KS 1<9-1 *a *MCaw£ c>«avO Tweets T*vCt" A"*. eSpeca^ltU i^wWi "Vd us a^€.'. p<2.^^t.ttcJl avuti^ £>ia ^9jDoo a.o-wv ot- UioUU. 2239 E. Colfax Avenue, Denver, CO 80206 303/321-8292 0 40 20 ltU.iw.wal5 i«r /Mie.«tJ2. e*|oWa-tlCM o»\ '^OODa.cKS of V.pavia^ ^at.+a.T One rtaio^, -£>•- V-^tsc- co^ctv^s w.L.WsltiUsuctattlu; Clea>\ i^itr ii p^oloaW^ (~itk +W. ooiSiLjlt cKcrptu^ ot loss, 1 iucU) ~tU*. v-*Ost ££o^o«£aL[ A/3 ac(L*e^«(.s affect U »lu of propW . tW £rS t>nje. "K< GL« 1b vWcWc -t< •folLus*'-. c^ l^'- 70 40 tf|[i>cw£&ui ot impacts. yL- fteco-^vSovlW pt^^.tWl S«io^ -ot-^se. -fir liixstock. Ltt.Utat-iuA CTT vipaM.aw "Bi^is a««i =<-=d!Jal-< o.i«,s 1^ ga«ivaJ2 . TV na^U TV-o-ik fVb. v^vsTfLdlo"^ VWii. /vol" O.Uoio Su^tle-d- Tviit -4.' Sail v«4„itnv-t_ ^Av>-t sW^uj^ iM" IcssTt^cvv lot Set! v^lhsIm^- 1.5 werrs^tw« l~o tick V**^C_ £JlA bvTt ti "^ Ma^ C-^v^t" >pav ia^ A^xi S^t.^fr), c.r«.a^ 5wi"W«AS , \o^t L-fj «.v-*Lo^L^ tpfj ^Ui. pej^atee-ct^-H^. o-e^« , pw-oUc- "t>at "t^-i pa^cw-lav- ^va&,'^ sl^s~Wi- •f Aploi,a^ c. tU. CR.TtsA^ ai^J, L/iaor- ot fl'ok^ douei^ «w)k cfgcvutW4. iw o^ «mtU uJ(ro«, C^>^a.*to~>. TV\t SLCl ^>^st *0-f u^,tv\e!va^ esisti^, ^^Jvau^ofi pr^cit^ stvra« c^^rt«ls a^iJ sUoolJi I'^.tiaVc ^,uj u-.TVc|tou«U Oeipitt A Ci^<^ EXi ess e^ '«!'»« ctcTlCLC^fctS lU t^<- U. pan a /e ^A fila* ■^"jO^t &.-S pect iW^t ca«. l^e ^fpUi^JwE c^pU^Sii av^^s' +0-T ^nvQa. WctW,W "<««l? Q-i" 20 T rooiOiJ^i "tUtJt rtKxioi^i.VlW wto„=,utv^3 ^a^^<_'btliC^^ Vi m lU*. *3LH 1~t> p-uttt't n j-DELTA \>><' — ^-County ^V^^^S^rL 1VEST0CK ** *-AsSOCIATION l^a**-^ -ta\ "Wv~ Upnf Cou^»i£^vatU"\ O f1k« ,p,«fc. iii.'^.rrvel i' 6 8^-> "Ta^tra Ljt-. 13S 111 131 68 131 66 c November k , 1987 ROBERT E. VECCHIA, RHP TEAM LEADER Bureau of Land Management Uncompahgre Basin Resource Area 2505 South Townsend Avenue Montrose, CO 81401 KROH: DELTA COUNTY LIVESTOCK ASSOCIATION John Botti, President R. 1 Box 14 Crawford, CO 81415 SUBJECT: UNCOMPAHGRE BASIN RESOURCE MANAGEMENT PLAN - COMMENTS The Delca County Livestock Association is in agreement that the Camel Back, the Adobe Badlands and the Gunnison Corge should continue to be managed as they now are by the BLM and prefer the no action alternative. The 10,402 acre Camel Back area should continue, as it now is, under mul- tiple use management. The area does not have the suitability for a Wilder- ness designation. The management plan now implemented is working well and the vegetation has already increased along the Roubideau River and Potter and Monitor Creeks. For several months each year these streams are dry. Damage by flash flood- ing governs plant growth along stream beds, not grazing by livestock. Be- cause of the terrain, this area is subject to several flash floods each Introducing big horn sheep into the area would only compete with the Jeer and elk now using these winter ranges. Private lands would be overrun by these animals needing forage in the winter. The 680 AUMs allocated for livestock grazing should remain unchanged. Neither is the Adobe Badlands suitable for Wilderness. All these natural resources should be utilized under multiple use and the 878 AUMs allocated to livestock grazing should remain the same. The Gunnison Gorge should also continue under multiple use. Proper manage- ment increases riparian habitat. The 662 AUMs currently allocated for livestock grazing should not change. One reason these lands are being suggested as Wilderness Areas is because the rancher appreciates the land and its value to the area. Thus they have properly utilized and managed them in cooperation with the BLM. 71 22 71 66 Sierra Club Rocky Mountain Chapter November 3, 1987 Gene Vecchia RMP Team Leader Bureau of Land Management Uncompahgre Basin Resource Area 2505 South Townsend five. Montrose, CD 81401 Dear Gene: Enclosed are comments for the Rocky Mountain Chapter of the Sierra Club on the Draft Uncompahgre Basin Resource Management Plan and EIS, and the accompanying Wilderness Technical Supplement (WTS) . The Sierra Club currently has over 8,300 members in Colorado, many of whom make recreational use of the public lands administered by BLM in the Uncompahgre Basin Resource Area. WILDERNESS The Sierra Club has several generic concerns with BUM'S analysis Df wilderness resources in the DEIS and UTS. A major concern appears on the very first page of the WTS (S-l) where BLM notes that "multiple- use management would continue" with non-wilderness designation of Camel Back WSA. Is BLM aware that wilderness, and the resources it protects, is a form of multiple use? Is BLM aware that the Wilderness Act itself (Section 4 Terri Martin Rocky Mountain Regional Representative National Parks and Conservation Associatio PO Box 1563, Salt Lake City, Utah 84110 601-532-4796 74 12 66 68 136 25 Adventures Ouray, Colorado 81427 ■ 1303) 3254640 68 136 Bureau Of Land Management Uncompahgre Resource Area At ten: Jon Searing and Staff After reading the first draft of the Resource Area Management Plan concerning the Gunnison Gorge, there are several points I feel should be reconsidered. We offer a safe, "resource aware" service to our customers as do other outfitters on the gorge. I feel very strongly about protecting the gorge and have written numerous letters endorsing "Wilderness and Wild And Scenic Designation". Below are the points that need to be re-examined: 1. In your Uncompahgre Basin Resource Management Plan and Enviromental Impact Statement "Prefered Alternative" Draft One , the BLM recommends that the Gunnison Gorge be designated "Wilderness Area". I support. thj# recommendation 100*, but I want Camel Back WSA and Adobe Badlands WSA included in 'the BLM recommendation to be designated "Wilderness Area". These two areas are ecologically unique and delicate to this area. Please make an enviromentally progressive and wise decision for Other federal agencies to follow. Recommend that Camel Back and Adobe Badlands are suitable for "Wilderness Designation". 2. I support, through whatever channels are nessary,for BLM staff in the field to have more power of enforcement, in order for private and commercial users to better adhere to BLM regulations. 3. I feel the BLM is making a regretable mistake by not automatically making fire- pans and porta-potty systems mandatory for all overnight horsepack and river trips. During the "67 season I noticed a marked increase in human waste in camping areas and numerous ground fire-rings. I would use firepans and porta-potties whether they were mandatory or not, but unfortunatly that isn't the prevailing attitude amoung some private users. Make firepans and porta-potties mandatory! A. Private and commercial launches should be split 50-50. That is 3 private launches and 3 commercial launches. Private boaters have every right to float a section On their own, provided they do so in a "low inpact" method. Commercial boaters equally have the right to launch availability. Commercial out- fitters, provided they operate "resource aware and responsible" trips provide a viable safe and low impact service. For customers who- want and have a right to experience the Gorge Area on a primative, pristine level/ outfitters provide the means. These outfitters provide a needed boost to many Western Colorado communities by bringing much needed tourism dollars to. west slope areas. 5. Include the season of '67 in consideration of this final draft towards your allo- cation plan for the Gunnison Gorge season of 19BB. As I wrote to you in a previous letter concerning just this matter, '87 was our first season as the true corporation. Putting People and Rivers Together 26 Robert E. Vecchia RHP Teajn Leader - BLM 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia, The following are my comments on the Uncompahgre Basin Wilderness Technical Supplement! I (do) fdo noO agree with the ELM '3 Proposed Action, the All Wilderness Alternative, for the Gunnison Gorge Wilderness Study Area. The Camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the No Wilderness Alternative. This alternative best exemplifies the multiple-use management. Site-specific objectives can be mitigated through the Allotment Management Plans. f& 25 12 Adventures Box 168 • Ouray, Colorado 81427 ■ (303) 325-1640 of Far Flung Adventures. We made a substancial investment in operating a business on the Gunnison.- Gorge, above and beyond Bureau Of Land Managements regulations and stipu lations for commercial outfitters. I'm speaking for other outfitters as well in this matter. 6. Trying to regulate use on the Gunnison Gorge by lengthening the hike from a parking area to the put-in on the river by a mile, or closing the trail to horsepack - ing is only "treating the symptom". A permit system for boaters is a viable method to regulate over-use on the gorge. We are anxious to work together with you on a management plan that can strike a balance between commercial/private use and maintain the integrity of this marvelous section of river. Yours for the river. -rtri Tracy Blashill Putting Peoph- and Rivers Together 86 27 Date 1 f&.f5-t7 Robert E. Vecchia RMP Team Leader -- BLM 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia, The following axe my comments concerning the Uncompahgre Basin Resource Management Plan and Environmental Impact Statement) "The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, is the 'Continuation of Current Management.' Under this policy, through Allotment Management plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation Interests can be met on a site-specific basis. 0&&r> TDock yfa^ m* ***** 75 66 68 136 113 P ,,,,/-.« a>^*Jl #$** 86 Robert E. Vecchia RMP Team Leader ■- BLM 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Rr. Vecchia, The following are my comments concerning the Uncompahgre Basin Resource Management Plan and Environmental Impact Statement 1 The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, Is the 'Continuation of Current Management.' Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation Interests can be met on a site-specific basis. 29 COLORADO WESTMORELAND INC. tt&fso^ t2T/^<~£~ fatt-' ■€i~,uC/i 6L'_ funic A-i,--. ./-'•"■■-■ *- *** ■ptiA^^c At****, -/—£ J<^<- yu-ui. <+--■■< Jin/*-y- "<- *Vm**SP„,£ ££t~*i-~* ,<*"-' s_3ic fu«Z?~i- ***& -**•«<- - < ■ir&.ur... si-*,.~*:( ' i<^Lt. i, jLt*^* ,-iA^^-i, co-Uxjs ici . a^y ai^" ^.'-■"' *« 7 '-*-^~ *' ci.r..-^ " y /<•..<• K./T^. Ci 30 MUSSER RANCHES 701 650F.8calente Delta. ColorsdoSMie Telephone: (303] 874-7372 October 30, l£i37 Robert -.. Vecchia, ;■:■" Tea^ Leader Bureau ef Land 'lanagtroent iineo.mjahfc.ss Pas in Resource Area 25^5 Jouth Townsend Vvenue, '■'ontrose, '" B140* fear ;%r. .'Sr:';hi.-i: raft '■n^omjan^re raait* : 'ana :<• .■-:-■. I l*r;/ rr.'/irsrxer.t&l rirjiBi ;taS8- :.en: k:^8-u to uiarsy nan ho.tr-- of rastareh and ao.-itiilatiDn -»f materials, Jt is vary irj'sreni thai this study has beer, imposed by -.aracas c-r sroi*;s who are no- really fasviliar with the work that haj been done zy t.'.s 1 ,:r ',..■ ; r;.'?- o;en siir.ia-j tg ?r*ss-Kt research aethods of range in:prcv3~.er.t, :ur family, for over s oer.tury, has been 3 jser cf part of the area that ihi-j st^y smokj a.;j*s, nnd, in fast, they were instrumental in helping set u; the 3114, The area with which we are beat, acquainted has improved a hundred fold since the BLM was implemented, and we feel it, would be an injustice to change many of the present managfnwct techniques that are showing great improvements, not only in grazing conditions, but raparian habitat, wildlife habitat, and recreation. The following are some of our c the Jnc onn. ahgre 3asin Draft age 4-7 Impacts from ,?ent i^ sentence; « aqaatic habitat would be maintained at less than opti^jDi conditions or would deteriorate over the long-ters due to trampling and excessive livestock utilization of streambani: vegetation." In area A-2 there is little if any evidence to prove this statement. "n3er present management, strea banks, aj well as all areas not adjacent to stream have improved considerably. Livestock grazing conditions are improving, wild life habitat is improving, riparian habitat is improving and I would recomment continjation of the present management jlan with cooperation between 3CW, rancners, and the FL." working together to further ixj.rove condition.';. y,Yi.k'-:z:~: ::::: >4 page 3-20 " •• liyaistccrt Erasing 'Uvsssocjs aove7ien-.3 vceli be restricted, if necesaary, to reduce trail leg and surface disturbance in riparian sones. Livestock ^.;e woi;15 be limited to^^S percent utilization by weight of key forage apeciei an; eliminated from Marcn 1 throu^.-. Vay jl," I.'^rcigh Holistic -ieso.:rce .\ana.jeiaent , it has been gra~_r,g -.rj*oughO'it the year improves riparian habitat, in tr.e Spring flourish and grow sore vi^orc^sly than th that livestock wa that are grazed at are not spring P.O. Box 1299 Paonia. Colorado 81428 HI 303-527-4135 November 2, 1987 Mr. Robert E. Vecchia, RMP Team Leader Bureau of Land Management Uncompahgre Resource Area 2505 South Townsend Avenue Montrose, CO 81401 R£r COMMENTS ON DRAFT UNCOMPAHGRE BASIN RESOURCE MANAGEMENT PLAN I ENVI RONKENTAL IMPACT STATEMENT Dea Mr. Vecchia Colorado Westmoreland Inc. (CWI) supports Che continuation of the 26 existing coal leases as proposed in each of the four alternatives presented in the Bureau of Land Management's Draft Uncompahgre Basin Resource Management Plan & Environ- mental Impact Statement. As CWI currently holds four federal coal leases con- tinuation of these existing leases is critical to CWl'a ongoing operation. Though local coal industries are presently suffering in depressed markets, in the long-term, coal markets are projected to improve . CWI also supports the identification of additional acreages of federal coal estate within the Uncom- pahgre Basin for future coal leasing as proposed in the "Production Alternative" and "Preferred Alternative". CWI appreciates this Opportunity to comment on the Draft Uncompahgre Basin Re- source Management Plan & Environmental Impact Statement. Please feel uee to contact me should you have questions. Sincerely, COLORADO WESTMORELAND INC. Kathleen G. Welt Environmental Specialist 30 grazed. We have evidenced this on our private land. For a aore stable habitat, a variety of jrazers is beneficial. Livestock tend to graze grasses xore than do g&ae ar.iaala. When grasses *re not grazed sufficiently, the old gra^ smother the plas; roots and the plants eventually die cut. iiru^i. then takes over, braaii alone cannot hold the stream banks as well as grasses, and mere erosion takes p'la an area that has 121 133 Tdiiis i3 very evident along t hid little or no livestock grazing for the past 50 years. Stream banks arc jer pendiCiJlar and adjacent areas that once were small meadow type lands axe now covered with brush that is too thick to be used by game animals. Instead they feed extensively in nearby irrigated pasture*, in the Little Ijominguez Tanyon, while it was grazed moderately, wild life found refuge and waa abundant. During the past few years the canyon has had --:.:.: or r.o js« by livestock. ?he brush has oescae so entangled it is almost impossible for the reoreat icnists to jet throjgh this sreek and there is IL:..-, ;. wildlife ■-.--■-. -...j..gL :■. i. -.sst by neither livestock nor r»c- reationiotj:. JMtera in the u.pper Ifscalante { nit "-IS} use the 3VA very ligr.'.ly, cut t-.ei— ranches that provide a great deal -ors excellsnt he EL! — ranch*3 that are used heavily by oeth dear : " limited to ;= percent, utilisation by weigh", of Key f era -f Tnic thrase arjaars fre-i.iently throughout tfea .^:-:-/^::;. How can i5 percent be deterrairjed when inadequate record3, or no records, have been kapt to ■"•nw what one nundred percent is. .-/h-it dpes this mean? Lues this mean for e or oz. £3 rp -3 n;'. iiv es 00 V, -9 ween the rip iriar hab han do and e k as we 11 a. li res ;eiiec" ent of the vegetation that wa^ in the area fifty years ago, five yearo ago, 0 efore tr.e start of the grazing season? Who is Soin,j to know what 100 percent as. To implement many of the ideas set forth in the R&, hugs amounti: of .oney will have to be allocated for monitoring and policing, ^heae ideas ertainly are not in seeping with reduction of government spending. «,. I SSf432®^ "'" D"12 r -^---^ VZ&ZXrVn page 3-40 26 -n* na-^gejent unit would be designated as the -Jscalante Canyon /urea of Triti: L^invir on-sent al ':oncern C A "-S "3 ; . livestock grazing is not mentioned. 106 aanajesaR'. ini; wculrl ns d9.>igr.at*d as the ■vte^ (ai'A).' This is the d».t* ar*i as 1ac _ uaje >i.. ?nd ptragra;:- H ;he iscalante ^ar.ycn sasearah Mat-iral gnflted ST£,", inireferrej -".iternat i/e. protect the listed plan unique pi'.--.-, aasoaialio ible to lives tnr.*. nr ohm >i and un;-;u'- plar.t 3Si'oci'ttioriO ii' abiiri. ~ra all located in rise that are jc'vlstely ini7-ces.s- Jildlife. Private lands ad lacent to the ';■;:."-,; have been^intensely grazed for nearly a century. However, there are hillsides wnere t.ie Jrand Junction nilkvetch is constantly increasing to the point of its over crowding other forbs and grasaea. Apparently livestock and wildlife find the plant unpalatable, or undesirable, but their trampling, as with so xany plant, help, to propagate the species. Jhftre is data indicating that livestock do not graze any of the listed plan: specie.;. 7ni3 is further illustrated oy the fact that, before the implement**. icn of the £:.:■:, the area was a natural drift for ^untold nusetn of livestack and therefore was extremely overgrazed. ■nder present management, vegetation, including many Species of native grasses and forbs, has been improved considerably. It is very evident, since the lifted plant species are preaen; in this area, they have a i trier neld their own or possibly have evslvtJ under -re-ient conditions. 76 30 67 132 114 [ At the same time, it is very evident that DSV use will have to be curtailed as there are several areas that have been denuded by QRV use and human trampling. In order for the ranches in the area to be efficient, livestock need to have at least a drift through this HSA* If ranches are not efficient, they will be sold for uses other than ranching, This will cut down on forage avaiable to the wildlife, and the increased use of the area for recreationists will cause further deterioration of the environment. In this canyon, wildlife is very much dependent on the irrigated ranches not only for food, but for the privacy that is necessary to sustain wildlife. The management of each allotment 3heuid be considered on an individual basis. 7or example, the riparian habitat (3-9 -referred Alternative) does not have the same qualities or problems at elevations above 7000 feet in some of the areas that occur below 5000 feet elevation in other areas. If ranchers axe forced to curtail their grazing use on the BLM, many of them will be forced out of their livestock operations. While this is exactly what many of the would-be environmentalists are pushing for, if the livestock operators are forced out of business, there will be deterioration of the ranges even for wild- life because livestock is an important and compatible part of the ecosystem. Contrary to popular opinion, 60/j of tne wildlife in the United Jtates, outside of Alaska, is very dependent upon private land. Cur public lands lack a vital supply of food, water, and the privacy needed for a desired wildlife population. For - continued improvement of range quality, we strongly urge the CONTIN- 3ATX0S "St THE FRE33»T MAHAG2KEI7T FLA." with emphasis on cooperation and under- standing between the affected parties — whether the areas of concern are air quality, grazing, wildlife habitat, or lining etc. Thank you for the opportunity to reply to the Draft RM/SIS. 3] Sincerely, h • z.uoser Ranches 71 61 Colorado - Lite ' Electric Association, Inc. Robert E. Vecchia RHP Team Leader United States Department of the Interior Bureau of Land Management Uncompahgre Basin Resource Area 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia: Draft Uncompahgre Basin Resource Management Plan Colorado-Ute Electric Association, Inc. is an electric gener- ation and transmission cooperative headquartered in Montrose, Colorado. It operates on a non-profit basis and provides whole- sale electric service on an "all-requirements" basis to 14 retail electric distribution cooperative members who serve 191,000 cus- tomers in parts or all of 48 of the state's 63 counties. Colorado- Ute owns electrical facilities, land and water rights in and near the BLM managed lands covered by the current draft Resource Manage- ment Plan. Colorado-Ute submits the following comments concerning the Draft Uncompahgre Basin Resource Management Plan and Environ- mental Impact Statement. Gunnison Gorge Wilderness Study Area (WSA) The impact to Colorado-Ute of wilderness designation for the Gunnison Gorge WSA would not be negligible as has been stated on page 4-12 of the Wilderness Technical Supplement (WTS) . The conditional water decrees (72,000 acre feet of conditional water rights) that Colorado-Ute owns on the Gunnison River are very valuable property rights. These decrees are senior to the entire Curecanti Project, including Blue Mesa Reservoir and are valued up to S7 million. If the Gunnison Gorge WSA is designated wilderness, the full potential value of Colorado-ute ' s water rights could not be realized. The Tri-County Reservoir right is decreed for three separate locations. The value of the original location, just downstream of the confluence with the North Fork, would be virtually eliminated. Two newer decreed locations further downstream would be restricted so that the full amount of decreed storage could not be realized. 71 61 58 31 31 Mr. Vecchia Mr. Vecchia November 4, 1987 30 30 The WTS also incorrectly describes the benefits and alterna- tives to Colorado-Ute's project. A reservoir constructed on the Gunnison River would provide Colorado-Ute benefits in addition to more generating capacity, which cannot be replaced by constructing coal-fired generation, as suggested on page 4-12 of the WTS. The operational flexibility of hydroelectric generation offers power system peaking and regulation benefits that cannot be obtained from coal-fired generation. In addition, a reservoir would provide a water supply for a downstream coal-fired generating station. It has been the consensus of the advisory committee studying the possible designation of a Black Canyon National Park and Scenic Recreation Area that the loss of that use of the water rights owned by Colorado-Ute and the City of Delta, and Colorado- Ute's associated hydroelectric project, should be mitigated. The final Uncompahgre Basin RMP and EIS should address how Colorado-Ute and others with development rights to be impacted, will be compensated for the water right development potential that would be lost as a result of wilderness designation. p— Colorado-Ute also has concerns resulting from the effect the Gunnison Gorge being designated as a wilderness area has on area economic development opportunities. One ramification is that once it is designated wilderness, there are those who would strive to have the area classified as a Class I area under the federal Clean Air Act. Such designation would severly restrict economic development opportunities for communit ies in the North Fork and Uncompahgre Valleys. This would be an unfortunate spin-off from a wilderness designation, where as, if the area were not designated wilderness, it could be managed to protect its scenic and other valued resources, and economic development opportunities would not be lost to communities in the surrounding area. Management Unit D-7 Colorado-Ute disagrees with the proposed management o£ major utilities in management unit D-7. A large geographic area {50,854 acres) is proposed to be closed to utility development to reduce conflicts between utilities and potential surface effects of coal mine subsidence. Colorado-Ute believes this action is unnecessary since the existing mines in the area are room and pillar opera- tions which typically cause little surface subsidence. If a trans- mission line were needed in this management unit, any potential subsidence problems could be addressed in the BLM permitting I process. We are also concerned about the potential public I opposition, due to visual concerns, in routing a line in the I proposed 0.5 mile wide corridor centered on Colorado Highway 133. The RMP should be flexible enough to allow consideration of other potential corridors during scoping and permitting of any future lines in that area. General Comments 95 The analysis of the impacts the RMP appears to have been heav Western Regional Corridor Study, old and is only a planning tool, service either on a local or regi rapidly. We do not agree with yo "Closure or restrictions on lands {in 1980 Western Regional Corrido would be assumed to have a neglig major utility development". The utility development is much more of major utility development in ily influenced by the 1980 This study is over seven years Projects requiring electric onal level can develop or change ur assumpt ion on page 4-58 not identified as being needed r Study) for utility facilities i ble impact on local and regional need for and predictability of dynamic than has been portrayed. 115 112 Colorado-Ute does not believe it is necessary or appropriate to prohibit siting transmission lines in riparian zones (See p. 4-51). In many of the narrow canyons in the area it would be possible to span the riparian zone or just trim the vegetation that would interfere with conductor clearance. Colorado-Ute does not believe utilities and their associated access are currently stressing or would stress wildlife in the North Fork area (See p. 4-53 Impacts on Terrestrial Wildlife Habitat). The benefits of confining utility facilities to existing corridors along major roads have been overstated. If necessary, gates or barriers can be used to restrict access to protect wildlife, and can be addressed as BLM permit conditions, when appropriate. Thank you for this opportunity to comment on the Draft Uncompahgre Basin Resource Managment Plan. Please contact me if you have quest ions concerning these comments. Very truly yours, Q(jJaM^^ Uerryf hi Walker, Manager ' Environmental Services JAW/MAR-.gr 77 32 Chevron U.S.A. Inc. 6400 South Fiddler s Green Circle, Englewood, CO 80111, P.O. Box 599, Denver, CO 80201 Litl Utitht Me.c.e. Sta'i Amivn LsgiilaTi.a mo Begulaiory AHjirj Mr, Robert Vecchia, RMP Team Leader Uncompahgre Basin Resource Area Bureau of Land Management 2505 S. Townsend Avenue Montrose, CO 8U0I Dear Mr. Vecchia: November 5, 1987 Draft EIS and Resource Management Plan Uncompahgre Basin Resource Area Pursuant to my phone conversation with you last week, please accept my comments on your draft EIS and RMP, even though you will have received them after November 5. As you recall, I had phoned your office for ten days and was not able to get through due to your phone number having been changed. On October 26, I finally wrote you a letter requesting a copy of the draft. In a subsequent phone conversation, you said that you would accept my comments as long as they were postmarked by November 5. Chevron commends your RMP team for preparing such a clean, understandable document. We believe that your decisions are justified and presented in a logical concise manner. We also support your preferred alternative. Under that alternative, your use of oil and gas stipulations seem reasonable, equitable, and unbiased. However, Chevron does have one suggestion that we believe would make your document more defensible. Possibly the appropriate place would be in Chapter 5, "Consultation and Coordination." We believe that it is important that the public be informed with a general description of the process involved when oil and gas activities are conducted on public lands. Specifically, it seems that it would be important to emphasize that the public will have future opportunities to comment on proposed oil and gas activities, and to give them a general idea of the procedures and regulations that industry and the BLM must comply _ with before we can lease or engage in exploratory or production activities. Thank you for your consideration of these comments. Sincerely, 33 i JERRY D. JACKA P. O SOX >Ln. uvt-t flvnJU- Dr. and Mrs. Prank Dennehy 3040A K VI RD. GRAND JUNCTION. COX* B1040 35 Uta.r Mr. sltct Is', S^kv-W- KNCH7 ^lu-aitls, eNcM ^^^"^'"'n Ctlev-ncit,'^ oictioov c^r'"ii. r\v-\c\ W'lYMi Hv-rvvx-V E «-.-.-^f-v-vv--v--J ^-Sl -vve v.o.IlVm,,^ Vjer-, cUicL VVva tk«.U«iAt <£ w«*-Ww Clur^e. U.c V** ««„ ^k ■kvt\o"i<-- v*.*,*J&5 6+ oyeT-At^«-lffpt>-i^"T ■ X c\vw .-Jr-i-tv-.^ To ^,3, r-t:Qevv-A\via Ik. U^tcf^vQ^.vC ^*.*T ^ m^c^^QA. M*.v\*«4mtM4: P }e T- ^ = u.ld like h> a*W \^o^. -U Jo voVi>H ^0k (^^ {^ ^* Ccvwv*.. T3..--V. *-«*. -C ^'"5^^ V+ ">-v Jj •tW 6 -A.v^V"N I 60 V V\ GlO-v"v* i? Vj~-",Uevv~t^i 6-NsA_ -1- v-j?^,n ^ ^aT,W BtH 4*- i-s^^', +U*« ^jWfc »,^ &* p-;|A<-r v>i-^ "iAjt>* (^ ^IcLtrrwLAC, e^cvC« av\C ^«-< 78 35 68 ^ AA.U &*aU<15 ? wK^ ^ 4, r^o'iv vi- v\=Ulv- hj -,s, itSi=m«i,4lf n tO««w Jt"-"7. T<-vj V" •* e* wis., is -tWi di^s^H. Viiis.-^. o. *»6- A^-"t>t--*'-"'i ^"Jni 0>" °- sh^ i»\\"ia Vi^-V 0>««-i l( »aV-WI_ u.v\ ru.tm:d \oviA. lit 's wtrt in*.A v|tk a s,Cv,v 4, L~i /L~X 68 136 59 die. *w-<-d w*tj i^Uc^^y^, if- ^fj^y ^^u^^^. <*L^_x ^x£i ■ KM--^L^jl.jCl^. -fee -^xt*/*/^-^*^. ■^^d^^.^JJ&jUs^ ■ ?z^ ^/?'<±&L ^L** <£Z~&<^-iP& , ^J/^z^e^ ******& *~y &^^ CHUCK SHEPARO 36995 HWY. 184 MANCOS, CO S1328 (303) 832-4743 CHUCK SHEPARD 36 36995 HWY. 184 MANCOS, CO 81328 /303) 882-4743 ^** ^2oty^i<-t^?t^.' - . ' cu~£a-£. 22, ^c «**• &~o co-e__ Uya^c gA^i-^-^J— CO-J—£6it*-^-l~~3 3ST 37 -^^ ^- //i^j 136 SS tit, tS-fft ftcch's* f-\s a Abn*'< £**— far* t£&*~ * -5/^-^ art htj*f JL-t-WtJ -^ "™* frtt-Jt fMsaj f^TTvif *<*.* 7%is~ .S-AV ttM*. th fir AtT#r Ja-J'/J&'Z fp *-*, < -/«.*7<>- ««M* — Kurt Johnson 747 12th St. Boulder, CO 80302 54959 Hickory Road Clathe, Colorado 81425 September 18, 1987 To: Robert E. Vecchia RMP Team Leader Bureau of Land Management 2505 South Townsend Avenue Montrose, Colorado 8H01 From: Dick Brown and family, Victor Reed and Rex A. Reed. 85 Subject: Proposed change in RMP, dated June, 1987. We have reviewed the June, 1987 Uncompahgre Resource Management Plan draft and would like the Bureau of Land Management to give consideration to the following lands for disposal. The BLK land we are interested in acquiring is not identified for disposal except for one 40 acre parcel. By proposing the following: land exchange for review in the URMP comment period, a later planning amendment can be prevented after the plan is completed. (See the attached maps). *he value cf the lands are approximately S75.00 to $100,00 per acre. Lands offered by the Brown family: I49N, R11 « KMPM Sec. 19 NEi SW*', Si SWi, nw$ SE^ -160 Acres Sec. 30 SEi SW i - 40 Acres TOTALS _ 200 Acres Lands selected by the Brown 'amily: T48N, R12W NMW Sec. 12 W£ NW£ - 80 Acres Nj SWi - 80 Acres Sec. 14 TGT&LS - 200 Acres 40 A c re s Lands T49N. „ Sec. 28 SW£ ffered by Victor and Rex Reed: 11W .NMPK. (The same for land selected) SW^ 40 acres 80 acres Sec. 29 NE? SEi - 40 acres Totals - 160 Acres 40 Lands selected by Victor and Rex Reed: Sec. 21 M SWi - 80 acres S{ NWJ - 80 acres TOTALS - 160 Acres The advantages of this proposed land exchange are as follows: 1. " The management unit would be managed to improve vegetation conditions and forage availability for livestock grazing." (Chapter 3, Page 31, UPMP). 2. "If they are available non-federal lands that would improve livestock management and increase crucial deer and elk winter range would be acquired through exchange only." (Chapter 3, Page 32, URNP) . 3. "Identification of public lands that are suitable for disposal and public lands that should be retained in public ownership; also, identification of non-federal lands that would best serve the public needs if in public ownership. " (Summary, Page 1, URMP). L. "The BLM actively acquires legal access as needs and opportunities arise. All forms of access acquisitions are considered including negotiated easements, cooperative right-of-way agreements and exchanges. " (Chapter 2, Page 24, URKP). 5, Boundaries will contain land in blocks for more efficient management. 6. Private inholdings would be acquired. 7; Exchange would give legal access to Cushman hesa. 6. Mineral rights held on the private lands owned by- Brown and Reed would be conveyed. Conclusion: For the above reasons we believe the proposed land exchange would be in the public interest. Attachments are available for review at the 3U-I office. Respectfully submitted, 2 %t*-c$-j ji 3X&L&., 41 68 136 69 41 w /' S • ^2^ &Jl»*j fcfl^wr^ JWr'V cQ" ■ 81 43 136 Gene Vecchia BLM 2505 5. Townsend Ave. Montrose, CO 81401 Dear Mr. Vecchia I am writing to ask BLM to be sure to include wilderness protection for the Camel Back area inasmuch as It is one of the most logical areas In the state to be so designated. With no real Justification for timber or mineral development, with a beautiful pristine canyon, and encompassing part of the unusual Uncompahgre Plateau not already badly scarred, It seems to be one area which should have been selected for wilderness protection without even any controversy. With the rapid disappearance of so many rare plant species and the fact that our state's wildlife herds are being further and further restricted in their habitat, I consider these additional reasons for your agency to reconsider the designation for Camel Back. Thank you for recommending Gunnison Gorge; If anything, Camel Back is more worthy of wilderness protection Nina Johnson 747 12th Boulder, CO 80302 44 Paul E. Lappala 486 Mesa Verde Carbondale. CO 81623 68 136 69 Seotember 17, 1967 Gene Vecchia RMP Team Leader Bureau of Land Management 2505 S. Townsend Avenue Montrose, CO flUtDl Dear Mr. Vecchia: we are writing to you In support of the BLM decision to recommend tne Gunnison Goroa far wilderness designation, Ue also want to go Dn record In support for the same recommendation in the caaes of the Camel Beck (RaubideBu Canyon) and the Adobe Badlands areas. From what ws have rBad, these areas seem to pose np problem in opposition ta wilderness designation, so why not7 In addition, we favor the preservation of the Storm King area for deer and elk calving grounds rether than a ski area. At least 1st the public be heard before permitting the 5-year grace period now being suggested. Sincerely yours, 45 *H£ FAIA/1 1660 S.Albion Sulte816 Denver, CO 80222 Claire C. Poole, Psy.D. Licensed Clinical Psychologist S^/rz-F? fit a. ^yi/^ur^- 6Vl^z. aAsuJ0U 'SSL,*-' *<•***?-*-** 6U^/»*^ (rCfte. l/e.c Ave.. loift-tv!.* CO ff/fO/ 45 Telephone: (303) 7B2-0252 ?S8-87 ._ \ 62 JS&f fit*. t&Miit*. : 68 136 69 82 (ssC&nSPJ**^ tr*v^«- U/S/9 ^Ct*> ^^- /^c«™,^w!t^*^ &*~l- OSVL. Cvrri/L*u?™^Uy d^L- iC*£&y , STtJv^ry, ^r^Jn^y ^>^/-2^ /lC^*~ jfr&j, „ ™r pee^fatJ. (?r^ &^ &>y <2-*- <4*J* ^r-JHse^. T>&*. a*p, uK^Ji«v, Xhr-yi LVJULi-lw^., tJu Mu^^^n,, MM. cQrjunsi&A**.^ ^-JxJt, u~JLJ KHf. a-cu-3 tXtjt skfr*S-£) aAio i"1 T^ 0-e Ct-i^P U~*M& ^hj /by^^^tM JL^^&^-AJUaJ? p$-&~Jt -^Jl fifi^cL^-, at yf* - u^M^^^i &*i4~y<«M-^ , 7/v CW*. A*-fl W -^-v^^w^-j^f C4rzjh*3t ffW***t J*V*ht *-t\UJ n-u^u-J1 pJLJ^.$ ttot*JL* , dUo+S Jo or v o~»s (^^JLfi-^ s £"1 , -W-M 'p 48 506? 5teu«boa(- 5f£ CO a»7T (tkaA/lvw.. 1/i/ccW. f/njn 68 136 69 l«J.Un*A ^(*f irU-di4 [^UM. MvtL Cue*, M Cdffladi (ju c3 ^A^ ^#i^ ■fe ^iUct H 'truJjuUnj^ Ca^yjt^i- lit. 44b OAoin b-aJUa-r^lQ. fon hu- cixJJ^^, -h it^ui un±L HLu* £Ui, Ituthj. Cm^-y^, AtiLty^ NjrtL U~ hcrr^ \pnA\-tr~ h£.C»#*j.b-a>* l<^ Cjmw^a. . PJU y/„ /%» c.u/J ^„ 0 ■ uX dA *«/ /^ LOTS fi Ttz predict 1*3» 0f , ' ^ ^^^ -A. 2>Drs «W tfgc ^ & W€*rf*r€$* fa ^k ***,*%* y& tSuvrntL. tj&rge slw/e/ be. fr*{-ec^d ^ a(l Oastf. l~P-&. Jv£s, ptn*^ (~£ SZu/ *rf* («, V/e Gfroe ne?r V/t C'"^ trwtr Cf$**t*& >A j i^**"/ \-l/er. Ser-touS Ctw.3ct/e'i ^tit C^ y^/T3 Cor, V 2 /So u>arr**rfeJ ■ IVi^er rm#*i ft'M V/si 3 Qefir^ w r*K n iMch/a 50 67 615 Wagon Trail Drive Grand JuncCion, CO 81503 Sepcember 21, 1987 Mr. Robert E. Vecchia RMP Team Leader Bureau of Land Management Uncompahgre Basin Resource Area 2505 South Townsend Avenue Montrose , Colorado 81401 Dear Mr. Vecchia: I have reviewed the BLM's Draft Uncompahgre Basin Resource Management Plan/Environmental Impact Statement (RMP/EIS) and have the following comments . I have compared the existing management plan alternative of lands available to off road vehicle (ORV) use and the BLM's Preferred Alternative acreages of lands available for ORV. The Draft RMP/EIS says there are currently some 444,521 acres available for ORV use and only 21,038 acres closed to that use. In BLM's Preferred Alternative there would be only 261,589 acres open to ORV use, 29,821 closed and 135,396 acres subject to seasonable closures to ORV use. As a winter and summer user of public lands, this amounts to a significant reduction in public lands open to public use. Consequently, I am strongly opposed to a BLM plan and preferred alternative which further limits, controls and/ or prevents the use of "public lands" for continued use by "the public." ""Consequently, I feel it is extremely important to prepare a detailed map and listing of roads and/or areas which would be closed or partially closed to use by ORV" s for review by the general public land ' s users . I am sure these folks will have some additional thoughts and comments on this issue . I appreciate the chance to comment on this Draft plan. An Interested Citizen, Larry Abbott 83 51 68 136 Dear Sir, I'd writing to you about your three desert wilderness recommendations. As I understand you've dropped The Caielback and Adobe Badlands. I sincerly hope that you would reconsider since these areas have unique geological and biological values Every day the value of preserving these areas becone apparant. So please reconsider, future generations will thank re vou Mr Gene vecchia 3mp Ti-arp deader Sureau of L2nd Management 2505 t Tcwnsend Ave lO^tfOW, CO 9 MO I ,e^2 iject: UncQfTfDSt Dear Mr Veccnia. ■ Basin Resource Maft»oem«nt Plan Sincerly yours , ^(W. Rodney McKinnon 7844A County tfl Montr ose , Colorado 81401 68 136 69 ■ 3m completely supportive of your decision to recommend all 21,038 acres of the Gunnison Gorge Wilderness 5tudy Area for wilderness protection Several important reasons exist in suooort of Gunnison Gorge wilderness The area Puffers Gunnison National Monument it contains 13 miles of a river whicn is now a gold medal trout fishery and someday will Pe a National Wild and jcenic River, The undeveloped, roadless lands of the Gunnison Gorge are themselves of great intrinsic value, more important than any other resources combined it is vital that every last acre of Colorado wilderness oe preserved. Thus l am greatly disappointed about BLM's non-wilderness recommendations for Camel Back and Adobe Badlands. No resource conflicts exist with the Came! Back canyons. You know this. There are no timoer or mineral conflicts, and planned cutbacks in grazing will protect the riparian of the perrenial RouPideau Creek, i have niKed this creek, and I attest to the great beauty and solitude of Camel Back I have visited Adobe Badlands Much of ft is reminiscent of Petrified Forest National Monument in northern Arizona. It shows a low potential for minerals, and is devoid of timber. These places are wild, Mr Vecchia, and I want BLM to reconsider. Please recommend the 10,402 acres of Camel Back and the 10,425 acres cf Acobe Badlands as wilderness. i am just as disappointed in BLM'S management position on Storm King Mountain, Why is it that, wner, there is a conflict between human economic expansion and large numbers of wild animals, the wild animals must go7 I do not want a sk i area anywhere near Storm King Mountain, and I object to BLM's five-year grace period in which the developers may proceed with the ski area l want BLM to manage Stonr King Mountain for elk. And mule deer. And nigh mountains And green forests. ance again, for the Gunnison Gorge nytjfcrten 50>T25U 12, Lahewood, CG 300 68 136 69 RMP Team Leader Bureau of Land Management 2505 5 Tgwnsind Ave Montrose, CO 81401 Suoject Uncompahgre Basin Resource Managemant Plan Dear Mr Vecchia i am completely supportive of your decision to recommend all 21,038 acres of the Gunnison Gorge Wilderness Study Area for wilderness protection. Several important reasons exist in support of Gunnison Gorge wilderness. The area puffers Gunnison National Monument. It contains 13 miles of a river whicn is now a gold medal trout fishery and someday will be a National Wild and Scenic River. The undevelooed, roadless lands of the Gunnison Gorge are themselves of great intrinsic value, more important than any otner resources combined It is vital that every last acre of Colorado wilderness be preserved. Thus I am greatly disappointed about BLM's non-wilderness recommendations for Camel Back and Adobe Badlands. No resource conflicts exist with the Camel Back canyons. You know this. There are no timber or mineral conflicts, and planned cutbacks in grazing will protect the riparian of the perrenial Roubideau Creek. I have hiked this creek, and ! attest to the great beauty and solitude of Camel Back I have visited Adobe Badlands. Much of it is reminiscent of Petrified Forest National Monument in northern Arizona, It shows a low potential for minerals, and is devoid of timber. These places are wild, Mr Vecchia, and I want BLM to reconsider. Please recommend the 1 0,402 acres of Camel Back and the 1 0,425 acres of Adobe Badlands as wilderness. I am just as disappointed in BLM's management position on Storm King Mountain Why is it that, when there is a conflict between human economic expansion and large numbers of wild animals, the wild animals must go? I do not want a ski area anywhere near Storm King Mountain, and ! object to BLM's five-year grace period in which the developers may proceed with the ski area I want BLM to manage Storm King Mountain for elk. And mule deer. And mqh mountains. And green forests Than*-: ycu, once again, for the Gunnison Gorge Jcnn CzarnecKi 520 3rentwood, Lakewood, CO 60215 53 54 68 136 69 Mr. Gene Yecchi 20 Sep 8? RMP Team Leader Bureau of Land Management 2505 3. Tovnsend Ave. Montrose. CO 81401 Subject: Uncompahgre Basin Resource Managemant Plan Dear Mr. Vecchia: I an completely supportive of your decision to recommend all 21.038 acres of the Gunnison Gorge Vilderne3s Study Area for vilderness protection. Several important reasons eiist in support of Gunnison Gorge wilderness. The area buffers Gunnison National Monument. It contains 13 miles of a river which is now a gold medal trout fishery and someday vill be a national ¥ild and Scenic River. The undeveloped, roadless lands of the Gunnison Gorge are themselves of great intrinsic value, more important than any other resources combined. It is vital that every last acre of Colorado vilderness be preserved. Thus I am greatly disappointed about BLM's non-vildernes3 recommendations for Camel Back and Adobe Badlands. No resource conflicts eiist with the Camel Back canyons. You know thi3. There are no timber or mineral conflicts, and planned cutbacks in grazing vill protect the riparian of the perrenial Roubideau Creek. I have hiked this creek, and I attest to the great beauty and solitude of Camel Back. I have visited Adobe Badlands. Much of it is reminiscent of Petrified Forest National Honument in northern Arizona. It sbovs a low potential for minerals, and is devoid of timber. These places are wild, Mr. Vecchia, and I want BLM to reconsider. Please recommend the 10,402 acres of Camel Back and the 10.425 acres of Adobe Badlands as vilderness. I am just as disappointed in BLM' s management position on Storm King Mountain, fhy is it that, when there is a conflict between human economic expansion and large numbers of wild animals, the wild animals mu3t go? I do not want a ski area anywhere near Storm King Mountain, and I object to BLM's five-year grace period in which the developers may proceed with the ski area. I want BLM to manage Storm King Mountain for elk. And mule deer. And high mountains. And green forests. Thank you, once again, for the Gunnison Gorge. Richard Kilwiry 3232 San Hateo HE St 33. Albucjuerque. HH 87110 84 55 136 P.C. BCX 675 Casc.rt*, CO 8030& 9-20-37 Cgn£ tftes'nlaj PJSP 7n*ra i-ead*r Bureau of Laud ktanatfement ££.05 3. lownsend *ve, Montrose, CO 61401 Dear jit. Veachia, I w»3 pleased to read that you have recommanaed the Gu*ni«o« Gorge n3>i for wilderness d9iig»atian; the mere I see of the western Slope semi-desert, eft's mere Interna ting it get. 3 . But don't let tfca lsr^e-scale thines iltie Gunnison Gorse distract you from thine-s cf ■ mere hum-in scale, li.■ so VXs-<0 Jon Tourville 58 niws si:itz li\ Mil .I.HAI.I- Mil, SAUX \. KVii7*01 68 136 Salina, Kansas September 24, 1987 Mr. Gene Vecchia RMP Team Leader Bureau of Land Management 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia: Thia letter is in regard to Gunnison Gorge, Camel Back, Adobe Badlands and Storm King aki area site. To begin, I would like to thank the Bureau of Land Management for its reccomendation of Gunnison Gorge for wilderness protection. Its natural features and its proximity to Gunnison National Monument make it emminently suitable for full protection, and the action should please thousands of those who do and will visit this area. However, I would also protest three other decision&recently made by BLM. I understand that Camel Back and Adobe Badlands have not been recommended for wilderness designation. Botn of these areas, according to BLM, have no resource conflicts: There is no timber, and drilling has yielded four dry oil and gas wells. Apparently grazing and CRV use are to be cut back or prohibited. But these measures will be only a partial solution. Camel Back is the site of several endangered plants species, as well as big game herds, and Adobe Badlands is a habitat of an endangered cactus. Both these areas have important wilderness characteristics, including a canyon containing colorful nandstone formations in Camel Back, end vistas of the San Juan Mountains and Uncompadre JRiJ-VBr valley in Adobe Badlands. We need more^irimple stop-gap measures to protect these wild places. 85 58 69 p. 2 The third action by BLM to which I object is a five-year "grace period" extended to developers of a ski site at Storm King. According to BLM itself, this area is a critical elk calving ground. In addition, development here would also have an adverse effect on mule deer fawning. By putting off action for five years while developers proceed with their plans is virtually to make a decision now in favor of the developers it would be many times more difficult to give elk and mule deer, as well as other wilderneoB values their full due with the developers' _intereBts «ntrenched by five years' investment and effort. These are public lands, and a decision as to their suitability for wilderness or other uses should be made now, before private uses are allowed to proceed. There must be a better way to assess "compatibility." Thank you for your time and consideration. Sincerely, Chris Seitz 124 South Hilldale Salina, Kansas 67401 59 68 136 9-2S-&7 yhZtr^X^-v ^7 , %*-&%^" Dr T Scott 1 639 Adrkl Dr Fi Collim Co 80524 136 68 69 September 23, 1987 60 support Gene Vecchia RMP Team Leader Bureau of Land Management 2505 S. Townscnd Ave. Montrose, CO 81401 Dear Mr. Vecchia; I am writing concerning three different areas you studied for Wilderness areas and a Ski area proposal. First of all, I would like to thank you for recommending the Gunnison Gorge Wilderness area for protection. The importance of this decision cannot be under-rated. This area contains 13 miles of the Gunnison River which has been up for recommendation as a Wild River under the Wild S. Scienic Act. The BLM has made a very positive decision that and hope they will continue to do in the future. Secondly, the CAmel Back area, which I believe should be recommended as a wilderness designation. There are not timber or mineral conflicts over this 10,402 arces of land. It also contains about 7 miles of perennial Roubideau Creek where it cuts through a 800 foot deep canyon of beatufil sandstone formations of the Uncompahgre Plateau. More important several endangered species of Plants and big herds who live in the area which would greatly benefit from a wilderness designation. I cannot understand why the BLM decidied NO on this proposal, please explain why they have made this decision. OUr state is expercining many problems with protection of our natural lands and animals, we have a great opportunity to insure the Colorado we know and keep the unquie attractions that people from all over come to see. The Third area is the Adobe Badlands which contains 10.42S acres of the Mancos Shale Badlands. They have tested for oil and gas and found no real mineral potential, and obvously there are no timber for cutting. Wehave an area that provides sweeping vistas in the San Juan Mountains and the Uncompahgre River Valley. It also contains the endangered Unita Basin hookless cactus which in itself is a real treasure. Again, this is an area which there is not alot of conflict over a wilderness designation. I an very confused by the BLM decision not to recommond this area, and I would greatly appreciate an explanation. The last issue is about the Storm King Ski area proposal. This area is 1,000 acres of BLM Land on the north end of Cimmaron Ridge. Now the BLM have stated that this Ski area would elimiate the ELK CALVING habitat and have an impact on the Mule Deer fawning grounds. Their solution to the problem is to grant a 5 year grace period to the developers to go ahead and start with the ski area and then let them know if they will approve the ski area after they have spent 5 years developing the 1,000 acres of land. The BLM is suppose to assess the compability of resources, not to give developers a five year head start. Our Elk and Deer areas have been greatly reduced in just a few years, alot more than mort peopel realize. The BLM needs to take another look at their decision, and the role of the BLM in land management decisions. The Elk and Deer populatins cannot come forth and speak for themselves is such matters, they are subject to the whims of men. I feel that the Deer E Elk should have their birthing places protected, its _ not like they have many places all over the state. Thank you for very much for your time with these ost important matters. Sincerely, ~J*»„^ J hi e*f^ 136 68 61 Dear Mr. Vecchia, We are writing to inform you of our feelings on the wilderness recarmendations of three arse in the Montrose BLM district. We frequently use wilderness areas of the state for backpacking trips. We have hiked in all but two wilderness areas of the state. We are very concerned about the future of "wilderness" in our nation. We are happy to hear that the BLM is proposing to protect the Gunn- ison Gorge area. This area with its proximinity to the Black Canyon of the Gunnison National Monument and 13 miles of the Gunnison River will make a wonderful addition to the other areas in the state. The Camel Back area seems to fall into wilderness consideration and we would like to know your reasons for not recamending this area. We understand that there are no resourse conflicts and that grazing is to be cut back in this area to protect the riparian zone. Why not protect the entire 10,402 acres with a wilderness designation? He would like to see this area of the Uncompahgre Plateau saved before it is too late. Please explain your stand on this. We also ask you to recommend the Adobe Badlands for wilderness as it has sweeping vistas and is home to an endangered cactus. This area has little resource potential and it would be nice to have an area that is in contrast to our mountains and riparian wilderness areas. We thank you for your time in considering our views on this matter. Sincerely, ■ -"" i / y. cist Harv Kieca Judy Kieca 201 S. Wilcox Castle Rock, CO 80104 86 62 SB 136 S3 69 67[ ?.0' 3pX fC Pni/-o_nnrV Tpo.r 5?rKy Gor^p f T fl_ ,,fT.^.nr *.„ ,,nll (,>,*,,*. ^o S*nWl Kfn# SV*.o tfl o o1> ppl-Hpr fl-pim^s =i^ ♦-*>« will* ropr 'owning nTOo, ?loSP ronf ^rnp.pr'r' t.r« *-l-+-pV« ^.ifpor ffpqeft, noTlonr fr>r t-ire sVl prpo, ^(>ir*lnnP*fi, Sfnr-i Klnc Xnun*- S^n^V OP le-ff ''Sr 1-np_ e?V on^ l*ft(*»», T>>pnV yrvi vprv mc'in . 3* nOPTo1 V i Jul 1 p 71. SmfcTflOP 64 207-29Rd. Grand Junction, Co. 8I503 September22, 198? Gene Vecchia RHP Team Leader BLH 2505 5. Townsend Ave. Montrose, Co. 81^01 Dear Mr. Vecchia, As a citizen of«estern Colorado and an avid outdoorsman I would like to offer my thanks and congratulations to you and the BLH for the wilderness designation recommendation for the Gunnison Gorge Wilderness Study Are*. If the recommendati on is accepted an invaluable and irreplaceable part of the west will have been saved from further exploitation and will have been afforded the necessary protection so that future generations may too enjoy its splendor. To my consternation though I understand that in your draft for the Uncon- pahgre Basin RHP that you have failed to include of the Camel Back Study Area! for Wilderness protection. I find this v^ry disturbing and the decision borders on the ludicrous. A public accounting for this decision is certainly in order, especially in light of the BLM's admission that there are no resource conflicts with wilderness designation for the area* That such an incredibly diverse and beautiful area as the Uncompahgre Plateau has no designated wilderness areas is in itself a disgrace. At hand lies the opportunity to rectify this situation, albeit in a very small way, I ask that the Camel Back Areai be given wilderness designation, to do otherwise would be a travesty* Another discrepancy in the report I would like to address is the exclusion of the Adobe Badlands f rom wi Iderness designation. Again, this decision is incomprehensible. Those familiar with the area know any resource conflict is virtually non-existent while the beauty and solitude offered are quite unique. Most of the Dobies have been severely jnd recklessly abused for generations, surely at least this very small part deserves the protection afforded by wilderness designation. Again, I must ask the BLM to publicly explain its1 decision in this natter and ask that the decision be sensibly reversed. The issue of the Storm King Ski Area. Site is a.lso very disturbing to me. By the BLH's own admission the sM area would eliminate a critical elk calving habitat and mule deer fawning area. In a time of ever increasing pressure upon big game populations by hunters and development how you can rationalize the sacrifice of this habitat is beyond me. As both a hunter and a conservationist I find the decision to allow a 5-year grace period in which development would proceed to be absolutely indefensible. In a time when all long range forecasts for the ski industry say the sport faces declining numbers because of the aging of the baby-boomers it becomes all the more ridiculous to sacrifice such an important area to the short- term profits of a few developers. I ask that this decision, too, be reversed for the sake of all long tern interests and values. 63 p.o. 3ot rr 136 68 I b* ».tt>< Hnc ^ n vpm a"hn'?* fV«T«po ot'oosj Siir»n i pon Got'tp ( ?1rsf of nl*} on *■>># Gunnison GorPffp fnpnV vrvi for "our Tfftf T^BfWWr'M*** l>33 ?lrnlfl o-crftfl "^ fV"" Gunnison GorKre Wl rVmppS S*tyl*t» A-pPaK fn" Wj Tr P.TTfiFS ^to^pcM o>*> , Seconr , n] fipsp rP. common^ *V>a Camp]. 3*cV fffl* ''* Io>rne(?S Prn+RfiMnn , TrnnV wot] for CU4-1"1 no- hncV OH + *(> PT*!!3 HP to TiroteC^" ^P r^T^T znn», 'Jf> rppfr *"r) n.'rft+ue*' 4-nP,)'neo,«YipVir'rfi nlfl^eoi], 1 +■ JS h w«,1rvr Ipp^nr"! of w<*fifi>rr r.nlnrsi'n, TV-prp arfi olRD SO™? ftn^ncpyp^ "lftp + s t>nc fVip "hip- p-D™p l-p-pp" p-*-V>of pppi* Tn+'RCM on , TVp.T-p. is nn r 1 -nhf-r or -ilnPTO] conflict's Wr. PLrprr atrfi^r v-rIti fo rm + fict1 f^lfl ores f alonrr wl +-V^ t-Vp Gnnni son Gotcp, Tvirr1, PlpPRp rpc-.o-npnr <->*p o.f'ohp Bernards *nr wi ]r«*-r«o r'esl trnpM np . T>lp o-p=o )S Vviynp, *>o Rnr5 p»irrprp.r c»ftfi|R, *-hp mlnprpl -no+-pri* 1 fl"1 's 1 nv , qnr* tVpfs, 4 powerful lobby exists that would oppose any restrictions but surely in the light of the ever increasing damage being done to lands under BLM management the BLH itself should draw up, at least, minimal guidelines. I would suggest that because the evidence is so overwhelming that the users of ATV'5 and dirt bikes are unable , or unwilling, to use public lands in a responsible manner that they be banned entirely. At the very least they should be restricted to existing roadways only, with stiff fines for any offenders. U-WD's should be restricted to the roadways also, with the same penalties- agarinst offenders. I know enforcement would be difficult, at best, but, as on Forest Service lands where restrictions are in force, the simple posting of restrictions would, in most cases, reduce the damage considerably. Thank you for your time and consideration. I would appreciate hearing from you regarding these issues. Yours truly. Dan Roberts Another area, of personal concern is the off-the-road-vehicle use lands. This situation is entirely out of hand. No area is safe fr on publ ic cc. Congressman Ben Campbell 87 68 136 2551 P 81. Cedaredge, CO. 81413 September 27, 1987 Phone: 856 3486 65 68 136 Dear Sir, I very much approve the BLM's decision to recommend the Gunnison Gorge for wilderness designation. Over much of its length the canyon of the Gunnison river I, one of western Colo- rado's jewels. It is a splendid recreation area for residents and vi.,itors alike. Perhap3 wilderness designation for the gorge would also help secure wild and scenic classification for that section of the river, which I also support. However, it i3 difficult to understand „hy the Adobe Bad- lands area in Delta County and the Camel Back area in Montrose County were not recommended. Both areas contain significant beauty and, as the BLM's own studies indicate, both areas have very little if any economic potential. It is difficult not to _ concludl^^e?!?!^ |& inherent bias against wilderness. Although „everal ..urveys have shown that there ia wide- spread support among the American people for wilderness, there seems to be a perception on the part of 3ome, perhaps especially ajnong those who hope to make money off of the public domain, that wilderness areas are primarily for the exclusive benefit of a few, hearty outdoor types, often referred to as elitists': It seems to me that this is a misconception. It is true that, ,ince roadbuilding is not permitted, those who can only experience the out of doors in a car are pretty much excluded. But would those who use this argument suggest that a road should be built to the top of every mountain peak in the state to accomodate these people? Unfortunately, life is like that; not everybody can do everything. Young children cannot appreciate the joys of sex women can't h*ve babies. No matter how much I may want to I can never be a professional football or basketball player.' Peo- ple who are too poor to get out of the inner city can never ex- perience the beauty of the Grand Canyon. One could go on. My personal perception is that support for wilderness, even among those who may never hope to vialt one of the areas, Old page 3 65 [ that he was placed in the garden of Eden "...to dress it and keep it", not to despoil it or ruin it or exploit it, but to make it beautiful and fruitful and unduring. Many of the Psalms continue this theme. The 19th, for ex- ample, begins with the words, "The heavens declare the glory of God and the firmament sheweth his handiwork." The 24th begins, "The earth is the Lord's and the fulness thereof; the world and they that dwell therein." And in the book of Revelations (11:16-24) thanks is given to God because, among other things, he is going to "...destroy them which destroy tbe earth." It is too bad that we find it necessary to set aside cer- tain small sections of the country as wilderness areas, actually, the whole earth should be treated with respect, but at least it is a small step in the right direction, ye owe it to ourselves, to our children, and to our noblest beliefs to tread so lightly on the earth that we leave the smallest tracks possible. I would liketo/as^h|h5fM reconsider its decision on the Adobe Badlands and the Camel Back ,tudy areas. Sincerely, ;^«sA, Chuck Uorley Cedaredge, CO 68 136 63 page 2 65 arises from two important aspects of American life:, the sudden flowering of a vigorous conservation ethic, and the innate relig- ious impulses common to most humans. THE CONSERVATION FACTOR When white people first came to the North American contin- ent they stumbled upon one of the richest pieces of real estate on earth. The land contained everything needed to support a large human population— vast stretcnes of rich soilt a moderate climate; for the mo„t part, adequate rainfall; a wonderful 8ystem of rivers; hundreds of miles of forest and grassland; generous deposits of minerals; a land teeming with wildlife. With the sudden development of the industrial revolution, vliich made possible a speed and degree of exploitation never be- fore imagined, and the immigration of a vigorous and ambitiou3 population, that vast storehouse has been harvested at a rate unparalleled in human history. Rivars and groundwBavi" been polluted, vast piles of poisonous wastes have been left exposed to the elements. The air in many areas has become unfit to breath. Top soil is rap- idly being flushed into the oceans. The readily available min- erals have been mined. Forests have been leveled and native grasslands plowed up. Huge herds of game animals have been eliminated. Unfortunately, much of this exploitation was done not to satisfy legitmate human needs but to make a fast buck, and to bell with the consequences. The situation has deteriorated to the point where the American people are beginning to recognize that if we are going to survive as a nation and as a people we need to begin to avoid waste and pollution, we need to clean up our messes, and we need to begin to live frugally on the land. THE RELIGION FACTOR Any religion worthy of the name has some beliefs about the creation of life and of the universe. It also has something to say about how we humans should relate to the creator and to ' - creation. The native American religions, for example, have cer- tain beliefs about a great spiritual father and also regard the earth as our mother. They teach that we should conduct ourselves with reverence toward both. Christianity is no exception. The first words in the Bible are, "in the beginning God created the heaven and the earth." Then it goes on to point out man's place in the scheme of things— 66 /£n.-vw S^ch. d^a-A. 'A^ 88 66 fM$*Jl*<. ^*~~ ^UL 3**^ ^^Ji- J&>«* Jt^wL J^jI fr^ . R -7^s4 67 68 136 69 527 Gilpin St. Denver, CO 80218 Gene Vecchia RMP Team Leader Bureau of Land Management 2505 S. Townsend Ave. Montrose, CO 814-01 Dear Mr. Vecchia: We would like to thank the BIM for recommending all 21,038 acres of the Gunnison Gorge Wilderness Study Area for wilderness protection. We support continued protection of the Gunnison Gorge. We would also like to see the Camel Back Wilderness Study Area and the Adobe Badlands recommended for wilderness designation. 3y 3LM's own admission there are no resource conflicts with wilderness designation of the area. We hope that these two areas will be preserved. One other area which concerns ub Is the potential Storm King Ski Area aite. Jtfe. do not support another Bki area in Colorado, especially in an area which happens to be critical elk calving grounds. At the very least, the plan should assess compatibility of resources, not give one a five-year headstart over the other. Sincerely, -. Ellen B. Braaten r:ric D. 3raaten 68 136 69 68 68 69 Robert E. Vecchia RMP Team Leader Bureau of Land Management Uncompahgre Bas in Resource Area September 28, 1987 [granted in :he draft should be eliminated. I would appreciate your sharing our concerns with the above issues when preparing your final draft of the Uncompahgre Basin RMP. Dear Mr. Vecchia, Upon review of the draft Uncompahgre Basin Resource Management Plan, I felt it necessary to voice my concerns regarding the wilderness recommendations it contained. I am in full support of your recommendation that the Gunnison Gorge wilderness study area ^be protected. The 21,038 acres of wilderness that Gunnison Gorge contains is indeed an area worth defending. However, I am dis- mayed that you did not apply the same reasoning in your conside- ration of the Camel Back and Adobe Badlands for wilderness taction as well. Sincerely Yours , Harry lOiperberg w 820 University Boulder, CO 80302 7H pro- Like Gunnison Gorge, Camel Back contains thousands of acres of beautiful wilderness area. The existence of big game herds and several endangered species of plants that currently thrive in Camel Back could be threatened if the area remains unprotected. As well, there are no timber or mineral conflicts in the area that could justify allowing its wilderness qualities to be destroyed. The Adobe Badlands is another area that needs to be protected, not ignored. In addition to being the home of the endangered Uinta Basin bookless cactus, the badlands provide its visitors with sweeping vistas of the San Juan Mountains and the Uncompahgre River valley. There is no timber in the area, and four dry oil and gas wells have been drilled nearby the badlands, indicating there is little conflict with a decision to supply wilderness protection. The same rationale used to designate wilderness protection for Gunnison Gorge should be applied to Camel Back and Adobe Badlands as well. 89 136 68 69 £*„tl Sao/ j^P -?&. jf^sZ* ^Ajg^*^ *u> J& 'aTt^-r*, tJ2 l^ , l<£l*^t*=> H/'T*** AJ } A+* &> •> *>" i~u Co *a J ," t&K / J*<2< T~t*>c f/z ; 3 7"/*. « wco^j. 68 136 ^CU, U.T- \iimc - [|v\tOY>paJA'5u. feuwv &a«wA lUiWWiwi Plan J - - (jLjl; do M* fiU- Oiwu ^aM iaM. HL GUiCM a It* pUJlMu- ^I'l'^XiM ii ^ / rtujo 90 73 62 68 136 613 Maxwell Boulder, CO 80302 Sept. 20, 1987 Gene Vecchia, RMP Tean Leader Bureau of Land Management 2505 S. Townsend Ave. Montrose, CO 81401 Dear Mr. Veeehia: I wanted to content on the draft Uncompahgre Baein Resource Management Plan. First, I want to endorse the recommendation of the Gunnison Gorge for wilderness protection. This would woke a fine addition to the Wild and Scenic Rivers trust. The expansion of the area adjacent to the all ready protected Black Canyon is right in line with the latest thinking of the need to protect large areas of similar ecology. Small ecosystems are not as inherently stable, and every measure to increase their size helps. Next, I am disappointed that the Camel Back and Adobe Badlands were not included in the wilderness recommendation. 136 68 69 Camel Back, according to your ow conflicts. The area is one of the few In the Uncompahgre Plateau, which cui wilderness, I think that this area wilderness recommendation to avoid the degradation by road building, which is sure to happen. report, has no mineral itantiol wilderness areas ently has no designated should be included for I don't understand the lack of inclusion for Adobe Badlands. Clearly again, there are no mineral or timber conflicts. This desert with it's fine views should be protected by wilderness recommendation, . Finally, I don't understand the Bureau's intentions with the potential Storm King ski area site. With the downswing in ski business, a_ong with increased competition from existing areas, I really don't think that another destination ski area has much o£ a chance. So I don't think that the local economy will really get a boost from developing it. To gamble the certain loss of elk calving grounds against profits for a few developers is wrong . The Bureau's 5 year wait-and-see plan will give the developers a free leg up, at the expense of the other resources, primarily elk. As a professional engineer who likes to ski , hike, and enjoy the wilderness, I would like to think that the BLM is considering people like me and our concern for wilderness In it's management plans. There is so little to lose in protecting wilderness, and so much to gain. Thank you for reading my comments. Timothy J. Cunningham, P.E. 75 3505 W. 39th Ave. Denver, CO 80211 September 30, 1987 Mr. Gene Vecchia RMP Team Leader Bureau of Land Management 2505 S. Townsend Ave. Montrose, CO 81401 Dear Mr. Vecchia: I strongly recommend the inclusion of Camel Back and Adobe Badlands in the proposed Gunnison Gorge Wilderness area. This is part of the Uncompahgre Plateau, yet it has not a single acre of designated wilderness. Camel Back is one of the handful of potential wilderness left on the plateau. _/ Mrs. Lorraine Lane 74 October 2, 1987 136 68 69 Gene Vecchia RMP Team Leader BLM 2505 So. Townsend Ave. Montrose, Co., 81401 Dear Sir, I wish to address recommendations in your draft Uncomphagre Basin Resource Management Plan. First, I support the designation of Gunnison Gorge USA for wilderness. That is in my opinion the strongest feature of the draft plan and an exceedingly good idea. I urge that the Camel Back area also receive wilderness protection due to its place as one of the few areas on the Uncomphagre Plateau that could preserve a wilderness character there. I urge that the wilderness qualities there be kept, not lost, especially given no real resource conflicts with such an action. I believe Adobe Badlands also warrants wilderness pre- servation. The vistas alone they provide are worthy of protection. They, too, have low resource conflicts and, in my opinion, hold no real obstacle to a wilderness designation. Finally, I oppose any allowance for ski area develop- ment on the north end of the Cimmaron Ridge. The plan acknowledges the importance of that area for elk calving and mule deer fawning. Our state has lost too much such habitat already. I urge the BLM to make a strong commit- ment to preserve this area for wildlife habitat/. Thank-you. ;fi/ioJi Ufatk Mark Meeks fyo 5"/" fad 76 &-Ji«, Co fOSoa. 68 136 -+t^ ~s.cn a _j -tu c^^> %~L <^J °^~^ ■To T^-a — £ u-^a -r yec?rS To 73 /&Mur--S_-/ il 79 da a, £, r\l. yJfcpii (\at-K. U ,> Js. ivr i1\a, i-i Qi-ci V-l.St- U-nrls ix:r years ein£ di 74M Cart e/ <& (a,J. 1% y l^tl/i fr-UXct ier ,f, rleiii. ^ic &l fa bock %!i* , Ihrs Fcbr-h (~rr-ay ¥tfi&J*r-X$ 0QC ~%7icU^, CO PY-2, 86 Robert E. Vecchla HMP Team Leader -- BLM 2505 South Townsend Avenue Montrose, Colorado 81i*01 Dear Mr. Vecchla, The following are my comments concerning the Uncompahgre Basin Resource Management Plan and Environmental Impact Statement! The test alternative offered to support the multiple-use objective, vrtth the fewest detriments to livestock grazing, Is the 'Continuation of Current Management.1 Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation interests can be met on a site-specific basis. i d t-v- l^-J&u- Signedi 92 80 Gene Vecchia, RMP Leader Bureau of Land .Management 2505 S, Townsend Ave. Montrose, CO BlUOl Dear Mr, Vecchia: October 14, 1987 136 68 I would like to congratulate the BLM on its wilderness recommendation for Gunnison Gorge. It is to be hoped that this protection will soon be law, I would like, however, for the BLM to reconsider its non-wilderness recommendation for the Camel Back Wilderness Study Area, There are no known resources of importance here, by the BLM's own admission, and wilderness designation would protect this important riparian "community on the Uncompahgre Plateau. I hope the BLM will alio recommend tha Adohe^ Badlands , with its rare hookless eutUB, for wilderness designation. Mark N. Williams Anorney a! Law 327 North Seventh P.O. Box 23 Grand Junction. CO 81502 1303)242 211] si October 12, 1987 Sincerely, S Bruce Berger / Box ^62 / Annan, CO 81612 l 68 136 69 68 136 Gene Vecchia RMP Team Leader Bureau of Land Management 2505 S. Townsend Avenue Montrose, CO 81401 Dear Mr. Vecchia Your Bureau's plans for future recommendation of land use regarding desert wilderness designations have come to my .attention. I want to thank you for your recommendation con- cerning the Gunnison Gorge. I must express my distress, how- ever, concerning your Camel Back and Adobe Badlands recom- mendations. I request that your organization take another long, hard look at the recommendations and do more extensive research, study and re-thinking before excluding Camel Back _and Adobe Badlands from desert wilderness designation. I was appalled at your giving thought to allowing yet another ski area in Colorado much less one at the north end of cim- maron Ridge. To even think of disturbing the elk and deer habitat is ludicrous. I was under the impression the Bureau was organized as a steward for this country's natural resources. Please do not allow private developers to misguide your guardian- Please, rewrite your recommendations for Camel Back, Adobe Bad- lands and Cimmaro- Ridge for the preservation of our wilder- ness areas that need so much protection. We must preserve our wilderness areas. It is vital that the Bureau and the citizens of the area discuss and study these ^arbitrary decisions before they become policy. ncerely Mark N. Williams 36 82 Robert E. Vecchia RHP Team Leader ■- BLM 2505 South Townsend Avenue Montrose, Colorado 8H+01 Dear Mr. Vecchia, The following are my comments concerning the Uncompahgre Basin Resource Management Plan and Environmental Impact Statementi The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, is the 'Continuation of Current Management.' Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and. salinity, utilize mineral and forest products, and protect our diverse recreation interests can be met on a site-specific basis. 68 136 83 Hobert E. Vecchia RMP Team Leader r BLM 2505 South Townsend Avenue Montrose, Colorado 8lWl Dear Mr. Vecchia, The following are my comments on the Uncompahgre Basin Wilderness Technical Supplement! I fdoV (do not) agree with the BLM's Proposed Action, the All Wilderness Alternative, for the Gunnison Gorge Wilderness Study Area, The camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the Ho Wilderness Alternative. This alternative best exemplifies the multiple-use management. Site-specific objectives can be mitigated through the Allotment Management Plans. Signed, Ch*A vJ ■ IM^° /i>-/A- ?7 &gC£- to -m-ty *-*~Yttt&L 93 84 36 /o/,i/S7 86 Robert E. Vecchla RMP Team Leaders BLM 2505 South Townsend Avenue Montrose, Colorado 81ii01 Dear Mr. Vecchia, The following are my comments concerning the Uncompahgre Basin Resource Management Plan and Environmental Impact Statement! - The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, is the 'Continuation of Current Management,' Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products , and protect our diverse recreation Interests can be met on a site-specific basis. 68 136 85 Date, Its / l~L / ' ' Robert E. Vecchia RMP Team Leader f BLM 2505 South Townsend Avenue Montrose, Colorado 81U01 Dear Mr. Vecchia, The following are my comments on the Uncompahgre Basin Wilderness Technical Supplement, I (do) Ql ■) agree with the BIJ('s Proposed Action, the All Wilderness Alternative, for the Gunnison Corge Wilderness Study Area. The camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the No Wilderness Alternative. This alternative best exemplifies the multiple-use management. Site-specific objectives can be mitigated through the Allotment Management Plans. Robert E. Vecchia RMP Team Leader -- BLM 2505 South Townsend Avenue Montrose, Colorado 81^*01 86 Dear Mr. Vecchia, The following are my comments concerning the Uncompahgre Basin Resource Management Plan and Environmental Impact Statement! The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, is the 'Continuation of Current Management.' Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation interests can be met on a site-specific basis. 87 ^h/v .{ /yv-*o /ioA)J~~ .-v!\ r^ioJ^-p 66 68 136 Robert E. Vecchia RMP Team Leader .- BLM 2505 South Townsend Avenue Montrose, Colorado 81W1 Dear Mr. Vecchia, The following are my comments on the Uncompahgre Basin Wilderness Technical Supplement, I (do) (do not) agree with the BLM's Proposed Action, the All Wilderness Alternative, for the Gunnison Gorge Wilderness Study Area. TCie Camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the No Wilderness Alternative. This alternative best exemplifies the multiple-use management. Site-specific objectives can be mitigated through the Allotment Management Plans. fN\ -tYYV^ /ioMM^^^ y^/3^^pp U^, ^-*"*V*s| As^V 91 (6 - /*- . Yf 88 86 Hobert 2. Vecchia. RMP Team Leader *- BLM 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia, The following are my comments concerning the Uncorapahgre Basin Resource Management plan and Environmental Impact Statement! The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, Is the 'Continuation of Current Management.1 Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation interests can be met on a 6lte-specific basis. <^*~t^- Signed 1 J6 - A* > tiff 39 66 68 136 Robert E. Vecchia RMP Team Leader - BLM 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia, The following are my comments on the Uncompahgre Ba3ln Wilderness Technical Supplement! I jjffF (do not) agree with the BLH's Proposed Action, the All Wilderness Alternative, for the Gunnison Gorge Wilderness Study Area. The Camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the No Wilderness Alternative. This alternative best exemplifies the raultiple-uaa management. Site-specific objectives can be mitigated through the Allotment Management Plana. fa i^/cC^- / Pl¥3.s- 90 Gent 1 enen , I am writing to vou again about the proposed Caaelback and Adobe Hills wilderness study areas. I am a native. My grandparent; were cattlemen on a ranch| near Norwood. In those days tney didn't, have income and property taxes. Today cattlemen still don't pay taxes and they receive subsides, handouts, low interest loans, bailouts, ect. They are for the lost part the complete opposites of the indepenaent self-sufficient people of the past. The history of The Uncompahgre after the forced departure of the Ute Indians is of total* exploitation. Huge cattle concerns, many from people in England who never saw or cared about the land proceeded to rape it. "Competition for grass reached sef-destruct excesses when the range was wide open. Each cowman stocked his area with as many cows as he could lay cash or mortage to and grazed to the roots. If he didn't, somebody else would. The herds were enormas. One old-timer reiembers seeing fifty thousand head in one bunch held for shipment on what is now Grand Junction suburia-- The Redlands. Overgrazing brought on regulation to save the mountain from dying, as mountains up around Gunnison died in that area. To bring grazing within the capacity of the range to maintain itself, the Forest Service gradually! (and proportate ly> reduced the herd population of the allotments.* Today sagebrush, clumps of pinion-cedar and the desert enviroment are a direct result of past and present abuses. The 1930 Taylor Grazing Act started the BLM. It covered land not in control of the Forest Service. 90 I live on Log Hill and personaly know how hard It ic to return the land to it's former productive self. It will probably take twenty or thirty years on my 40 acres. Special interest groups like to mention the mul-ti-use or more properly the multi-abuse approach to public land management as though is was a popular approach, nothing could be further from the truth. During the Ford Administration they had hearings all over for the proposed wilderness areas. 'Citzens who testified at the Forest Service hearings in Colorado in January of this year or submitted statements for the record supported nearly five to one the Colorado Open Space Council citizen f recommendations for three wilderness areas totaling about 5 72,000 acres. "^ Certain special interest groups especially the Chamber of Commerce whispered in the more than receptive ear of the Ford Administration who whispered into the Forest Service's receptive ear, that they didn't like the outcome of the hearings. It's interesting to note that former president Ford has a vested interest in the Beaver Creek Ski Area. We have a responsibility to future generations to see that they have places to go and enjoy untouched wilderness areaf free from small-narrow-minded special interests groups who want public land for they're own private use and profit. Sincerly , W.Rodney Mckinnon 78A4A County 81 Montrose, Colorado 81A01 95 69 90 I. Uncompahgre, Muriel Marshall P/35 Caxton Printers, Ltd. Caldwell, Ixlaho I TO? 2. The Denver Post, Sunday Dec. 8 IS74 P/3E The quote was froi Clifton Merritt, regional director of the Wilderness Society. 01ir% 91 Le^-^iS p;k 1(2, 6u.f*^Ju4 or L<^~^1 tM.ew*\iXj3 -s.ua 4-a.t" D^x^- Mr. \/«.<-cU, «o^ uoj 4e> r *<.*« J v ot Ci^-i-vv^X Da-t-K ( Hoots i Ji-iL-6^. C<9_«V)O»0 ^5/" t*/l IcL-t-/ ^;a-w« +c clou 4^» £fcl*4 S>a_(*.la. k.<*-j wt«. 91 ciU.0,^ ^4^ 1 ^ /At pruc-fttd v_^ (4^ rive ^k-, ■slx^^iJL ,?UriAtoKXu b-c }L\&-*\ /C mdo tro/" uovr Tl irt^<. fit-j/utf •^M COt^Sl JL^ScJiOa . 92 68 136 October/P, 1987 Gene Vecchia RHP Team Leader Bureau of Land Management 2505 S Townsend Ave. Montrose, Co. 81401 Dear Mr. Vecchia I would like to provide brief comments regarding the recently released Uncompahgre Basin Resource Management Plan. As a frequent visitor to this portion of the state, I have had the pleasure to enjoy this fine area (as well as aid the local economy through purchases at local stores) . My purpose to visit is not to view logging areas or oil rigs oc other such industrial artifacts but to enjoy the lasting beauty of the terrain. It is with real regret that I learned the plan does not designate certain areas for wilderness protection that really deserve it. It appears the Gunnison Gorge has been recommended for wilderness protection and that is perfect. That river is a recreational resource that will do more for the economy and environment over the years than any development ever could. But what happened to Camel Back and Adobe Badlands? The Camel Back area has no mineral value at all as referenced in the plan itself and should be designated for wilderness in that the Uncompahgre Plateau includes no wilderness at all at this time! I THIS AREA SHOULD BE DESIGNATED AS WILDERNESS. I am not as familiar with the Adobe Badlands but it appears this area has no mineral or logging values at all and it to should be preserved as wilderness. Please incorporate these comments into your review process and alter the plan to reflect these areas as wilderness. Thank you for your consideration and action on these thoughts. Gar 9" G. *>3Tbot 6333 Kendall Street Arvada, Co. 80003 96 93 /n//r/g-7 86 Robert E. yeechla RMP Team Leader-- BLH 2505 South Townsend Avenue Montrose, Colorado 81^01 Dear Mr. Vecchla, The following are my comments concerning the Uncompahgre Basin Resource Management Plan and Environmental Impact Statement! The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, Is the 'Continuation of Current Management.' Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation interests can be met on a site-specific basis. ^ A*^L-~ \ (U^u. r 69 68 136 95 3^ft> "Be^-Ut-. U<- 3ouU^ Co W*>o1> PefcW (3, H<«7 You,- »»Y -fU» o«rt* **+ swtV 4 At^^^l Vour ;A«a V 4 *»->(*>, Wt ^«ri»i" n * u.T-«t. You K»M- iitii, nov0 J^U- fU^* -tor Stsrn KA-j st\ 0.1-01 5WIA -pretttA 61- (drwXj. 1 ury. y«( 4 ^ro+tc+ -tV*. elk. TWfc Y°* ** recoiMw.A>v«, Gwvo^f>\ -iW tv. iL ]>«+. ' ~ Bvit I io nrf- ukAk-s2-t- ■c^U-CcpL^C 96 JOHN C CALHOUN AND ASSOCIATES DELTA, COLORADO 91*16 October 19, 1937 Robert E. Vecchla RMP Team Leader 2505 South Townsend Avenue Montrose, CO 8H01 Dear Mr, Vecchla 68 136 Having lived in this area all my life, and seeing the improvement in range conditions over the past years 1 would support the continuation of the present continuation of the multiple use management concept. The use of the land for livestock grazing, wildlife, recreation, mineral exploration, and forest products must be considered as of imminent importance to the "west" and the United States. The camel back and adobe badlands should be excluded from wilderness classification because of historical use. The charge of ownership of the Black Canyon may very well call for the change in classification which does not bother me In the least. The other areas, in my opinion, do not lend themselves to wilderness classifications. Very truly yours, ^^J^^cT^iJ*-^ George C. Calhoun xc: D.R. Gore 56850 Fern Rd. Olathe, CO 81425 97 97 \946 Clover Court Grand Junction, CO 81306 October 19, 1987 69 136 68 Gene Uecch i a RMP Team Leader Bureau o-f Land Mgt . 2505 S. Townsend Mon trose , CO 8140 1 Dear Mr , Uecch i a : The purpose o-f this letter is to commen t on the Resource Man age me nt PI an for the Uncompahgre Basi n . I wholeheartedly support wilderness protection -for the Gunnison Gorge. The area is beau t i f u 1 , unique, and wild. Even now, however, helicopter parties come into parts o-f the lower gorge -for -fishing. Please maintain your strong stand to protect this unique resource. I ami baf 4 led by the Storm King Ski area pi an. Here in Grand Junction, our beautiful ski area has been in finacial troubl e for years . A new owner was sure that fixing up some th i ngs wou Id imp roue revenue and now he is facing the possibility of the bank taking over. Many other areas have gone up to *30 and more ski passes. Can you afford to ski? My family cannot - but we can afford to hike and camp and x-country ski and that's why wild areas must be maintained. This area is important elk habitat. Please preserve it as such. I have hiked Robideau Canyon on the Uncompahgre. Its the best place on the plateau. Your plan really gives no rati on ale for not recommend i ng wi 1 derness des i gnat i on . I have small children and I want them to have areas tike this to show to their children in 20 years. The Came 1 Back area is wilderness - please designate it as such. Finally, what about the Adobe Badlands? Yes this is badlands. Thank goodness you are banning off-road vehicles. So many of these areas are ouerun wi th DRUs - and that's fine. They need some pi aces, but hikers need some too . Hiking through an open desert and knowing you cannot be run over by a motorcycle is a wonderful feeling. The views from this area are spectacular. Let the hikers have one of these areas too and de si grate Adobe Badl ands as wi 1 derness. Thank You Nic Korte S3 68 136 69 October 16, 1987 Eox 263 Florissant, CO 80816 Gene Vecchia S8P Team Leader Bureau a;' Land Management 2505 S. Townsend Ave. Montrose, CO 81401 Dear Hr. Vecchia: It is my understanding the BLM in in the process of final- izing its Uncompahgre Basin Resourse Management Plan. It is doubtful anyt&ing I can suggest will be of value even tho I have spent over thirty-five years in land management in the National Park Service and private ranching. It seems each new generation of land managers must re-invent the wheel without fully utilizing past experiences and studies (':). Regardless, please keep in mind that wilderness desiccation can always be rescinded but wilderness can rarely be reclaimed within a lifetime, as you evaluate the Gunnison Gorge, Camel Back, ana the Adobe Badlands. Please consider the pure economic point-of-view in evaluating the Storm Kind Ski area site. A successful ski area of moderate size in Colorado is shaky at best and many have incurred bankruptcy in recent years due to the industry's overkill. It is ludicrous to think the area's economics can be bettered by a ski area over current big game hunting resources. Often the best management of land i3 to physically leave it alone. I can only hope your successors will be proud*., that you left them something to manage wisely. ely, R. Williams 99 68 136 Gr^we V«ix>*i A. "De.A.e- Ac. VecEiKi^ , 86 100 Robert E. Vecchia RMP Team Leader-- BLM 2505 South Townsend Avenue Montrose, Colorado 91401 Dear Mr. Vecchia, The following are my comments concerning the Uncompahgre Basin Resource Management plan and Environmental Impact Statementi ~The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, Is the ' .flHM^"11 cgg?ggH^^ageagBift£r Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation interests can be met on a site-specific basis. GS. rffi-U- - -■41 1."' ' 1 :'. 1 : - 98 66 68 136 101 Robert E. Vecchla RHP Team Leader - BLH 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchla, The following are my comments on the Uncompahgre Basin Wilderness Technical Supplement! t) agree with the BLM's Proposed Action, the All Wilderness Alternative, for the Gunnisor Gunnison Gorge Wilderness Study Area. The Camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the WEjIUfc^gas^g^g^trfr^; ■ -This- alte-raatl ve la — L £****''' '"i"~n"jmiT?rir — in"iiinLllU^- _5fl$&s£-eci.'fle 'objectives "Mb W i^t"lgat'ea~«troagh"-«ie Allotftfe^t. 102 IXlASI ??ll l^CC-hc-Os , c/2o/r, cX uji>ti/i/ ^UXx-. /b ,Lejlu ■iXi^yLO 68 fhi- &L/HS ^*ctcyych--o-^i /o d_J/crt-teLL t Hu.-&> {X*jL&~ cr^pLA^X /yia ^tsynjj&s) clO^ cts LUilojfi ^4. to i*L £:, S3 t--»Ov. \ *CJO^ <±^S. V" **--<^<8. i l *-, ■ \V.\* v(oe>*- ■re.ptA.v ■*~v> A*-«j^- o^.cA. &*» +N"»%*S *-t_A-^<5^^ W-\ «**_.; •a— o^ r^Sto^»<. Tlihiii'imi ki\ j=*-r-«bJt v*- 104 68 136 Vtc s^^f :)-m 106 fc4'f/' ^5(>^/^ /tVc /,'ft three fioftsej w.'k/w** 4/-f«s acre J ^/y /^ Zw^jgv &0* MUrm &£ ^f?«sfr fife* As /,ts sAofr fast W A, tC?*'*f««._ "7 tuf- fk JUL #**/ U«4 6^ j^ fmttf „m7* i//v 4, (&(o>'?r('c f' -^ ^ tfsfc/* ^ or*f J 100 *fV^, y ^, ^fc 68 106 pk 7^iC-zz7r yo/zz/fl 107 '6-<^ie decc/>/CL, 136 68 69 rf(£/d SL/r7 ptcfosaJs . /)/Ar Stm/faS1 SfaJus Ca/k&/ Soot 's^fe%im Me 6//>c c apxs/e/ditz/ oudd&r/uss \ 7?u AdoJs? mc//artds sfyoadd adsc> £0 cfes/?/?adzd OS ouddjW&ss S//?Ce^ -Me Condf/cfc co/7^i ou'/djZS/u?s£ d£$

ccf is M* Sdor/77 Pjoq St/ 'd/ra Sde o/?Hu zios-di g/?d c'f (dmrno-fon /idae, . fh/s /add /s eddrcad Ji>r- e/fc adu//?q Ammqfe dad dttdi. d&u- vfaow/m, /)f/o(tyda' *4V Sk/' area dujeJopers 3~ t/eass &> psoazj&d uj'dti Hie sk/ arm. S£jzv77ds>aqe/?o2srf- . P6losz soppo/f- 7dtp e/k 0/1 Sfora? fam ffloadfam t/isfrad O-f 7^1/- Sp/ /Trea ekedopars . -5t*j ajiw ^&oicAo(ty ldA-^D7 ifj.l^nfuis iirtte/f-jA. &U£ c-.'~. T^,'JT X al%o fwc ti»- udj< 'oiaawiftTio^ -tv*^4 u-*V^w 101 no BETTY NiCKHRSON ELWELL F U. BOX 522 LA VETA, COLO. 81055 68 136 69 fa^M tiUtfi^^J^. ************ any /m^- &frCJ^i fas«** a f ^AUdot^ /& j^jl Office: 874-7598 DELTA VETERINARY CLINIC DR. TOM CORE 1520 Bluff St. Delta, CO 81416 112 111 rc\ 86 Robert E. Veechla RMP Team Leader *- BLM 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Kr. Vecchia, The following are my comments concerning the Uncompahgre Basin Resource Management plan and Environmental Impact Statement] The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, Is the 'Continuation of Current Management.' Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation Interests can be met on a site-specific basis. Qj&juAv© 113 136 67 65 United States Department of the Interior Bureau of Land Management Montrose District Office 2465 SQUth Townsend Avenue Montrose, Colorado 81401 To Whom It May Concern, These are my written comments on the Uncompahgre Basin Resource Management Plan, Environmental Impact Statement, and Camel Back Wilderness Study Area. I am in favor of the Current Management Alternative for the Uncompahgre Basin. I am in favor of the No Wilderness Alternative for the Camel Back Wilderness Study Area. The current system for this area has served everyone very well by utilizing the Multiple Use Concept of Public Land Management. As a current radio commercial says, "If it ain't broke, then don't fix it." I am also advocating restriction of Off-Eoad Vehicles (ORVs) to be used only on designated roads in the entire Uncompahgre Basin District. The reasons for these restrictions are 1) ORVs cause increased stress and harassment Of wildlife on a year-around basis, 2) ORVs do not try to avoid vegetation, but instead drive over grasses, bushes, and shrubs, which leads to their destruction that then causes, 3 ) increased soil erosion. My final opinion is a very general idea. I am a recreational user of BLM administered lands. I believe all recreational users of public lands should be charged a day-fee or a yearly users-fee. Historically, other users of public lands such as grazing, lumber, and raining interests have been charged fees for their use of the public domain. To me, it is an inconsistant policy that allows hunters, f isherpersons, and/or perusers of scenery to be given a "free ride". As a businessman, I have learned that if anything is given away it is not appreciated, but if something is charged for it is more likely to be used properly and taken care of. I have many times used National Parks and National Recreation Areas where the fee system was in effect. I think people tend to pick-up after themselves more and appreciate what they use when they are charged a fee. Those who use it should pay for it. Finally, a major source of revenue to support and improve public lands is being neglected and left totally untapped by not charging users fees to recreationists. Thank y 68 136 RuuiX* Alcuy-l-l Plan. 1\ la ,~ptvK( HW g* iwWl &»»«»»/ U/ilitetott! A"< |J?ftil*l UlH^A- PoW( n»*l^ "t^ 0*Li k*p**. Ad 6uNNO«M Gelt^ OfSl link \.RwR> 0&f V ■M-ol- Alfatf 1M tt, nA Med vtA -7 4, 7 *v**y /> frnp*tr 'ir /cmcU and 7*j cftTTZni* a~d ff*-<- T£&.-cfl THm isw/r*dr-tc/ *rfk/4rx&q ij <*/co ^rpa^e/^y, 7T <^c not /*a*€ A pei ,,-h/i. 'A 41 ^^Joq H* -}/& tt n efik, HisnjJ Ait ( uj(rvf[ ,-t/<-/£ nomas Gore, 1365 Bluff St. Delta, CO 81416 1-303-874-5190 //l^ue, 3 a~U 4,/tiu/ -rf«+ -i-/>« A«/r <-**««* Q OMcJ rtJaf -/?v>v '^t A n>*. y / ^ />' . * a 102 68 136 114 fc/At&r s&f&mL i/uw(m cu r E>eOA beiU Ve-c-e b***~ MckOA 2Cj mi- 115 ■}c Ik ri&L-- «j c^6u_cy <_£.-A« 4c s-hcUi.it U tsu. 4-L 136 68 foxcA.4&\ to tJcteA-xOAJ c(iS^^v-i;e/i'<5YV.Vl"'*-a-l-!' cue /n6 CiTrLf e-ot^ w^.^ Sta audi, . J-y^py/a<_4*l~ .^^V >l cU. &&* max $ a** W k u* o^,ck h tuurfcuy 121 Uc« Pi "JLno tf&Jib 6&u6u, cu.'-c1 t/ltujs . wbo BtOvi'- Cree*4z_ Sun en p& asu*. ^fh Jfu beaM.fy, loCuc£ hex? /UAdf, lVtU> (r^H f% g tirlom-cb, l£{l pT'ShnjL Jc S~?&m.% 68 136 69 ^ Sf '„ur MM^^-^i: *2. 122 ^ iiM vAh<42+ ys*^ Jp A^ir>wn&*d*T*& ,£?*< *<, AStUOOrtf'*-' # fyfyfirt-t, , **i ^&„ ^ 4^i sl^L4^0*s*-~ -*-^L^tff ^fc*t_j *^-c#i^ ■^^x^^^^t^ --^^crt^^ Otirt^ku^yvf ■HSfy&f fl/2°t-~fi- Mr'2i- JlcOSE" iVCT gecew/re7U6£2s t*BQ Kj«_toee/uess tsfis/ fiX'/Prou. I fitH iHHtUftk. WtrH ^CTW A RCt^S C ££K£X&£73- rwes -- ooe7£ ¥,$00 i/£*iA£, 0cb ! THtrr a££*i '& so ijtmtstue - F££Qi=o / J Mifc» PAIL TO uobcSsVT^U^ THE (Z£nS*X-'V&- BEH/XZt> fteyteer i4£tevt)s(.6£?e_ uOvG_ inKU£>eo/U- i|& LIU.E- Vo "TTrVWe. you- f&A. KeaE^WOUrVO^ ^Her \gULMlSotJ QJD6&S" tU.J.AJ A"- cP W£ tunc LOUS YH<5~ 1116 128 oofcp»**7. "i%y (-&A, rA- Q«. Sit , is -yon. K/u3<~j yM ^I^sta., Gjj/tafix A-fis<3_ £»3 aSyct- A&.«_ »^Js' o"jm outarf" 3r^Ta -Puen-rr ■fm.rJ?,i^J> joL j^T,'M. ACT", fiL.™ T^a&e^ 'Ta O^ckjo *J jCSs ^«T To G~*L. 3=<-(C T^S »ptK-.Tjii t^ F.C^. (C. l^a^J S*i: ^v^t^-a p ^j>^« JUtC^i -fuR S^^ji paolt So'.-P -r^n£ti k t^T*--, "-«? , 129 HENRY G. WRIGHT OURANGO. COLOBADOBi: 3031 2303303 October 29 1987 Robert Vecchia BL.M 2505 S. Townsend Ave. Montrose CO 81401 Dear Robert: 129 68 136 I wish to comment upon the RHP recently issued by your office. I personally have visited the lands covered by the RKP on a very regular basis, and have also visited each of the USAs a number of times as veil. I would urge the BLM to reconsider its preferred alternative so as to more closely follow the Conservation Alternative. The negative impact of grazing is just to severe for the arid and simi- arid land to handle. The results of overgrazing are all too clear in a number of places in the area. I am especially concerned about the proposed land treatment as suet "treatment" has a severe impact ujon the natural vegetation and is of limited value so far as actually increasing forage. = So far as the V.'SAs are concerned, the BD1 is to be congratu- ated upon its All Wilderness proposal for the Gunnison Gorge. How- ever, the BLM should also include both the Camel Back and Adobe Badlands area as wilderness. It would appear from the reports that wilderness desigantion would not in any way influence either graz- ing or mineral extraction. Both areaE offer pristine country which should be preserved. The Camel Back area offers one of the last undisturbed areas of the Uncompahgre Plateau while the Adobe Hills area offers a great expanse of Mancos Shale which provides numerous opportunites for solitude. I— Thank you for considering my comments. Please keep, me in touch as to your final decision. Sincerely/ Henry 0. Wrigti? Attorney at Law HGW/ps 107 68 136 °jvL-\ *">y ^".ci-n cU, "* — St?~\rC ,t -^ /V~e 68 136 131 Wl«- t» W^iS^. -Bf-tAa. cu^A- vj^iXi^^jl. . 9JUacjl_, -!L axM ~-> V~t. ^nU «5 ^K^Sjk -V-WJ1. JU^lAr, V^> pMJ*^ 69 130 68 136 ^/(^ a^J. t^~o3^ +LW" c^\ r-e^l/y /,is4 ~^^ ' T V-eA-^y iid^ -Qi or r-e-AcU ^ A,. r -/-T^tL ^[/e^p^. , 1 UQW, JzV.MWd 132 zkh VN\cIij. ae. jJ^ m i/J i im /hM wit iLoTuryj U.WY1 u>fi^ jy\ UulikrAaafi CLVrttif Lr/i. S/ ^Acai> "Mwfc kJ 108 Ut^yJ vyvwct J^ lUWfJbJUmi Mud, ca-rJ mw " /r.-vithi . J) d 63 136 133 Robert E. Vecchia RMP Team Leader .- BLM 2505 South Townsend Avenue Montrose, Colorado 81 Wl Dear Mr. Vecchia, The following are my comments on the Uncompahgre Basin Wilderness Technical Supplement! I {!-) -Ci-^1 ) as^88 rith the BLM's Proposed Action, the All Wilderness Alternative, for the Gunnison Gorge Wilderness Study Area. The Camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the No Wilderness Alternative. This alternative best exemplifies the multiple-use management. Site-specific objectives can be mitigated through the Allotment Management Plans. Signedi 86 134 Robert E. Vecchia RMP Team Leader-- BLM 2505 South Townsend Avenue Montrose, Colorado 81V01 Dear Mr. Vecchia, The following are my comments concerning the Uncorapahgre Basin Resource Management plan and Environmental Impact Statementi The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, is the 'Continuation of Current Management.' Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation Interests can be met on a site-specific basi3. &#^5*^ >y> t'A £^ Signedi 68 136 85 122 135 136 5555 East Yale, Apt. 3 Denver, Colorado 80222 October 31, 1987 Robert E. Vecchia, RMP Team Leader Bureau of Land Management Uncompahgre Basin Resource Area 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia,- During the past several weeks, I have had the opportunity of reviewing the Uncompahgre Basin Resource Management Plan and Environmental Impact Statement. I appreciate the opportunity provided to make written comments concerning it. I am pleased that the Gunnison Gorge WSA is recommended as suitable for wilderness designation in the Preferred Alternative. The Carnal Back WSA and the Adobe Badlands WSA should also be so designated. I could find no convincing argument presented for not doing so. There is a great need for preserving wilderness areas in our great country and every effort should be made to do so while the opportunity remains. The designations for Escalante Canyon and for Fairview should be for the greatest possible protection of the endangered, threatened, candidate, and sensitive plant and animal species and for the unique plant associations found there. Careful and adequate monitoring must be maintained to insure that these species are indeed protected. Rodney Ui 1 son 21« N. Washington Cortez. CO BlSli. Novembe r 2, 1967 Gene 'vecchia RMP Team Leader Bureau of Land Management 250S S. Townsend Ave. Montrose. CO 61401 Dear Mr. Vecchia: I'm writing to express my appreciation for the BLM's decision to recommend Gunni son Gorge for wilderness protection. The great tishing and beautiful scenery of this area shou Id rightly be preserved as a wilderness area. While this action by the BLM warrants my appreciation. I would like to express my regrets at your omission of recommendations for Camel Back and Adobe Badlands. |~ I would f c-7 which would gi sensitive plan sideration bef [ favor the maximum closed and limited use designations for ORV use .ve the most protection for endangered, threatened, candidate, and ant species. I would hope that this issue is given careful con- before the Final Plan is adopted. The Conservation Alternative seems to present a more acceptable land tenure adjustment with no public lands being considered for disposal and for pursuing acquisition of some private lands. It should not be necessary to lose habitat for endangered, threatened, candidate, and sensitive plant species by disposing of those lands. [' Every possible means should be taken to protect the cultural and paleontological resources in the planning area. These are resources that are "nvaluable and once destroyed are lost to scientific study forever. Thank you again for this opportunity to make comments. Sincerely, Eleanor Von Bargen " 136 68 69 "Camel Back, as one of the few remaining potential on the Uncompahgre Plateau, deserves your rec wilderness designation. The endangered species exist in the area would benefit from wilderness would the big game population. As there are no t I derness area endat ion lor plants which s i gnat ion, as er or mineral conflicts to interfere with the designation, please reconsider your recommendation. *The Adobe Badlands. with its beautiful views of the San Juan Mountains and the Uncompahgre River valley, also should be recommended for wilderness designation. With a low potential for minerals and no timber, there are no obvious conflicts with a wilderness designation. I understand that you intend to close the area to off-road vehicle use so why not go one step further and recommend for wilderness protection. *0n» other issue in the Uncompahgre Basin RMP is the Storm King Ski Area site. Your plan says the ski area would eliminate the elk calving habitat and Impact mule deer fawning areas. Despite this, the BLM intends to let developers proceed with the ski area during a 5 year grace period. Please do not destroy this area lor the sake of some private developers. Wilderness and wildlife are shrinking resources that must be preserved. I realize that you must consider many conflicting interests in making your recommendat ion but please reconsider recommend ing Camel Back and Adobe Badlands as wilderness areas and stopping the destruction Of an elk calving habitat. S i ncere I y yours , Rod_»ey"Ui I son 109 0er*3t,f9X7\Z1 A^ /Ka. . S^^Mk , 68 136 •J Urn /&Ly ttyj&l£Ct<2£*S J/-*%(S x^Wa^ ^ Mft&L^xeao tM£t& /ya^-a^u/*/? £*-*S ~*:*c i^z^s^ tfU^M- yC^n^^n^aXyy-e, ^La^n. sff??/0 j^a^y ^nu^ jfc M/ li^77C^U^>7 J%zf P&L^S stl/a^ J?a*S srzc S-if/tA'/SOAJj &c S/^So. ot>35 .-.ao. .iou-uer, 138 (ten ..vs. 77 ,< 10302 136 nobert 1. ;ecchia — l ieaa eeaaer Jureau of ~ar;d ,-anu;ement Unccrapahjre 5asin aesource jjrea 2505 Jouth oownsend ..vs. Montrose, CO 31401 Sir, x have reviewed the ^raft o'ncompabjre Basin Resource i-anaseBient Ilan and environmental Impact Jtatement, and the itiiderness Technical oupuiement . 1 command y.u for y&ur fine efforts . rti though there appear to be no major resource conflicts with the designation cf the Camel jack wilderness Study Area as wilderness, 1 could not find in the above documents the rationale for your net recommending the H&A as suitable for wilderness. I would request that this issue be addressed in the ?inal environmental Impact etatenient. I visisted the Canel 3ack .J., and surrounding region in July of 1 966 , and was impressed with the ruj^ed landscape and -pportunities for solitude. It is an excellent area for wilderness day hikinr in a canyon country setting, all the more enjoyable since it is close to populated areas and is easily accessable. 1 believe that the Jamel 3ack ..'J.-, is suitable for wilderness designation, and encourame you to reexamine decision . Thank you for the oncortunity t' comment. sincerely, •7P- S6 68 136 Date, ft-}. 'SI 139 Robert E. Vecchla HKP Team Leader - BLH 2505 South Townsend Avenus Hontrose, Colorado 81401 Dear Mr. Vecchia, The following are oy comments on the Uncompahgre Baain Wilderness Technical Supplement, I 8W (do not) agree with the BLM's Proposed Action, the All Wilderness Alternative, for the Cunnison Gorge Wilderness Study Area. The Camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the No Wilderness Alternative. This alternative best exemplifies the multiple-use management. ^Site-specific objectives can be mitigated through the Allotment Management Plans. 140 //- Xi 86 ./_..; ^ M- ,.,...x_ - ii^ /L. y-cs/^ £J]e tv*tf « t I / U 4^. -75L l^-lo Ls*l>*— % sd~^« / r.ts.l' 1 •<*-*- L Signed, ;/. (^ ui«/ ^J' 7j> jlaJla-*^* ~7zi'- l^Atf.'*-'!'—* "L. tk.M rj- •<- no — ,"""n iimiiiiiiiiwiiiiiiiwi HBBSOBBIHUtBBBHHH iiw. 3, n?7. 141 Robert E. Vecchla BMP Team Leader *- BLM 2505 South TownSend Avenue Montrose, Colorado 81401 Dear Mr. Veochia, 86 66 68 136 The following are my comments concerning the Uncompahgre Basin Resource Management Plan and Environmental Impact Statement 1 The best alternative offered to support the multiple -use objective, with the fewest detriments to livestock grazing, la the 'Continuation of Current Management.' Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilise mineral and forest products, and protect our diverse recreation interests can be met on a site-specific basis. 66 68 136 142 Batei J\xnr> 3, ) *\ * 1- Robert E. Vecchla RKP Team Leader - BLM 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchla, The following are my comments on the Uncompahgre Basin Wilderness Technical Supplement! I $|M) (do not) agree with the BLM'a Proposed Action, the All Wilderness Alternative, for the Gunnison Gorge Wilderness Study Area. The Camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the No Wilderness Alternative. This alternative best exemplifies the multiple-use management. Site-specific objectives can be mitigated through the Allotment Management Plans. Jj. st&t* oL*. t-ip\ **> M^ alt. uJJJ«*-^ signed, ~^T) jlLa^j K Ga-a^JO + 30- /s-in KA 143 Robert E. Vecchla RHP Team Leader - BLM 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchla, The following are my comments on the Uncompahgre Basin Wilderness Technical Supplement! I £**} ^donot) agree with the BLM's Proposed Action, the All Wilderness Alternative, for the Gunnison Gorge Wilderness Study Area. The Camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the No Wilderness Alternative. This alternative best exemplifies the multiple-use management. Site-specific objectives can be mitigated through the Allotment Management Plans. * faVft %■/?*§■ Slgnedi 86 144 Robert E. Veochia RMP Team Leader •- BLM 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchla, The following are my comments concerning the Uncompahgre Basin Resource Management plan and Environmental Impact Statement] The beet alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, is the 'Continuation of Current Management.' Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation interests can be met on a site-specific basis. 'JUp 111 Dat«. 145 65 68 136 Robert E. Vecchta RHB Team Leader - BLM 2505 South Townsend Avenue Montrose, Colorado 81^01 Dear Mr. Vecchia, The following are my comments on the Uncompahgre Basin Wilderness Technical Supplement) I JBP (do not) agree with the BLM's Proposed Action, the All Wilderness Alternative, for the Gunnison Gorge Wilderness Study Area. The Camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the No Wilderness Alternative. This alternative best exemplifies the multiple-use management. Site-specific objeatWfes can be mitigated through the Allotment Management Plans. 86 146 Robert 2. Vecchia RMP Team Leader -- BLM 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia, The following are my comments concerning the Uncompahgre Basin Resource Management Plan and Environmental Impact Statementi The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, is the 'Continuation of Current Management.' Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation interests can be met on a site-specif j.c basis. '■ptjS^— 52 rir, /s> igned. P e- I»t°',<^7rWlj 'V Robert E. Vecchia RMP Team Leader - BLM 2505 South Townsend Avenue Montrose, Colorado 81 Wl 68 136 64 68 136 Dear Mr. Vecchia, The following are my comments on the Uncompahgre Basin Wilderness Technical Supplement] I £4fli-(dfl not) agree with the BLM's Proposed Action, the All Wilderness Alternative, for the Gunnison Corge Wilderness study Area. The Camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the No Wilderness Alternative. This alternative best exemplifies the multiple-use management. Site-specific objectives can be mitigated through the Allotment Management Plans. nJL/ *iA*^ (Uet &IH.-U ^ Ant*-- «tfct'*6±~<**-', <,£ *■*+*** '' .<.~M ****■ J*. nJM I* £f*~**-£. .^A ****** (UuttU. W ^ *L "e,^ **^" -^ A Signedi - imf ft *» lJmf< l fie** VS% /L^ - ^-/^^^w^9^ 151 Robert E. Vecchia RMP Team Leader "- BLM 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia, The following are my comments concerning the Uncompahgre Basin Resource Management plan and Environmental Impact Statementi The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, is the 'Continuation of Current Management.' Dg Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation interests can be met on a site-specific basis. 152 ■gi -DuJ&frt*- - ■^u- Slgnedt 7M suj*^ ikttrt-U I** f*m&> 121 66 68 136 1740-2723 Road Cederedgif, CO 0l4i3 NovBBher 2, 1 9^7 «o oert H. Vecchia KM? Tea* Lesaer-BLM 250b South Townsend Avenue Montrose, CO 91401 Dear Mr. Veccnia , In ti.e absence of what I view to be compelling argument for substantial change, I favor a continuation of the present management of land under BLM control; I favor the "Continuation of Current Management" alternative. Comments about the specific land uses addressed! Riparian Zones--! do not see In the "Plan" sufficient documentation presented to Justify elimination of 3500 acres from livestock use. I understand that in one Instance this action will create particular hardship for one ranching operation. I do not believe that this should be done without strong evidence of the need for such action. WllderneBB tesignatlon- - Based on the arguments I have heard and read, I do not find sufficient reason for a change in status of any of the three pro po Bed areas. in bllahlng rl ences lly the any nviaionB ccesses Access-- For thofle of us who own land and opera t the vicinity of the BLM lands, the idea of esta public access roada is a real concern. Our expe have fihown that an access is treated by especia hunting and wood cutting public as license to u of the landB they croaE. I doubt that the BLM e a sufficient lncreaae in staff to police sucn a which again leaves the very painful task to the individual landowner. Aa a concept I oppose access roads without the approp- riate controls; in the advent of a decision to create sucn accesses, I would hope that they will be selected so as to create a minimum of hardship to landowners. lhankyou for the opportunity to comment on your proposals. Sincerely , harry B. Vaughan 113 153 2184 Stonehenge Circle Lafayette, Colorado 80026 Nov.l, 1987 136 68 69 Dear Sirs; We are writing to inform you the following Colorado Desert Wild consideration . We thank you for recommending Gunnison Gorge Wilderness Area for prime wilderness and is tied in wi Gunnison River which are so import On the Camel Back arsa of the an explanation to your approach on resource . By your own admission, in regards to wilderness designati the BLM should support Wilderness none of this Uncompahgre Plateau h _ as yet. As far as the Adobe Badlands your decision to close the area to realize that there is virtually no we see no conflict in declaring wi _ this area. And one more thing; even thou not support the potential Storm Ki critical elk calving habitat and w veil the fact that there are mor parts of the State of Colorado, Storm King Mountain for elk and no Thank you for your time . Of our support in protecting erness Areas currently under all 21 ,038 acres of the protection. This land is th both the Black Canyon and ant for preservation. Uncompahgre Plateau, we want managing this wilderness ere are no resource conflicts We strongly feel that ignation for this area as as a single acre of wilderness are concerned, we appreciate off-road vehicle use. We resource to utilize here, so lderness designation for gh we are avid skiers, we do ng Ski Area site. As it is ould impact deer terrain as than enough ski areas in all implore that the BLM manage t ski developers . Laura S. Ray Wynfield Is*. ?~/ftf 154 86 Robert S. Veochla RMP Team Leader •- BLM 2505 South Townsend Avenue Montrose, Colorado 81 WI Dear Mr. Vecchia, The following are my comments concerning the Uncompahgre Basin Resource Management plan and Environmental Impact Statement! The best alternative offered to Support the multiple-use objective, with the fewest detriments to livestock grazing, is the 'Continuation of Current Management.' Under this policy, through Allotment Management plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and. salinity, utilize mineral and forest products, and protect our diverse recreation Interests can be met on a site-Specific basis. —&&-/jr-£~Jf'*» ■ MA* 68 136 155 Robert E. Vecchia RMP Team Leader - BLM 2505 South Townsend Avenue Montrose, Colorado 81W1 Dear Mr. Vecchia, The following are my comments on the Uncompahgre Basin Wilderness Technical Supplementi I /do/ (do^»%-) agree with the BLM's Proposed Action, the All Wilderness Alternative, for the Gunnison Gorge Wilderness Study Area. The Camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the No Wilderness Alternative. This alternative best exemplifies the multiple-use management. Site-specific objectives can be mitigated through the Allotment Management Plans. 156 Cjf^w- t/' 121 133 134 701 650 Road Delta, Colorado BI416 November 1, 1987 Mr. Robert B. Vecchia, RMP Leader Bureau of Land Management 2505 South Townsend Ave. Montrose, CO 8I4OI Dear Mr. Vecchia: The personnel in the Montrose office of the BLM have spent considerable time and effort on the Draft RMP/2I3 for the Dncompahgre Basin Resource area and I want to commend them for the quality of the document. It is too bad that only a comparatively small number of the citizenry of the United States, most of whom have never seen this area, have demanded this study which required a great deal of time and money that could have been used for some worthwhile endeavor. I thank the study team for making the right decision or. the Oamel Back W3A and the Adobe Badlands W3A. We already have too many of these areas set aside, and we are over a hundred years too late to have real wilderness areas. As far as the Gunnison Gorge is concerned, it is alreaiy too well ad- vertised to be of any value as a so called wilderness. However, it aeem3 unneces-* aary to reduce the livestock grazing in these areas that are showing improvement under present grazing conditions. Throughout the Draft RMP/EIS, the riparian zones are to be "limited to 55 percent utilization of key forage species and eliminated from March.- 1 through May 31" t for livestock grazing. Why not use the lower elevation stream areas in the spring when livestock use would invigorate the willows along the stream banks? Anytime a stream in a desert area is excluded from livestock use, the riparian zone will deteriorate. If livestock are excluded from any area, the big game will move out of that same area. The two ungulates seem to need each other. — As far as putting a percentage of use on so called "key species", I challenge this also. There is no such tning as a "key species". This is just a cliche used by some to make an impression on the layman. No plant Species is more of a key than is any other species. As far as percentage of utilization, this is another thing that is very questionable. It would be more practical to classify use as; light, moderate or heavy. This makes more sense since no one knows what 100 percent vegetation by weight was, or is, in any given area before any grazing occurs. In the more than 50 years since the passage of the Taylor Grazing Act, there has generally been a continual reduction of livestock numbers over the whole area of the Uncompahgre 3asin Resource Area. If by proposed management, as set forth in thi3 RXP/3I.%we are going to see so much improvement, then the ^ast reduction of livestock use has been to no avail. Why not change and get out of the "reduction rut" and try something such as the Hoiistice Resource Management. This is being proven to be advantageous in other areas. 114 ™\h 65 9R Concerning the endangered species and livestock use, the endangered 3pecies have survived more than a century of livestock use and are still here. Kay be these species need livestock or large ungulates io order to propagate, but due to people pressure, there will never again be popula- tions of big gaae animals large enough to take the place of livestock. While I am not well acquainted with the whole 'Jncompahgre Baain .Resource Area, I am very familiar with the Escalante Canyon area and, to a leaser degree, with the Roubideau Canyon. I visited the lower Roubideau Canyon recently and wa3 very impressed with the improved conditions that have taken place in the area over the past eight years. The vegetative cover in both areas has shown great improvement in recent years which proves that the present management is working there. Let's not change a plan that is proven to be beneficial. I see no reason for restriction nor reduction of livestock use in either area. There are more than 175 permitted livestock users in the Uncotnpahgre Basin Resource Area. These users are spending many thousands of dollars of their own money trying to improve these public lands. This money is over and above their grazing fees, and this shows that these people are the real conservationists. They are doing something to make their area a better place. I believe that everyone wants the same thing, to improve the resource area, and if we all work together there is no telling w.-.at can be accomp- lished. *'hy not have the recreationist pay to use the public land and why not have the DOW pay a grazing fee? In closing, let me remind everyone that in this area where the greatest percent of the land area is public land, the ranchers depend upon the contin- ued use of these public lands, but to an even greater extent, the wildlife are dependent upon the livestock use and the feed and privacy offered by the private lands. Sincerely, <5*^-<*. >; Jack Husser 157 701 650 Hoad Delta, n.O 81416 November 2, 1987 t'r. Robert Z. Vecohia, BMF Team Leader Bureau of Land Management — Uncompahgre Sasin Resource Area 2505 South Townsend Ave. Montrose, CO 8I4OI Dear Mr-. Vecohia: please find enclosed an article by Heather Smith Thomas, which wa3 recently published in the 139? live:--tt:-?.t Buyers Cuide v "atalOb'-e. a joint publication of; THE LIVESTOCK JOURKAL, TEXA3 FAHK AND RANCH HEWS, AND THE RECORD STOCKMAN. This article gives new insite into the livestock versus wildlife problem, and we feel it is worth consider- ation by the RKP team. Thank you for your work as the RHP team leader. News article available for review at BLM office. sincerely, P/MtaC, Cclc 8»i3t M01/ 2., IS?7 km 2. 18 VfcfrtiA MuiTKcic, Colo. Sltci T)ea« iftft Veccri.A, I i-'OULO LlKU TO CO,Y\Al£XJT CM THE dMfT Of The LUcorv\PAhC£t BA'iM (JesooHcl- C\ANA«(r>*ewT r^-AM. 1 ^upfic-e- ujiwo«/JcS5 "n>t"%ic^/^i i6«j pzf. rue ThC£l ft£*S fe»U(»Wfc» ,AtK ^"(SoU'SiOeiHI. cAnvc^) Mb AOOSc Si i>lAaj,j5 I a! the FiMAl CEScoiecj; /is SJiTJVftt* Fo«c uJilOcTEa-'ss TrtC CAmCL ^Aet: <-OSA «ro(v.Tftl«J5 T (Xn_Fb tf PfgetlUlM- tfeoaiOeAu ceegK As it ccr a^ 9«C foor t>ffp caaIvoaj TnT^JC,rt C«L««Fi/t. & A«J& STOAiE FoiinftTiG^j. THi S Miffs is Owe of Tus Faj (SemAiAi'iUi. fleAOujss A&rrvs u'Pt c*-5 Th; UAi^om pAna.ee PlatitAu.. .Scvctcal eM0AAi Of THE iK .Ti^A^ mcij^TAiAj'j /V'& THf Jr)ct,(«PRit-6«s ^v'ft i'au^oi /wo Afi» Hc-rt-ir to a^ t^^A*ctnfoli cAct THiS AfCA MA^i A 68 69 J1TH u0 1 L&i?S-WErS CX. iSTJAlT. 1>e^ltNftT1<«0 A£C t'.^l-MT [A L(_H NCK- X di-sr. l'Cc-.c Tfrs TiLm tc MAuAfce Tut i>T(_£,y\ ptlWfi SiT£ Fee. ET_K CAt^iMfi A^O AJ^t Gl/f Sf-I Ise/ELt. Pfflls A Fn/£- -VfAiC &Ca« feltiDft iw v^Kitu Tc Ptoc eETj WiTH THeSPI Aft*. TK A1 AtJ ACc>ntX>T A-AM IS SoPPoScrO TC A^CfS^ Amp/Vft.uTu Cr PfSoofirs MCT Ci« o«i A HETto SrA-er ^^cii THe CTrtelC 6 fV l~AuJfe^a: A, P/ AfP i^ai A'MO A(!s L£tt»j Pervxj-TiAu fflinj si£A-ts Aajo itA^ticrs 115 159 86 °"ei N»v. 3, 1987 Robert E. Vecchia RHP Team Leader *- BLM 2505 South Townsend Avenue Montrose, Colorado 814-01 Dear Mr. Vecchia, The following are my comments concerning the Uncompahgre Basin Resource Management plan and Environmental Impact Statement! The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, is the 'Continuation of Current Management.' Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation interests can be met on a site-specific basis. 68 136 Signedi ■°pp-iL„z 2^5. 160 Datei November 5, 198? Robert E. Vecchia RMP Team Leader - BLM 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia, The following are my comments on the Uncompahgre Basin Wilderness Technical Supplement] I (do) {M 4M) agree with the BLM's Proposed Action, the All Wilderness Alternative, for the Gunnison Gorge Wilderness Study Area, The Camel Back and Adobe Badlands Wilderness Study Areas will benefit most from the No Wilderness Alternative. This alternative best exemplifies the multiple-use management. Site-specific objectives can be mitigated through the Allotment Management Plans. Richard and I are true natives of this area. Our families, for two and three gen- erations before us, evolved their llvllhoods in the Camel Back, Winter Mesa, and Roubideau Creek area. It is written in stone in the Roubideau where my great -great Uncle and friends spent Christmas day in 1884. He was a cattle rancher who worked this very area. The next generation saw my great Uncle's brother-in-law homesteading the Ben Lowe place in the canyon, which is still in our family's ownership. The years of 1920 and 1928 saw my Grandfather, and Richard's Grandfather, holding grazing permits in these adjionlng areas. (These same permits are still held by our family members or us.) We grew up learning the history of this area from the actual people who first 'settled' it. This Roubideau Canyon shaped their llvllhoods, their lives, and their persons. (as it still does ours, today.) Through our heritage and knowing and living with the majestic beauty, the defiant ruggedness, the severe forces of flooding, and the extremes of weather causes us to truely understand and greatly appreciate this area. Tt is our home, our 'back yard', and we love it. The Camel Back terrain has defied change for, at least, over a hundred years of 'civilization' . And it still demands the same respect and offers the same subjects for appreciation, ,, without a title. We need more water development on the top and benches of Winter Mesa to better manage our entire grazing allotment. There would also be gr^at, long term benefits from chaining or timbering and reseeding in the saddle area between Winter and ?N Mesas. The road across the top of Winter Mesa is essential for catchment and fence repairs, and has been necessary for transporting sick and injured livestock. It is heavily used for big game hunting, recreatlonists, and some Division of Wildlife activities. With these factors in mind, therefore, our preference is only the No Wilderness Alternative for the Camel Back WSA. Thank you for your consideration of these comments, Signedi 161 1 Management 86 69 67 111 Date i November 5,1987 Robert E. Vecchia RMP Team Leader "- BLM 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia, The following are my comments concerning the Uncompahgre Basin Resoi Plan and Environmental Impact Statement! The best alternative offered to support the multiple-use objective, with the fewest detriments to livestock grazing, is the 'Continuation of Current Management.' Under this policy, through Allotment Management Plans, the objectives to enhance livestock grazing and wildlife and riparian habitats, control erosion and salinity, utilize mineral and forest products, and protect our diverse recreation interests can be met on a site-specific basis. a few additional comments and concerns are: We support the Bureau's position to continue your fact-finding process underway for the Storm Kinc ski development. Only when you and those Involved can analyze all the facts and Impacts can a valid decision be reached. The Uncompahgre Valley could certainly benefit from the diversity of income generated by this. - But our concerns are the same as others', le. ,Is the area in question now, or historically, a grazing allotment?, and- Will the lack of this elk habitat adversly affect the surrounding uses, both on public and private lands? We also have concerns about off road vehicle use. We support only the Current Management Alternative but there are areas which need to be under more strict restrictions from this activity. -Especially during crucial erosive periods, and while wildlife is under winter stress. Throughout the draft are references to Introducing desert sheep to the Camel Back area. We object to this proposal. Becausei 1. The only reliable water for this area is the Roubideau and Criswell creeks. Both are designated riparian zone habitats, and it has been suggested that limiting useage In these zones will improve them. Introducing more animal units to directly conflict with the historical use of cattle grazing and the crucial deer winter range is defeating our range management objectives. 2. The revenues derived from the grazing permits and deer hunting activities historically and are now progressive and dependable. This area is presently a study area for mountain lion with no hunting or trapping of them allowed. (Their numbers are increasing.) There are also coyotes there year around, and bear to the South in the summer months. With these ob- stacles it Is certain to take years for the herd (band?) to produce enough trophy-size animals for harvest. The money, time, and man-hours alloted for this could be better spent. Signedi continued on next page 98 117 121 / V-V; 163 28 103 27 87 68 136 116 4700 Venturi Lane Fort Collins CO 80525 November 1, 1987 Mr. Robert Vecchia, RMP Team Leader Bureau of Land Management Uncompahgre Basin Resource Area 2505 South Townsend Avenue Montrose, Colorado 81401 Dear Mr. Vecchia, This letter provides my comments on the Draft Resource Management Plan (DUMP) for the uncompahgre Basin Resource Area. I have made many visits to locations within this Resource Area, and am familiar with the beauty and resources it en coin pa 8 see. The Preferred Alternative of the DRMP ie inadequate in its attention to the botanical resources of the Resource Area. Although I support the Escalante Canyon ACEC and Fairview RNA, these areas need formal management provisions spelled out in the RMP. Escalante Canyon ACEC should be larger, should allow no livestock grazing, and should prohibit camping. Management intent with respect to utility corridors, roads, mineral exploration, grazing, and surface occupancy should be specifically listed for each SHA. Plant species and vegetation associations considered sensitive by the Colorado Natural Areas Program should be listed for the entire Resource Area, and if appropriate, additional Special Management Areas should be proposed in the final RMP, I oppose the proposed North Delta ORV use area as incompatible with management prescribed by the federal Endangered Species Act for listed plants. Although this area already has suffered damage, that is no excuse for BLM's abdication of its responsibility to preserve the remaining values. Because of their destructive potential on the fragile adobe badlands, I ask that ORVs be restricted to existing roads throughout the area. The Mancos- shale-der ived adobes of the Oncompahgre provide a Specialized habitat for numerous rare plants and plant associations. It is sad that the short-term pleasure of a few is considered more vital than an irreplaceable resource. Thank you for recommending the Gunnison Gorge WSA for wilderness protection. It is a spectatular area that, under wilderness designation, will be a valuable supplement to Black Canyon of the Gunnison National Monument. However, nowhere in the DRMP do I find sufficient justification for dropping Adobe Badlands and Camel Rock WSAs from recommendation for wilderness. In view of their wilderness characteristics, I favor a favorable recommendation for both areas. I ask that the final RMP clearly delineate the areas of riparian vegetation within the Resource Area, and list specifically the management plans for 163 116 119 -page 2 this vegetation type (as a separate unit, not fragmented, hidden, and thus — lost within the "Management Unit" format). Such plans should include complete exclusion of livestock grazing from the riparian areas. Please include my comments in the final RMP, and keep me on your mailing list for information regarding the RMP and Resource Area. Sincerely yours, sthMJboS rf. 1?Ka$Vu^ Susan S. Martin 164 136 121 111 November 4, 1987 Robert E. Vecchia Bureau of Land Management 2505 South Townsend Avenue Montrose, CO 81401 Dear Sir: I am in agreement that the Camel Back should continue to be managed by the BLM as it now Is. I prefer the no action alternative. For many years the Multiple Use Act has worked for the pre- servation of this area. The forage 19 harvested yearly by wildlife and livestock to help feed the hungry world. At no time have these uses interfered with recreational uses of these lands. This area does not lend Itself to wilderness. There are roads in the area and some fencing. The land is managed as it should be and the area is accessible to the general public. I was brought up on the theory that Public Lands were for Multiple Use. With proper management, these lands will provide us with food and fibre for all time to come, but we must be allowed to properly manage livestock grazing. Fences must be kept, stock ponds properly maintained and the range properly utilized to prevent over- grazing and forest fires. Reducing livestock grazing in the so called riparian zones would defeat the purpose of a riparian habitat. Many riparian species of vegetation are of low palatability to livestock. Streambanks in this area are unstable and water turbidity will occur in the absence of livestock use. Many flash floods come down these canyons each year as evidenced by the rocks and sandy washes. These streams usually dry up during the summer and when flooding occurs there is no way to hold the sandy, rocky dry banks. Some areas are definitely too dry for vegetation and defin- itely does not lend itself to streambank stability. Reduction of AUMs would defeat the purpose of a riparian zone when properly managed. Vegetation and the canyon areas has improved many times over in the few years since a riparian habitat was first introduced, even though the AUMs have remained the same. Riparian habitat properly managed should increase available forage. Bighorn sheep should not be introduced into the area. Lack of adequate winter forage should preclude this. Private land in the area would, of necessity, have to support these animals especially in the winter months. 117 164 67 69 It would appear that livestock, grazing has been given prac tically all the credit for increased erosion and for the destruction of habitats of big game and non game species. Thes< biased and founded without fact, temcnt-S are All these natural resources should be utilized thru a practical and beneficial program, not locked up for the exclusive use of hikers back packers and the affluent few with time on their hands. The young, too, grow old. They also will be denied access to roadless areas in their declining years when they are no longer able to walk or back pack long distances. The need to continue Multiple Use management of all Public Lands will provide forage for wildlife and livestock, minerals for energy development and protection of watersheds, the most valuable resource of all. The west has a valid existing right to keep these Public Lands open for all to use and enjoy. Creating wilderness areas does not guar- antee these lands for the enjoyment of future generations. Proper man- agement does. ^fosepltine M. Gore "445 Hwy 348 Delta, Colorado ■7?J~u^ 136 68 71 126 Gene Vecchia Bureau of Land Management P-2 165 8. Having almost 90 percent of the resource area open to ORV use is preposterous! Sgch non-management of these vehicles encourages ecological degradation, soil erosion, and the destruction of archaeological sites. 9. The Storm King Ski Area is NOT NEEDED- the present crop of ski areas can barely make a go of it so WHY develop another? However, the elk DO NEED their calving grounds, and the deer their fawning areas. No develonmentactivity should be allowed during the 5-year grace period proposed by BLM. Thank you for considering my comments. Sincerely, Danni L. Langdon 136 68 69 7 Chardonnay Court Grand Junction, CO 81503 3 November 1987 Gene Vecchia RM? Team Leader Bureau of Land Management 2505 S. Townsend Avenue Montrose, CO 8M01 Dear Mr. Vecchia: 165 1 offer the following comments regarding the Uncoznpahgre Basin Resource Management Plan and Environmental Impact Statement and Wilderness Technical Supplement 1 . The document is generally well-written-thorough and without the usual obscurities! 2. BLM's recommendation ofwilderness for the Gunnison Gorge is laudable. The gorge is geologically spectacular and offers war-round opportunities for primitive and unconfined recreation. 3. There are no resource conflicts with respect to Camel Back, yet BLM has failed to recommend any of the WSA for wilderness designation! On what was this recommendation based? 4. Adobe Badlands WSA, as described by BLM on p, 3-11, "includes the most outstanding Mancos shale mesa formations found in the planning area" and presents no resource conflicts that would preclude wilderness designation. So why was this WSA given a non-wilderness recommendation? 5. The cultural resource density within the Gunnison Gorge WSA compotes at .003/acre, and the potential for cultural resources is evaluated as "moderate." The cultural resource density within the Camel Back WSA computes at ,01/acre, and the potential for cultural resources is evaluated as "low to moderate." Please explain the justification for these evaluations and this discrepancy. 6. While a site density of .01/acre may be "low" in some contexts (e.g., south- western Colorado), it is not "low" in west-central Colorado. Furthermore, 1 don't know which 3 percent of the Camel Back WSA has been inventoried, but I am dubious about site-frequency predictions made from such small samples. This area contains three perennial creeks and is topographically similar to the Dominguez and Eecalante areas, both of which have proven to be extremely archaeologically sensitve. 7. It is stated on p. 4-57 that 'High-value cultural sites on these acres could be protected by special designations. " How? 166 jjOnofesr iv.«:7 Dear Gene Vecchia. First I »'ant to thank you for recommending the Gunnison Gorge area for Wilderness designation It is very important thai we preserve intact significant areas of desert ecosystems I do not understand vfty you did not recommend the Camel Back area for Wilderness protection as veil The BLM even said that there are absolutely no resource conflicts with wilderness designation of the area The I'ncompahgre Plateau is one of Colorado s major landforms. yet none of it is protected as Wilderness I would like to know why There are several endangered plant species in the area and big game herds that would benefit from wilderness protection I also want to know why you have chosen not to recommend the Adobe Badlands lor Wilderness designation Obviously there are no trees there for the limber industry, and the four dry oil and gas well prove the low- potential for mineral development. There are no significant conflicts for wilderness designation. Please manage Storm king Mountain for elk. There are more than enough ski areas land I am a skier I in Colorado, and wildlife habitat is an ever- dimishing resource The BLM says that the ski development would totally eliminate the elk calving grounds as well as impact mule deer fawning areas The plan to give the developers a five year grace period" in which they may proceed with the ski area is ludicrous. After five years of working on the resort, it will be very convenient for you to allow them to continue since they will have put so much money into it, This sounds like a roundabout way to avoid dealing with an issue that needs to be confronted and dealt with now, while we still have undisturbed ecosystems left Please don t be afraid to take a stand in favor of protecting the wide-open spaces that make the American West what it is I would appreciate your response to these issues. Sincerely. CrtA/i-a Susan Detweiler 64 Willard Boulder. CO 80310 118 2832 Unaweep Avenue Grand Junction, CO 81503 3 November 1987 167 68 136 69 Gene Vecchia RMP Team Leader Bureau of Land Management 2505 S. Townsend Avenue Montrose, CO 81401 Dear Mr. Vecchia: 1 would like to make the following comments regarding the Uncompahgre Basin Resource Management Plan and Environmental Impact Statement and Wilderness Technical Supplement. I, I support BLM's recommendation for wilderness designation for the Gunnison Gorge and I am In favor of similar designations for the Adobe Badlands and Camel Back WSA's. Why, if there are no resource conflicts, has BLM not recommended them for wilderness? 2 The Storm King Ski Area is unnecessary; Colorado has enough ski areas, most of which are constantly complaining about their financial struggles. Thank you." Sincerely, ^£^u/ CtWW- Bella Conner 169 47BH Ventun Lane Ft . Co 1 1 ins . CO November 2 . 1987 Mr. Robert Vecchia. RMP Team BLM. Uncompahgre Resource Ar 2505 South Townsend Ave. Montrose. CO 91401 Vecchia. Un ish to com mpahgre R nt on the Draft Resource Management Fla 68 136 116 119 27 100 67 Please recommend both Adobe Badlands and Camel Back WSAs for potential designation as wilderness. The DRMP g ives no good reasons why each of these areas should not be recommended , and clearly describes the loss of wilderness characteristics that will occur if they are not so designated. It makes no sense to a 1 low the few remaining areas still having such characteristics to be degraded. I support the recommendation of Gunnison 05org=- ! £€^<^nj .Lis-A^^^c^J AjttanU*^ __,* virWr.*. *?&+!-„ tjXfVf^t_ jAr — - y ow . vv~u-s ,Sr ,J*r- ?l lc**m~.-0i&Jbe,.-: ^0"ii>v K C(v.<- i QV3tO L19 68 136 171 1045 E. 4th Avenue Durango, CO 81301 November 5, 1987 Gene Vecchia RHP Team Leader Bureau of Land Management 2505 S. Townsend Ave. Montrose, CO 81401 Dear Mr. Vecchia: I am writing you to express my support for additional wilderness recommendations by the BLM in the Uncompahgre Basin Resource Management Plan. I'd like to thank you for recommending wilderness designation for the Gunnison Gorge WSA in the draft RMP. As I'm certain you know, this area contains a significant diversity of recreational and scenic resources worthy of preservation. There are two additional KSAs, Adobe Badlands and Camel Back, that I believe deserve wilderness designation and should receive BLM recommendations for such designation in the final RMP. There are few landforms more obviously meeting wilderness criteria than the Mancos shale badlands typified by the Adobe Badlands WSA. Although this area has relatively easy access, little interest has been shown in extractive development. With no resource conflict and management plans expressed in the draft RMP to close the area to off-road-vehicle use, wilderness designation is an obvious and proper route for preservation of the area. Likewise, there are no resource conflicts in the Camel Back WSA As one of the few remaining areas of true wilderness on the Uncompahgre Plateau, this area merits protection as a component of the National Wilderness Preservation System. A majestic canyon system with a perennial stream, Camel Back can orovide a remote recreational experience for the backcountry hiker, and wilderness designation would provide protection for fragile riparian habitat and rare plant species in the unit. I urge you to reconsider your position on Adobe Badlands and Camel Back and recommend those areas, in addition to the Gunnison Gorge, for wilderness designation. Sincerely, Lewis McCool 173 jJCZaY-^/fAj __& JIujmL 68 136 / 1/K ryorrtiSr/f SiAr r?a/,c fY(oW/>jt,~xf?-rj /Mrr/jrl f:o.i JMp&e no /%n j&JjlSMM t/1 /ifirhcr-. izhafjkl, tkz. f/SAaCS y /.. y) // "tcVifiiir'S /rh.-lrrfnnt^ ur'/ci,u> If/fit b . 9/0/1 //■> k/Jub/ftfGu 'Cre^r and ' iJo'iPmpghrrf. ^afraiJ . find Ml firfa a Lo in m fcrrj, .Xtrfr*/ w^.W y*>ru>; <,/- p/aniZ.^tho, tfc /Q ,H?r fitfirrk */ ;.u/r*rn,-v. P i/\ ArS/x fatiAinJ? f,,nfran $%, term/fa I (S^rJorn /.:ointriirr> an) ffr Um,yiry>Q/ib/?r<- !sZ^lC__._ kwY jj^% arc A:vT)f of rrvrlinrrraf rrSr.ru*> l^Z I Uf—- . fi L-L—Y. C-LUJLULi K,£ iJ W.i.^1 -i-J. lt-f.^, i-LA.U <,T.J„ . stf/ if ftn Ifiirr/ deserve tn ip ars'/rfn^brr-? fl<> protfc+rd (/.'//rferryss SM / ftij/Pe Sla-i % SfWrr*? ,fa ntf/siam on rjjm=r 'fat- anr) sfJabr . ?aJ/r. r/f!fitPt ]££rjifi\fflA'-fo&; J^-fri/k/yi Jf/fcrpM jr/i .(n,^ eubuiriftH (D uJli&ArUiOA /CCvJ's — -feJUcaf( "aA/Tidi 'b'cejZaJ 63 135 -f^u\ *±Kj.2j^JU\3 5. UDv^l- a L"f ~-o 4m 67 l\%T-d ^otx^ -Hajl (U VJ intiii. ijo tiJ Wr,c\ Mo 44%a Oe\Jt -L kiXAcUUj. cdYxyxAju* -Haj2_ jaA:,. pyi'iCu 6 1 4o °3cJ£ JL -+ivo p^jr\tuj\a OS. &L.V3 110 85 louyn- ffX^YX^cr^L.^d ~ -H\jLci djZ&xJYra &Q$,\j-tHiw>e i^e^Vj i "rxflLul-uw h>zliifiAj2- yjg. amo isJeTVu: 1 I ' — ^ ' j n ib J ' Q3a*tL.>J-uiyfl to J-J-n IPC *4& _L PiU VS TrW-e. -H-ud- -^" 'Suri ^oU' ^ ^4^0.^.4 85 172 cWn i^jl iiiLL _, ia.^1 4W Hiuti loUjI i^uec a, ipo^„TT ^Y-, ■~j4\Jj ^^_^ a/-u."°\|yoiAt-o cn>ei> ^cruji lar\d pSIx-ou- Ons. ^1 soMiryp^jj _L LOiTKilcl LJc^e 4x3 -^>j -mom ^TTw L^ 5e nca '.AJtJLsu , So^JcL) CO %02&(c 120 RESPONSES TO PUBLIC COMMENTS Table 3 presents the BLM's responses to comments submitted during the public comment period. The response numbers correspond to the numbers on the margins of the hearing transcripts and comment letters. The commenter or letter numbers correspond to the numbers on the upper right corner of each page of the hearing transcripts and comment letters and identify the individual commenter (see Table 1 and Table 2). Responses are arranged by resource or resource use. Responses explain why a particular issue was or was not addressed, clarify the BLM's position on some issues, state whether a text change was made, and refer the reader to applicable sections of this document or the Draft RMP/ EIS. The responses must be read in conjunction with the appropriate comments. Table 3 RESPONSES TO PUBLIC COMMENTS RESPONSE NUMBER COMMENTER OR LETTER NUMBER BLM's RESPONSE TO THE COMMENT AIR QUALITY 58 31 There is a pervasive misconception that recommendation and designation of new wilderness areas is automatically tied to restrictive federal Prevention of Significant Deterioration (PSD) Class I air quality status. There is no such connection. Certain existing national parks and wilderness areas were designated as mandatory Class I areas by Congress in the 1977 Clean Air Act Amendments, but since then each state is and has been responsible for any redesignation. Since 1977, several areas in Colorado have been designated as wilderness but none have been redesignated as PSD Class I. The state of Colorado identifies air quality areas as Category I, II, and III; the sulfur dioxide limitations in the state categories are identical to those established for federal PSD Class I, II, and III areas. In 1977, the Gunnison Gorge Recreation Area was designated a Colorado Category I area; it remains a federal PSD Class II area. COAL 31 32 16, L-21 16 The development of thresholds was considered as required by 43 CFR 1610.4- 4(i); however, since all of the coal in this area is to be extracted using underground mining methods and since mitigation has been built into the management prescriptions and no major adverse impacts are anticipated, the establishment of thresholds was not deemed necessary. Under the Continuation of Current Management Alternative, only emergency short-term lease applications and maintenance leases would be considered. The average increases under the other alternatives allow for consideration of future long-term leasing of lands with coal potential. The land-use planning groundwork presented in this plan will enable the BLM to respond more quickly and efficiently and avoid frequent amendments to the RMP if there is a future demand for coal. It also provides industry with a variety of coal qualities with which to meet future market needs. 121 RESPONSES TO COMMENTS Table 3 (continued) RESPONSE NUMBER COMMENTER OR LETTER NUMBER BLM's RESPONSE TO THE COMMENT 33 8, 16, L-21 34 42 45 L-2 16, 22, H-3, L-21 16, L-21 46 16, L-21, M-12 72 L-21 A summary of the application of the coal unsuitability criteria is described in Chapter One, pages 9 and 10, of the Draft RMP/EIS. As stated in the cover letter (the first page of the Draft RMP/EIS) and again on page 1-8, the coal unsuitability report is available for public review and comment. This report describes in detail the lands in the Paonia/Somerset coal planning area and a portion of the Bookcliffs coal planning area which are deemed unsuitable based on the 20 unsuitability criteria. The management of the lands around the Tomahawk Mine has been changed in the Proposed Plan. These lands are now included in Management Unit 7. (See plan map.) The acreages available for coal leasing consideration do not vary much between alternatives since all mining would occur underground. There were no multiple- use trade-offs or resource conflicts that prevented lands from being considered as suitable for coal leasing. The final regulations regarding increased emphasis on the six criteria mentioned were not finalized until December 1987, six months after the release of the Draft RMP/EIS. These criteria were, however, analyzed in the Draft RMP/ EIS. Riparian areas are protected in Management Units D-9 and D-ll. The other criteria (sole source aquifers, wetlands, Class I air quality areas, and buffer zones around National Park Service areas) were not addressed because there were no impacts to them or, as in the case of reclaimability, the impacts will be analyzed when a potential coal lease tract is delineated. The RMP does not make any coal leasing proposals. Coal leasing levels are established by the Secretary of the Interior through the regional coal teams (43 CFR 3420.2). The RMP does analyze the four coal screens described on page 1-9 and identifies whether the coal is available for coal leasing consideration. If there is a demand for coal in the future, coal within the areas identified as available for coal leasing consideration will be analyzed on a tract-specific basis. The BLM cannot lease coal for which there is no industry interest. The coal leasing process includes a detailed site-specific analysis of potential impacts of proposed lease tracts following tract delineation. Mitigation to eliminate or lessen anticipated impacts is identified at that time. Mining or associated activities would not be permitted where it is known that ground or surface water impacts would result. The BLM recognizes, however, that some degree of risk and the occurrence of unanticipated impacts does exist. OIL AND GAS 35 38 17,32 3 2,9 This information is contained in the Oil and Gas Technical Report which supports the RMP and which is available for public review. By not making the Oil and Gas Technical Report a part of the RMP (i.e., an appendix), it can be updated and revised without amending the entire RMP. The text on page 2-3 of the Draft RM/EIS has been changed. See the Changes to the Draft RMP/EIS section of this document. The effects of aquifer mixing are not discussed because of the low level of oil and gas activity. In addition, the immediate and long-term impacts on water resources are not significant because measures are taken at the drilling stage to prevent aquifer mixing and other groundwater impacts on a site-specific basis. 122 RESPONSES TO COMMENTS Table 3 (continued) RESPONSE NUMBER COMMENTER OR LETTER NUMBER BLM's RESPONSE TO THE COMMENT 44 47 16, 24, L-21 The oil and gas resources in Management Unit D-9 would be open to leasing with standard lease terms as described on page 3-29 of the Draft RMP/EIS. In addition, a more comprehensive analysis of oil and gas activities is included in the Oil and Gas Technical Report, which is available for public review as stated in the cover letter to the Draft RMP/EIS. The Connors vs. Burford decision pertained to the leasing of lands in the National Forest system and not to public lands administered by the BLM. The BLM feels that a comprehensive and cumulative analysis of oil and gas activities is discussed in the RMP/EIS and also in the Oil and Gas Technical Report. As stated in the cover letter and on page 1-8 of the Draft RMP/EIS, the Oil and Gas Technical Report is available for public review. OTHER MINERALS 36 39 41 43 2.2 18 The statement is correct. The mineral leasing process is conducted in such a way that the risks of water injury are minimized. It is the responsibility of the lessee or claimant to mitigate any injury to an adjudicated water right. Current policy does not permit mining and disposal of mineral materials in floodplains if the floodplains will be adversely affected. There is no criteria used to permit this activity on alluvial valley floors. Mining on alluvial valley floors is regulated only for coal mining, not disposal of mineral materials. If there are proposals for disposal or mining of mineral materials on alluvial valley floors, they will be analyzed on a site-specific basis to assure all impacts are mitigated. Management of this area allows for low but evident human concentrations and impacts. Mineral exploration and development is not in conflict with this management guidance and does not, therefore, necessitate maintaining the existing mineral withdrawal. The mineral resources (including production figures) were identified in greater detail in narrative and overlay formats in the Management Situation Analysis (MSA). As stated on page 1-8, the MSA is available for public review and comment. Information from the MSA was condensed and summarized for inclusion in the Draft RMP/EIS. As indicated in the environmental impacts section (Chapter Four) of the Draft RMP/EIS, the Preferred Alternative presented little or no impacts to mineral development, especially for high potential minerals. SOILS AND WATER RESOURCES 73 74 When reviewing site-specific actions, the BLM will comply with state water quality standards as noted in the introduction to each alternative prescription. Existing water quality standards are established by the State of Colorado, not the BLM. Information on these standards is available at the BLM's Montrose District Office. The amount of data available precluded incorporation into the RMP/EIS. The BLM does monitor water quality on public land to ensure compliance with established standards. This information is also available at the Montrose District Office. 123 RESPONSES TO COMMENTS Table 3 (continued) RESPONSE NUMBER COMMENTER OR LETTER NUMBER 75 76 77 8 78 8 79 8 80 8 81 82 83 9,H-7 23 BLM's RESPONSE TO THE COMMENT The BLM has a representative on the Colorado Non-Point Source Advisory Committee which is currently developing the Section 319 Assessment Report. When completed, this report will identify non-point sources on public land. The specifics of Section 319 program projects will be incorporated into BLM activity plans. Salinity and sediment, the two primary water source issues addressed in this RMP/EIS, are also discussed in the 1986 Colorado 305(b) Assessment Report. Site-specific monitoring is a follow-up process for objectives identified in activity plans. As activity plans are developed, monitoring studies designed to evaluate progress in attaining specific objectives will be developed. "Local surface waters" refers to the water resources within the drainage where the impact is occurring. Domestic water users of water from public land were contacted during the preparation of the Draft RMP/EIS. No water quality problems, potential impacting activities, or water quality improvement needs were identified. Aquatic habitat activity plans would be designed to meet or exceed the water quality standards for each particular area. The assumption is that AMP objectives for increased ground cover would be met, even if adjustments to the grazing systems are required. The text in the Proposed Plan reflects this assumption. The BLM administers the public land under numerous Acts, Executive Orders, Secretarial Orders, etc. The BLM feels erosion and water quality can be improved through proper management without the need for on-the-ground erosion control projects. Each of the alternatives was designed to comply with existing laws and regulations. The impacts that are identified on pages 4-44 through 4-60 are often based on a worst-case scenario; they are not proposed management directions, which are identified in Chapter Three. Impacts to aquifers are discussed in each alternative prescription under a section called Impacts to Water Resources from Locatable Minerals. See pages 4-4, 4-14, 4-30, and 4-39 of the Draft RMP/EIS. Watershed protection for the Gunnison River through the Gunnison Gorge is identical in both the Conservation and Preferred alternatives. RIPARIAN/ AQUATIC SYSTEMS The 200 AUM reduction is not a management action but rather the impact on livestock grazing that would result from limiting forage utilization in the riparian management unit to 35 percent. The intent of the restrictions on forage utilization and spring period grazing is to enhance recovery of woody vegetation and reduce soil compaction and bank damage during the wet, spring season. The figures used on page 4-53 of the Draft RMP/EIS are actually impacts to aquatic habitat from other uses, and are not the result of the prescription for Management Unit D-9. The 70 miles recommended for intensive management includes the 40 miles in Management Unit D-9 along with additional miles that would be improved or protected through intensive grazing management and other actions. 124 RESPONSES TO COMMENTS Table 3 (continued) RESPONSE NUMBER COMMENTER OR LETTER NUMBER 24 40 97 113 114 [16 8, 9, 23, L-21 2G 30 30 23, 163, 169 117 161 118 BLM's RESPONSE TO THE COMMENT 119 9, 16, 23, 163, 169, L-21 The 1,034-acre figure in Table 2-5 (page 2-8 of the Draft RMP/EIS) describes the actual existing riparian vegetation within the planning area. The 6,320 acres in the Preferred Alternative and other figures used in other alternatives reflect acres that would be managed for riparian improvement. This includes areas without existing riparian vegetation. Current withdrawals do not restrict sales of mineral materials or mineral leasing. Revocation of the withdrawals would open the lands to mineral location under the 1872 Mining Laws. The BLM feels that current laws and regulations provide sufficient means to allow mining and still protect water quality and stream hydrology. The numbers appearing after the stream names (e.g., Gunnison River No. 3) are the identifiers used by the Colorado Division of Wildlife for specific sections of a given stream. Although there has been some improvement in stream bank cover in some areas over the past 10 to 20 years BLM data does not indicate this improvement is widespread or that optimum conditions would be obtainedunder the continuation of current Management Activities. The BLM recognises that differences exist within and between riparian areas. Specific management objectivities and guidelines would be developed in Allotment Management Plans or other activity plans. Riparian vegetation in the planning area generally exists as small, isolated areas along stream channels; the size of these areas precludes identification at the 1:200,000 scale of the RMP maps. Those areas which have the highest potential for improvement were identified in Management Unit D-9; management in these areas would be geared for riparian improvement. Other riparian areas would be either maintained or improved under the Preferred Alternative even though they are not identified individually. The 35 percent utilization limit proposed in the Draft RMP/EIS would be the upper limit for livestock utilization only. There is no evidence at present to indicate that big game animals concentrate in, or make substantial use of, woody riparian vegetation within the planning area. The greatest concentration of animals occurs during the winter months; however, snow cover reduces big game dependence on free water sources, and animals do not concentrate in riparian areas. Improved water sources on the bench areas would improve wildlife habitat and distribution during the warmer months, but most of these sources would be frozen during the winter. The management of riparian areas as described in each of the alternative prescriptions conforms to BLM's riparian policy, EO 11988, and EO 11990. None of these policies or Executive Orders exclude all negative impacts to riparian vegetation or aquatic habitat. Public lands are managed by the BLM for a variety of uses which, in most cases, can be compatible with appropriate stipulations. Specific objectives for improvement would be incorporated into new or existing activity plans after the Record of Decision for this plan is completed. The restrictions the BLM is recommending are anticipated to result in riparian improvement. Monitoring studies would be utilized to determine if additional restrictions are needed. 125 RESPONSES TO COMMENTS Table 3 (continued) COMMENTER RESPONSE OR LETTER NUMBER NUMBER BLM's RESPONSE TO THE COMMENT 121 11, 12, 30, 148, 152, The term riparian is defined on page A-39 of the Draft RMP/EIS. Year-round 156, 161, 164, M-l, surface water is not necessary to maintain healthy riparian vegetation. In the M-3, M-5, M-6, Proposed Plan, the limit of 35 percent utilization would be used when other M-l 4, M-l 5 methods of improving riparian vegetation have been unsuccessful. The BLM has a substantial amount of information which supports even more severe restrictions than those in the Proposed Plan. However, based on the current conditions of the riparian areas, it is felt that substantial improvement would be obtained through other methods (i.e., changing season-of-use) and that a 35 percent utilization limit would be implemented only if necessary. THREATENED AND ENDANGERED SPECIES 11 7 Table 2-6 and Table 2-8 have been changed (see the Changes to the Draft RMP/EIS section in this document). 27 8, 9, 16, 23, 163, 169 The text has been changed; see the prescription for Management Unit 8 in this document. 99 7 The U.S. Fish and Wildlife Service would be consulted prior to any surface disturbance or the deveopment of any activity plan which may effect listed species or their habitat. 100 9, 23, 169 Tracts with known populations of threatened and endangered species are no longer identified as suitable for further consideration for disposal. All tracts would be inventoried for listed, candidate, and sensitive species prior to being offered for disposal. 103 9, 23, 163 The BLM consulted with the Colorado Natural Areas program throughout the development of the Draft RMP/EIS. Table 2-6 (page 2-10 of the Draft RMP/ EIS) identifies all protected species known to occur within the planning area. Astragalus wetherillii has been added to Table 2-6 (see the Changes to the Draft RMP/EIS section of this document). All of the species listed on Table 2-6 are also on the State list. There were no other areas of public land identified for special protection within the planning area. 1 04 9,16, L-2 1 A pre-disturbance clearance is conducted prior to the authorization of any surface- disturbing activity and occupied habitat is avoided. Monitoring studies designed to monitor long-term population trends and to detect impacts from livestock grazing and ORV use have been established in several areas. 105 M-3 Some species of cacti, such as prickly pear, can be spread by livestock use. Available data does not show that the spineless hedgehog cactus is benefitted by livestock grazing in any way. 106 30 Based on the objectives of the Conservation Alternative, maximum protection was afforded the special plant resources in this management unit. In addition to the federally-listed plant species occurring in this area, the management unit was designed to afford protection for unique plant associations which are grazed by livestock and are readily accessible. 135 23 The protective measures mentioned on page 3-2 of the Draft RMP/EIS do extend to BLM sensitive species. They do not extend to State sensitive species or plant associations unless these species are included in the Colorado BLM's sensitive species list. 126 RESPONSES TO COMMENTS Table 3 (continued) RESPONSE NUMBER COMMENTER OR LETTER NUMBER BLM's RESPONSE TO THE COMMENT WILDLIFE HABITAT 29 96 98 L-21 34 156, 161 107 109 M-12 110 172 111 21, 161, 164, M-15 Timber harvesting in this area would be designed to improve elk calving habitat. These design features could include season of harvest, increasing the rotation age, and harvesting to increase small openings in dense stands. The badlands areas are not suitable habitat for bighorn sheep. Requiring the Colorado Division of Wldlife to pay grazing fees is an issue which goes beyond the scope and purpose of this RMP. At present, the BLM does not receive a percentage of the State's hunting license fees. However, the BLM has received contributed funds from the Colorado DOW for cooperative project work to improve wildlife habitat on public lands. These funds are derived from license fees and have amounted to a considerable sum statewide. We agree that wildlife do receive spin-off benefits from some range improvement projects funded by the BLM and grazing permittees. Present conflicts for forage between livestock and wintering big game are isolated. The Preferred Alternative allocates additional forage to wildlife in most of those areas where conflicts between private interests and wintering big game are occurring. The BLM recently inventoried Fruitland Mesa for sage grouse strutting and wintering areas. The Colorado Division of Wildlife has been, and would continue to be, consulted prior to any habitat modification. The present sage grouse population is too small to be considered suitable for hunting and the available habitat is so limited that little can be done to increase the population. Under the Preferred Alternative, every effort would be made to maintain the present sage grouse population. Many areas which were once available for big game use have been converted to other uses, such as agricultural and residential developments. With less habitat available on private land, it becomes necessary to selectively open up some closed pinyon-juniper stands to provide more forage on public land, especially in wintering areas. Prior to removal of the pinyon-juniper, the needs of other species using the area are identified so that system diversity can be maintained or improved. Prior to reintroduction of desert bighorn sheep into the Camel Back area, a site-specific environmental analysis which would identify potential impacts would be completed. The reintroduction of desert bighorn sheep into similar habitat in Dominguez Canyon in 1983 has not resulted in detectable conflicts with livestock, big game, or riparian vegetation. Although bighorn sheep would use the streams as water sources, they would not remain in those areas where dense vegetation inhibits their ability to recognize predators and hazards. LIVESTOCK GRAZING 26 70 30 20, 34, H-6 The text has been changed; see the prescription for Management Unit 12 in this document. The Preferred Alternative (page 3-30, Draft RMP/EIS) also provides guidance for livestock grazing management. Public land administered by the BLM is managed for multiple-use. Livestock grazing is a legitimate use of public land and can be managed to avoid detrimental effects on sensitive areas. Under the Preferred Alternative, livestock grazing would 127 RESPONSES TO COMMENTS Table 3 (continued) RESPONSE NUMBER COMMENTER OR LETTER NUMBER BLM's RESPONSE TO THE COMMENT 127 128 129 131 132 133 134 H-2 129 21 30 30, 156 156, M-6 be limited to 35 percent utilization and the season of use would be restricted. ORV use and other surface-disturbing activities would also be restricted to improve watershed conditions. The BLM anticipates that both soil and vegetation conditions would improve as a result of the implementation of these measures. AUMs were estimated to increase by one percent per year for 10 years for impact analysis purposes only. This assumes that land treatments and more intensive grazing systems would be successfully implemented. Livestock grazing is already restricted around most developments and facilities. The BLM would be willing to work with the Bureau of Reclamation (BOR) in adjusting or restricting livestock use where the BOR has identified adverse impacts from grazing on developments or facilities. The BLM's livestock management program is designed to eliminate overgrazing and to improve vegetation condition. The Preferred Alternative would accomplish this through improved management, facility development, and land treatments designed to improve forage condition. Studies have shown a substantial increase in forage species' vigor and density following successful land treatment projects. The decreases in AUMs in the Camel Back and Adobe Badlands WSAs are not proposed reductions; rather, this is the anticipated impact resulting from the 35 percent utilization restriction that is a part of the management precriptions for the riparian and salinity areas. Under the Conservation Alternative, livestock grazing and drifting would be completely eliminated in the Escalante Canyon RNA, Management Unit C- 2. However, this would not preclude trailing of cattle on the Escalante Canyon road. Percent utilization is the amount — based on weight rather than height or appearance — of a plant's current growth which has been removed. Key species are those plants that, because of their importance, are monitored to evaluate whether objectives are being met. Reductions mentioned in the Draft RMP/EIS reflect estimates under worst- case situations and are for impact analysis purposes only. Actual adjustments would be determined through long-term monitoring in accordance with grazing regulations. The BLM's philosophy for proper range management incorporates range management principles and various systems or philosophies, such as holistic resource management, where appropriate. RECREATION AND VISUAL RESOURCES 12 50 53 25, H-5, H-8, H-10 1 These concerns have been addressed in the Addition to the Gunnison Gorge Recreation Area Management Plan. Table 2-16 (page 2-19 of the Draft RMP/EIS) has been changed to include the proposed Curecanti National Recreation Area. The Fruitgrowers and Paonia areas will be evaluated for scenic quality and visual sensitivity when the BLM revises its visual resources inventory. As stated on page 1-8 of the Draft RMP/EIS, additional background information concerning recreational use is available in the Management Situation Analysis. The only adequate information the BLM has on actual recreation use is for 128 RESPONSES TO COMMENTS Table 3 (continued) RESPONSE NUMBER COMMENTER OR LETTER NUMBER BLM's RESPONSE TO THE COMMENT 59 65 69 120 24 112, 156, M-2, M-3 14,16,22,36,37,38, 41,42,44,45,46,48, 52, 53, 54, 56, 57, 58, 60, 62, 64, 66, 67, 68, 71,73,74,76,77,81, 91, 95, 97, 98, 107, 110, 119, 122, 123, 128, 130, 136, 153, 158, 161, 165, 166, 167, 168, 172, H-8, H-10, H-ll, H-12, L-5, L-8, L-9, L-ll, L-13, L-14, L-16, L-17, L-18, L-21, M-4, M-7, M-8, M-12 22 the Gunnison Gorge. All other recreation use is estimated from staff observations and from recreation users' comments. The management prescription for part of Management Unit D-4 (15,610 acres) calls for a minimum of restrictions on surface-disturbing activities. The remainder of the unit (25,182 acres) would be managed for low but evident human concentrations and impacts. Leasing for oil and gas is not in conflict with this management guidance and, therefore, does not necessitate closing the area to leasing. The BLM may charge a user fee for recreational use of the public land if a permit system is in effect. Normally, a permit system would be considered only in a Special Recreation Management Area, such as the Gunnison Gorge, and not in extensive recreation areas. Costs of implementing and enforcing a fee system throughout the planning area could be prohibitive. The management prescription for Management Unit D-10 of the Preferred Alternative has been rewritten for the Proposed Plan (see Management Unit 10 in this document). The new prescription reflects management of the unit to enhance its use as an elk calving area. Specific interim management related to the potential ski area proposal has been deleted; the public lands within the unit would therefore be managed for extensive recreational use as indicated on page 3-30 of the Draft RMP/EIS. At present, information available on the potential ski area is insufficient to determine its compatibility with wildlife habitat, timber production, and coal production. Should a completed and final ski area plan be proposed, it would be considered in light of this plan's Record of Decision, resource conditions, and other pertinent factors existing at the time the proposal is submitted. Under the Preferred Alternative, management direction for this area would emphasize elk calving. It was assumed all impacts to elk calving use from ski area development would be mitigated prior to approval of the ski area proposal. OFF-ROAD VEHICLES 55 67 50, H-2 64 9, 11, 16,23,24,30, 34.50,64, 112, 135, 161, 163, 165, 169, 172, H-2, L-21, M-2, M-13 The expense involved prohibited the inclusion of large, detailed ORV maps in the Draft RMP/EIS. It was felt that the smaller maps in Appendix G would serve to indicate potential problems from ORV proposals. More detailed maps were available upon request (see page A-21, Draft RMP/EIS). The Preferred Alternative recommends more acres for limited ORV use, based on the need to reduce impacts on soils, vegetation, and wildlife. The regulations governing ORV use on public lands are contained in 43 CFR 8340. The BLM recognizes ORV use as a valid recreational use of the public land. Restrictions on ORV use are based on protecting natural resources and preventing conflicts with other public land uses. Where ORV use would cause excessive damage to resources or where conflicts with other uses are anticipated, areas were recommended for closure to or limitations on ORV use. If the effects from ORV use were not considered to be significant, the areas were recommended to be open to ORV use. 129 RESPONSES TO COMMENTS Table 3 (continued) RESPONSE NUMBER COMMENTER OR LETTER NUMBER BLM's RESPONSE TO THE COMMENT 88 1 137 19, H-7 Although the withdrawal order does not prohibit ORV use, lands actually being developed for Bureau of Reclamation (BOR) projects are closed by BOR regulations, unless opened by the BOR. ORV use on withdrawn lands not being used for project development is administered by the U.S. Forest Service or the BLM in accordance with their regulations (43 CFR 420). The ORV designations in this plan apply only to lands for which the BLM has administrative responsibilities. In the Proposed Plan, the area within the boundary of the Camel Back WSA is recommended for closure to ORV use. CULTURAL RESOURCES 122 123 124 125 126 135 15, M-9 15, M-9 15, M-9 165, 168 Cultural and paleontological resources are protected by numerous laws and regulations. The BLM uses these laws and regulations to protect these resources through avoidance or mitigation of surface-disturbing activities. In the Preferred Alternative, a portion of this area (5,848 acres) would be intensively inventoried for cultural resources. Through the Operation Respect program, the remaining area could be inventoried and monitored using volunteer expertise and labor from the Colorado Archeological Society. These recommendations would be incorporated into activity plans designed to improve protection and public awareness of cultural resources on public lands. Under the auspices of Project Pride, brochures and interpretive displays could be funded through grant money made available to organizations committed to the preservation of cultural resources. The Preferred Alternative recommends intensive inventory of 5,848 acres. Once this inventory is completed and specific information on high-value and high-density sites is obtained, activity plans designed to protect these sites would be developed. These could include changes in ORV designation. Upon completion of the intensive inventory, significant cultural sites would be assigned an appropriate designation such as Conservation for Future Study or Public Education use. The activity plans developed for these areas would identify the specific measures that would be needed to protect the areas' cultural values. WILDERNESS 10 20 19 10 L-21 The Wilderness Technical Supplement (WTS) is an integral part of the RMP. It specifically details the wilderness issue and supports and backs up the RMP. Wilderness evaluations, analyses, and considerations are in the WTS. Only the recommendations from the WTS are brought forward into the RMP/EIS. Also see Responses Number 66, 68, and 136. The Draft RMP/EIS and Draft WTS address and analyze the wilderness issue and the effects on it and from it. It is not the purpose of these documents to address alternative methods of power production. Coal leasing would be allowed in the upper portion of the Adobe Badlands WSA because this WSA would be recommended as nonsuitable for wilderness under the Proposed Plan. 130 RESPONSES TO COMMENTS Table 3 (continued) RESPONSE NUMBER COMMENTER OR LETTER NUMBER BLM's RESPONSE TO THE COMMENT 21 L-12 49 51 52 22 22 54 56 10 13 57 60 61 22, L-17 3LH-1 If all three WSAs were designated as wilderness, it would result in the closing of 41,865 acres to ORV use and oil and gas leasing. Since only the Gunnison Gorge WSA was recommended for wilderness designation in the Preferred Alternative, only 21,038 acres would be closed to these uses as a result of wilderness designation. Under the Proposed Management Plan, however, 6,783 acres within the Adobe Badlands WSA and the entire 10,402 acres of the Camel Back WSA would be closed to ORV use even though they were not recommended for wilderness designation. Use of motorized equipment for emergency rescue operations may be allowed in a designated wilderness area. Use of motorized equipment by the Colorado Division of Wildlife (i.e. helicopters, outboard motors) may be allowed in a wilderness area with BLM State Director approval. These situations would be addressed in the wilderness management plan that would be developed for designated wilderness areas. Mancos shale badlands are not inherently unsuitable for wilderness designation. The Adobe Badlands area will be managed as an Outstanding Natural Area, set aside to preserve unique geologic features and threatened and endangered plants. An alternative that would recommend the Camel Back WSA as wilderness with provisions for water development on Winter Mesa is not needed. Under the BLM's Interim Management Policy, new permanent range improvements (i.e. stock reservoirs) may be approved for the purpose of enhancing wilderness values by better protecting the rangeland in a natural condition. Under the BLM's Wilderness Management Policy, new rangeland improvements may be allowed if determined to be necessary for the purpose of resource protection. The text has been changed (see the Changes to the Draft RMP/EIS section in this document). None of the WSAs are rated as having high mineral potential. The Gunnison Gorge WSA, which is recommended for wilderness designation, has a moderate rating for mineral potential, but there are no known mineral deposits. The BLM feels that the highest and best use of the Gunnison Gorge is as wilderness and has, therefore, recommended it as suitable. Congress will ultimately make the final decision on wilderness designation. FLPMA (section 603(a)) requires that a mineral survey be conducted by the U.S. Geologic Survey and the Bureau of Mines to determine the mineral values, if any, that may be present in an area recommended as suitable for wilderness by the BLM. This report will be completed before the Secretary of the Interior forwards the wilderness designation recommendations to the President. The BLM will address issues such as low level military flights in the Wilderness Management Plan that would be developed after Congress designates an area as wilderness. Public Law 96-560, which released the U.S. Forest Service's Roubideau Rare II area from wilderness consideration, did not make any determination on adjacent lands administered by the BLM. Also see Response Number 136 (the last response in this section of this table). If Congress designates the Gunnison Gorge as a wilderness area, Congress will also make the determination as to whether the proposed water projects would be allowed in the wilderness area, and if any mitigation of water rights would occur. 131 RESPONSES TO COMMENTS Table 3 (continued) RESPONSE NUMBER COMMENTER OR LETTER NUMBER BLM's RESPONSE TO THE COMMENT 62 63 64 66 68 7! 46, 47, 73 16, 24, L-21 78, 147, M-10 21,22,26,28,87,89, 101, 125, 139, 142, 143, 145, 150, 152, H-9 4, 11, 13, 14, 16, 19, 21,22,23,24,25,26, 28,35,36,38,39,41, 44,45,46,47,48,51, 52, 53, 54, 56, 58, 59, 60,61,63,64,65,66, 67,68,69,70,71,72, 73,74,75,76,80,81, 83,85,87,89,91,92, 94, 95, 96, 97, 98, 99, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 113, 114, 115, 116, 117, 118, 119, 120, 121, 122, 123, 125, 126, 127, 128, 129, 130, 131, 132, 133, 135, 136, 137, 139, 142, 143, 145, 147, 149, 150, 152, 153, 155, 158, 160, 162, 163, 165, 166, 167, 168, 169, 170, 171, 172, 173, H-2, H-4, H-6, H-8, H-10, H-ll, H-12, L-l, L-3, L-4, L-5, L-6, L-7, L-8, L-9, L-10, L-ll, L-12, L-13, L-14, L-15, L-16, L-17, L-18, L-l 9, L-20, L-21, M-4, M-7, M-8, M-10 1,3,8,10,22,31,49, 165, 168 Wilderness designation and wild and scenic river designation are two separate issues. Both require Congressional action under separate and distinct Acts. The private land in Red Canyon (within Management Unit D-4) was identified for acquisition on page 3-34 of the Draft RMP/EIS. The Gunnison Gorge Recreation Area Management Plan (July 1985) also identifies these tracts for acquisition. Livestock grazing is permitted in designated wilderness areas to the extent established prior to wilderness designation. New rangeland improvements may be allowed in designated wilderness areas if determined to be necessary for resource protection. The Gunnison Gorge WSA contains outstanding geologic, ecologic, scenic, and wilderness values. The area provides a wilderness Whitewater boating opportunity not available in most other wilderness areas. If designated, this area would complement the adjacent National Park Service designated wilderness area. There is local and regional public and political support for designation of the Gunnison Gorge as wilderness. All of the WSAs addressed in the Draft RMP/EIS and Draft WTS meet the requirements for study and consideration for preservation as wilderness. However, additional factors such as potential land uses, impacts to other resources, enhancement of the wilderness preservation system, actual wilderness values of the area, and other available management options all play a major role in determining whether an area should be recommended for designation as wilderness. The BLM recognizes that the Adobe Badlands area meets the minimum wilderness criteria, but does not feel that the area's wilderness qualities are significant enough to warrant inclusion in the National Wilderness Preservation System. Shale-type badlands are presently represented in the NWPS by the Bisti and De-na-zin wilderness areas in New Mexico, both of which are similar in appearance to and within a day's driving distance of the Adobe Badlands WSA. Although the wilderness qualities of the Adobe Badlands are not significant enough to warrant designation as wilderness, it is felt that the area's interesting landforms, threatened and endangered plants, and other values are deserving of some form of protection. Designation of the area as an Outstanding Natural Area is a more appropriate management option for protection of these values. The BLM is therefore recommending that the 6,783 acres of the WSA which contain these values be designated as the Adobe Badlands ONA/ACEC (see Management Unit 15). This management option would also allow the northern portion of the WSA, with its high to moderate coal potential, to remain available for coal leasing. These concerns will be addressed during preparation of the final wilderness EIS. 132 RESPONSES TO COMMENTS Table 3 (continued) RESPONSE NUMBER 130 136 19 28 COMMENTER OR LETTER NUMBER BLM's RESPONSE TO THE COMMENT 19 9, 11, 13, 14, 16, 19, 21,22,23,24,25,26, 28,35,36,37,38,39, 41,43,44,45,46,47, 48,49,51,52,53,54, 55,56,58,59,60,61, 63, 64, 65, 66, 67, 68, 69,70,71,72,73,74, 75,76,77,80,81,83, 85,87,89,91,92,94, 95, 96, 97, 98, 99, 101, 102, 103, 104, 106, 107, 108, 109, 110, 112, 113, 114, 115, 116, 117, 118, 119, 120, 121, 122, 123, 125, 126, 127, 128, 129, 130, 131, 132, 133, 135, 136, 137, 138, 139, 142, 143, 145, 147, 148, 149, 150, 152, 153, 155, 158, 160, 162, 163, 164, 165, 166, 167, 168, 169, 170, 171, 172, 173, H-2, H-4, H-6, H-7, H-8, H-10 , H-ll, H-12, L-l, L-3, L-4, L-5, L-6, L-7, L-8, L-9, L-10 , L-ll, L-12, L-13 , L-14, L-15, L-16 , L-17, L-18, L-19 , L-20, L-21, M-4, M-7, M-8, M-1C Under the Preferred Alternative, the Camel Back WSA becomes part of Management Units D-l, D-2, and D-9. Management for these units corresponds to and is consistent with the management direction outlined in Table 3-8 of the Draft RMP/EIS. All of the WSAs addressed in the Draft RMP/EIS and Draft WTS meet the requirements for study and consideration for preservation as wilderness. However, additional factors such as potential land uses, impacts to other resources, enhancement of the wilderness preservation system, actual wilderness values of the area, and other available management options all play a major role in determining whether an area should be recommended for designation as wilderness. The BLM recognizes that the Camel Back area meets the minimum wilderness criteria, but does not feel that the area's wilderness qualities, although possibly important on a local or regional scale, are significant enough to warrant inclusion in the National Wilderness Preservation System. The Dominguez WSA (73,568 acres) and the Gunnison Gorge WSA (21,038 acres) have both been recommended as suitable for wilderness designation; both of these WSAs are within short driving distances of regional population centers so wilderness designation of the Camel Back WSA would not significantly expand wilderness opportunities in this area. The character, landforms, rock formations, and vegetation of the Camel Back WSA are very similar to those of the Dominguez WSA, which is located within eight miles of the Camel Back WSA. Features typical of both the Camel Back WSA and the Dominguez WSA are the steep-sided mesas covered with pinyon-juniper woodlands and scattered sagebrush parks, and the deep, colorful, sandstone canyons with canyon-bottom riparian vegetation that includes Cottonwood, willow, and tamarisk. Roubideau Canyon (within the Camel Back WSA) possesses some outstanding visual features, but it is not unlike several other plateau-region canyons, including upper Spring Creek Canyon, Escalante Canyon, and especially Dominguez Canyon, all of which have similar formations, vegetation, coloration, and scenic qualities. In addition to its natural and scenic values, the Camel Back area provides important habitat for wildlife and threatened and endangered species, and is also used for livestock grazing. Because the Camel Back area's wilderness values are not significant enough to warrant inclusion in the NWPS, the BLM is not recommending it for wilderness designation, and has determined that identifying the area for continued multiple-use management is both effective and appropriate. To provide protection for the area's natural and scenic values, to prevent accidental destruction of threatened and endangered plants, and to reduce active erosion, the Proposed Plan recommends closing the area within the WSA boundary to ORV use. SPECIAL MANAGEMENT AREAS L-21 9, 16, 23, 163, L-3,L-4, L-5, L-7, L-8, L-9, L-ll, L-13, L-17, L-21, M-12 The BLM feels there is adequate space within Management Unit 14 for a nature trail and other interpretive purposes. The text has been changed; see the management prescriptions (in this document) for Management Units 12, 13, and 15. 133 RESPONSES TO COMMENTS Table 3 (continued) COMMENTER RESPONSE OR LETTER NUMBER NUMBER BLM's RESPONSE TO THE COMMENT 37 9 The recommendations of the BLM Geologic Advisory Group concerning the 1,800 acres in Chukar Canyon and the Ute Indian fault zone were reviewed and considered. These areas are within the Gunnison Gorge WSA, which is recommended for designation as wilderness. On August 22, 1972, the BLM designated Needle Rock as a Class IV Outstanding Natural Area under the Bureau of Outdoor Recreation classification system. 101 8, 24 One purpose of an Environmental Impact Statement is to analyze the impacts of the various alternatives to a proposed action. If management of Areas of Critical Environmental Concern (ACECs) are identical under all management alternatives, there would be no reason to analyze the impacts. The Preferred Alternative gives priority to the protection of ACECs; management priorities emphasize ACECs less in other alternatives. The designation of an ACEC is a discretionary management action which necessitates full environmental analysis and public input. Activity plans will be developed for all designated ACECs as the BLM's operating budget permits. 102 8, 11, 24 Both the Conservation and the Preferred alternatives recommend three areas for ACEC identification; under the Proposed Plan the recommendation has been expanded to four areas. All of the areas which have been identified by either the public, other agencies, or the Resource Area staff have been recommended for some form of special designation. LAND TENURE ADJUSTMENTS AND LAND USE MANAGEMENT 16 4 The Final RMP/EIS map has been changed to show all lands within the Black Canyon of the Gunnison National Monument which are administered by the National Park Service. The lands within the proposed Curecanti National Recreation Area are shown as Bureau of Reclamation withdrawn lands since formal designation as a National Recreation Area has not yet occurred. 17 4 The lands near the northeast boundary of the Black Canyon of the Gunnison National Monument are Bureau of Reclamation withdrawn lands, not potential exchange tracts (see map legend). 85 7, 9, 16, 22, 24, 40, Specific criteria for the identification of tracts determined to be suitable for 135, 172, H-2, L-21, further disposal consideration have been added (see the Disposal of Public Lands M-12 discussion in the Proposed Plan section of this Final RMP/EIS). Tracts that do not meet these criteria are no longer being considered as suitable for disposal. All public lands administered by the BLM that do not meet these criteria would be retained in public ownership. 87 1 The BLM would retain withdrawals for all Bureau of Reclamation structures and linear rights-of-way for all laterals on tracts that would be identified for disposal. 89 1 The Final RMP/EIS map has been changed to reflect these corrections. Standard mapping practice is to not show withdrawals over water surfaces. The withdrawal boundary extending into the reservoir is indicative of the lands affected by the withdrawal. Disposal would be contingent upon the lifting of existing withdrawals on those tracts in T. 14 S., R. 92 and 93 W. 90 1 The text has been changed to include all public entry laws. See the Changes to the Draft RMP/EIS section of this document. 9 1 1 Current laws and regulations do not permit the transfer of BLM powersite reserves to the Bureau of Reclamation. Under the Proposed Plan, the powersite 134 RESPONSES TO COMMENTS Table 3 (continued) RESPONSE NUMBER COMMENTER OR LETTER NUMBER 92 93 30 11,31 94 9? 9, 16, L-21 31 112 115 31 31 BLM's RESPONSE TO THE COMMENT classifications in the Dominguez area would be lifted to allow a full range of multiple-use management. The text has been changed; the column in Table 2-17 entitled "Purpose" is now entitled "Primary Purpose". See the Changes to the Draft RMP/EIS section in this document. All tracts currently under Bureau of Reclamation withdrawal would be evaluated through the withdrawal review program; if the withdrawals are not lifted, these tracts would be retained in public ownership. MAJOR UTILITIES Management Unit D-7 would be managed for existing and potential coal development. Major utilities in areas containing coal resources would result in a loss of coal revenue because State regulations require that surface structures be protected from subsidence. This is usually accomplished by leaving more coal in-place to support the surface structures than would normally be required for room-and-pillar mining. If utility corridors were permitted over coal resources, the coal would not be managed in the best and most efficient manner. Whether an area (including all special management areas) is open, closed, or restricted to major utility development is addressed by management unit in each of the alternative prescriptions (see Chapter Three of the Draft RMP/ EIS). The 1980 Western Regional Corridor Study is a planning tool and has been used as such during the preparation of this RMP/EIS. In addition to the 1980 Study, the BLM also utilized the 1985 Western Regional Corridor Study, and consulted with the Delta-Montrose Electric Association, the Colorado-Ute Electric Association, the San Miguel Power Association, the U.S. Forest Service, and the BLM offices administering adjacent public lands. The disturbance associated with construction and maintenance of major utilities and their related facilities increases stress on big game, especially when this disturbance occurs on crucial winter ranges when the animals are already under stress caused by environmental factors. Mitigating measures help avoid or reduce much of this impact, although such measures are seldom 100 percent effective. As stated on page 3-38 of the Draft RMP/EIS, riparian areas would be open to the development of major utility facilities. Only surface-disturbing activities which would have long-term adverse effects would be prohibited. ACCESS AND TRANSPORTATION 152, H-9, H-ll 18 H-2 Public access across private land is generally obtained through purchased easements. Condemnation can be used as a last resort, but only if negotiations fail completely and such action is justifiable. After a route analysis is completed to determine the best access location, the BLM negotiates with the landowner(s) to determine mitigating measures and resolve problems and conflicts. The BLM usually assumes maintenance responsibility for all acquired easements. The BLM recommends acquisition of public access on the McCarty Trail in the Preferred Alternative on page 3-32 of the Draft RMP/EIS. 135 RESPONSES TO COMMENTS Table 3 (continued) COMMENTER RESPONSE OR LETTER NUMBER NUMBER BLM's RESPONSE TO THE COMMENT 48 H-2 As stated on page 3-35 of the Draft RMP/EIS, the BLM has proposed access acquisition in these areas. The BLM presently manages some land at the confluence which is used as a boater put-in/take-out site. The adjacent private land (Gunnison River Pleasure Park) provides a raft/kayak take-out point, but a user fee is charged; public use is not otherwise restricted. 84 22 Revised Statutes 2477 (RS 2477) was repealed by the Federal Lands Policy and Management Act of 1976 (FLPMA). The acknowledgement and documentation of RS 2477 grants for public highways constructed on unreserved public land prior to October 21, 1976, is a non-discretionary action and, therefore, does not necessitate inclusion in this RMP/EIS. SOCIAL AND ECONOMIC RESOURCES 1 H-2 The location of the Storm King Ski area is shown as Management Unit C-10 on the Conservation Alternative map. The information on pages 4-60 and 4-61 of the Draft RMP/EIS was derived from data provided by Storm King Associates (the proposal's developer), Colorado Ski Country U.S.A., and the State of Colorado through the Division of Local Government's Computer Model-Planning and Assessment Model. 3 11 In Chapter Four of the Draft RMP/EIS, resource management trade-offs are identified as impacts which are generated by various management actions. These impacts, including effects on economic conditions under each of the management alternatives, were considered in the development of the Preferred Alternative and will be considered in the final resource management plan. GENERAL RESOURCE MANAGEMENT 2 22, L-17 The Preferred Alternative was developed based on the identified issues, public input, conflicts with other resources and uses, and laws and regulations. It is composed of portions or combination of portions of the other management alternatives. The Preferred Alternative is not a final decision; rather it represents the management that the BLM has proposed for the public lands in the planning area. The RMP/EIS is published as a Draft to allow for public review and comment. After consideration of the public input, the BLM will develop the Final Resource Management Plan and provide rationale for the final decisions. 5 H-2 It would be impossible to show in detail on a map all the areas that would be impacted by the various actions. The maps in the Draft RMP/EIS illustrate where most resources are located and this helps indicate where impacts would occur. Since the plan covers a possible 15-year period and some actions, such as utility development, mining, and oil and gas exploration and development are not planned by the BLM, the locations and time frames on specific impacts are not known. 13 11, H-3, H-ll The RMP is a general land use plan that establishes land use allocations. The BLM feels this plan provides the general objectives and guidance needed to manage the public lands. Based on the direction in the RMP, specific activity plans which will identify objectives, mitigating measures, and specific management actions will be developed for the various resources and resource uses. 136 RESPONSES TO COMMENTS Table 3 (continued) RESPONSE NUMBER 14 15 22 25 86 108 COMMENTER OR LETTER NUMBER H-13 16, L-21, M-12 BLM's RESPONSE TO THE COMMENT 27, 28, 79, 82, 84, 86, 88,93,100,111,124, 134, 140, 141, 144, 146, 148, 151, 154, 159, 161, Although the management unit boundaries shown on each map cross private and other non-federal lands, the management prescriptions apply to only those lands for which the BLM has administrative authority. This includes surface and/or subsurface estate. The boundary of Management Unit D-15 is the Cimarron River; the unit is not adjacent to High Mesa. Since specific data for proposed actions from mining and other surface-disturbing activities are not known, impacts were expressed in qualitative rather than quantitative terms. Environmental assessments will be prepared on specific actions and projects, following the general land use allocations provided in the RMP. Impacts will be analyzed and quantified at that time. It is the BLM's policy to involve the public and local, state, and federal government agencies in the planning process. Attempts have been and will be made to gain input from these entities on site-specific proposals, actions, and environmental assessments. BLM management is based upon the principles of multiple-use and sustained yield; it is a combination of uses that takes into account long-term needs for renewable and non-renewable resources. All of the alternatives described in the Draft RMP/EIS are designed to provide multiple-use management but are based upon different overall management objectives. The areas covered by the three proposed wildfire suppression strategies are discussed in the Management Situation Analysis, which is available for public review. Consultation with the U.S. Forest Service will be completed prior to issuance of the Record of Decision for this resource management plan. 137 CHANGES TO THE DRAFT RMP/EIS Table 4 is a list of changes that have been made to the text of the Draft RMP/EIS. Map 1 shows the changes in the Limited ORV use areas, and Map 2 depicts the changes in the areas Closed to ORV use; these maps (originally in Appendix G of the Draft RMP/EIS) immediately follow Table 4. These text and map changes were made in response to public comments or to internal BLM review. The list of changes is not extensive since the Proposed Resource Management Plan (a modified version of the Preferred Alternative) and its accompanying map are included in this document. Table 4 CHANGES TO THE DRAFT RMP/EIS LOCATION OF CHANGE CHANGE Page 1-1; Topics Not Addressed in this Plan At the end of this section add: Potential Colorado National Guard Artillery Range. (This land use proposal will be analyzed in a site-specific analysis when a final application for use is received.) Page 2-3; Oil, Gas and Geoth- ermal Resources; second paragraph Page 2-10; Table 2-6 Change the third sentence to read: The potential for oil and gas production in the planning area is considered low to moderate. There has been little past and no recent production. Add the following entry: (Common Name) Wetherill milkvetch; (Scientific Name) Astragalus wetherillii; (Status) BLM Sensitive; (Habitat) Clay hills in association with pinyon-juniper and sagebrush; (Estimated Population) Unknown; (Estimated Acres of Habitat) Unknown. Page 2-10; Table 2-6 Change the habitat description for Spineless hedgehog cactus to read: Rocky soils. Change the habitat description for Uinta Basin hookless cactus to read: Gravelly soils on flats and low hills along major drainages. Change the habitat description for Delta lomatium to include: and mid-altitude Mancos shale in association with pinyon-juniper. Page 2-12; Table 2-8 Page 2-19; Table 2-16 Change the status for the river otter to read: State endangered and federal candidate. Add the following entry: (Area Identification, Number and Name) 35 Proposed Curecanti National Recreation Area; (Size, acres) 3,200; (Scenic Quality) A; (Visual Sensitivity) H; (Viewing Distance) FG; and (Visual Resource Management Class) II. Page 2-20; Gunnison Gorge WSA At the end of this section add: The City of Delta, the Pittsburg and Midway Coal Company, and the Colorado-Ute Electric Association hold conditional water decrees on the Gunnison River for potential hydroelectric development. Each proposal for hydroelectric development would affect the Gunnison Gorge WSA in some way. In March 1988, the Pittsburg and Midway Coal Company donated flow rights of 300 cubic feet per second in the Gunnison Gorge to The Nature Conservancy. Page 2-21; Withdrawals; first paragraph At the end of the paragraph add: Legal descriptions identifying withdrawals, classifications, and reservations are included in the Management Situation Analysis (MSA) document, which is available for public review at the Montrose BLM Office. 139 CHANGES TO THE DRAFT RMP/EIS Table 4 (continued) LOCATION OF CHANGE Page 2-21; Withdrawals; second paragraph Page 2-21; Withdrawals; third paragraph Page 2-22; Table 2-17 Page 3-18; Management Unit C-l; Locatable Minerals Page 3-25; Management Unit C-l 5; Special Land Uses CHANGE Change the second and third sentences to read: These withdrawals segregate the affected lands from all public entry laws, including the general mining laws. Change the second sentence to read: Each reserve typically involves 40 acres and segregates the affected lands from operation of the public land laws and from non-metalliferous minerals under the mining laws. Change the title of column four from Purpose to Primary Purpose. Remove the word pre-FLPMA. Delete this entire paragraph. 140 PROPOSED PLAN Off-road Vehicle Designation Map m LIMITED: Areas Where Official Vehicle Use Would be Limited to Designated Roads and Trails, Either Seasonally or Year-round. 141 • !MV Scale: 1" =10 Miles PROPOSED PLAN Off-road Vehicle Designation Map CLOSE D: Areas Which Would be Closed to Off-road Vehicles Use Year-round. 142 ■ M%'- Scale: 1" =10 Miles THE PROPOSED RESOURCE MANAGEMENT PLAN The Proposed Resource Management Plan was developed based on an analysis of the public comments received on the Draft Uncompahgre Basin RMP/EIS. Under the Proposed Plan, the planning area would be managed under the multiple-use concept with restrictions applied so that management objectives would be achieved. All actions proposed in this plan would comply with current state and federal regulations, standards, and policies. In addition, the following assumptions were made: 1. Site-specific activity plans would be developed or revised, if necessary, to provide detailed management guidance for all management units except the general resource management unit. 2. Site-specific Environmental Analyses (EAs) and Environmental Impact Statements (EISs), if required, would be developed for all management plans and projects within the planning area. 3. The most reasonable foreseeable level of oil, gas, and geothermal development throughout the planning area would involve a maximum of ten applications to drill per year, with an estimated total of 30 acres of surface disturbance per year. 4. Lands cases generated by other agencies, individuals, and entities would be analyzed and processed on a case- by-case basis in accordance with guidance provided by this plan. 5. Recreation and Public Purposes Act (R&PP) land use classifications currently under lease would be retained with the exception of the Delta County and Montrose County landfills. 6. All Wilderness Study Areas (WSAs) would be managed consistent with the Wilderness Interim Management Policy until the final decision on wilderness designation or non-designation is made. 7. The areas recommended for designation as an Outstanding Natural Area (ONA) or a Research Natural Area (RNA) would also be designated as areas of critical environmental concern (ACEC). Some resource management programs would be standard throughout the planning area under the Proposed Plan. Unless changes in or additions to standard management directions are specifically addressed in the management prescription for each management unit, these resources, programs, and activities would be managed as follows. Air Quality. Activities and projects on public land would comply with applicable local, state, and federal air quality regulations. Mitigation to minimize air quality degradation would be incorporated into project proposals as appropriate. Coal. Federal coal estate would be identified as acceptable for further leasing consideration. Oil, Gas, and Geothermal Resources. At present, the oil and gas program within this planning area is highly speculative. Only three applications to drill have been received over the past twelve years; none of these resulted in producing wells. Based on this data, the BLM does not foresee any change in the oil and gas program over the life of this plan. Federal oil, gas, and geothermal estate on both federal surface and split-estate lands would be open to leasing with standard lease terms. Other conditions for leasing such as no surface occupancy and seasonal stipulations (see Appendix A of this Proposed Plan) are assigned in each management unit prescription; special stipulations and conditions also apply to federal surface and split-estate lands. Any special stipulations (i.e., seasonal closures) prescribed for a management unit would apply to seismic and drilling activities. Resource information for split-estate lands, upon which the recommended stipulations are based, has not been verified by the BLM. Verification will occur during review of Applications for Permit to Drill (APDs). On-site inspection and consultation with the surface owner and operator may reveal that (1) the impacts addressed by the stipulation will be avoided or mitigated to an acceptable level, or (2) the resources of concern are not present. Upon either of these determinations by the Authorized Officer, the stipulations can be waived, modified, or excepted without public notice other than that provided for the APD. Consultation with the surface owner also requires the consideration of private uses of the surface. If, after on- site inspection and consultation, it is determined by the Authorized Officer that conditions necessary to avoid impacts to private resources would adversely impact the public resources addressed by these stipulations, the impacts will be assessed. If, based upon such assessment, the Authorized Officer makes a decision to substantially change or waive one or more stipulations, a 30-day public review period will be provided in addition to the public notice period for receipt of the APD. Locatable Minerals. All existing withdrawals that segretate federal mineral estate from location and entry under the general mining laws would be recommended for retention. Federal mineral estate in areas not under withdrawal would be open to entry and location. 143 PROPOSED PLAN Mineral Materials. Federal mineral estate would be open to disposal of mineral materials. Soils and Water Resources. Water quality and erosion conditions would be inventoried and monitored. Measures designed to minimize erosion and water quality deterioration would be required in plans for surface-disturbing land use activities. The area would be open to land treatments and development of in-channel structures and project facilities. Riparian/ Aquatic Systems. Riparian zones and aquatic habitats would be inventoried and monitored where necessary to provide information for proper management. Vegetation conditions and streambank cover would be maintained or improved. Measures designed to minimize site-specific riparian and aquatic deterioration would be required in plans for surface-disturbing land use activities. Threatened and Endangered Species. Threatened and endangered species and unique plant associations would be inventoried and monitored where necessary to provide information for proper management. Clearances would be conducted on all proposed surface-disturbing activities and the U.S. Fish and Wildlife Service (USFWS) would be consulted as required. Measures designed to protect threatened and endangered species and their habitat would be required in all land use activity plans. Supplemental releases and reintroduction of federal and state listed endangered, threatened, and candidate species could be authorized following environmental analysis and consulta- tion with the USFWS, the Colorado Division of Wildlife (DOW), and other affected parties. Wildlife Habitat. Wildlife forage allocations would remain at current levels until studies determine adjustments are needed to achieve management objectives. Additional forage allocations would be divided equally between wildlife and livestock grazing. Wildlife habitat monitoring studies would be established and/or maintained on all crucial winter ranges. The planning area would be open to land treatments and project facility development. Existing wildlife facilities and land treatments would be maintained. Supplemental releases and reintroduction of native or naturalized fish and wildlife species (excluding federal or state listed endangered, threatened, or candidate species) could be authorized by the District Manager following environmental analysis. Livestock Grazing. Suitable public lands would be available for livestock grazing use. Livestock utilization would be managed at current forage allocation levels until studies indicate adjustments are needed to achieve management objectives. New or additional available forage would be divided equally between livestock and wildlife. Existing livestock facilities would be maintained. Existing allotment management plans (AMPs) would be updated as needed and new AMPs would be developed. New livestock facilities and land treatment projects would be developed if needed to achieve AMP objectives. Vegetation condition and trend monitoring studies would be established and/or maintained. Maximum sustained livestock utilization levels of key forage species would be 50 percent. Allotment categorization would determine management and monitor- ing intensity. Forestry. Suitable commercial forest lands and pinyon- juniper woodlands would be managed for sustained yield production within the allowable cut restrictions determined by the Timber Production Capabilities Classification (TPCC) inventory. Recreation. Public lands would be managed for extensive recreational use. Off-Road Vehicles. Public lands would be open to off- road vehicle (ORV) use. Cultural Resources. Cultural and historical sites would be inventoried. Clearances would be conducted on sites of all proposed surface-disturbing activities. Measures designed to protect cultural and historical resources would be required in all land use activity plans. Paleontoiogical Resources. Paleontological resources would be inventoried and appropriate protective measures would be developed if necessary. Visual Resources. Public lands would be managed under current visual resource management (VRM) classifications and guidelines. Major Utilities. Public lands would be open to development of major utility facilities. Stipulations and mitigating measures would be developed on a case-by-case basis. Powersite Withdrawals. Pending determination of potential, existing powersite withdrawals would be maintained. These lands would not be subject to further consideration for disposal. No significant long-term investments would be made on these lands unless the investment could be recovered prior to development. Access. In addition to the specific access needs identified in the management unit prescriptions, the access needs identified in the resource area's transportation plan would be acquired as opportunities arise. Fire Management. Any fire which occurs in a fire use category area before a prescribed burn plan is approved, or which is not within the limits of the prescription, or which threatens life or property would be suppressed as a conditional suppression area fire. The following management prescriptions comprise the Proposed Resource Management Plan. Acreage figures used in this discussion are approximations. Table 5 identifies the management units that were established for the Proposed Plan. 144 Table 5 MANAGEMENT UNITS: PROPOSED PLAN PROPOSED PLAN MANAGEMENT UNIT ACRES OF PUBLIC SURFACE PERCENTAGE » OF THE PLANNING AREA IMPORTANT RESOURCES, VALUES, OR LAND USES 186,810 39% 2 3 4 5 6 7 9 10 II 12 13 14 15 16 67,320 14% 47,607 10% 40,792 8% 24,177 5f* 21,038 4% 17,232 4% 8,942 2% 6,320 \% Livestock grazing, wildlife habitat, recreation, woodlands Wildlife habitat, coal, woodlands Woodlands, wildlife habitat, livestock grazing Recreation, soils, woodlands Soils, recreation, oil and gas Wilderness, recreation, T&E species Coal, wildlife habitat Recreation, soils Riparian/aquatic habitat, livestock grazing 3,292 Less than 1% Wildlife habitat, coal, recreation, commercial timber 1,990 Less than 1% Wildlife habitat, recreation 1,895 Less than 1% Recreation, T&E species 377 Less than 1% T&E species, soils 80 Less than 1% Recreation, scientific values 6,783 1% T&E species, scenic values, soils 48,422 10% General land uses Percentages are rounded to whole numbers. 145 PROPOSED PLAN DISPOSAL OF PUBLIC LANDS Disposal criteria have been developed for use in identifying disposal tracts under the Proposed Plan. These tracts are identified on the map that accompanies this document. General Disposal Criteria. Tracts of public land that are difficult and uneconomical to manage because of their location and other characteristics, and tracts of public land that would best serve the public interest through their disposal would be identified as suitable for disposal under the Proposed Plan. Specific Disposal Criteria. Tracts of public land meeting the following specific criteria would be identified as suitable for disposal under the Proposed Plan: 1. Tracts of 500 acres or less which: (1) are not administrative sites; (2) do not contain important mineral resources; (3) do not contain known threatened or endangered species; or (4) do not border lakes, rivers, or perennial streams where potential recreational development is likely. 2. Existing R&PP landfill sites. A total of 143 tracts of public land totalling 1 1,026 acres would be identified for consideration for disposal through sale or exchange under the Proposed Plan. Existing R&PP classifications on two tracts and existing withdrawals on several tracts would be lifted prior to disposal. Prior to disposal, resources within identified tracts would be managed according to the management prescription for the management unit in which they are located. Minimal funds, if any, would be spent on improvements on these lands. Federal mineral estate would be conveyed with surface estate where it would be in the public interest. MANAGEMENT UNIT 1 186,810 Acres of Public Surface; 39 percent of the Planning Area Management Unit 1 consists of 186,810 acres of public land located primarily on the northeast-facing slopes of the Uncompahgre Plateau north of Colorado Highway 90. The area's range of elevations gives it a high value for both summer and winter livestock grazing. Public lands within the management unit would be managed as "I" category (150,114 acres), "M" category (25,727 acres), and "C" category (8,950 acres) grazing allotments. Also, 2,019 acres that are presently unallotted for livestock use would be available for grazing application. The management unit would be managed to improve vegetation conditions and forage availability for livestock grazing. Land treatment projects and other facilities designed to improve livestock forage and distribution would be developed. Intensive monitoring studies would be established and maintained on all "I" and "M" category allotments. Existing AMPs would be updated as needed and new AMPs would be developed for allotments without plans. As additional forage becomes available, livestock would have priority for allocation. Relinquished, cancelled, or acquired livestock grazing permits would be reissued according to regulations. Oil and Gas. Federal oil and gas estate would be open to leasing. Seasonal stipulations on seismic and drilling activities would be in effect from December 1 through April 30 on 64,815 acres (federal surface) and 560 acres (split- estate) of crucial deer and elk winter range, and on 3,757 acres (federal surface) and 63 acres (split-estate) used by bald eagles for hunting habitat. Variances to this seasonal stipulation may be granted on a case-by-case basis (see Appendix A). Locatable Minerals. The Bureau of Reclamation (BOR) withdrawal on Fruitland Mesa and both the BOR withdrawal and the BLM powersite classifications along the Gunnison River downstream of Delta would be recom- mended for revocation to allow for mineral exploration and development, facilitate resource management, and permit long-term land use planning. Soils and Water Resources. Non-conflicting erosion control objectives, projects, and mitigating measures would be incorporated into new and existing AMPs. In-channel structures and land treatment projects designed to reduce runoff and soil erosion would be developed. Wildlife Habitat. Non-conflicting wildlife habitat management objectives, projects, and mitigating measures would be incorporated into new and existing AMPs. Existing wildlife habitat projects would be maintained. Bighorn sheep could be transplanted into the Winter Mesa area if they would not conflict with current and future livestock grazing forage allocations. Wildlife would have first priority for all additional forage made available as a result of non-BLM wildlife-funded rangeland improvement projects. Forestry. Woodland harvest areas would be managed for increased forage production and would be compatible with AMPs. Recreation. River access would be developed at the Escalante Bridge. Maps and informational materials on river use would be provided. The BLM would manage recreation use in a manner that would minimize recreational impacts on interspersed and adjacent private land. Off-Road Vehicles. A total of 7,240 acres in the Winter Mesa/Roubideau Creek area would be closed to ORV use. Vehicle use on crucial deer and elk winter range (64,815 acres) would be limited to designated roads and trails from December 1 through April 30 if necessary to reduce stress 146 PROPOSED PLAN on wintering deer and elk. The remainder of the management unit would be open to ORV use. Cultural Resources. A total of 5,848 acres of public land between Colorado Highway 90 and the Big Sandy Wash would undergo a Class III cultural inventory to determine the significance and location of high-value archeological sites. Upon completion of the inventory and data analysis, some of these sites may be assigned a special designation and a management plan would be developed. Visual Resources. The management unit would be managed under VRM Class III guidelines, except for Escalante Canyon which would be managed under VRM Class II guidelines to protect its scenic qualities. Acquisition of Non-Federal Lands. If they are available, non-federal lands that would improve livestock management and increase crucial deer and elk winter range would be acquired through exchange only. Access. Public road access would be acquired into the Olathe Reservoir area for hunting and other recreational purposes. Public trail access would be acquired on the McCarty Trail in lower Escalante Canyon to provide additional access into the Dominquez Canyon WSA. Fire Management. A total of 97,543 acres of public land would be managed under the fire suppression category, with 8,657 acres identified for intensive suppression and 88,886 acres identified for conditional suppression. A total of 89,267 acres would be managed under the fire-use category where fire would be utilized as a management tool. Planned or natural ignitions meeting pre-determined prescriptions would be allowed on these areas. MANAGEMENT UNIT 2 67,320 Acres of Public Surface; 14 percent of the Planning Area Management Unit 2 consists of 67,320 acres of public land located primarily on the southern end of the Uncompahgre Plateau and in the lower elevations of the North Fork Valley. These areas have large wintering deer and elk populations. Approximately half of the management unit is considered crucial deer and elk winter range. A portion of the unit, in the Camel Back/Roubideau Creek area, is suitable habitat for desert bighorn sheep. The management unit would be managed to improve the areas' capabilities to support wintering deer, elk, and bighorn sheep populations. Land treatment projects and other facilities designed to improve the quality and quantity of winter habitat would be developed. Wildlife would have first priority for all additional forage made available as a result of BLM habitat improvement projects. All other land uses would be permitted if they would not degrade the areas' winter range capabilities. Disturbances would be minimized from December 1 through April 30 on crucial deer and elk winter range (37,007 acres). Habitat in the Camel Back/Roubideau Creek area would be available for possible introduction of desert bighorn sheep. Coal. Federal coal estate would be open to leasing. Within crucial deer and elk winter range, seasonal stipulations on new road and facility construction may be necessary from December 1 through April 30 to reduce stress on wintering deer and elk. Oil and Gas. Federal oil and gas estate would be open to leasing. Within crucial deer and elk winter range (37,007 acres of federal surface and 8,850 acres of split-estate), seasonal stipulations on seismic and drilling activities would be in effect from December 1 through April 30 to reduce stress on wintering deer and elk. Variances to this seasonal stipulation may be granted on a case-by-case basis (see Appendix A). Mineral Materials. Federal mineral estate would be open to disposal of mineral materials. Within crucial deer and elk winter range, seasonal restrictions on disposal activities may be necessary from December 1 through April 30 to reduce stress on wintering deer and elk. Soils and Water Resources. Non-conflicting erosion control objectives, projects, and mitigation measures would be incorporated into new wildlife habitat management plans (HMPs). Land treatment and erosion control projects would be permitted if they would be compatible with wildlife habitat management objectives. Livestock Grazing. Livestock grazing would continue at current forage allocation levels and seasons of use unless studies determine adjustments are needed. Livestock would have first priority for all additional forage made available as a result of livestock operator-funded rangeland improvement projects. Non-conflicting livestock manage- ment objectives, projects, and mitigating measures would be incorporated into new wildlife HMPs. Facility development and land treatment projects would be permitted if they would be compatible with wildlife habitat management objectives. Forestry. The management unit would be available for woodland product harvests. On 37,007 acres of crucial deer and elk winter range, seasonal restrictions on harvests may be necessary from December 1 through April 30 to reduce stress on wintering deer and elk. Woodland harvests would be designed to increase forage production and would be compatible with wildlife habitat management objectives. Off-Road Vehicles. A total of 2,482 acres in the Camel Back/upper Roubideau Creek drainage area would be closed to ORV use. Vehicle use in the remainder of the management unit would be limited to designated roads and trails from December 1 through April 30. Variances to this seasonal 147 PROPOSED PLAN limitation may be granted if ORV use would not result in any negative impacts on wintering deer and elk. Visual Resources. The management unit would be managed under VRM Class III guidelines. Major Utilities. The management unit would be open to development of major utility facilities. Within crucial deer and elk winter range, construction activities may be restricted from December 1 through April 30 if necessary to reduce stress on wintering deer and elk. Acquisition of Non-Federal Lands. If they are available, non-federal lands that would be necessary for effective management of crucial deer and elk winter range may be acquired through exchange. Access. Public access would be acquired into the McDonald Mesa, Roatcap-Jay Creek, Spaulding Peak/Dry Creek, Oak Mesa, and Oak Ridge areas for hunting and other recreational uses, wildlife habitat management, and timber and woodlands management. Fire Management. A total of 53,502 acres of public surface would be managed under the fire suppression category, with 48,118 acres identified for intensive suppression and 5,384 acres identified for conditional suppression. A total of 13,818 acres would be managed under the fire-use category where fire would be utilized as a management tool. Planned or natural ignitions meeting pre-determined prescriptions would be allowed in these areas. MANAGEMENT UNIT 3 47,607 Acres of Public Surface; 10 percent of the Planning Area Management Unit 3 consists of 47,607 acres of public land located primarily on the northeast-facing slopes of the Uncompahgre Plateau. The management unit contains some of the most productive pinyon-juniper woodland sites in the planning area which are used extensively for livestock grazing and are valuable deer and elk habitat. The management unit would be managed for sustained yield production of the woodland resource within the allowable cut restrictions determined by the TPCC inventory (23,206 acres). Oil and Gas. Federal oil and gas estate would be open to leasing. A seasonal stipulation on seismic and drilling activities would be in effect on crucial deer and elk winter range (28,552 acres of federal surface and 25 acres of split- estate) from December 1 through April 30 if necessary to reduce stress on wintering deer and elk. Variances to this seasonal stipulation may be granted on a case-by-case basis (see Appendix A). Soils and Water Resources. Non-conflicting erosion control objectives, projects, and mitigating measures would be incorporated into new forest management plans (FMPs). Existing erosion control projects would be maintained and new projects would be developed if they would not decrease the woodland base. Wildlife Habitat. Non-conflicting wildlife habitat management objectives, projects, and mitigating measures would be incorporated into new FMPs. Existing wildlife habitat projects would be maintained and new projects would be developed if they would not decrease the woodland base. Livestock Grazing. Non-conflicting livestock grazing management objectives, projects, and mitigating measures would be incorporated into new FMPs. Existing livestock projects would be maintained and new projects would be developed if they would not decrease the woodland base. Off-Road Vehicles. The management unit would be open to ORV use except in crucial deer and elk winter range (28,552 acres) where vehicle use would be limited to designated roads and trails from December 1 through April 30 if necessary to reduce stress on wintering deer and elk. Use of ORVs for woodland management and harvest purposes would be authorized year-round. Access. Public access would be acquired into the Beaver Hill and Linscott Canyon areas for woodland harvest and recreation purposes. Fire Management. A total of 25,162 acres of public land would be managed under the fire suppression category, with 21,187 acres identified for intensive suppression and 3,975 acres identified for conditional suppression. A total of 22,445 acres would be managed under the fire-use category where fire would be utilized as a management tool. Planned or natural ignitions meeting pre-determined prescriptions would be allowed on these areas. MANAGEMENT UNIT 4 40, 792 Acres of Public Surface; 8 percent of the Planning Area Management Unit 4 consists of the 40,792 acres of public lands surrounding the Gunnison Gorge. The management unit is characterized by a diversity of landscapes and high- value recreation opportunities. The need to protect both the quality and diversity of recreation opportunities and to facilitate recreation use would be recognized as important during the formulation of management decisions affecting the area. The management unit would be managed as the Gunnison Gorge Special Recreation Management Area (SRMA). Maps, interpretive materials, and facilities would be developed. Recreation use would be monitored and possibly 148 PROPOSED PLAN restricted as necessary to protect natural features and recreation opportunities. Lands in the Peach Valley area (15,610 acres) would be managed for ORV recreation opportunities. A minimum of restrictions would be placed on surface-disturbing activities and a high concentration of recreation users would be permitted within this area. Motorized access to the remainder of the management unit (25,182 acres) would be restricted to designated roads, the majority of which are primitive in character. This area would be managed to maintain a predominantly natural environment with low but evident human concentrations and impacts. Oil and Gas. Federal oil and gas estate would be open to leasing. A seasonal stipulation on seismic and drilling activities would be in effect from December 1 through April 30 on crucial deer and elk winter range (8,077 acres of federal surface and 280 acres of split-estate). Variances in this seasonal restriction may be granted on a case-by-case basis (see Appendix A). Locatable Minerals. Federal mineral estate would be open to entry and location. The BLM protective withdrawal (PLO 5261; September 15, 1972) would be revoked and the BOR withdrawal on Fruitland Mesa would be recommended for revocation. Revoking these mineral withdrawals would allow for mineral exploration and development, facilitate resource management, and permit long-term land use planning. Soils and Water Resources. The Elephant Skin Wash salinity control project would be maintained to reduce saline runoff. Elephant Skin Wash would be protected from surface-disturbing activities. Wildlife Habitat. Bighorn sheep habitat in the Smith Fork Canyon (2,250 acres) would be monitored and protected. Activities and land uses that are consistent with maintaining the necessary forage and isolated habitat requirements of bighorn sheep would be permitted. Livestock Grazing. Livestock grazing would continue at current forage allocation levels and seasons of use unless studies indicate that adjustments are needed. The 140-acre Gunnison Forks habitat management area would remain unallotted for livestock grazing. Livestock forage utilization would be limited to 35 percent in the Elephant Skin Wash area (2,370 acres) as necessary to protect soils by maintaining an optimum basal ground cover. Forestry. A 1,255-acre portion (in the Black Ridge area) of the 2,500 acres of harvestable woodlands within the management unit would be available for management and harvest. This area would be closed to harvest from December 1 through April 30 to protect crucial deer and elk winter range. The remaining harvestable woodlands (1,245 acres) would be managed for scenic and relic-area values and would not be harvested. Off-Road Vehicles. A total of 15,610 acres in the Peach Valley area would be open to ORV use. To protect natural and scenic values, vehicle use in the Elephant Skin Wash area and the remainder of the management unit would be limited to designated roads and trails yearlong. Visual Resources. The 15,610 acres open to ORV use would be managed under VRM Class IV guidelines. Major Utilities. A total of 2,462 acres in the Smiths Mountain and Gunnison Forks areas would be open to but not preferred for development of new major utility facilities. These lands could be utilized for major utility development if there are no feasible alternatives. The remainder of the management unit would be closed to new major utility development to protect natural and scenic values. Acquisition of Non-Federal Lands. Actions would be initiated to acquire 2,200 acres of non-federal lands, as identified in the Gunnison Gorge Recreation Area Management Plan (RAMP), that would be necessary to facilitate public access and enhance recreational values. Access. Public access would be acquired along the Gunnison Gorge rim southwest of the Gunnison Forks and from Colorado Highway 92 to the Gunnison River in the Austin area for recreation purposes. Fire Management. A total of 26,070 acres of public land would be managed under the fire suppression category and identified as conditional suppression areas. A total of 14,722 acres would be managed under the fire-use category where fire would be utilized as a management tool. Planned or natural ignitions meeting pre-determined prescriptions would be allowed on these areas. MANAGEMENT UNIT 5 24, 1 77 Acres of Public Surface; 5 percent of the Planning Area Management Unit 5, totalling 24,177 acres, consists of Mancos shale hills commonly known as the "adobes". These highly erodible soils, combined with a lack of protective vegetation, can produce sediment loads in local watersheds that are high in salinity. High precipitation runoff rates from the adobes contribute to overall salinity levels in the Upper Colorado River Basin. Salinity yields are increased within localized areas due to increased erosion from surface- disturbing activities including ORV use and livestock grazing. The management unit would be managed to reduce salinity loads in the Upper Colorado River Basin. In-channel structures and land treatment projects designed to reduce runoff, erosion, and sedimentation would be developed, and 149 PROPOSED PLAN surface protection measures would be implemented. Forage utilization would be managed to achieve the basal ground cover objectives identified in Table 6. Surface-disturbing activities would be curtailed from March 1 through May 31 when saturated soils are most vulnerable to damage. Activities and other land uses which are consistent with maintaining the soil and vegetative conditions necessary to reduce erosion and salt contributions to the river basin would be permitted. Fire Management. A total of 22,992 acres of public land would be managed under the fire suppression category and identified as conditional suppression areas. A total of 1,185 acres would be managed under the fire-use category where fire would be utilized as a management tool. Planned or natural ignitions meeting pre-determined prescriptions would be allowed on these areas. MANAGEMENT UNIT 6 Table 6 OBJECTIVES FOR PERCENT GROUND COVER WITHIN MANAGEMENT UNIT 5 RANGE SITE LOCATION PERCENT BASAL GROUND COVER Stony saltdesert North of Delta 10 Clayey saltdesert South of Hotchkiss 10 Salt flats South of Hotchkiss 7 Clayey saltdesert Bone Mesa 10 Oil and Gas. Federal oil and gas estate would be open to leasing. A seasonal stipulation on seismic and drilling activities would be in effect from March 1 through May 31 to protect erodible and saline soils on 24,177 acres of federal surface and 4,155 acres of split-estate. Variances to this seasonal stipulation may be granted on a case-by-case basis (see Appendix A). Mineral Materials. Federal mineral estate would be open to mineral material activities except from March 1 through May 31 if necessary to protect wet soils. Livestock Grazing. Livestock grazing would be allowed except from March 20 to range readiness to protect plant species during the spring growth period, and to prevent soil disturbance when saturated soils are most vulnerable to damage. If the basal ground cover is less than the objectives identified in Table 6 livestock forage utilization would be managed at 35 percent of key forage species to increase basal ground cover. Off-Road Vehicles. To protect highly saline soils, vehicle use in the entire management unit would be limited to designated roads and trails yearlong. Major Utilities. The management unit would be open to development of major utility facilities but no surface- disturbing activities would be permitted from March 1 through May 3 1 if necessary to protect wet soils. 21, 038 Acres of Public Surface; 4 percent of the Planning Area Management Unit 6 is the Gunnison Gorge WSA (CO- 030-388). The WSA, totalling 21,038 acres, would be recommended as preliminarily suitable for wilderness designation. Until a final decision on wilderness designation or non-designation is made, the Gunnison Gorge WSA would be managed according to the Wilderness Interim Management Policy and the Gunnison Gorge RAMP. During the wilderness intensive inventory, the Gunnison Gorge was determined to meet the wilderness size requirement of at least 5,000 acres, to be natural, and to provide outstanding opportunities for solitude and primitive/ unconfined recreation. The scenic and wilderness canyon complex of the area has received considerable publicity and public interest. If designated as wilderness by Congress, activities and land uses that are consistent with preserving the natural condition and wilderness character of the area would be permitted. Air Quality. The management unit would be managed within federal air quality Class II guidelines unless the State of Colorado reclassifies the area, or other areas, as a result of procedures prescribed in the Clean Air Act as amended in 1977. Under other state authorities, the Gunnison Gorge WSA is currently managed as a Category I area where more restrictive sulfur dioxide requirements apply. Oil and Gas. Federal oil and gas estate would be closed to future leasing. There are no pre-FLPMA leases in the WSA. Development of any post-FLPMA leases would be permitted only if activities would result in no impairment of wilderness characteristics. Locatable Minerals. The management unit would be closed to mineral entry and location except for pre-FLPMA claims determined to have valid discoveries. The majority of the area (74 percent) is presently withdrawn from mineral entry. Mineral Materials. The management unit would be closed to disposal of mineral materials. Soils and Water Resources. Where natural recovery is unlikely, deteriorated watershed conditions would be restored if life, property, or wilderness values are threatened, or if serious depreciation of important environmental 150 PROPOSED PLAN qualities outside the wilderness area is evident. Revegetation efforts would be limited to use of native or naturalized species. Whenever feasible, non-motorized access and project development methods would be required. Approval of the BLM Director would be required for all watershed restoration projects. Threatened and Endangered Species. Threatened and endangered species research and habitat improvement would be permitted if activities are consistent with protection of wilderness values. Habitat would be managed for federally- listed bald eagles and peregrine falcons and state-listed river otters. Recreation use would be restricted if necessary for the protection of threatened and endangered species. Wildlife Habitat. Wildlife habitat would be managed to allow for natural distribution, numbers, and interaction of indigenous wildlife and fish species. Developed facilities, if necessary for the continued existence or welfare of a wildlife species, would be permissible if wilderness characteristics would not be impaired. Bighorn sheep habitat and deer and elk winter range would be managed in cooperation with the Colorado DOW. Supplemental releases of bighorn sheep would be permitted as identified in the 1986 reintroduction plan or its future amendments. Livestock Grazing. Livestock grazing and facility maintenance would be managed at levels and conditions established prior to wilderness designation. New rangeland improvements would be permissible if determined to be necessary for rangeland and/or wilderness protection. Forestry. Woodland harvest and/or management would be permitted only for control of insects and disease if determined necessary to protect resources outside the management unit. There is a total of 337 acres of productive woodlands within the WSA that would be unavailable for management and harvest. Recreation. Recreation use would be regulated as necessary to protect wilderness values. Highest priority would be given to low-impact recreation activities that could not be accommodated outside the wilderness environment. Opportunities for non-motorized recreation in a predom- inantly natural environment would be maintained. Facilities, improvements, and signs would be limited to those necessary to protect wilderness resources along with public health and safety. Permits would be required for all commercial recreation uses and, if necessary to protect wilderness values, for all non-commercial recreationists. Hunting, fishing, and recreational trapping would be permitted. The river corridor would be managed to maintain very low human group concentrations and little overall evidence of human use. River-boating use would be limited to six to ten group encounters per day with no more than one commercially-outfitted trip allowed per day. Allocations between private and commercial river-boating use would be made if necessary to protect wilderness values or to emphasize opportunities for specific recreational experiences such as self-reliance as opposed to guided and outfitted experiences. Off-Road Vehicles. Vehicle use in general would be eliminated from the management unit. Vehicle use would be permitted in certain circumstances involving valid existing rights, livestock grazing, fire suppression, life-threatening emergencies, and wilderness area administration. The rugged canyon area has few vehicular access routes. Cultural and Paleontological Resources. In most instances, cultural and paleontological resources would be subject to the forces of nature in the same manner as other wilderness resources. Study or management would not entail excavation, stabilization, or interpretation. Exceptions may be granted by the BLM State Director for unusually significant cultural or paleontological resources. Visual Resources. The management unit would be managed under VRM Class I guidelines. Major Utilities. The management unit would be closed to development of utility facilities. The area is not within the lands identified as needed for future major utility development in the 1980 and 1985 Western Regional Utility Corridor Study(s). Hydroelectric Development. Several hydroelectric projects have been proposed for development on the Gunnison River which would be within or affect the WSA. Temporary protective withdrawals have disallowed major on-the-ground evaluations by the proponents. The President has compatibility decision authority between the wilderness and the prospecting for hydroelectric sites, and BLM recommends that he recommend to Congress the unsuit- ability of actual dams or construction of dams in the wilderness designation. BLM recommends the revocation of BOR withdrawals. However, if BOR determines that the withdrawal is still needed for Reclamation purposes, the withdrawal will be continued. Access. Public access to the WSA boundary in the Red Canyon area would be identified for acquisition. Agricultural Development. No agricultural or related development would be permitted within the management unit. The BLM would recommend revocation of the portion of the BOR Fruitland Mesa withdrawal that is within the WSA. Fire Management. A total of 21,038 acres would be managed under the fire-use category where fire would be utilized as a management tool. Only natural ignitions meeting pre-determined prescriptions would be allowed in this area. 151 PROPOSED PLAN MANAGEMENT UNIT 7 17,232 Acres of Public Surface; 4 percent of the Planning Area Management Unit 7 consists of 54,474 acres of federal coal estate within the planning area and 1,756 acres of federal coal estate outside of the planning area. A 17,232-acre portion of this federal coal estate underlies federal surface estate. The management unit would be managed for both existing and potential coal development. Development of existing coal leases would continue, and unleased federal coal would be identified as acceptable for further coal leasing consideration with a minimum of multiple-use restrictions. Activities and land uses that are consistent with maintaining existing coal operations and the potential for coal development would be permitted. Oil and Gas. Federal oil and gas estate would be open to leasing. A seasonal stipulation on seismic and drilling activities would be in effect from December 1 through April 30 on 1,730 acres (federal surface) of crucial deer and elk winter range, and on 1,637 acres of federal surface and 630 acres of split-estate lands used as hunting habitat by bald eagles. Variances in these seasonal stipulations may be granted on a case-by-case basis (see Appendix A). Riparian/Aquatic Systems. Riparian/aquatic zones up to one-quarter mile wide would be protected. Activities that disturb these areas could be approved on a site-specific basis after consultation with affected entities and development of mitigating measures. Wildlife Habitat. Wildlife would have priority for forage allocations on crucial deer and elk winter range ( 1 ,730 acres). Forestry. All commercial forest lands and pinyon-juniper woodlands that are suitable for harvest would be managed for sustained yield production within allowable cut restrictions determined by the TPCC inventory. Off-Road Vehicles. Vehicle use in the riparian zones associated with Bear and Roatcap creeks would be limited to designated roads and trails yearlong. Vehicle use in crucial deer and elk winter range (1,730 acres) would be limited to designated roads and trails from December 1 through April 30. This seasonal ORV designation would be subject to change on a site-specific basis if mild winter conditions eliminate the need for protection of a crucial winter range. Major Utilities. Corridors one-quarter mile wide and located on each side of Colorado Highway 133 would be open to development of major utility facilities. The remainder of the area would be closed to major utility facilities except for those needed for coal development. Within the management unit, 83 percent of the public lands that are identified as needed for future major utility development would be closed to this type of development. This management would greatly reduce the long-term conflicts between new utility facilities and the potential surface effects of coal mine subsidence. Acquisition of Non-Federal Lands. If they are available, non-federal lands that would be necessary for effective management of riparian zones along with crucial deer and elk winter range would be acquired through exchange only. Fire Management. A total of 14,910 acres of public land would be managed under the fire suppression category and identified as intensive suppression areas. A total of 2,322 acres would be managed under the fire-use category where fire would be utilized as a management tool. Planned or natural ignitions meeting pre-determined prescriptions would be allowed on this area. MANAGEMENT UNIT 8 8,942 Acres of Public Surface; 2 percent of the Planning Area Management Unit 8 is 8,942 acres of public land northeast of Delta that consists of Mancos shale (adobe badlands) hills with little vegetative cover. The area is suitable and utilized for ORV recreation. ORV activities typically involve local residents and occur during the spring, fall, and winter. The management unit would be managed as open to ORV use. Recreational and competitive ORV use and a high concentration of recreation users would be permitted within the management unit. Facilities such as informational signs and motorcycle loading ramps could be developed if constructed and maintained to BLM standards by local ORV organizations. A minimum of restrictions would be placed on surface-disturbing activities that do not impede or endanger ORV recreationists. Prior to management of the area for ORV use, an inventory will be conducted to identify threatened and endangered plant populations. The management unit's proposed boundary will be adjusted to exclude threatened and endangered plants. If plants or plant communities cannot be excluded from the management unit, protective fencing or other measures will be implemented to protect the plants. The USFWS will be consulted. Livestock Grazing. Grazing use would continue in the management unit but construction of facilities, such as livestock control fences, that create safety hazards or impede free vehicle use would not be permitted. Visual Resources. The management unit would be managed under VRM Class IV guidelines. Major Utilities. The management unit would be open to development of major utility facilities. 152 PROPOSED PLAN Fire Management. A total of 8,942 acres of public land would be managed under the fire suppression category and identified as conditional suppression areas. MANAGEMENT UNIT 9 6,320 Acres of Public Surface; 1 percent of the Planning Area The public land riparian zones that comprise Management Unit 9 occur throughout the planning area and are generally associated with perennial or intermittent streams. These areas (6,320 acres) have a very high productive capability and are very important in maintaining the water quality of the adjacent streams. The management unit would be managed to restore and enhance riparian vegetation along 40 miles of streams. Objectives and projects designed to accelerate improvement of species diversity, streambank cover and stability, and instream structure, and to raise the water table would be incorporated into existing activity plans or developed in new riparian/aquatic system management plans. All areas would be intensively monitored for vegetation, aquatic habitat, and erosion conditions. Coal. Coal development would be considered on a site- specific basis after consultation with affected entities and formulation of mitigating measures. Mineral Materials. Federal mineral estate would be closed to disposal of mineral materials except for sales which would result in negligible or no impacts to the riparian and aquatic systems. Soils and Water Resources. Non-conflicting erosion control and water quality improvement objectives and projects would be incorporated into new riparian/aquatic system management plans. Wildlife Habitat. Non-conflicting wildlife habitat management objectives, projects, and mitigating measures would be incorporated into new riparian/aquatic system management plans. Livestock Grazing. Livestock grazing use would be permitted in riparian zones except from March 1 through range readiness, during which time it would be eliminated to accelerate improvement of riparian vegetation. To improve the condition of riparian zones, management practices and principles would be established in activity plans. Utilization of 35 percent by weight of key forage species will be used as a general guidance for improvement; this may vary depending on the individual riparian system. Trailing use would be limited as much as possible and confined to established roads, and trailing livestock would not be permitted to bed in riparian zones unless absolutely necessary. Forestry. Woodland product harvests would not be permitted in the management unit. Off-Road Vehicles. A total of 680 acres in Roubideau and Potter creeks would be closed to ORV use. Vehicle use in the remainder of the management unit would be limited to designated roads and trails yearlong. Major Utilities. The management unit would be open to development of major utility facilities. Surface-disturbing activities which would have long-term adverse effects on riparian/aquatic systems would be prohibited. Acquisition of Non-Federal Lands. If they are available, non-federal lands that would be necessary for effective management of riparian/aquatic systems would be acquired through exchange only. Access. Public access would be acquired into the Terror Creek area for project development and recreation purposes. The Potter Creek road (five miles) and the Dry Fork of Escalante Creek road (two miles) would be closed and rehabilitated and removed from the transportation plan. Fire Management. A total of 3,082 acres of public land would be managed under the fire suppression category, with 1,607 acres identified for intensive suppression and 1,475 acres identified for conditional suppression. A total of 3,238 acres would be managed under the fire-use category where fire would be utilized as a management tool. Planned or natural ignitions meeting pre-determined prescriptions would be allowed on these areas. MANAGEMENT UNIT 10 3,292 Acres of Public Surface; less than 1 percent of the Planning Area Management Unit 10 consists of two tracts in the High Park/Storm King Peak area 20 miles southeast of Montrose. The management unit (3,292 acres of public land) ranges from 8,500 feet to over 10,000 feet in elevation, and is used extensively as an elk calving area in the spring. The largest commercial timber stands in the planning area exist in this unit. The management unit would be managed to enhance its use as an elk calving area. Any disturbance during the calving season (May 1 through June 15) would be limited as much as possible. Habitat in elk calving areas would be improved, and wildlife would have first priority for allocation of new forage. Oil and Gas. Federal oil and gas estate (3,292 acres of federal surface and 1,423 acres of split-estate lands) would be open to leasing with a seasonal stipulation on seismic and drilling activities in effect from May 1 through June 15 to prevent disturbance of calving elk. Variances to this 153 PROPOSED PLAN seasonal stipulation may be granted on a case-by-case basis (see Appendix A). Soils and Water Resources. Stipulations designd is used extensively as an elk calving area in the spring. The largest commercial timber stands in the planning area exist in this unit. Forestry. Skid trails and other roads would be closed and rehabilitated; main haul roads would remain available for public use. Off-Road Vehicles. The management unit would be open to ORV use except during the elk calving season when all roads would be closed. Access for maintenance of the existing communications site would be permitted at all times. Major Utilities. Public lands would be open to development of major utility facilities but no surface- disturbing activities would be permitted during the elk calving season. Acquisition of Non-Federal Lands. If they are available, non-federal lands that would expand elk calving areas and improve extensive recreational opportunities would be acquired through exchange only. Access. Public access would be acquired into the Storm King and High Park areas for timber harvest and extensive recreation purposes. Fire Management. A total of 3,292 acres of public land would be managed under the fire suppression category and identified as intensive suppression areas. MANAGEMENT UNIT 11 1,990 Acres of Public Surface; less than 1 percent of the Planning Area Management Unit 1 1 is comprised of 1,990 acres of public land adjacent to the Gunnison River west of Delta. It adjoins the Escalante State Wildlife Area which is administered by the Colorado DOW. The management unit presently receives considerable use by waterfowl as nesting and resting habitat. Additional management and minor developments could enhance its potential for increased use as waterfowl habitat. The management unit would be managed as waterfowl habitat. Adequate cover, wetlands, and nesting structures would be provided. Disturbance would be minimized during the breeding and nesting season (March 15 through June 30). Activities and land uses that are consistent with maintaining waterfowl habitat characteristics would be permitted. The BLM would coordinate management of the area with the DOW. Oil and Gas. Federal oil and gas estate (1,990 acres of federal surface and 150 acres of split-estate lands) would be open to leasing with seasonal stipulations on seismic and drilling activities in effect from March 15 through June 30 to protect waterfowl habitat, and from December 1 through April 30 on habitat used for hunting by bald eagles. Variances to the seasonal stipulations may be granted on a case-by-case basis (see Appendix A). Locatable Minerals. The BOR withdrawal and the BLM powersite classifications in this management unit would be recommended for revocation and opening to permit mineral exploration and development, facilitate resource manage- ment, and permit long-term land use planning. Federal mineral estate would be opened to entry and location. Mineral Materials. Federal mineral estate would be open to disposal of mineral materials except during the waterfowl nesting season. Acquisition of Non-Federal Lands. If they are available, non-federal lands that would be necessary to increase waterfowl habitat and facilitate development and manage- ment of the area would be acquired through exchange only. Fire Management. The entire management unit (1,990 acres) would be managed under the fire suppression category and identified as a conditional suppression area. MANAGEMENT UNIT 12 1,895 Acres of Public Surface; less than 1 percent of the Planning Area Management Unit 12 is 1,895 acres of public land in Escalante Canyon approximately six miles southwest of the Gunnison River. Several listed plant species and two unique plant associations occur in the management unit. The area also receives significant recreational use due to its scenic qualities and the presence of eroded potholes in Escalante Creek. The management unit would be designated as the Escalante Canyon Area of Critical Environmental Concern (ACEC). This designation would enhance management and protection of the listed plant species and unique plant associations, and would improve the public's awareness of the recreational hazards of the Escalante Potholes. Plant monitoring studies would be developed and activities designed to improve these plants' habitat conditions would be initiated. Surface-disturbing activities would be restricted. Informational signs identifying potential recreational hazards would be provided. Camping would be limited to designated areas. Oil and Gas. Federal oil and gas estate would remain open to leasing with a no surface occupancy stipulation. Locatable Minerals. The management unit would be withdrawn from entry and location for locatable minerals. 154 PROPOSED PLAN Mineral Materials. The management unit would be closed to disposal of mineral materials to protect the potential habitats of listed species and unique plant associations. Livestock Grazing. Livestock grazing would continue at current levels unless studies determine threatened and endangered plant species and unique plant associations or their potential habitats are being degraded. Forestry. To prevent accidental destruction of listed species and unique plant associations, woodland harvests would not be permitted. Off-Road Vehicles. To prevent accidental destruction of listed species and unique plant associations, vehicle use within the management unit would be limited to designated roads and trails yearlong. Visual Resources. The management unit would be managed under VRM Class II guidelines to maintain its scenic qualities. Major Utilities. The management unit would be closed to development of major utilities to prevent accidental destruction of listed species and unique plant associations, and to maintain its scenic qualities. Fire Management. All 1,895 acres of public surface in the management unit would be managed under the fire- use category where fire would be utilized as a management tool. Planned or natural ignitions meeting pre-determined prescriptions would be allowed. MANAGEMENT UNIT 13 377 Acres of Public Surface; less than 1 percent of the Planning Area Management Unit 13 consists of two tracts totalling 377 acres of public land eight miles east of Montrose. The smaller tract is north of Highway 50 and the larger tract is south of the highway. The tracts contain the largest population of the endangered clay-loving wild buckwheat in the planning area and also have significant populations of Montrose penstemon, a candidate species. The management unit would be designated as the Fairview Research Natural Area, an area of critical environmental concern (RNA/ACEC). Plant monitoring studies would be developed in cooperation with the Colorado Natural Areas Program and actions designed to improve habitat conditions would be initiated. Surface-disturbing activities would be restricted to protect the threatened and endangered species and their potential habitat. Oil and Gas. Federal oil and gas estate would remain open to leasing with a no surface occupancy stipulation. Locatable Minerals. The management unit would be withdrawn from entry and location for locatable minerals. Mineral Materials. The management unit would be closed to disposal of mineral materials to prevent accidental destruction of threatened or endangered plant species or their potential habitat. Livestock Grazing. Livestock grazing would continue at current levels unless studies determine threatened and endangered plant species or their potential habitats are being degraded. Off-Road Vehicles. To prevent accidental destruction of threatened or endangered plant species or their potential habitat, the management unit would be closed to ORV use. Major Utilities. The management unit would be open to development of major utility facilities, except pipelines, so long as there would be no disturbance of threatened or endangered plant species or their potential habitat. Fire Management. The management unit (377 acres) would be managed under the fire suppression category and identified for conditional suppression. MANAGEMENT UNIT 14 80 Acres of Public Surface; less than 1 percent of the Planning Area Management Unit 14 is an 80-acre site consisting mainly of a volcanic structure with high- value scientific, interpretive, and scenic characteristics. A shelter facility and interpretive nature trail have been developed in the area. Needle Rock is part of the Colorado Natural Areas Program and is one of the significant public land geologic features in Colorado as identified by the BLM's Geologic Advisory Group. The management unit would be designated as the Needle Rock Outstanding Natural Area, an area of critical environmental concern (ONA/ACEC). This designation would preclude all surface-disturbing activities that are not consistent with management of the area for natural, scenic, and educational values. The area would be managed to protect these values and for recreation opportunities (sightseeing, picnicking, and geologic study) in a roaded but natural environment. A management plan would be developed following designation. Oil and Gas. Federal oil and gas estate would remain open to leasing with a no surface occupancy stipulation. Locatable Minerals. The management unit would remain withdrawn from entry and location for locatable minerals. Mineral Materials. The management unit would be closed to disposal of mineral materials. Livestock Grazing. The management unit would remain unallotted for livestock grazing use. Off-Road Vehicles. Vehicle use within the management unit would be limited to designated roads and trails yearlong. 155 PROPOSED PLAN Visual Resources. The management unit would be managed under VRM Class I guidelines. Major Utilities. The management unit would be closed to development of major utility facilities. Fire Management. The entire management unit would be managed under the fire suppression category and identified as an intensive suppression area. MANAGEMENT UNIT 15 6, 783 Acres of Public Surface; 1 percent of the Planning Area Management Unit 15 consists of 6,783 acres of public land approximately three miles northwest of Delta, Colorado. This area, commonly known as "the adobes", consists of Mancos shale hills and flats which, through wind and water erosion, have formed unique scenic formations. The unit's soils are highly erodible and saline. Spring and summer storms frequently result in high sediment loads and very saline runoff. The management unit also contains populations of the threatened Uinta Basin hookless cactus and is potential habitat for the endangered clay-loving wild buckwheat and the candidate Montrose penstemon. The management unit would be designated as the Adobe Badlands Outstanding Natural Area, an area of critical environmental concern (ONA/ACEC). The area would be managed to protect its unique scenic qualities and threatened and endangered species' habitats, and to reduce active erosion. The management unit would be protected from surface- disturbing activities which would degrade the area's scenic qualities and accelerate erosion. A complete inventory for threatened and endangered species would be conducted. Forage utilization would be managed to achieve a basal ground cover of 10 percent. Coal. Federal coal estate would be closed to leasing. Oil and Gas. Federal oil and gas estate would remain open to leasing with a no surface occupancy stipulation. Mineral Materials. The management unit would be closed to the disposal of mineral materials. Soils and Water Resources. Erosion and salinity control measures would not utilize structures or land treatments which would alter scenic values. Threatened and Endangered Species. A complete inventory for threatened and endangered species would be conducted. Research and monitoring studies would be established. Wildlife Habitat. Wildlife forage allocations would remain at current levels. No additional forage allocations would be made. To protect scenic values, no new habitat improvement projects or maintenance of existing projects would be permitted. Livestock Grazing. Livestock grazing would continue at current levels unless studies determine threatened and endangered plant species or their potential habitat are being degraded. If basal groundcover is less than 10 percent, livestock forage utilization would be managed at 35 percent utilization of key forage species. No additional forage allocations would be made. To protect scenic values, no new livestock improvement projects or maintenance of existing projects would be permitted. Recreation. The unit would be managed for primitive non-motorized recreational use. Off-Road Vehicles. The unit would be closed to ORV use to protect the scenic qualities and to prevent accidental destruction of threatened and endangered plant species and their potential habitat. Visual Resources. To maintain its scenic qualities, the unit would be managed under VRM Class I guidelines. Major Utilities. The unit would be closed to the development of major utility facilities to prevent accidental destruction of threatened and endangered species and to maintain its scenic qualities. Fire Management. The unit would be managed under the fire suppression category and identified for conditional suppression. MANAGEMENT UNIT 16 48,422 Acres of Public Surface; 10 percent of the Planning Area In general, the public lands in Management Unit 16 (48,422 acres) would be managed according to the policy assumptions and standard resource program management guidance developed for this Proposed Plan. No single resource or resource use would have management priority. No activity plans would be written and no major BLM- funded projects or facilities would be developed within this area. Habitat, vegetation, and other resource studies would be minimal. Specific resource management in this area would be prescribed as follows. Oil and Gas. Federal oil and gas estate would be open to leasing. A seasonal stipulation on seismic and drilling activities would be in effect from December 1 through April 30 on 1,042 acres of federal surface along the Gunnison and North Fork of the Gunnison rivers that are used by bald eagles as hunting habitat. Variances to the seasonal 156 °*~ Tlffl stipulation may be granted on a case-by-case basis (see Appendix A). Locatable Minerals. The BOR withdrawals on Fruitland Mesa and along the Gunnison River downstream of Delta would be recommended for revocation to allow for mineral exploration and development, facilitate resource manage- ment, permit long-term land use planning, and allow for disposal of 806 acres of public land on Fruitland Mesa. Withdrawals on all other lands identified for disposal would be recommended for revocation. Portions of withdrawals in the management unit would be affected, including those associated with 108 acres of the Paonia Project, 37 acres of the Gunnison/Arkansas Project, 72 acres of the Uncompahgre Valley Project, and 25 acres along the East Canal. Federal mineral estate would be open to entry and location after a withdrawal is revoked. PROPOSED PLAN Forestry. The reserved federal timber (123 acres) on 160 acres of land deeded to the Girl Scouts of America would be removed from the timber base and not considered for harvest. The management and harvest of this timber would be inconsistent with use of the land as a Girl Scout camp. Off-Road Vehicles. Public lands within the management unit would be open to ORV use. Fire Management. A total of 48,422 acres of public land would be managed under the fire suppression category, with 12,401 acres identified for intensive suppression and 36,021 acres identified for conditional suppression. 157 "—™™°™HII1IWW1MI COMPARISON OF THE PROPOSED PLAN AND THE MANAGEMENT ALTERNATIVES Table 7 is a composite summary of the data presented in resource use the major land use allocations that would be the prescriptions for the Continuation of Current made under each management alternative and under the Management Alternative, the Production Alternative, the proposed plan. The purpose of this comparison is to identify Conservation Alternative (all of which are described in major differences between the alternatives and the proposed Chapter Three of the Draft RMP/EIS), and the Proposed plan, and to provide a clearer basis for management Management Plan. The table summarizes by resource or recommendations. 159 Table 7 COMPARISON OF THE RESOURCE MANAGEMENT ALTERNATIVES AND THE PROPOSED RESOURCE MANAGEMENT PLAN RESOURCE/ RESOURCE USE GENERAL GUIDANCE MANAGEMENT UNDER THE ALTERNATIVES AND THE PROPOSED PLAN Continuation of Current Management Alternative Production Alternative Conservation Alternative Proposed Plan COAL. Allow coal develop- ment on all areas not excluded from leasing. Consider coal leasing on a demand basis; ap- ply unsuitability cri- teria and resource screening. Continue with 26 existing coal leases on 26,663 acres and identify 20,737 acres of federal coal es- tate in the Paonia/Somer- set and Cimarron Ridge coal areas as acceptable for further leasing for maintenance and emergency purposes. Continue with 26 existing coal leases on 26,663 acres and identify 83,334 acres of federal coal es- tate in the Paonia/Somer- set, Cimarron Ridge, and Bookcliffs coal areas as acceptable for further coal leasing with limited stipulations. o Continue with 26 existing coal leases on 26,663 acres and identify 82,827 acres of federal coal es- tate in the Paonia/Somer- set, Cimarron Ridge, and Bookcliffs coal areas as acceptable for further coal leasing. A no sur- face disturbance restric- tion would apply on 6,288 acres of public land and restrictions on surface disturbance and on sub- sidence activities would apply on another 1,525 acres. Continue with 26 existing coal leases on 26,663 acres and identify 83,334 acres of federal coal es- tate in the Paonia/Somer- set, Cimarron Ridge, and Bookcliffs coal areas as acceptable for further coal leasing with limited stipulations. OIL, GAS, AND GEOTHERMAL RESOURCES Allow development of oil, gas, and geother- mal resources on all areas not excluded from leasing. Allow leasing of oil, gas, and geothermal resources on 445,364 acres with standard lease terms; on 31,200 acres on a case-by- case basis; on 220 acres with a no surface occupan- cy stipulation; and on 229,950 acres with season- al stipulations. Allow leasing of oil, gas, and geothermal resources on 706,654 acres with standard lease terms. The Needle Rock ONA/ACEC (80 acres) would be managed with a no surface occupancy stipulation. Allow leasing of oil, gas, and geothermal resources on 367,488 acres with standard lease terms; on 29,915 acres with a no surface occupancy stip- ulation; and on 267,466 acres with seasonal stip- ulations. Three areas recommended as wilderness (41,865 acres) would be closed to leasing. Allow leasing of oil, gas, and geothermal resources on 484,349 acres with standard lease terms; on 9,135 acres with a no surface occupancy stipu- lation; and on 192,212 acres with seasonal stipulations. The Gunnison Gorge WSA (21,038 acres), recommended as wilderness, would be closed to leasing. Table 7 (continued) RESOURCE/ RESOURCE USE MANAGEMENT UNDER THE ALTERNATIVES AND THE PROPOSED PLAN GENERAL GUIDANCE Continuation of Current Management Alternative Production Alternative Conservation Alternative Proposed Plan LOCATABLE MINERALS Allow development of locatable minerals on all areas not closed to mineral entry and location Allow mineral entry and location on 615,892 acres. Current withdrawals total- ling 59,250 acres are closed to entry and loca- tion. Recommend revocation of all withdrawals on pub- lic lands (59,250 acres) and allow entry and loca- tion on the entire fed- eral mineral estate (675,142 acres). Recommend retention of all existing withdrawals (59,250 acres); withdraw an additional 39,602 acres from entry; allow entry and location on the remaining federal mineral estate (576,290 acres). Recommend retention of all existing withdrawals on 9,440 acres; close the Gunnison Gorge WSA, the Escalante Canyon ACEC and the Fairview RNA/ACEC to mineral entry and location (23,310 acres); allow entry and location on the remaining federal mineral estate (642,392 acres). £ MINERAL ~ MATERIALS Allow disposal of min- eral materials on all areas not excluded or withdrawn. Allow disposal of mineral materials on all public lands with federal miner- al estate (480,805 acres). Disposal of mineral mater- ials on 59,250 of these acres currently under with- drawal would require the approval of the with- drawing agency. Disposal of mineral materials would not be permitted on 220 acres. Allow disposal of mineral materials on 480,945 acres with federal mineral es- tate. The Needle Rock ONA/ACEC (80 acres) would be closed to dis- posal of mineral mater- ials. Allow disposal of mineral materials on 396,264 acres with federal mineral es- tate. Disposal on 196,700 of these acres would be subject to seasonal re- strictions. Disposal on 98,852 of these acres would require the approval of the withdrawing agency. Disposal would not be per- mitted on 84,761 acres. Allow disposal of mineral materials on 444,532 acres with federal mineral es- tate. Disposal on 63,174 of these acres would be subject to seasonal restrictions. Disposal on 9,360 of these acres would require the approval of the withdrawing agency. Disposal would not be per- mitted on 36,493 acres. SOILS AND WATER RESOURCES Establish water qual- ity studies through- out the planning area. Continue intensive manage- ment and development of the Elephant Skin Wash watershed (2,370 acres) to control salinity. No public lands would be intensively managed for salinity and/or erosion control. Public lands totalling 21,615 acres would be in- tensively managed to con- trol erosion and 26,580 acres would be intensive- ly managed to control sa- linity. Projects and special protective mea- sures would be developed. Public lands totalling 26,547 acres, including the Elephant Skin Wash project, would be inten- sively managed to reduce salinity loads in the up- per Colorado River. Ap- propriate projects and special protective mea- sures would be developed. Table 7 (continued) RESOURCE/ RESOURCE USE GENERAL GUIDANCE MANAGEMENT UNDER THE ALTERNATIVES AND THE PROPOSED PLAN Continuation of Current Management Alternative Production Alternative Conservation Alternative Proposed Plan Require mitigation to min- imize erosion and water quality deterioration in plans for surface disturb- ing activities. Mainte- nance of existing pro- jects would have priority over implementation of new projects. Projects would be devel- oped to control salinity on 7,810 acres if com- patible with livestock grazing use. Projects would be developed to re- duce runoff, erosion, and sediment on 27,430 acres if compatible with livestock grazing use, crucial deer and elk win- ter range, and forest man- agement. Projects would be devel- oped to control salinity on 29,978 acres and ero- sion on 21,703 acres if compatible with recrea- tion, T&E species, and cultural resource manage- ment. Projects would be devel- oped to reduce runoff, erosion, and sediment on 47,260 acres if compati- ble with livestock graz- ing use, forest manage- ment, deer and elk winter range, and riparian habi- tat management. S> RIPARIAN ZONES Continue to inventory and monitor riparian areas. Improve the vegetation condition on 3,500 acres of riparian zones through decreased livestock util- ization and trampling. Maintain riparian zones in the remainder of the planning area in their present condition. Maintain riparian zones in the planning area in their present condition so long as it does not interfere with other re- source uses and needs. Improve the vegetation condition on 6,385 acres of riparian zones by im- plementing special pro- tective and restorative measures. Maintain ri- parian zones in the re- mainder of the planning area in their present condition. Improve the vegetation condition on 6,320 acres of riparian zones by im- plementing special pro- tective and restorative measures. Maintain or im- prove riparian zones in the remainder of the plan- ning area. THREATENED AND ENDANGERED SPECIES Continue to inventory and monitor T&E plant and animal habitats. Continue T&E clear- ances and Section 7 consultations with the USFWS. Require measures to pro- tect T&E species, indivi- duals, and habitats in plans for all surface dis- turbing activities. Require minimal measures to protect T&E species, individuals, and habi- tats in plans for all surface disturbing activ- ities. Require additional mea- sures beyond minimal re- quirements to protect T&E species, individuals, and habitats in plans for all surface disturb- ing activities. Require measures to pro- tect T&E species, indivi- duals, and habitats in plans for all surface dis- turbing activities. Maintain suitable habitat for bald eagles and river otters in the Gunnison Gorge area. Maintain suitable habitat for bald eagles, peregrine falcons, and river otters in the Gunnison Gorge area. Table 7 (continued) RESOURCE/ RESOURCE USE MANAGEMENT UNDER THE ALTERNATIVES AND THE PROPOSED PLAN GENERAL GUIDANCE Continuation of Current Management Alternative Production Alternative Conservation Alternative Proposed Plan Designate one ACEC and one RNA/ACEC, totalling 2,272 acres, for protec- tion of T&E plants and unique plant associations. Designate one ACEC, one RNA/ACEC, and one ONA/ACEC, totalling 9,055 acres for protection of T&E plants, unique plant associations, and identi- fication of recreational hazards. WILDLIFE HABITAT Monitoring of both terrestrial and aqua- tic wildlife habitat would continue. In-channel structures and improvements to benefit aquatic wild- life habitat would be implemented. Maintain big game forage allocations at present levels; future increases/ decreases would be divid- ed evenly between big game and livestock. Maintain big game forage allocations at present levels; no future addi- tional forage would be allocated to big game. Maintain big game forage allocations at present levels; all future addi- tional forage would be allocated to big game. Maintain big game forage allocations at present levels. Big game would have priority for future additional forage on 72,342 acres; future addi- ional forage on another 193,612 acres would be di- vided evenly between big game and livestock. No additional forage would be allocated on the Adobe Badlands ONA/ACEC (6,783 acres). Protect and mitigate wild- life habitat and improve browse condition on cru- cial deer and elk ranges. Non-conflicting wildlife habitat management objec- tives and projects would be incorporated into fu- ture livestock grazing and forest management plans. Existing wild- life projects would be maintained as long as the timber and woodland base on 27,522 acres would not be decreased. Intensively manage habi- tat and minimize distur- bance on all crucial deer and elk winter ran- ges, elk calving areas (High Park), antelope ranges (Wells Gulch/ Cactus Park), sage grouse habitats (Fruitland and Simms mesa), in several proposed waterfowl areas, and aquatic wildlife hab- itat in seven drainages. No vegetation manipula- tion would be permitted on 2,738 acres of cultur- al resource sites. Intensively manage habi- tat and minimize distur- bance on 67,320 acres of important deer and elk winter range. Intensively manage and protect 3,292 acres in the Storm King Peak area for elk calving habitat. Table 7 (continued) RESOURCE/ RESOURCE USE GENERAL GUIDANCE MANAGEMENT UNDER THE ALTERNATIVES AND THE PROPOSED PLAN Continuation of Current Management Alternative Production Alternative Conservation Alternative Proposed Plan Continue cooperative man- agement effort with the DOW to benefit deer and elk in the Billy Creek area. Continue cooperative man- agement effort with the DOW to benefit deer and elk in the Billy Creek area. ON -P. Manage habitat in the Gun- nison Gorge for 1 50 big- horn sheep. Continue management of the Gunnison Forks HMP area for fisheries and wildlife habitat benefits. Manage habitat in the Gunnison Gorge for 150 bighorn sheep. Allow re- introduction of bighorn sheep into the Camel Back area so long as livestock forage needs are not impacted. Revise the Gunnison Forks HMP to restrict ORV and other recreation use, and to accommodate livestock grazing and oil and gas activities. Allocate forage, minimize disturbance, and manage habitat in the Gunnison Gorge and Camel Back areas for bighorn sheep. Continue management of the Gunnison Forks HMP area for fisheries and wildlife habitat benefits. Manage habitat and mini- mize disturbance in the Gunnison Gorge and Camel Back areas for bighorn sheep. Intensively manage and im- prove 1,990 acres along the Gunnison River for waterfowl habitat. Intensively manage 70 miles of streams for re- storation and protection of aquatic habitats. LIVESTOCK GRAZING Develop AMPs for "I" category grazing al- lotments if no plan exists. Maintain ex- isting AMPs on "M" "C" allotments. Con- tinue monitoring on all allotments, with emphasis on "I" allot- ments. Allow intensive manage- ment on 353,068 acres of "I" allotments; maintain current conditions on 65,497 acres of "M" allot- ments; manage 38,900 acres as "C" allotments. Manage 25,612 acres as un- allotted; authorize no grazing use on currently unallotted areas. Allow intensive manage- ment on 353,068 acres of "I" allotments; maintain current conditions on 65,497 acres of "M" allot- ments; manage 58,695 acres as "C" allotments (includes suitable exist- ing unallotted areas). Manage 5,817 acres as un- allotted areas. Allow intensive manage- ment on 350,796 acres of "I" allotments; maintain current conditions on 65,497 acres of "M" allot- ments; manage 38,433 acres as "C" allotments. Manage 28,351 acres as unallotted; all unallot- ted areas would remain unallotted. Allow intensive manage- ment on 336,562 acres of "I" allotments; maintain current conditions on 74,8 17 acres of "M" allot- ments; manage 39,033 acres as "C" allotments. Suitable unallotted pub- lic lands (26,873 acres) could be considered for grazing use authoriza- tions except on areas where big game has prior- ity for forage alloca- tions. Table 7 (continued) RESOURCE/ RESOURCE USE GENERAL GUIDANCE MANAGEMENT UNDER THE ALTERNATIVES AND THE PROPOSED PLAN Continuation of Current Management Alternative Production Alternative Conservation Alternative Proposed Plan Manage at present forage allocation levels; future forage increases would be divided evenly between livestock and big game. Manage at present forage allocation levels; future forage increases would be allocated to livestock. Manage for no additional forage allocations to livestock. Manage at present forage allocation levels. Fu- ture additional forage would be allocated to livestock on 186,810 acres, and divided evenly between livestock and big game on 193,612 acres. No additional forage would be allocated on the Adobe Badlands ONA/ACEC (6,783 acres). Implement projects and land treatments to meet AMP objectives with re- strictions protecting other resource needs. Implement projects and land treatments to meet AMP objectives with mini- mal restrictions. Land treatments and fac- ility developments would be restricted on 124,963 acres. Land treatments and fac- ility developments would be restricted on 151,690 acres. Livestock grazing use would be in accordance with the Uncompahgre Basin RPS and its updates. Livestock grazing use would be restricted on adobe soils (9,201 acres) during the spring. Livestock grazing use would be eliminated on 3,059 acres and restrict- ed (season of use, utili- zation) on 75,626 acres. No livestock grazing use would be allowed on 5,792 acres due to RMP deci- sions and unsuitability for grazing. Livestock grazing authorizations are unlikely on an addi- tional 6,967 acres be- cause of future wildlife forage needs. Livestock grazing would be restrict- ed (season of use, utili- zation) on 39,590 acres. FORESTRY Manage both commercial forest and suitable woodlands for sus- tained yield produc- tion with harvest re- strictions determined Commercial forest on 3,482 acres (257 MBF/year) and suitable woodlands on 6,536 acres (327 cords/ year) would be managed for sustained yield pro- Commercial forest on 2,001 acres (148 MBF/year) and suitable woodlands on 7,072 acres (353 cords/ year) would be managed for sustained yield pro- Commercial forest on 2,251 acres (166.5 MBF/ year) and suitable wood- lands on 31,997 acres ( 1 ,600 cords/year) would be managed for sustained Commercial forest on 3,127 acres (231.5 MBF/ year) and suitable wood- lands on 24,255 acres (1,213 cords/year) would be managed for sustained Table 7 (continued) RESOURCE/ RESOURCE USE GENERAL GUIDANCE by the TPCC inventory. MANAGEMENT UNDER THE ALTERNATIVES AND THE PROPOSED PLAN Continuation of Current Management Alternative duction. Seasonal re- strictions would be ap- plied on a case-by-case basis. Production Alternative Conservation Alternative duction with no seasonal restrictions. yield production. Sea- sonal restrictions would apply on 1 ,263 acres of commercial forest. Proposed Plan yield production. Sea- sonal restrictions would apply on 1 ,606 acres of commercial forest. RECREATION Manage the Gunnison Gorge SRMA in accor- dance with its RAMP. Continue to manage the Needle Rock ONA/ACEC and develop a management plan. Continue management of the the Gunnison Gorge recrea- tion area (61,067 acres) for motorized and non- motorized recreation op- portunities. Manage Whitewater boating use in the Gunnison Gorge for a maximum of 10 group encounters per day. Com- mercial overnight trips would be limited to 2 per day. Unrestricted day- use would not exceed 10 group encounters per day. Manage the inner Gunnison Gorge (21,038 acres) for intensive recreation use. Manage Whitewater boating use in the Gunnison Gorge for a maximum of 20 group encounters per day, with 8 overnight and 12 day- use permits issued daily (one-half commercial; one-half private). Manage the Gunnison Gorge recreation area (40,792 acres) for motorized and non-motorized recreation opportunities. Manage the Gunnison Gorge WSA (21,038 acres) for wilderness values and Whitewater boating oppor- tunities. Maximum boat- ing use would be 6 group encounters per day, with 3 overnight and 3 day-use permits issued daily (one-third commercial; two-thirds private). Manage the Gunnison Gorge recreation area (40,792 acres) for motorized and non-motorized recreation opportunities. Until a decision is made on wilderness designation or non-designation, man- age the Gunnison Gorge WSA (21,038 acres) for non-motorized recreation and Whitewater boating op- portunities. Boating use would be limited to 6 to 10 group encounters per day with no more than one commercial trip starting per day. Manage the remainder of the planning area for ex- tensive recreation use. Manage the lower Gunnison River, below Escalante Bridge, as an SRMA and develop river access. Manage the lower Gunnison River, below Escalante Bridge, as an SRMA for boating opportunities. Manage the lower Gunnison River, below Escalante Bridge, for boating oppor- tunities. Develop river access and provide maps and information. Manage the remainder of the planning area for ex- tensive recreation use. Restrict recreation use to primitive walk-in ac- cess in the Escalante Canyon RNA/ACEC. Manage and develop the Escalante Canyon ACEC for recreation use that does not conflict with T&E plants and unique plant associations. Manage the Table 7 (continued) MANAGEMENT UNDER THE ALTERNATIVES AND THE PROPOSED PLAN RESOURCE/ RESOURCE USE GENERAL GUIDANCE Continuation of Current Management Alternative Production Alternative Conservation Alternative Proposed Plan Adobe Badlands ONA/ACEC for its scenic qualities and for non-motorized recreation opportunities. Manage the North Delta adobe area (8,942 acres) as an SRMA for ORV use. Manage the North Delta adobe area (8,942 acres) for ORV use. Manage the Storm King Peak area (1,520 acres) for possible development of a commercial ski area. Manage the remainder of the planning area for ex- tensive recreation use. 5 Manage the remainder of the planning area for ex- tensive recreation use. OFF-ROAD VEHICLES A total of 444,521 acres would be open to ORV use and 21,038 acres would be closed to ORV use. Vehi- cle use would be limited to designated roads and trails on 17,518 acres. A total of 208,952 acres would be open to ORV use and 35 acres would be closed to ORV use. Vehi- cle use on 49,840 acres would be limited to des- ignated roads and trails yearlong and another 224,250 acres would have seasonal limited designa- tions. A total of 151,000 acres would be open to ORV use and 44,137 acres would be closed to ORV use. Vehi- cle use on 147,059 acres would be limited to des- ignated roads and trails yearlong and another 140,881 acres would have seasonal limited designa- tions. A total of 224,276 acres would be open to ORV use and 38,600 acres would be closed to ORV use. Vehi- cle use on 56,974 acres would be limited to des- ignated roads and trails yearlong and another 1 63,227 acres would have seasonal limited designa- tions. CULTURAL RESOURCES Continue to inventory and monitor cultural resource sites; re- quire clearances for all surface disturbing activities. Perform necessary stabil- ization, restoration, and interpretation of sites in the Gunnison Gorge Recreation Area. Conduct a Class III in- ventory on 2,738 acres. Temporarily manage 2,738 acres as Current Scienti- fic Use Areas. Allow no projects or land treat- ments. Conduct a Class III inventory and pro- tect cultural values in Conduct a Class III in- ventory on 5,848 acres. Some high-value sites could be assigned a long- term protective classifi- cation. Table 7 (continued) RESOURCE/ RESOURCE USE MANAGEMENT UNDER THE ALTERNATIVES AND THE PROPOSED PLAN GENERAL GUIDANCE Continuation of Current Management Alternative Production Alternative Conservation Alternative the area. High-value sites would be assigned a long-term protective classification. Proposed Plan VISUAL RESOURCES Visual resource manage- ment would be under cur- rent VRM classifications: Class I - 80 acres, Class II - 64,800 acres, Class III - 46,580 acres, Class IV- 371,617 acres. Visual resource manage- ment would be: Class I - 80 acres, Class II - 64,800 acres, Class III - 46,580 acres, Class IV - 371,617 acres. Visual resource manage- ment would be: Class I - 43,807 acres, Class II - 47,852 acres, Class III - 37,355 acres, Class IV - 354,063 acres. Visual resource manage- ment would be: Class I - 27,901 acres, Class II - 27,384 acres, Class III - 293,417 acres, Class IV - 134,375 acres. WILDERNESS Recommend all three WSAs (41,865 acres) as non- suitable for wilderness designation. Recommend all three WSAs (41,865 acres) as non- suitable for wilderness designation. Recommend all three WSAs (41,865 acres) as suit- able for wilderness des- ignation. Recommend the Gunnison Gorge WSA (21,038 acres) as suitable for wilder- ness designation. Recom- mend both the Camel Back WSA (10,402 acres) and the Adobe Badlands WSA (10,425 acres) as non- suitable for wilderness designation. Manage all three areas un- der a general multiple- use policy. The Gunnison Gorge area would be man- aged with emphasis on re- creation and habitat for T&E animal species. Manage all three areas with emphasis on live- stock grazing and miner- al exploration. The pro- tective withdrawal would be lifted on the Gunnison Gorge. The area would be managed for possible hy- droelectric development. Manage the Camel Back area with emphasis on riparian/aquatic system management, wildlife habi- tat, and livestock graz- ing. Close the entire area to ORV use. Manage 6,783 acres of the Adobe Badlands WSA as an ONA/ACEC to protect the scenic qualities and T&E plants, and to reduce active erosion. Manage the remainder of the Adobe Badlands WSA (3,642 acres) as wildlife habitat. Table 7 (continued) RESOURCE/ RESOURCE USE GENERAL GUIDANCE MANAGEMENT UNDER THE ALTERNATIVES AND THE PROPOSED PLAN Continuation of Current Management Alternative Production Alternative Conservation Alternative Proposed Plan MAJOR UTILITIES Public lands on 421,930 acres would be open to development of major utilities; 40,029 acres would be open but not pre- ferred for utility develop- ment; 21,118 acres would be excluded from utility development. 0-N LAND TENURE ADJUSTMENT As opportunities are presented, primarily through exchange, pur- sue acquisition of non-federal lands which would meet es- tablished criteria and enhance resource management within management units. Consider 1 9 tracts of pub- lic land totalling 830.25 acres as suitable for dis- posal. Pursue acquisition of 2,200 acres of private land in the Gunnison Gorge Recreation Area. Public lands on 449,597 acres would be open to development of major utilities; 33,480 acres would be excluded from utility development. Consider 171 tracts of public land totalling 29,496 acres as suitable for disposal. Pursue acquisition of 3,640 acres of Colorado DOW land in the Escalante Creek area and available private land near Dry Creek and along the lower Gunnison River below the Roubideau Creek confluence in proposed wateifowl areas. Public lands on 106,851 acres would be open to development of major utilities; 32,356 acres would be open but not preferred for utility development; 69,906 acres would be excluded from utility development. Special stipulations would restrict utility development on 273,964 acres. Consider no public lands as suitable for disposal. Pursue acquisition of 2,200 acres of private land in the Gunnison Gorge Recreation Area and 320 acres of private land in and adjacent to the Camel Back WSA. Pur- sue acquisition of pri- vate lands in proposed waterfowl areas, in ri- parian zones, and in cru- cial deer and elk winter ranges. Public lands on 301,006 acres would be open to development of major utilities; 82,038 acres would be excluded from utility development. Special stipulations would restrict utility development on 100,033 acres. Consider 1 43 tracts of public land totalling 1 1 ,026 acres as suitable for disposal. Pursue acquisition, pri- marily through exchange, of private lands which meet established criteria and enhance resource man- agement within management units. ACCESS- Acquire public road ac- cess into 14 areas and public trail access into one area. Acquire public road ac- cess into 1 3 areas. Acquire public road ac- cess into 7 areas. Acquire public road ac- cess into 1 5 areas and public trail access into one area. Table 7 (continued) MANAGEMENT UNDER THE ALTERNATIVES AND THE PROPOSED PLAN RESOURCE/ RESOURCE Continuation of Current USE GENERAL GUIDANCE Management Alternative Production Alternative Conservation Alternative Proposed Plan FIRE All public lands in the Public lands totalling Public lands totalling Public lands totalling MANAGEMENT planning area (483,077 1 12,945 acres would have 1 12,945 acres would have 1 10,252 acres would have acres) would have full intensive fire suppres- intensive fire suppres- intensive fire suppres- and immediate fire sup- sion; 201,799 acres would sion; 201,799 acres would sion; 202,895 acres would pression, with safety and have conditional fire have conditional fire have conditional fire cost-effectiveness consid- suppression. Prescribed suppression. Prescribed suppression. Prescribed erations. fire would be permitted fire would be permitted fire would be permitted on 168,333 acres. on 168,333 acres. on 169,930 acres. o IMPACTS OF THE PROPOSED PLAN This section describes the physical, biological, and economic consequences of implementing the Proposed Resource Management Plan. Only those resources which would be impacted as a result of implementation of the proposed management actions are discussed. Topography, geology, and prime and unique farmlands would not be impacted by the BLM's proposed plan and are therefore not discussed. Both adverse and beneficial impacts, based on the effects of proposed management actions, were analyzed. The impact analyses also reflect a comparison of these environmental consequences with the affected environment (Chapter Two of the Draft RMP/EIS). Mitigating measures designed to avoid or reduce environmental impacts were incorporated into the proposed plan. Identified impacts are considered unavoidable given the prescribed mitigation. An interdisciplinary approach was used in developing and analyzing environmental consequences. The general assumptions and guidelines which defined the process included: 1. Only significant changes or impacts, which vary by resource, would be analyzed. 2. Changes or impacts described are short-term unless otherwise stated. Short-term impacts would occur within the life of the proposed plan (10 to 12 years); long-term impacts would occur over a 20-year period. 3. Proposed management actions were analyzed under the assumption that the proposed plan would be fully implemented and that adequate funding and staffing would be available for implementation. The analysis of the impacts of the proposed plan is subdivided by impacted resources or resource uses. Impacts are then described as (1) Impacts from Proposed Management Actions, and (2) Cumulative Impacts. (Where cumulative impacts are not presented separately, they would be the same as the impacts from proposed management actions.) The impact analysis is presented as impacts on a resource/resource use that would result from a proposed management action or actions. For example, impacts on air quality would result from proposed off-road vehicle management. IMPACTS ON AIR QUALITY IMP A CTS FROM PROPOSED MAN A GEMENT A CTIONS Impacts from Air Quality Management. Air pollution emissions from primary sources would be minimized through enforcement of applicable policies, regulations, and statutes. Impacts from Wildlife Habitat and Livestock Grazing Management. Short-term localized impacts on air quality would result from vegetation manipulation practices. These minor impacts would be dispersed throughout the planning area. Impacts from Off-Road Vehicle Management. Managing 80 percent of the planning area as open to ORV use for all or portions of the year would result in increased fugitive dust emissions due to vehicle-caused soil erosion. Allowing ORV use on 25,277 acres of highly erodible soils during critical soil moisture periods would significantly increase localized fugitive dust levels as recreational ORV use increases. CUMULA TIVE IMPACTS ON AIR QUALITY Increased levels of air pollution are anticipated due to regional growth and development. No land-use allocations specified in this proposed plan would have significant long- term effects on air quality. IMPACTS ON COAL IMP A CTS FROM PROPOSED MAN A GEMENT A CTIONS Impacts from Coal Management. Allowing continued development of coal on 26,663 acres of existing coal leases and identifying 83,334 acres of federal coal estate as acceptable for further coal leasing consideration could permit leasing and mining of up to 5,730 million tons of in-place coal. An additional 1,756 acres of federal coal reserves under private surface and bounded by the Gunnison National Forest would be managed to permit leasing consideration of 101 million tons of in-place coal. The possible leasing of up to 5,730 million tons of coal would far exceed coal demand over the life of this plan as the 1985 coal production from Delta and Gunnison counties was 2.2 million tons and optimistic annual coal production forecasts for this area range from 4.5 to 7.35 million tons for the years 1990 to 2000. However, any increase in available coal would increase coal leasing opportunities for coal developers. 171 PROPOSED PLAN IMPACTS Impacts from Oil and Gas Management. Leasing and subsequent development of oil and gas in the same areas identified as acceptable for further coal leasing consideration could reduce the amount of coal available for mining. This reduction would depend on the scope and timing of development of both resources and the amount of coal determined necessary to be left as pillars to protect oil and gas wells. No projections have been made on coal losses due to oil and gas well protection. However, there could be a conflict if the amount of coal required to be left in place would make the area uneconomical to mine. Impacts from Riparian/ Aquatic Systems Management. Requiring mitigating measures for surface disturbances within these areas would result in increased operating costs for coal companies. Impacts from Wildlife Habitat Management. Not permitting new road and facility construction from December 1 through April 30 on 920 acres of deer and elk winter range could result in higher development costs and scheduling inconvenience for coal companies. Impacts from Recreation Management. Closing 6,783 acres to coal leasing would have no impact since there are no coal resources within the Adobe Badlands ONA. CUMULA TTVE IMPACTS ON COAL The proposed plan is not anticipated to impact coal production levels over the life of the plan. Restrictive management on portions of the coal planning areas would be likely to increase operating costs and result in scheduling inconvenience for coal companies. Under the proposed plan, 4,396 million tons of in-place federal coal (84,170 acres) would be acceptable for further coal leasing consideration and 48 million tons of in-place federal coal (920 acres) would be acceptable for further coal leasing consideration with stipulations. Development of 1,387 million tons of coal on 26,663 acres of existing coal leases would continue. IMPACTS ON OIL AND GAS IMPACTS FROM PROPOSED MANAGEMENT ACTIONS Impacts from Oil and Gas Management. Table 8 lists the acres of federal oil and gas estate in each leasing category, and Table 9 lists the acres under each leasing category by management unit. Managing 484,349 acres with standard lease terms would allow for exploration and development with few restrictions. Managing 176,076 acres of federal surface and 16,136 acres of split-estate lands with seasonal stipulations on surface occupancy could result in higher exploration, drilling, and development costs, along with scheduling inconvenience. Managing 5,872 acres with a no surface occupancy stipulation would increase drilling costs as directional drilling would be required. Although these acres are within the practical limits of directional drilling, any increased operating costs could lower the potential for production. For the purposes of this document, the practical limits of directional drilling are defined as being within 0.5 mile from the boundary of the management area. Table 8 LAND IN EACH OIL AND GAS LEASING CATEGORY: PROPOSED PLAN LEASE CATEGORY NO LEASING Federal Surface STANDARD LEASE TERMS Federal Surface Split-Estate LEASING WITH STIPULATIONS No Surface Occupancy (NSO) - Federal surface Seasonal - Federal surface - Split-estate ACRES 21,038 276,828 207,521 9,135 176,076 16,136 Oil and gas development would be essentially foregone on 3,263 acres that are under no surface occupancy stipulations and beyond the practical limits of directional drilling. These 3,263 acres are determined to have moderate favorability for oil and gas accumulation. Impacts from Coal Management. Coal mining could result in delays in drilling schedules, higher drilling and development costs, and requirements for use of special techniques and alternate drilling sites. Coal mining could damage existing wells and remove or reduce gas resources if potential gas producing zones were located within mineable coal beds. Impacts from Soils and Water Resources Management. Managing 24,177 acres of federal surface and 4,155 acres of split-estate lands in the salinity control areas with seasonal stipulations (March 1 through May 31) could result in higher exploration, drilling, and development costs, along with scheduling inconvenience. This potential adverse impact would be most significant in the KGS areas where the probability of continued exploration and development is the greatest. 172 Table 9 MANAGEMENT OF OIL AND GAS LEASES BY MANAGEMENT UNIT: PROPOSED PLAN ACRES WITH SEASONAL STIPULATIONS ACRES WITH NO SURFACE APRFS ACRES WITH CLOSED STANDARD 3/15 to 6/30 OCCUPANCY TO LEASE TERMS Federal Split- 12/1 to 4/30 12/1 to 4/30 Federal Split- 5/1 to 6/15 Federal Split- 3/1 to 5/31 Federal Split- STIPULATIONS Federal LEASING Federal MANAGEMENT Federal Split- UNIT Surface Estate Surface Estate Surface Estate Surface Estate Surface Estate Surface Surface 1 118,238 20,897 68,572 623 — — 2 30,313 13,645 37,007 8,850 — — — — — — — — 3 19,055 67 28,552 25 — — — — — — — — 4 32,715 970 8,077 280 — — — — — — — — 5 — — — — — — — — 24,177 4,155 — — 6 — — — — — — — — — — — 21,038 7 8 13,865 8,942 28,515 3,367 630 z z 9 10 6,320 — — — — — 3,292 1,423 z — 11 — — — — 1,990 150 — — — — — — 12 13 14 — — — — — — — — — — 1,895 377 80 — *d _ _ 1 15 — — — — — — — — — — 6,783 — § 03 16 47,380 143,427 1,042 — — — — — — — — — TOTALS 276,828 207,521 146,617 10,408 1,990 150 3,292 1,423 24,177 4,155 9,135 21,038 r4 CO PROPOSED PLAN IMPACTS Impacts from Threatened and Endangered Species Management. Managing 2,272 acres of threatened and endangered species habitat and unique plant association areas with a no surface occupancy stipulation would result in higher drilling and development costs as directional drilling would be required. Impacts from Wildlife Habitat Management. Managing 151,899 acres of federal surface and 11,981 acres of split- estate lands in crucial deer and elk winter range, bald eagle winter habitat, elk calving areas, and waterfowl habitat areas with seasonal stipulations could result in higher exploration, drilling, and development costs, along with scheduling inconvenience. This potential adverse impact would be most significant in the KGS areas where the probability of continued exploration and development is the greatest. Impacts from Recreation Management. Managing the Needle Rock ONA/ACEC and the Adobe Badlands ONA/ ACEC with a no surface occupancy stipulation would eliminate oil and gas production potential on 3,263 acres which are not suitable for directional drilling. This would also result in higher drilling and development costs on 3,600 acres where directional drilling would be required. Impacts from Wilderness Management. The negative impact of closing the Gunnison Gorge WSA to leasing would be negligible as geologic structures in this area have no favorability for oil and gas accumulation. CUMULATIVE IMPACTS ON OIL AND GAS No surface occupancy stipulations within the Adobe Badlands ONA/ACEC would result in unquantifiable negative impacts on oil and gas development. These impacts would be expected to be moderate. The favorability for oil and gas is considered moderate based on the area's proximity to three KGS areas. Seasonal stipulations on 176,076 acres of federal surface and on 16,136 acres of split-estate lands and no surface occupancy stipulations on 9,135 acres of federal surface could increase exploration and development costs to the point of decreasing production potential throughout the planning area. Production potential would be eliminated on 3,263 acres managed under no surface occupancy stipulations that are beyond the practical limits of directional drilling. Overall, these negative impacts would be rated low to moderate since the entire planning area has a low to moderate favorability for oil and gas production. IMPACTS ON LOCATABLE MINERALS IMP A CTS FROM PROPOSED MAN A GEMENT A CTIONS Impacts from Locatable Minerals Management. Identifying 642,392 acres as open to mineral entry and location would make this area available for exploration and development under the general mining laws. Withdrawing 32,750 acres from mineral entry and location would eliminate these lands from possible mineral development. Table 10 lists the acres proposed for protective withdrawal. Table 10 FEDERAL SURFACE/MINERALS WITHDRAWN FROM ENTRY TO PROTECT EACH LISTED RESOURCE: PROPOSED PLAN RESOURCE REQUIRING PROTECTIVE WITHDRAWAL ACRES WITHDRAWN THREATENED AND ENDANGERED SPECIES Escalante Canyon ACEC Fairview RNA/ACEC 1,895 377 RECREATION Needle Rock ONA/ACEC 80 WILDERNESS Gunnison Gorge WSA 21,038 OTHER Bureau of Reclamation withdrawals 9,360 TOTAL 32,750 The negative impact of withdrawing the Gunnison Gorge WSA from mineral entry and location would be low to moderate as geologic structures in the area have a moderate favorability for accumulation of locatable minerals. There are no known mineral deposits in the WSA. Approximately 20 lode claims and several prospects which are located within or adjacent to the WSA indicate some minerals interest in the local area. Mining claimants with invalid claims located within the WSA would be adversely affected as development or extraction would be permitted only on claims proven to have valid mineral discoveries. In addition, the potential for mineral discoveries on lands unclaimed prior to wilderness designation would be eliminated. Retaining the withdrawal on the 80-acre Needle Rock ONA/ACEC would have a low negative impact as there are no known mineral values within this area. Retaining the Bureau of Reclamation withdrawals on 9,360 acres would have an unknown impact as little data is available on mineral potentials within these areas. There are no known mineral values on these withdrawn lands and little interest has been expressed for mineral explorations. 174 The negative impacts of withdrawing the Escalante Canyon ACEC (1,895 acres) and Fairview RNA/ACEC (377 acres) from mineral entry and location would be low as geologic structures in these areas have a low favorability for accumulation of locatable minerals. There are no known locatable mineral deposits or evidence of past mineral development within these areas. The potential for economic discoveries is poor. There has been recent interest in possible placer deposits adjacent to the Fairview RNA/ACEC, but the future of this interest is speculative. Uranium and vanadium mineralization is considered likely within the Escalante Canyon ACEC but there are no known concentrations. Managing the Adobe Badlands ONA/ACEC (6,783 acres) and 10,402 acres of recreation areas as closed to ORV use would result in increased operating costs and inconvenience for mining claimants as plans of operations would be required for all activities except casual use. Disposal of public lands could result in management problems associated with split-estate lands. PROPOSED PLAN IMPACTS IMPACTS ON MINERAL MATERIALS IMPACTS FROM PROPOSED MANAGEMENT ACTIONS Impacts from Mineral Materials Management. Identifying 381,358 acres as open to disposal of mineral materials with no seasonal restrictions would make this resource available to the public and government entities on 79 percent of the planning area with a minimum of restrictions. Managing 63,174 acres with seasonal restrictions on disposal activities could result in scheduling inconvenience for operators. The impact of closing 36,493 acres to disposal of mineral materials would be low as there are numerous alternate sites available elsewhere in the planning area. In some circumstances, the costs of hauling mineral materials could be increased as closures could increase travel distances to open mineral material locations. Requiring approval of the withdrawing agency for disposal of mineral materials on 9,360 acres could result in the denial of permit applications for mineral materials on these lands. Table 1 1 lists the federal surface in each mineral material disposal category by protected resource. Table 11 FEDERAL SURFACE IN EACH MINERAL MATERIAL DISPOSAL CATEGORY BY PROTECTED RESOURCE: PROPOSED PLAN ACRES WITH SEASONAL RESTRICTIONS 12/1 3/1 3/15 RESOURCE REQUIRING ACRES to to to ACRES PROTECTIVE CATEGORY OPEN 4/30 5/31 6/30 CLOSED Federal surface with no restrictions required 381,358 — — — — SALINITY AREAS — — 24,177 — — RIPARIAN/ AQUATIC AREAS — — — — 6,320 T&E SPECIES Escalante Canyon ACEC — — — — 1,895 Fairview RNA/ACEC — — — — 377 WILDLIFE HABITAT Deer/elk winter range — 37,007 — — — Waterfowl area — — — 1,990 — RECREATION Needle Rock ONA/ACEC Adobe Badlands ONA/ACEC WILDERNESS Gunnison Gorge WSA 80 6,783 21,038 TOTALS 381,358 37,007 24,177 1,990 36,493 175 PROPOSED PLAN IMPACTS IMPACTS ON SOILS IMPACTS FROM PROPOSED MANAGEMENT ACTIONS Impacts from Soils Management. Minimizing soil disturbance on all surface-disturbing activities would decrease potential losses of soil productivity. Permitting soil and watershed projects within 312,489 acres, of which 17,806 acres have soils that are determined to be highly erodible, would allow for mitigation of soil erosion as problem areas develop. Impacts from Mineral Resources Management. Surface-disturbing activities would decrease soil productivity through soil compaction, erosion, mixing of soil horizons, and reduced soil moisture retention capabilities. Coal development could result in soil productivity losses on less than 1,000 acres due to road and facility placement and increased soil slumping and mud flows. Development of oil and gas leases on 676,561 acres, locatable minerals on 642,392 acres, and mineral materials on 444,532 acres would decrease soil productivity unless rehabilitation efforts are successful. Development of locatable minerals within 69,389 acres of easily eroded soils during critical soil moisture periods (March 1 through May 31) would decrease soil productivity over the long-term. Similar impacts would result from development of oil and gas leases and mineral material areas within 41,288 acres of these soils. Accidental fluid discharges during drilling operations could also contaminate soils. Impacts from Water Resources Management. Seasonal restrictions on surface-disturbing activities and potential livestock forage utilization limits on 30,960 acres of highly saline soils (Management Unit 5 and Management Unit 15) would decrease erosion and increase soil productivity within these areas. Developing in-channel structures and land treatments on 24,177 of these acres would further protect soils from erosion. Impacts from Wildlife Habitat and Livestock Grazing Management. Intensively managing 336,562 acres of "I" category grazing allotments would reduce soil compaction and erosion rates over the long-term in these areas as AMP objectives to increase ground cover are achieved. Permitting grazing during soil moisture periods (March 1 through May 31) and forage utilization greater than 35 percent on 38,953 acres of easily eroded soils would result in soil productivity losses within these areas. Eliminating grazing from March 20 to range readiness and increasing basal ground cover on 24,177 acres (Management Unit 5), along with restricting forage utilization to 35 percent on 2,370 acres (Elephant Skin Wash area) would increase soil productivity and decrease long-tferm annual erosion rates by up to three tons per acre in these .areas. Short-term erosion would increase by one to ten times present levels on vegetation treatments designed to increase wildlife and livestock forage. Soil productivity would surpass present levels over the long-term as treatments increase basal ground cover. Impacts from Forest Management. Road construction and surface disturbance from harvest activities would result in increased erosion. Erosion would decrease over time if harvests result in an increase in basal ground cover. Harvesting activities during critical soil moisture periods on 13,582 acres of easily eroded soils would result in moderate increases in erosion and decreases in soil productivity. Impacts from Recreation Management. Managing 24,552 acres for ORV recreation opportunities would result in long-term erosion within these areas. Soils within a 19,957- acre portion of these ORV recreation areas are determined to be highly erodible. ORV-derived erosion would increase as more ORV enthusiasts become aware of and utilize these areas. Impacts from Off-Road Vehicle Management. Not permitting ORV use on 20 percent of the planning area would protect these areas form ORV-derived erosion and other soil disturbance. Managing 46 percent of the planning area as open to ORV use would allow for decreased soil productivity as soils are disturbed and vegetation is trampled. Soil productivity losses would be greatest from ORV use on 25,336 acres of highly erodible soils. Seasonal ORV restrictions would partially protect soils on 163,227 acres from ORV-derived erosion during some of the soil moisture periods when soils are most vulnerable to damage. Impacts from Major Utility Development. Managing 301,066 acres as open to development of major utility facilities would allow for increased soil disturbance due to construction and maintenance activities. Soil productivity losses would be greatest from these activities during critical soil moisture periods (March 1 through May 31) on 25,277 acres of highly erodible soils. Seasonal restrictions on these activities would partially protect 24,177 acres of highly erodible soils during portions of the critical soil moisture periods when soils are most vulnerable to damage. Impacts from Fire Management. Management for both planned and natural prescribed burning on 169,930 acres would allow for vegetation type conversion from pinyon- juniper woodlands to a more soil-protective grass and forb plant community. Fire suppression activities (fire lines, ORV use) could decrease soil productivity by removing protective vegetation and increasing erosion and compaction. The overall net deterioration of soils would depend on site-specific variables. 176 PROPOSED PLAN IMPACTS CUMULATIVE IMPACTS ON SOILS Under the proposed plan, soil conditions would be anticipated to improve slightly throughout the entire planning area. Intensive management of salinity areas and grazing allotments would benefit soil conditions within these areas. Intensive management would be especially beneficial on 39,000 acres of highly erodible soils. Permitting soil and watershed projects within 312,489 acres would allow for mitigation of soil erosion as problem areas develop. Mineral activities, forest and woodland product harvests, livestock grazing on 38,953 acres, and ORV use would result in decreased soil productivity in portions of the planning area. This productivity loss would be most pronounced on 25,000 acres of highly erodible and saline soils where few watershed-protective measures would be implemented. IMPACTS ON WATER RESOURCES IMPACTS FROM PROPOSED MANAGEMENT ACTIONS Impacts from Water Resources Management. Seasonal restrictions on surface-disturbing activities and potential livestock forage utilization limits on 30,960 acres of highly saline soils (Management Unit 5 and Management Unit 15) would reduce salinity and sediment levels in local surface waters and assist in reducing salinity levels within the Upper Colorado River Basin. Developing in-channel structures and land treatments on 24,177 of these acres would further protect surface waters from salinization and sedimentation. Permitting watershed projects within an additional 312,489 acres would allow for mitigation of water quality deterioration as problem areas develop. Of these areas, 17,806 acres are within highly erodible and saline soil areas. Impacts from Coal Management. Coal leasing and development would result in increased sediment yields from roads, mine facilities, or other surface-disturbing activities. Mine discharges and spoil-pile runoff could increase salt levels in local surface water systems. Overburden fracturing and subsidence from underground mining could result in loss of ground water quantity and quality. Loss of either surface or ground water could adversely affect adjudicated water rights. These impacts would be less pronounced within riparian corridors where mining would be restricted to protect riparian habitat. Impacts from Oil, Gas, and Geothermal Resources Management. Identifying 685,696 acres as acceptable for oil and gas leasing could result in both surface and ground water impacts. Construction of roads and drilling pads would increase sediment and salinity yields in local surface waters. These impacts would be most pronounced on 34,505 acres of easily eroded and/or high salinity soils as oil and gas operations would be permitted during the critical wet soil period (March 1 through May 31) when these soils are most vulnerable to damage. Accidental fluid discharges during drilling operations could contaminate surface water. Impacts from Locatable Minerals Management. Identifying 93 percent of the planning area as open to mineral entry and location could result in water quality degradation. Road construction and other mine-related disturbance would increase sediment and salinity loads in local surface waters. These impacts would be greatest from placer mining operations. All operations could result in heavy metal contamination from mine water discharges and spoil-pile runoff. Impacts from Mineral Materials Management. Managing 92 percent of the planning area as open to disposal of mineral materials would impact water resources. Road construction and extraction of mineral materials would increase sediment and salt loads in local surface waters. These increased sediment and salt loads would be most pronounced from mineral material activities on 34,505 acres of easily eroded soils during critical wet soil periods (March 1 through May 31). Mineral material operations in close proximity to perennial water courses would have the potential of destabilizing and altering natural stream channels and disrupting the beneficial values of floodplains. These impacts could result in alteration of water tables and surface water flows and could increase the destructiveness of floods. Impacts from Riparian/ Aquatic Systems Management. Managing riparian zones and aquatic habitat on 6,320 acres to improve vegetation condition, streambank cover, and aquatic diversity would result in reduced sediment yields and streambank erosion and improved chemical water quality. Closing seven miles of roads in the Potter Creek and Dry Fork of Escalante Creek drainages would reduce sediment loads in these areas. Impacts from Wildlife Habitat Management. Soil disturbances from chainings and other vegetation treatments scattered over 300,527 acres would cause short-term sediment yield increases. Successful land treatments would reduce sediment yields and improve overall erosion conditions over the long-term. Impacts from Livestock Grazing Management. Intensively managing 336,562 acres as "I" category grazing allotments would result in lower sediment yields as AMP objectives to increase ground cover are achieved. Short- term sediment yield increases would be expected from vegetation treatments. Sediment yields are not expected to change on 113,850 acres that are not within intensively managed allotments. Permitting grazing during wet soil periods (March 1 through May 31) and forage utilization greater than 35 177 PROPOSED PLAN IMPACTS percent on 38,954 acres of easily eroded and highly saline soils could result in increased sediment and salinity yields. Eliminating grazing from March 20 to range readiness and increasing basal ground cover on 24, 1 77 acres, and restricting forage utilization to 35 percent on 2,370 acres (Elephant Skin Wash area) of easily eroded and highly saline soils would reduce sediment and salt yields from these areas. Eliminating grazing from March 1 to May 15, potentially restricting forage utilization to 35 percent, and restricting livestock trailing on 6,320 acres of riparian/aquatic areas would result in reduced sediment yields and streambank erosion and improved water quality on 70 stream miles. Impacts from Forest Management. Road construction and surface disturbance from harvest activities would result in increased sediment yields. Sediment yields would decrease over time if harvests result in an increase in basal ground cover. Harvesting activities during wet soil periods on 13,582 acres of easily eroded soils would result in moderate increases in surface water sedimentation. Impacts from Recreation Management. Managing 24,552 acres for recreational ORV use would increase sediment and salt yields from these easily eroded and highly saline soil areas. Impacts from Off-Road Vehicle Management. Not permitting ORV use on 20 percent of the planning area would protect these areas from ORV-derived sedimentation. Managing 46 percent of the planning area as open to ORV use would allow for increased sediment loads as soils are disturbed and vegetation is trampled. Water quality deterioration would be greatest from ORV use on 25,336 acres of highly erodible and saline soils. Seasonal ORV restrictions on 163,227 acres would partially protect these areas from ORV-derived sedimentation during wet soil periods when soils are most vulnerable to damage. Impacts from Major Utility Development. Managing 301,066 acres as open to development of major utility facilities would allow for increased sediment loads due to construction and maintenance activities. Water quality deterioration would be greatest from these activities at stream crossings and during wet soil periods (March 1 through May 31) on 25,277 acres of highly erodible and saline soils. Seasonal restrictions on construction and major maintenance activities would partially protect 24,177 acres of highly erodible and saline soils from disturbance during wet soil periods when these soils are most vulnerable to damage. Impacts from Fire Management. Management for both planned and natural prescribed burning on 169,930 acres would allow for vegetation type conversion from pinyon- juniper woodlands to a more watershed-protective grass and forb plant community. Fire suppression activities (fire lines, ORV use) could decrease watershed productivity by removing protective vegetation and increasing erosion and sedimentation. The overall net deterioration of watershed conditions would depend on site-specific variables. CUMULATIVE IMPACTS ON WATER RESOURCES Under the proposed plan, a slight improvement in water resources would be anticipated throughout the entire planning area. Intensive management of salinity areas, riparian zones, aquatic habitats, and grazing allotments would benefit the hydrologic condition of water courses and improve the chemical and physical properties of surface waters. Intensive management would be especially beneficial on 39,000 acres of highly erodible and saline soils. Mineral activities, forest and woodland product harvests, livestock grazing on 38,954 acres, and ORV use would result in increased sediment and salt yields in portions of the planning area. These increased yields would be most pronounced on 25,000 acres of highly erodible and saline soils where few watershed-protective measures would be implemented. IMPACTS ON RIPARIAN ZONES IMPACTS FROM PROPOSED MANAGEMENT ACTIONS Impacts from Riparian Zone Management. Intensively managing 6,320 acres of riparian zones would improve vegetation cover, composition, density, and diversity. Overall improvement to fair or good vegetation condition could be expected over the short-term. Impacts from Mineral Resources Management. Approximately 4,000 acres of riparian zones would be opened to mineral exploration if withdrawals are lifted. Road construction, facility development, dredging operations, and other surface-disturbing activities in riparian zones would remove riparian vegetation, compact the soil, and could redirect subsurface water. Impacts from Soils and Water Resources Management. Water impoundment projects would improve conditions necessary for establishment of riparian vegetation. This could potentially increase riparian zones by 100 to 200 acres over the long-term. Impacts from Wildlife Habitat Management. Devel- opment of in-channel structures designed to improve aquatic habitat would stabilize riparian vegetation and enhance its quality. Impacts from Livestock Grazing Management. Potentially restricting livestock utilization to 35 percent on 6,320 acres of riparian zones and intensively managing grazing use on 5,125 acres of riparian zones would improve vegetation density, diversity, and stability over the next ten years. 178 PROPOSED PLAN IMPACTS Impacts from Forest Management. Road and facility construction and other surface-disturbing activities in riparian zones would remove riparian vegetation. An estimated 60 to 100 acres of riparian vegetation would be degraded over the next ten years. Impacts from Recreation Management. Riparian vegetation on 35 acres in the Gunnison Forks area would be severely impacted by trampling and vehicle use. Impacts from Off-Road Vehicle Management. Restricting vehicle use to designated roads and trails on 5,640 acres and closing an additional 680 acres of riparian zones in Potter and Roubideau creeks to ORV use would improve vegetation condition and eliminate rutting and soil compaction. Impacts from Major Utility Developemnt. Eliminating riparian zones from major surface-disturbing activities having long-term adverse effects would protect these areas and maintain their present condition. CUMULATIVE IMPACTS ON RIPARIAN ZONES Direct and indirect intensive management under the proposed plan would result in improved vegetation conditions on 7,310 acres of riparian zones. IMPACTS ON THREATENED AND ENDANGERED SPECIES IMPACTS FROM PROPOSED MANAGEMENT ACTIONS Impacts from Threatened and Endangered Species Management. Designating 1,895 acres in Escalante Canyon as an Area of Critical Environmental Concern (ACEC) would protect the Uinta Basin hookless cactus (threatened), the Grand Junction milkvetch (candidate), the Delta lomatium (sensitive), and three unique plant associations from most surface-disturbing activities. Opportuntiies for research and special studies of the plant associations would be expanded. Designating 377 acres east of Montrose as a Research Natural Area, an area of critical environmental concern (RNA/ACEC) would protect populations and habitats of clay-loving wild buckwheat and Montrose penstemon from most surface-disturbing activities. Designating 6,783 acres north of Delta as an Outstanding Natural Area, an area of critical environmental concern (ONA/ACEC) would protect occupied and potential habitat of the Uinta Basin hookless cactus and clay-loving wild buckwheat from disturbance over the long-term. Pre-disturbance inventories area-wide would add substantially to the data base for all threatened and endangered species. Some inadvertent destruction of individual plants would occasionally occur. Impacts from Mineral Resources Management. Closing 2,272 acres of threatened and endangered species habitat to mineral entry and location and placing a no surface occupancy stipulation on 9,135 acres would prevent accidental destruction of threatened and endangered plant species and potential habitat. Possible disturbance could affect 21,633 acres of potential endangered, threatened, candidate, and sensitive plant species habitat. Removing the no surface occupancy stipulation on 140 acres of bald eagle wintering habitat would displace some bald eagles. Lifting mineral withdrawals on the lower Gunnison River and allowing surface-disturbing activities would reduce the value of 6,680 acres as wintering bald eagle habitat. Impacts from Soils and Water Resources Management. In-channel structures and land treatment projects would be slightly beneficial to bald eagles and peregrine falcons. Water impoundments and resulting increases in vegetation cover would improve these raptors' prey base habitat. Impacts from Riparian/Aquatic Systems Management. Improvement of the riparian zones along Roubideau and Escalante creeks and in the North Fork Valley would improve peregrine falcons' and wintering bald eagles' prey base habitat. Impacts from Wildlife Habitat Management. Continued management of the Gunnison Forks HMP area would maintain existing bald eagle and river otter habitat. Peregrine falcons would be expected to increase their use of the area over the long-term. Waterfowl habitat improvement and associated land acquisition could provide migrating whooping cranes, long-billed curlews, and white-faced ibis with additional protected habitat and stop-over points. Impacts from Livestock Grazing Management. Some localized disturbance and destruction of individual threatened and endangered plants would occur due to livestock trampling. Impacts from Recreation Management. Decreasing river use in the Gunnison Gorge would improve river otter habitat through decreased destruction of riparian vegetation. Bald eagles and peregrine falcons would benefit from reduced human disturbance in the gorge. Impacts from Off-Road Vehicle Management. Closing approximately 38,600 acres to ORV use and restricting vehicle use to designated roads and trails would eliminate potential destruction and damage of the Uinta Basin hookless cactus, spineless hedgehog cactus, Montrose penstemon, Grand Junction milkvetch, and clay-loving wild buckwheat. Impacts from Wilderness Management. Management of 21,038 acres under wilderness guidelines would protect potential habitat of threatened and endangered plant and animal species from any mechanical disturbance. Habitat values would be maintained or improved. 179 PROPOSED PLAN IMPACTS Impacts from Major Utility Development. Closing 6,783 acres of potential habitat of the Uinta Basin hookless cactus, clay-loving wild buckwheat, and Montrose penstemon to development of major utility facilities would protect these species from accidental destruction. CUMULATIVE IMPACTS ON THREATENED AND ENDANGERED SPECIES The research potential and study opportunities of several threatened and endangered species and unique plant associations would be protected with special designations. Designation of the Gunnison Gorge WSA as wilderness would protect bald eagle, peregrine falcon, and river otter habitats. IMPACTS ON TERRESTRIAL WILDLIFE HABITAT IMPACTS FROM PROPOSED MANAGEMENT ACTIONS Impacts from Wildlife Habitat Management. Forage allocations for big game species on public land would meet both short-term and long-term demands. Crucial deer and elk winter range management and land treatment projects would improve distribution, reduce stress, and decrease big game utilization of adjacent private lands. Minimizing disturbance in elk calving areas would reduce fetal mortality and increase calf survival. Bighorn sheep habitat and herd management in the Gunnison Gorge area would potentially increase the population to 300 individuals by 1997. A small herd of bighorn sheep could be established in the Roubideau Canyon/Camel Back area. Rocky Mountain bighorn sheep habitat in the Baldy Peak area would be improved. Waterfowl production on the lower Gunnison River would increase by up to 50 percent. Impacts from Mineral Resources Management. Road and portal construction and other surface-disturbing activities associated with mineral development would reduce crucial deer and elk winter range in the North Fork area by 500 acres. Seasonal restrictions on oil and gas activity on crucial deer and elk winter range (140,181 acres of federal surface and 9,715 acres of split-estate lands) would lessen stress on deer and elk, thereby reducing mortality and fetal loss and improving overall condition and health of the herds. Revocation of existing withdrawals that presently segregate federal minerals from entry and location under the general mining laws could increase surface disturbance on 61,270 acres of habitat. Raptor hunting habitat and some nesting areas would be lost. Habitat for other birds, including Lewis' woodpeckers, western bluebirds, and Scott's orioles, would possibly be reduced due to coal development. Impacts from Soils and Water Resources Management. In-channel structures and water impoundments would provide habitat for waterfowl, chukars, mourning doves, mule deer, and non-game species. Impacts from Riparian/ Aquatic Systems Management. Restoring and protecting 6,320 acres of riparian zones would provide additional forage and cover for big game, waterfowl, and non-game birds and animals. The prey base for raptors and other predators would be improved. Impacts from Livestock Grazing Management. Development of grazing systems, land treatment projects, and improved livestock management practices would improve forage conditions, reduce competition between livestock and big game, and improve distribution of most big game species. Eliminating livestock grazing use on approximately 24, 1 77 acres during the spring would improve big game forage at a time when food reserves are low and females are pregnant. Improved nutrition may result in heavier birthweights and more successful reproduction. Land treatment projects designed to reduce sagebrush cover to less than 20 percent would eliminate present and potential sage grouse habitat in the Simms Mesa and Fruitland Mesa areas. Impacts from Forest Management. Woodland harvests would provide temporary openings in forest stands, increasing edge effect and big game forage. The removal of old-growth timber would reduce thermal and hiding cover for big game and eliminate some nesting habitat for cavity- nesting birds. Woodland harvests could occur during the winter on 28,500 acres of crucial deer and elk winter range. On an annual basis, deer and elk would be displaced from 80 to 100 acres of active cutting area and adjacent habitat. Impacts from Recreation Management. Restricting river use in the Gunnison Gorge would encourage continued expansion of the bighorn sheep population and prevent some degradation of riparian habitat for non-game species. Encouraging recreational and competitive ORV use in the North Delta area would curtail antelope utilization of the area, reducing antelope range by 8 percent. ORV use in the area would increase harassment of game and non-game wildlife and would displace prairie dog populations. Impacts from Off-Road Vehicle Management. Closing 38,600 acres to vehicle use would eliminate disturbances or harassment of wildlife. This would be especially beneficial if desert bighorn sheep are reintroduced into the Camel Back area. Restricting vehicle use to designated roads and trails in crucial deer and elk winter range would reduce habitat loss. Seasonal ORV use restrictions in crucial deer and elk winter range would reduce stress on big game species, 180 PROPOSED PLAN IMPACTS thereby reducing fetal mortality and losses from poaching, and permitting wildlife utilization of the entire area. Impacts from Major Utility Development. Confining development of major utility facilities in the North Fork area to existing corridors along major roads would limit disturbance and stress on all wildlife species. Prohibiting development of utility facilities on 82,038 acres would prevent short-term disturbances and long-term wildlife habitat modifications due to road construction and use. Bighorn sheep would benefit greatly from exclusion and restriction of utilities in the Gunnison Gorge and Camel Back areas. Impacts from Disposal of Public Lands. Disposal of 3,337 acres of crucial deer and elk winter range and an additional 1,028 acres of non-crucial winter range would result in the loss of habitat for 35 elk and 20 deer and would increase big game pressure on adjacent private lands. Disposal of 120 acres of antelope range would result in an approximate one percent reduction in herd size. Disposal of tracts providing prairie dog habitat could affect potential occurrences of burrowing owls. Habitat for band-tailed pigeons, Cooper's hawks, goshawks, flammulated owls, and other non-game species would be affected. Impacts from Acquisition of Non-Federal Lands. Acquiring non-federal lands in crucial deer and elk winter range would increase habitat and potential big game populations, and reduce wildlife conflicts and impacts on adjacent private lands. Acquiring non-federal lands for waterfowl habitat management would increase waterfowl populations on public lands. Impacts from Acquisition of Access. Acquiring public access would improve big game harvests and population control practices. Impacts from Fire Management. Natural and planned prescribed fires would reduce closed brush and tree canopies, stimulate plant growth and vigor, and temporarily improve forage palatability, resulting in improved habitat for many wildlife species. Large wildfires would reduce effective screening and thermal cover for deer and elk use. CUMULATIVE IMPACTS ON TERRESTRIAL WILDLIFE HABITAT Increased coal development and disposal of public lands in crucial deer and elk winter ranges in combination with the loss of habitat on private lands would be offset by improvement of habitat conditions throughout the planning area. Present big game populations would be maintained; small game and non-game populations and habitats would be improved. IMPACTS ON AQUATIC WILDLIFE HABITAT IMPACTS FROM PROPOSED MANAGEMENT ACTIONS Impacts from Wildlife Habitat Management. Structures placed in Escalante, Cottonwood, Monitor, Potter, and Jay creeks would improve pookriffle ratios, stabilize stream- banks, increase instream cover, and reduce channelization, streambank erosion, and sedimentation. Approximately 30 stream miles of aquatic habitat would be improved. Managing approximately 52 stream miles associated with Terror, Escalante, Monitor, Criswell, Potter, and Dry creeks would stabilize streambanks, increase instream cover, and reduce sedimentation. Limiting surface-disturbing activities on aquatic habitat would increase streambank cover, improve bank stability and water quality, and reduce soil compaction, sedimentation, and siltation. Land treatment projects in or near stream channels would increase sedimentation over the short-term and decrease it over the long-term. Impacts from Mineral Resources Management. Road and pipeline development and other surface-disturbing activities would lead to increased sedimentation and streambank instability on 25 stream miles of aquatic habitat. Site-specific approval of surface-disturbing activities in aquatic areas could result in slight to moderate increases in sedimentation, water temperatures, and streambank erosion. Impacts from Soils and Water Resources Management. In-channel structures designed to reduce sedimentation and salinity would improve aquatic habitat on streams below these structures. Impacts from Riparian/ Aquatic Systems Management. Improved riparian management on 6,320 acres of public land would result in improvement of 40 stream miles of aquatic habitat. Streambank stability, sedimentation, and water temperatures would benefit from improved stream- bank cover. Impacts from Livestock Grazing Management. Intensive grazing management on 60 stream miles of aquatic habitat combined with a potential 35 percent utilization of key forage species limitation would improve streambank stability and cover. Sedimentation would decrease and water temperatures would stabilize. The existing condition would be maintained on the balance of the aquatic habitat. Land treatment projects in or near stream channels would increase sedimentation over the short-term and decrease it over the long-term. Impacts from Forest Management. Road construction across aquatic areas could cause increased sedimentation, bank degradation, and water temperatures, and decreased streambank cover. 181 PROPOSED PLAN IMPACTS Impacts from Recreation Management. Restricting river use in the Gunnison Gorge to six group encounters per day would improve streambank vegetation and water quality and reduce sedimentation. Aquatic habitat in the Gunnison Forks area would continue to be degraded due to trampling and intensive recreational use. Impacts from Off-Road Vehicle Management. Closing areas to ORV use, imposing seasonal restrictions on ORV use, and restricting vehicle use to designated roads and trails in riparian zones should improve streambank stability and reduce sedimentation. The areas remaining open to ORV use would be subject to degradation. Impacts from Major Utility Development. Short-term impacts caused by road construction, clearings for powerline pads, and pipelines would result in slight to moderate adverse impacts on aquatic and riparian habitat. Loss of vegetation, streambank deterioration, sedimentation, and erosion would cause localized impacts on aquatic/riparian organisms and habitat. Prohibiting or seasonally restricting surface- disturbing activities that would have long-term adverse effects on riparian/aquatic systems would, at the minimum, maintain current habitat quality. CUMULATIVE IMPACTS ON AQUATIC WILDLIFE HABITAT Approximately 140 stream miles of aquatic wildlife habitat would improve under management emphasizing habitat quality and protection. Eliminating or reducing surface-disturbing activities and potentially limiting livestock grazing utilization to 35 percent in riparian zones would have the greatest overall beneficial effect. IMPACTS ON LIVESTOCK GRAZING IMP A CTS FROM PROPOSED MAN A GEMENT A CTIONS Impacts from Livestock Grazing Management. Not allocating additional forage for livestock use on 74,133 acres would reduce present grazing preferences by the 3,380 animal unit months (AUMs) currently in suspension. Land treatment projects and grazing management would increase forage allocations for livestock by 1,424 AUMs. Impacts from Soils and Water Resources Management. Limiting livestock utilization to 35 percent of key forage species on 30,960 acres would reduce livestock allocations by 594 AUMs on ten grazing allotments. Eliminating livestock grazing on 24,177 acres from March 20 to range readiness could shift some livestock use to the fall, resulting in increased conflicts between livestock grazing and hunting use, higher mortality from disease due to longer spring confinement, increased trailing use, and decreased hay production due to livestock use of base property hay lands for a longer period in the spring. Additional forage would become available over the long-term due to reduced spring use. In-channel structures and land treatment projects designed to reduce erosion and salinity would improve livestock distribution and increase available forage. Impacts from Riparian/ Aquatic Systems Management. If forage utilization by livestock is limited to 35 percent of key forage species on 6,320 acres of riparian vegetation, livestock allocations could be reduced by approximately 200 AUMs on seven grazing allotments. Eliminating livestock grazing on 6,320 acres from March 1 through range readiness could shift some livestock use to the fall, resulting in increased conflicts between livestock grazing and hunting use, higher mortality from disease due to longer spring confinement, increased trailing use, and decreased hay production due to livestock use of base property hay lands for a longer period in the spring. Reduced trailing use through riparian zones could increase trailing time and operating costs and require more corrals. Impacts from Wildlife Habitat Management. Devel- oping new land treatment projects and maintaining existing projects would improve livestock distribution and enhance maintenance of existing livestock forage allocations in treatment areas. Impacts from Forest Management. Forest and woodland harvests would increase forage available for livestock grazing use in most harvested areas. Improved access and thinning would improve livestock distribution. Precluding any development or maintenance of land treatment projects on 47,384 acres would result in a 10 percent loss of forage (1,087 AUMs) over the long-term. Impacts from Recreation Management. Restricting fencing in portions of the Gunnison Gorge SRMA could preclude the possibility of changing the livestock class from sheep to cattle, and could eliminate opportunities to use fencing to improve livestock distribution. Impacts from Off-Road Vehicle Management. Limiting vehicle use on grazing areas through closures or restrictions would improve livestock forage, decrease harassment of livestock, and reduce management problems created by ORV use. Impacts from Disposal of Public Lands. Disposing of 7,522 acres of public land that is currently grazed by livestock would reduce livestock allocations by a total of 786 AUMs on seven "M" category, ten "I" category, and 26 "C" category grazing allotments. Impacts from Acquisition of Access. Acquisition of public access would improve administration of the livestock grazing program but could result in increased harassment of livestock and vandalism of livestock facilities. Impacts from Fire Management. Available forage and species diversity would improve on 169,930 acres of public land where fires meeting pre-determined prescriptions would 182 PROPOSED PLAN IMPACTS be permitted. Fires could cause some damage to livestock facilities (fences, catchments, and corrals). CUMULATIVE IMPACTS ON LIVESTOCK GRAZING A net loss of 5,682 AUMs would occur over the long- term, due primarily to disposal of public lands and a 35 percent utilization limit on the riparian and salinity areas. Increased livestock operator costs and increased conflicts with recreational users would occur. The demand for livestock forage would probably not be met over the long- term. IMPACTS ON FORESTRY IMPACTS FROM PROPOSED MANAGEMENT ACTIONS Impacts from Forest Management. Intensive manage- ment of 24,255 acres of suitable pinyon-juniper woodlands would result in potential annual harvests of 1,213 cords of fuelwood. Suitable commercial forest lands on 3,127 acres would produce 160.5 thousand board feet (MBF) of timber annually. Harvest of 123 acres of suitable commercial forest on 160 acres of land owned by the Girl Scouts of America would be precluded. Impacts from Mineral Resources Management. Road, pad, and portal construction and other surface-disturbing activities associated with mineral development would reduce suitable woodlands and commercial forest lands to a limited degree. Road construction could improve access into several potential sale areas, thereby reducing costs associated with forest harvest. Impacts from Riparian/ Aquatic Systems Management. Eliminating 482 acres of suitable woodlands within riparian/ aquatic zones from harvest would reduce annual fuelwood production by 24 cords. Eliminating 32 acres of commercial forest lands within riparian /aquatic zones from harvest would reduce timber production by 2.5 MBF. Impacts from Threatened and Endangered Species Management. Eliminating 116 acres of suitable woodlands within the Escalante Canyon ACEC from harvest would reduce fuelwood production by six cords annually. Impacts from Wildlife Habitat Management. Maintain- ing existing land treatment projects on 600 acres of pinyon- juniper woodlands would reduce annual fuelwood harvests by 30 cords. Restricting timber harvests on 2,565 acres in the Storm King/High Park area would increase the stand rotation from 120 to 200 years. Impacts from Livestock Grazing Management. Managing 17,314 acres of suitable pinyon-juniper woodlands for increased forage production could reduce fuelwood harvests by 866 cords annually. Impacts from Recreation Management. Eliminating 1,311 acres of woodlands within the Gunnison Gorge SRMA from harvest would reduce annual fuelwood harvests by 66 cords. Impacts from Wilderness Management. Annual harvests of 17 cords of fuelwood would be precluded on 337 acres of woodlands which would be included in the designated wilderness area. The effect on the total forestry program would be miminal. Impacts from Disposal of Public Lands. Disposal of 1,471 acres of suitable woodlands would preclude potential fuelwood harvests and reduce annual fuelwood production by 74 cords. Disposal of 403 acres of suitable commercial forest lands would reduce annual timber harvests by 30 MBF. Impacts from Acquisition of Access. Acquiring access into the 1 1 identified areas would allow harvesting on 1,606 acres of commercial forest lands and on 2,040 acres of pinyon-juniper woodlands. Impacts from Fire Management. Maximum fire protection in the Storm King, High Park, and North Fork areas would protect 36,800 MBF of commercial timber. Minimum fire protection in the pinyon-juniper woodlands would result in only minor losses estimated at approximately nine cords per acre burned. CUMULA TTVE IMP A CTS ON FORESTR ¥ Multiple-use needs would eliminate sustained yield production on 21,631 acres of suitable woodlands, resulting in an annual loss of 1,083 cords of fuelwood. Harvest on 558 acres of suitable commerical forest lands would be precluded, resulting in an annual loss of 41.5 MBF of timber. Intensive management of the forest resource would result in an annual harvest of 160.5 MBF of timber from 3,127 acres of suitable commercial forest lands and 1,213 cords of fuelwood from 24,255 acres of suitable woodlands. IMPACTS ON RECREATION IMPACTS FROM PROPOSED MANAGEMENT ACTIONS Impacts from Recreation Management. Under the proposed plan, recreationists would benefit significantly from management of the variety of recreation opportunities available within the planning area. Managing 47,655 acres (Management Unit 4, Management Unit 14, and Manage- ment Unit 15) for recreation would protect scenic values and increase recreation opportunities in these areas. Designating 1,895 acres within Escalante Canyon as an ACEC would protect the scenic qualities of this valued recreational resource and allow for increased management of the "Potholes" swimming area. Managing 8,942 acres 183 PROPOSED PLAN IMPACTS north of Delta as an ORV use area and 15,610 acres within the Gunnison Gorge SRMA as open to ORV use would accomodate long-term recreational ORV demands. Developing river access at the Escalante Bridge would facilitate boating use on the lower Gunnison River. Limiting boating use in the Gunnison Gorge to a maximum of ten group encounters per day would be highly beneficial to recreationists seeking scarce wilderness boating experiences. No Colorado rivers are managed for wilderness experiences. Recreation demand on the six designated wilderness rivers (273 river miles) in the continental United States exceeds the number of use permits available annually. As competition for river-use permits in the Gunnison Gorge exceeds allocations, private and commercial users would experience inconvenience in trip planning and increased possibilities of not obtaining a permit. Impacts from Mineral Resources Management. Withdrawing 23,390 acres from mineral entry and location, and closing or restricting oil and gas activity surface uses on 30,173 acres would protect the natural and scenic features of these areas from disturbances resulting from mineral activities. Revoking all portions of the BLM protective withdrawal (8,446 acres) and the BOR Fruitland Mesa withdrawal (1,235 acres) located within the Gunnison Gorge SRMA would allow for miner?; activities in these areas. These activities would degrade recreation opportunities in predominantly natural areas that are accessed by primitive roads. Impacts from Salinity Control Management. Limiting vehicle use within the Elephant Skin Wash area to designated roads and trails would reduce the lands available for recreational ORV use by 2,370 acres. This area is presently utilized and preferred for ORV recreation. Impacts from Riparian/Aquatic Systems Management. Protecting and enhancing 6,320 acres of riparian/aquatic systems would benefit recreationists seeking scenic and educational opportunities within this diverse wildlife community. Impacts from Wildlife Habitat Management. Manage- ment of the Gunnison Forks and Billy Creek habitat management areas, deer and elk winter ranges, elk calving areas, and waterfowl habitats would enhance opportunities for hunting, fishing, and wildlife observation. Impacts from Livestock Grazing Management. Recreational ORV opportunities would be protected by not permitting placement of livestock facilities that would create safety hazards or impede vehicle use on 8,942 acres. Impacts from Forest Management. Prohibiting woodland harvests in the Escalante Canyon ACEC and on all but 1,255 acres of the Gunnison Gorge SRMA would protect scenic and predominantly natural recreation settings. Impacts from Off-Road Vehicle Management. Closing the Gunnison Gorge WSA, the Camel Back area, and the Adobe Badlands ONA/ACEC to ORV use would ensure continued availability of high quality and non-motorized recreation settings in the planning area. Restricting vehicle use to designated roads and trails on 25,182 acres of the Gunnison Gorge SRMA, the Escalante Canyon ACEC, the Needle Rock ONA/ACEC, and in riaprian areas would protect the scenic values of these recreation lands. Managing 24,552 acres for recreational ORV use would accomodate long-term ORV use demands and would decrease pressure on areas under ORV use restrictions. Impacts from Cultural Resources Management. A Class III cultural resource inventory would benefit recreationists by identifying cultural sites with public educational values. Impacts from Visual Resources Management. Protect- ing scenic qualities of the Gunnison Gorge WSA, the Adobe Badlands ONA/ACEC, and the Needle Rock ONA/ACEC (VRM Class I) and 15,208 acres of the Gunnison Gorge SRMA (VRM Class II) would ensure continued availability of high quality scenic resources in these areas. Impacts from Wilderness Management. Designating 21,038 acres within the Gunnison Gorge as wilderness would protect wilderness recreation opportunities in this area. Impacts from Major Utility Development. Management of 61,327 acres of recreation and wilderness areas as closed to development of major utility facilities would protect high quality recreation settings. Managing 2,478 acres of the Gunnison Gorge SRMA in the Smiths Mountain and Gunnison Forks areas as open to development of major utility facilities would allow for potential deterioration of natural settings within these areas. Impacts from Acquisition of Non-Federal Lands. Acquiring 2,200 acres within or contiguous to the Gunnison Gorge SRMA would protect recreation settings, provide more public access, and reduce conflicts between recreationists and private landowners. Impacts from Acquisition of Access. Acquiring public access along the Gunnison Gorge rim southwest of the Gunnison Forks area and from Colorado Highway 92 to the Gunnison River in the Austin area would provide access to high value recreation lands and facilitate recreation opportunities. CUMULA TTVE IMP A CTS ON RECREA TION Recreation opportunities would be significantly enhanced and increased under the proposed plan. A total of 74,267 acres would be managed for a wide variety of recreation opportunities including but net limited to river boating, ORV use,, wilderness experiences, back country travel, hunting, fishing, and scenic viewing. Revoking the BLM protective 184 PROPOSED PLAN IMPACTS withdrawal within the Gunnison Gorge SRMA (8,446 acres) and permitting major utility development in the Smiths' Mountain and Gunnison Forks areas would result in deterioration of recreation values if these lands are developed. IMPACTS ON CULTURAL RESOURCES IMPACTS FROM PROPOSED MANAGEMENT ACTIONS Impacts from Cultural Resources Management. Cultural clearances of areas proposed for disturbance would contribute to the cultural data base, decrease cultural site disturbances, and increase the potential for discovery of sites eligible for inclusion to the National Register of Historic Places. Class HI inventories on 5,848 acres would significantly add to the cultural data base. High-value cultural sites on these acres could be protected by special designations. Impacts from Mineral Resources Management. The no surface occupancy stipulation for oil and gas activities and the closure to disposal of mineral materials on 9,135 acres would protect the integrity of the cultural resources in the area from potentially disturbing activities. Cultural resources on an additional 2,352 acres would be protected by a locatable mineral withdrawal. Impacts from Off-Road Vehicle Management. Exposed cultural resources would remain vulnerable to vehicle-related damage on the 80 percent of the planning area that would be open to ORV use for all or portions of the year. Cultural resources would also remain vulnerable to vandalism and illegal artifact collection by individuals using vehicles for easy access and transport of artifacts. Closing the 10,402 acres within the Camel Back WSA to ORV use would eliminate vehicle-related damage and reduce illegal collection and site vandalism in this area. Impacts from Wilderness Management. Designation of the Gunnison Gorge WSA (21,038 acres) as wilderness would generally benefit cultural resources. The integrity of these resources would be protected as no potential would exist for removal of cultural resources as mitigation for surface-disturbing activities. Gaining knowledge of cultural resources would be impeded as site excavations would not be permitted in most instances. Field surveys, normally required during environmental analyses of proposed surface-disturbing activities, would also be eliminated as a data source. Since stabilization would not normally be permitted, exposed cultural sites would continue to deteriorate over the long- term due to weathering and other natural forces. Impacts from Acquisition of Access. Acquiring public access to any of the 16 areas identified for access acquisition would increase the potential for illegal disturbance of cultural sites in these areas. CUMULATIVE IMPACTS ON CULTURAL RESOURCES Cultural resources would be protected from land uses that require use authorizations but would remain susceptible to vandalism and theft. Vandals and relic-hunters would have easy access to the 80 percent of the planning area that would be managed as open to ORV use for all or portions of the year. With the exception of Class III inventories on 5,848 acres, cultural research would continue to be random inventories and salvage efforts in response to project proposals. High-value cultural sites on inventoried acres could be protected by special designations. IMPACTS ON VISUAL RESOURCES IMPACTS FROM PROPOSED MANAGEMENT ACTIONS Impacts from Visual Resources Management. Table 12 lists the acres of land in each VRM classification. Table 12 ACRES IN EACH VRM CLASSIFICATION: PROPOSED PLAN VRM CLASS ACRES PERCENTAGE OF PLANNING AREA I II 111 IV 27,901 27,384 293,417 134,375 6 6 60 28 TOTALS 483,077 100 Impacts from Mineral Resources Management.Mineral development in the planning area would be anticipated to alter the landscape characteristics of a few localized viewsheds. Impacts from Wildlife Habitat and Livestock Grazing Management. Major vegetation treatments would alter landscape characteristics. Changing VRM classifications in the Billy Creek area from Class II to Class III would increase the allowable visual contrast of projects from low to moderate. Impacts from Forest Management. Timber and woodland product harvests would alter landscape charac- teristics in localized areas. 185 PROPOSED PLAN IMPACTS Impacts from Recreation Management. Recreation management would maintain landscape characteristics and preserve scenic qualities in the Escalante Canyon ACEC, the Adobe Badlands ONA/ACEC, the Needle Rock ONA/ ACEC, and portions of the Gunnison Gorge SRMA. Visual resource protection needs would increase in all recreation areas as viewer volume and sensitivity would increase and viewing distance would decrease. Impacts from Off-Road Vehicle Management. Managing 80 percent of the planning area as open to ORV use for all or portions of the year would degrade landscape characteristics in these areas. This impact would be most pronounced on 24,552 acres managed for ORV recreation. Changing VRM classifications from Class II to Class IV in large portions of the ORV recreation lands would increase the allowable visual contrast of surface disturbing activities on these lands from low to high. Impacts from Wilderness Management. Designating the Gunnison Gorge WSA as wilderness would preserve the natural scenic values of the area. Impacts from Disposal of Public Lands. Disposal of a 40-acre tract adjacent to Colorado Highway 62 and within one mile of the community of Ridgway could result in the loss of a scenic overlook site in a VRM class II area. CUMULATIVE IMPACTS ON VISUAL RESOURCES Designating 12 percent of the planning area (55,285 acres) as VRM Class I or Class II would protect highly scenic visual resources. These lands include all the areas that are most used by recreationists seeking natural settings. Designating the remainder of the area as VRM Class III or Class IV would maintain the overall visual characteristics of the planning area but would allow for visually-contrasting projects or disturbances in localized viewsheds. IMPACTS ON WILDERNESS IMPACTS FROM PROPOSED MANAGEMENT ACTIONS Impacts from Wilderness Management. Designating the Gunnison Gorge WSA as wilderness would permanently protect the high quality wilderness values of this area, which include a pristine environment and outstanding opportunities for primitive and unconfined recreation. The high quality nature of these values is evidenced by the BLM recreation lands designation in 1972, the determination that the area is suitable for wild and scenic river designation, and the Colorado DOW's Gold Medal Trout Fishery designation. The WSA is contiguous to the nationally acclaimed Black Canyon of the Gunnison V/ilderness Area, which is administered by the National Park Service (NPS). Designating the Gunnison Gorge as wilderness would expand that wilderness area. It would also permanently protect the Black Canyon/Gunnison Gorge system as one geologic, ecologic, and physiographic unit. Not designating the Camel Back WSA and Adobe Badlands WSA as wilderness would prevent the permanent protection of these areas' existing wilderness values, which include pristine environments and outstanding opportunities for primitive and unconfined recreation. The ORV closure on the Camel Back area (10,402 acres) and the ORV closure and restrictions on surface-disturbing activities on 6,783 acres of the Adobe Badlands ONA/ACEC would partially protect wilderness values on these lands as long as this type of management remains in effect. Surface-disturbing activities would be anticipated to impair wilderness values within both WSAs over time. IMPACTS ON MAJOR UTILITY DEVELOPMENT IMP A CTS FROM PROPOSED MAN A GEMENT A CTIONS Impacts from Major Utility Management. Determining which public lands within the planning area are available for development of major utilities provides utility companies with information necessary to plan and design projects. Table 13 lists the acres of public land identified as needed and not needed for major utility development under each management classification. The following impacts pertain only to those public lands that are identified in the 1980 and 1985 Western Regional Utility Corridor Study(s) as being needed for future development of major utility facilities. Closures or restrictions on lands not identified as being needed for utility facilities would be assumed to have a negligible impact on local and regional major utility development. Impacts from Coal Management. Managing 3,51 1 acres of the Paonia/Somerset coal planning area as closed to major utility development would restrict future development of these facilities to a one-half mile wide corridor adjacent to Colorado Highway 133. This management would result in a low adverse impact to future major utility development as this corridor is anticipated to accommodate future major utility needs in this area. Route options available to utility developers would be reduced. Future major utility development would be precluded on public lands in the Terror Creek drainage. Utility development linking the Montrose and Rifle areas would be restricted as Terror Creek is one of two important utility corridors connecting these areas. These lands are presently utilized for a 235 kv electrical transmission line. Utility companies could not utilize this route nor realize the cost/ benefits of grouping new and existing facilities; they would be required to utilize lands adjacent to Colorado Highway 133 or private lands adjacent to the Terror Creek drainage. 186 PROPOSED PLAN IMPACTS Table 13 MANAGEMENT OF PUBLIC LANDS FOR MAJOR UTILITY DEVELOPMENT: PROPOSED PLAN ACRES OF PUBLIC LAND MANAGEMENT CLASSIFICATION FOR DEVELOPMENT OF MAJOR UTILITIES Identified as needed for major utility development Identified as not needed for major utility development TOTALS Open Sensitive Seasonally closed Closed 98,612 934 22,739 3,511 202,394 5,762 70,598 78,527 301,006 6,696 93,337 82,038 TOTALS 125,796 357,281 483,077 Source: 1980 and 1985 Western Regional Utility Corridor Study(s). Both of these options would probably be less desirable and cost-effective than utilizing existing routes. Impacts from Soils and Water Resources Management. Construction and major maintenance of new utility facilities would not be permitted on 11,062 acres from March 1 through May 31 if necessary to protect wet soils. Utility companies would experience operating inconvenience on these areas from April 15 through May 31, based on a typical construction/maintenance season of April 15 to October 15. Impacts from Riparian/ Aquatic Systems Management. Major utility development would not be effected on 557 acres as vegetation rehabilitation would mitigate surface disturbances over the long-term. Impacts from Threatened and Endangered Species Management. Management of two tracts of land totalling 377 acres (Management Unit 13) as closed to buried major utility facilities and limited to no surface disturbance from above-ground facilities to protected threatened and endangered plants and their habitat would have a low impact on utility development. These tracts could easily be avoided during planning and placement of utility facilities. Impacts from Wildlife Habitat Management. No construction and major maintenance of new utility facilities would be permitted on 11,677 acres of crucial deer and elk winter range from December 1 through April 30. Utility companies would experience operating inconvience in these areas from April 15 to May 1, based on a typical construction/maintenance season of April 15 to October 15. CUMULA TWE IMP A CTS ON MAJOR UTILITY DEVELOPMENT Management under the proposed plan would result in a low adverse impact to major utility development. Seasonal restrictions on construction and major maintenance on 18 percent of the public lands identified as needed for future utility development would result in operating inconvenience and potential cost increases for utility companies. Restrictions would be most significant in the salinity control areas (1 1,062 acres) where one-quarter of the typical construction season would be under this seasonal operating restriction. Excluding major utility development within the Terror Creek drainage would restrict utility development linking the Montrose and Rifle areas to alternate and possibly less desirable and cost-effective routes. IMPACTS ON ACCESS IMP A CTS FROM PROPOSED MAN A GEMENT A CTIONS Impacts from Acquisition of Access. Acquiring access into 16 areas would improve administration and allow for public utilization of these public lands. IMPACTS ON ECONOMIC RESOURCES IMP A CTS FROM PROPOSED MAN A GEMENT A CTIONS Impacts from Coal Management. Present and future demands for coal in Delta and Gunnison counties, with market values ranging from $31 million to $103 million annually (1984 values), would be met over the life of this 187 PROPOSED PLAN IMPACTS plan. Meeting coal demands would have a corresponding positive impact on generation of local incomes and royalties paid to federal and state governments. Coal production costs would be anticipated to increase slightly within the riparian, aquatic, and crucial winter range areas where requirements for additional mitigation or seasonal restrictions would be applied. Impacts from Locatable Minerals Management. Economic benefits associated with the unknown mineral potential on 32,750 acres of withdrawn lands would not be achieved. Impacts from Soils and Water Resources Management. Completing and maintaining the Elephant Skin Wash salinity control project would contribute to lower water treatment costs downstream. During the life of the plan, the projected reduction in salinity of 1,434 to 2,209 tons would serve to lower salinity costs in the Colorado River Basin by $83,172 to $128,122. Any additional projects would have similar economic benefits. The local economy would benefit from slightly increased soil productivity and reduced costs for less frequent removal of reservoir sedimentation. Impacts from Livestock Grazing Management. Current trends and conditions associated with management of 32,607 AUMs, valued at $247,813 (1985 values), would continue. These AUMs represent a decrease of 5,677 AUMs, valued at $43,145, from the existing situation. Any loss of AUMs could result in financial losses for the affected ranching operations. Impacts from Forest Management. The sale of forest and woodland products would produce about $19,267 in federal revenues annually. These revenues would be nearly the same as the average annual revenues since 1981. Local employment and income would be supported to the extent that timber and woodland harvesting would be by local commercial cutters and sold locally. The sale of 1,213 cords of fuelwood annually would offset local residential heating costs. Impacts from Disposal of Public Lands. The disposal of the 143 tracts of public land (totalling 11,026 acres) within the planning area which are identified as suitable for disposal could result in revenues ranging from $3 million to $6 million, based on estimated average sales prices of $300 to $600 per acre. Disposal would occur over a period of several years, with receipts going primarily to the Federal treasury. These receipts would represent less than one-tenth of one percent of estimated Federal revenues and are not, therefore, significant. CUMULATIVE IMPACTS ON ECONOMIC RESOURCES The cumulative impact on the local economy is likely to be beneficial but not large. The loss of AUMs could result in financial losses for ranching operations. Develop- ment of coal, water, forest, and recreation resources could offset any negative economic impacts from losses of AUMs. 188 PREPARATION AND DISTRIBUTION LIST OF PREPARERS Bureau of Land Management staff and resource specialists who provided resource data, coordinated input and revisions, and responded to public comments during the development and preparation of the Proposed Resource Management Plan and Final Environmental Impact Statement are listed as follows: ALLAN J. BELT Area Manager, Uncompahgre Basin Resource Area ROBERT E. VECCHIA Team Leader, Uncompahgre Basin RMP Team SCOTT F. ARCHER Air Quality and Climate DAVID J. AXELSON Economics JOHN A. DAVIS Lands and Realty JAMES R. FERGUSON Wildlife and Threatened and Endangered Species LARRY FRAZIER Forestry RON D. HUNTLEY Vegetation and Livestock Grazing JOE KUKA Water Power CHERYL D. LAUDENBACH Word Processing LYNN D. LEWIS Geology and Minerals DENNIS M. MURPHY Soils and Water Resources JON WESLEY SERING Recreation, Wilderness, and Visual Resources YVONNE KUTA SMITH Writer/Editor, Uncompahgre Basin RMP Team ROBERT P. VLAHOS Technical Coordinator, Uncompahgre Basin RMP Team W. MAX WITKIND Cultural Resources DISTRIBUTION OF THE PROPOSED RMP AND FINAL EIS This Proposed Resource Management Plan and Final Environmental Impact Statement will be distributed to approximately 900 addresses, including all addresses to which the Draft RMP/EIS was sent (see the Review of the Draft RMP I EIS section of this document). The original distribution list for the Draft RMP/EIS has been expanded to include those individuals, organizations, and agencies who testified at the public hearings, submitted written comments, or requested copies of the draft. 189 APPENDIX A STIPULATIONS FOR OIL AND GAS LEASES The following stipulations would be added to future oil and gas leases on both federal surface and split-estate lands where assigned for each management unit (see beginning page 146). The actual wording of these stipulations may be adjusted at the time of leasing to reflect future legislation, court decisions or policy changes; however, the protection standards contained in these stipulations would be maintained. Any change to the protection content of the stipulation would require an amendment to the RMP/EIS. Highly Erodible and/or Saline Soil Areas Stipulation: To protect watersheds from salinity infusions and to protect highly erodible soil areas where low soil productivity would prolong or disallow revegetation, all development activities (exploration, drilling, etc.) will be allowed only from June 1 through February 28. Exceptions to this limitation may be authorized in writing by the BLM's Authorized Officer. The affected portions of this lease are (legal description). Reasons for Exceptions: This stipulation may be waived, excepted, or modified by the Authorized Officer if the lessee can demonstrate that operations can be conducted without causing unacceptable impacts on salinity and highly erodible soil areas. The stipulation would not be waived, excepted, or modified if it is determined that the activity would cause accelerated erosion that would result in excessive amounts of salinity being contributed to the Colorado River. Variances could be allowed if soils are not saturated during the typical high soil moisture period when these soils are most susceptible to damage (March 1 through May 31), or if impacts could be mitigated, or if site-specific conditions do not warrant the stipulation (small amount of disturbance, short duration of operations, etc.). Resource information for split-estate lands has not been verified by the BLM. Verification will occur during review of Applications for Permit to Drill (APDs). On-site inspection and consultation with the surface owner and operator may reveal that (1) the impacts addressed by the stipulation will be avoided or mitigated to an acceptable level, or (2) the resources of concern are not present. Upon either of these determinations by the Authorized Officer, the stipulations can be waived, modified, or excepted without public notice other than that provided for the APD. If, after on-site inspection and consultation with the private surface landowner, it is determined by the Authorized Officer that conditions necessary to avoid impacts to private resources would adversely impact the public resources addressed by these stipulations, the impacts will be assessed. If, based upon such assessment, the Authorized Officer makes a decision to substantially change or waive one or more stipulations, a 30-day public review period will be provided in addition to the public notice period for receipt of the APD. Threatened, Endangered, Candidate, and Sensitive Plant Areas Stipulation; To protect the threatened, endangered, candidate, and sensitive plants and their potential habitat within the Escalante Canyon Area of Critical Environmental Concern and the Fairview Research Natural Area, an area of critical environmental concern, no surface occupancy would be permitted in these areas. Exceptions to this restriction may be authorized in writing by the BLM's Authorized Officer. The affected portions of this lease are (legal description). Reasons for Exceptions: This stipulation may be waived, excepted, or modified by the Authorized Officer if the lessee can demonstrate that operations can be conducted without causing unacceptable impacts on threatened, endangered, candidate, and sensitive plants and their potential habitats within these areas. Bald Eagle Winter Concentration Areas Stipulation: To protect bald eagles from activities that would cause abandonment of winter concentration areas, all development activities (exploration, drilling, etc.) will only be allowed in these areas from May 1 through November 30. Exceptions to this limitation may be authorized in writing by the BLM's Authorized Officer. The affected portions of this lease are (legal description). Reasons for Exceptions: This stipulation may be waived, excepted, or modified by the Authorized Officer if the lessee can demonstrate that operations can be conducted without causing unacceptable impacts on wintering bald eagles. Resource information for split-estate lands has not been verified by the BLM. Verification will occur during review of Applications for Permit to Drill (APDs). On-site inspection and consultation with the surface owner and operator may reveal that (1) the impacts addressed by 191 APPENDIX A the stipulation will be avoided or mitigated, to an acceptable level, or (2) the resources of concern are not present. Upon either of these determinations by the Authorized Officer, the stipulations can be waived, modified, or excepted without public notice other than that provided for the APD. If, after on-site inspection and consultation with the private surface landowner, it is determined by the Authorized Officer that conditions necessary to avoid impacts to private resources would adversely impact the public resources addressed by these stipulations, the impacts will be assessed. If, based upon such assessment, the Authorized Officer makes a decision to substantially change or waive one or more stipulations, a 30-day public review period will be provided in addition to the public notice period for receipt of the APD. Crucial Deer and Elk Winter Ranges Stipulation: To protect crucial deer and elk winter ranges from activities that would cause these species to abandon areas of crucial winter forage and cover for less suitable ranges, all development activities (exploration, drilling, etc.) will only be allowed from May 1 through November 30. Exceptions to this limitation may be authorized in writing by the BLM's Authorized Officer. The affected portions of this lease are (legal description). Reasons for Exceptions: This stipulation may be waived, excepted, or modified by the Authorized Officer if the lessee can demonstrate that operations can be conducted without causing unacceptable impacts on deer and elk utilization of crucial winter ranges. Variances could be allowed if these crucial ranges are not being utilized due to mild winter conditions or temporary changes in winter range utilization, or if impacts could be mitigated, or if site-specific conditions do not warrant the stipulation (small amount of disturbance, short duration of operations, etc.). Resource information for split-estate lands has not been verified by the BLM. Verification will occur during review of Applications for Permit to Drill (APDs). On-site inspection and consultation with the surface owner and operator may reveal that (1) the impacts addressed by the stipulation will be avoided or mitigated to an acceptable level, or (2) the resources of concern are not present. Upon either of these determinations by the Authorized Officer, the stipulations can be waived, modified, or excepted without public notice other than that provided for the APD. If, after on-site inspection and consultation with the private surface landowner, it is determined by the Authorized Officer that conditions necessary to avoid impacts to private resources would adversely impact the public resources addressed by these stipulations, the impacts will be assessed. If, based upon such assessment, the Authorized Officer makes a decision to substantially change or waive one or more stipulations, a 30-day public review period will be provided in addition to the public notice period for receipt of the APD. Elk Calving Areas Stipulation: To protect elk calving areas from activities that would force elk to abandon these areas during critical calving periods, all development activities (exploration, drilling, etc.) will only be allowed from July 16 through April 14. Exceptions to this limitation may be authorized in writing by the BLM's Authorized Officer. The affected portions of this lease are (legal description). Reasons for Exceptions: This stipulation may be waived, excepted, or modified by the Authorized Officer if the lessee can demonstrate that operations can be conducted without causing unacceptable impacts on calving elk. Resource information for split-estate lands has not been verified by the BLM. Verification will occur during review of Applications for Permit to Drill (APDs). On-site inspection and consultation with the surface owner and operator may reveal that (1) the impacts addressed by the stipulation will be avoided or mitigated to an acceptable level, or (2) the resources of concern are not present. Upon either of these determinations by the Authorized Officer, the stipulations can be waived, modified, or excepted without public notice other than that provided for the APD. If, after on-site inspection and consultation with the private surface landowner, it is determined by the Authorized Officer that conditions necessary to avoid impacts to private resources would adversely impact the public resources addressed by these stipulations, the impacts will be assessed. If, based upon such assessment, the Authorized Officer makes a decision to substantially change or waive one or more stipulations, a 30-day public review period will be provided in addition to the public notice period for receipt of the APD. Waterfowl Habitat Stipulation: To protect waterfowl from activities that would alter breeding behavior, increase the incidence of nest abandonment, and decrease breeding success, all development activities (exploration, drilling etc.) will only be allowed in waterfowl habitats from July 1 through March 14. Exceptions to this limitation may be authorized in writing by the BLM's Authorized Officer. The affected portions of this lease are (legal description). Reasons for Exceptions: This stipulation may be waived, excepted, or modified by the Authorized Officer if the lessee can demonstrate that operations can be conducted without causing unacceptable impacts on 192 APPENDIX A breeding and nesting waterfowl. Variances could be allowed if these breeding habitats are not being utilized, or if impacts could be mitigated, or if site-specific conditions do not warrant the stipulation (few individuals affected, short duration of operations, etc.). Resource information for split-estate lands has not been verified by the BLM. Verification will occur during review of Applications for Permit to Drill (APDs). On-site inspection and consultation with the surface owner and operator may reveal that (1) the impacts addressed by the stipulation will be avoided or mitigated to an acceptable level, or (2) the resources of concern are not present. Upon either of these determinations by the Authorized Officer, the stipulations can be waived, modified, or excepted without public notice other than that provided for the APD. If, after on-site inspection and consultation with the private surface landowner, it is determined by the Authorized Officer that conditions necessary to avoid impacts to private resources would adversely impact the public resources addressed by these stipulations, the impacts will be assessed. If, based upon such assessment, the Authorized Officer makes a decision to substantially change or waive one or more stipulations, a 30-day public review period will be provided in addition to the public notice period for receipt of the APD. Outstanding Natural Areas Stipulation: To protect the scenic, natural, and scientific values of the Adobe Badlands Outstanding Natural Area, an area of critical environmental concern, and the Needle Rock Outstanding Natural Area, an area of critical concern, no surface occupancy would be permitted within these areas. Exceptions to this restriction may be authorized in writing by the BLM's Authorized Officer. The affected portions of this lease are (legal description). Reasons for Exceptions: This stipulation may be waived, excepted, or modified by the Authorized Officer if the lessee can demonstrate that operations can be conducted without causing unacceptable impacts on the scenic, natural, and scientific values of these areas. Wilderness Study Areas Stipulation: Wilderness Protection Stipulation Form CSO 3000-1 (July 1980) is attached per Washington Office Instruction Memo No. 80-509 (5/12/80). This memo implements the Interim Management Policy and Guidelines for Land Under Wilderness Review (12/12/79 and amendments). Reasons for Exceptions: This stipulation would be attached to all leases involving lands within WSAs, and would apply until these lands are released from WSA status. 193 A & <,t ^v O'r" £> ACRONYMS ACEC: Area of Critical Environmental Concern AMP: Allotment Management Plan APD: Application for Permit to Drill AUM: Animal Unit Month BLM: Bureau of Land Management BOR: Bureau of Reclamation CFR: Code of Federal Regulations DOW: Colorado Division of Wildlife EA: Environmental Assessment EIS: Environmental Impact Statement EO: Executive Order EPA: Environmental Protection Agency FERC: Federal Energy Regulatory Commission FLPMA: Federal Land Policy and Management Act FMP: Forest Management Plan HMP: Habitat Management Plan KGS: Known Geologic Structure kv: kilovolt MBF: Thousand Board Feet MSA: Management Situation Analysis NPS: National Park Service ONA: Outstanding Natural Area ORV: Off-Road Vehicle PLO: Public Land Order PSD: Prevention of Significant Deterioration RAMP: Recreation Area Management Plan R&PP: Recreation and Public Purposes Act RMP: Resource Management Plan RNA: Research Natural Area ROD: Record of Decision RPS: Rangeland Program Summary RS: Revised Statutes SRMA: Special Recreation Management Area T&E: Threatened and Endangered TPCC: Timber Production Capabilities Classification UBRA: Uncompahgre Basin Resource Area USDI: U.S.Department of the Interior USFS: U.S. Forest Service USFWS: U.S. Fish and Wildlife Service USGS: U.S. Geological Survey VRM: Visual Resource Management WSA: Wilderness Study Area WTS: Wilderness Technical Supplement 195 U.S. GOVERNMENT PRINTING OFFICE:1988-573-065/60009