CWF/NMWF/NWF letter re Rio Grande National Forest draft plan

January 7, 2018

 CWF, New Mexico Wildlife Federation and National Wildlife Federation submitted our comment letter re the Rio Grande National Forest draft plan on December 28, 2017.  Our organizations have been working for wildlife connectivity between the Rio Grande National Forest in Colorado the Carson and SantaFe National Forests in New Mexico. We also are concerned with the vitality of bighorn sheep in the Rio Grande National Forest and are urging it become designated as a "species of conservation concern" in this National Forest.

December 28, 2017

 Dear Rio Grande Forest Supervisor Dan Dallas and Rio Grande National Forest Planning Team:

 This letter is in response to the Rio Grande National Forests (RGNF) Draft Plan (DP) and Draft Environmental Statement (DEIS).  Below, we offer a few recommendations for how the RGNF can improve the Draft Plan and Draft Environmental Impact Statement.

I.  Continue to increase and enhance Landscape/Habitat and Wildlife Connectivity

 We are pleased to see several Special Interest Areas (SIAs) included in Alternative D of the DEIS but are very disappointed by the proposed Plan and strongly believe that these SIAs should be included in the preferred alternative and at the very least, the Rio Grande National Forest (RGNF) should adopt the following SIAs in the final Plan, which would help maintain and restore connectivity in the Upper Rio Grande Watershed: Spruce Hole/ Osier/Toltec Connectivity Special Interest Area, Chama Basin Watershed Protection Special Interest Area, Jim Creek Special Interest Area and Carnero Creek Special Interest Area.

We also request that the RGNF adopt substantive plan components for each SIA to ensure that the values for which they are established are maintained and enhanced over the life of the plan. Our recommended plan components for each SIA are included in this letter. We request that the RGNF analyze these plan components in the FEIS and include them in the final Plan. These Special Interest Areas include over 100,000 acres of recognized landscape designated to promote Wildlife Connectivity, the protection and restoration of native Rio Grande cutthroat trout, and the conservation of wildlife. We also support the inclusion of forest-wide plan direction that would maintain and restore terrestrial and aquatic connectivity.

We appreciate the RGNFs efforts to approach wildlife connectivity holistically in the plan and to incorporate some levels of wildlife habitat protections throughout the Forest. However, just as there are places that are identified and proposed for particular management due to their particular recreation or development values, it is imperative to recognize specific areas that are of particular significance for wildlife habitat connectivity. Protecting these SIAs is not only critical for wildlife conservation and connectivity, but also are critical to providing opportunity to sportsmen and women as well as critical to supporting the regional economy and culture. For example, maintaining premiere wildlife habitat provides exceptional hunting, fishing and other recreational opportunities that are critical to economic livelihood and identity of many communities in southern Colorado and northern New Mexico. For example,  according to a study conducted by Colorado Parks and Wildlife on the Economic Contributions of Outdoor Recreation in Colorado: Over 180,000 days were spent hunting alone by residents in Alamosa, Conejos, Mineral, Hinsdale, Archuleta, Rio Grande, Costilla and Saguache Counties in 2013. The average days spent fishing by those who participated was 16.35 in South-central and South-eastern counties.[1]  Alamosa, Conejos, Mineral, Hinsdale, Archuleta, Rio Grande, Costilla and Saguache had nearly 28$ million in Output for Economic Hunting Contributions and created nearly 650 jobs directly related to hunting. South-central Colorado had a total output for fishing of 294$ million in 2013. [2]

A.   Spruce Hole/Osier/Toltec Special Interest Area

This 36,000-acre area is critical for big game movement from southern Colorado into northern New Mexico. Protecting this movement corridor in the forest plan will ensure core roadless habitat in Colorado that is connected to core habitat in New Mexico. This area is also of critical economic and cultural importance to local communities within Rio Grande, Mineral, Alamosa and Conejos Counties.

The Final Plan should describe the primary values of this area as:

       Wildlife migration and connectivity for large game species, including mule deer, elk, pronghorn, and Rocky Mountain bighorn sheep, as well as carnivores such as Canadian lynx, mountain lions, and black bears. (DEIS at 314).

       High quality wildlife habitat for species of conservation concern and federally protected species, including the boreal owl, peregrine falcon, Brewers sparrow, flammulated owl, Rio Grande cutthroat trout, Gunnisons prairie dog; Ripleys milkvetch, slender cliffbrake, Plumbers cliff fern, Colorado divide whitlow grass, and flowered gilia; federally protected species such as the Mexican spotted owl, southwestern willow flycatcher, yellow-billed cuckoo, and New Mexico meadow jumping mouse; migratory birds including ferruginous hawks, black swifts, sage sparrows, burrowing owls, Cassins finches, Graces warblers, gray vireos, juniper titmouse, Lewiss woodpeckers, loggerhead shrikes, long-billed curlews, mountain plovers, pinyon jays, and Virginias warblers. (See DEIS at 314.)

Site-specific plan components and management approaches should include:

 DESIRED CONDITIONS

      Long-term connectivity and integrity of habitat utilized for fish and wildlife movement through the area is maintained and, where necessary, restored to provide for ecological integrity.

       This SIA is managed for wildlife movement and habitat connectivity and for the enjoyment of the public as they hunt, fish, recreate, study, and observe wildlife. Natural conditions prevail in the area while providing an opportunity for interpretation, education, and research.

       Wildlife habitat connectivity provides an essential ecological condition for supporting viable populations of at-risk species and offers educational and research opportunities.

       Interpretive signing is used to explain major features of the area and explain protection of sensitive ecosystems.

       Management activities will limit the surface disturbance footprint temporally and spatially to minimize adverse impacts to wildlife.

      The Forest Service in cooperation with permittees, Colorado Department of Transportation, Colorado Department of Parks and Wildlife, and other stakeholders implement projects to reduce and minimize barriers to wildlife movement such as fences and dangerous road crossings.

STANDARDS

        Authorized activities shall be harmonious with the primary values of wildlife movement, habitat                 connectivity, and habitat condition for at-risk species.

       New permanent roads within the corridor will not be constructed in order to maintain un-fragmented habitat for wildlife migration and dispersal.

       Temporary roads will only be constructed if necessary, and with the smallest impact possible, and will be reclaimed and obliterated within one year of the termination of the project for which they were authorized to protect watershed condition, minimize wildlife disturbance, and prevent illegal motorized use.

       New or reconstructed fencing shall allow for wildlife passage and prevent wildlife entrapment, taking into consideration seasonal migration and access to water resources (except where specifically intended to exclude wildlife -- e.g., elk exclosure fence -- and/or to protect human health and safety).

       New rights-of-way for energy development that would negatively impact wildlife, their habitat and its connectivity will not be issued.

       Projects will consider the cumulative impacts of ground-disturbing projects that are occurring or will occur on adjacent lands and will strive to minimize as possible the spatial, temporal, or other design features can mitigate impacts to connectivity.

       The area is not suitable for timber production.

      The area is not suitable for oil and gas leasing with no surface occupancy.

GUIDELINES

      Do not exceed a motorized route density of one mile per square mile generally, or a threshold determined by best available science for specific at-risk species.[3]

MANAGEMENT APPROACHES

       Where motorized route densities exceed one mile per square mile, develop and implement a strategy to reduce the densities to below this threshold level.

       In coordination with the Colorado Department of Transportation, develop and implement a strategy for mitigating highway related barriers to wildlife movement.

       As possible, augment wildlife values through purchase from willing sellers, exchange, transfer, or donation of additional acreage of crucial wildlife habitat for their migration, movement and dispersal.

.      Work with livestock permittees to identify fencing that is not critical for livestock operations. Remove fencing that is not critical for livestock operations and that is impeding wildlife movement. Where possible, modify existing fencing that is not wildlife friendly.

                        B.  Chama Basin Watershed Protection Special Interest Area:

This 17,790-acre area en- compasses the headwaters of the Rio Chama. The area has a high potential for oil and gas development so it is important the area is protected in the forest plan. This area is of critical economic and cultural importance to local communities within Rio Grande, Mineral, Alamosa and Conejos Counties. This area is of critical due to the close proximity and cross border collaboration with the Carson NF, New Mexico Department of Game and Fish, and Tribal Communities.

Site-specific plan components and management approaches should include:

DESIRED CONDITIONS

     Long-term connectivity and integrity of habitat utilized for fish and wildlife movement through the area is maintained and, where necessary, restored to provide for ecological integrity.

       This SIA is managed for wildlife movement and habitat connectivity and for the enjoyment of the public as they hunt, fish, recreate, learn about, and observe wildlife. Natural conditions prevail in the area while providing an opportunity for interpretation, education, and research.

       Wildlife habitat connectivity provides an essential ecological condition for supporting viable populations of at-risk species and offers educational and research opportunities.

       Interpretive signing is used to explain major features of the area and explain protection of sensitive ecosystems.

       Management activities will limit the surface disturbance footprint temporally and spatially to minimize adverse impacts to wildlife.

      The Forest Service in cooperation with permittees, Colorado Department of Transportation, Colorado Department of Parks and Wildlife, and other stakeholders implement projects to reduce and minimize barriers to wildlife movement such as fences and dangerous road crossings.

STANDARDS

       Authorized activities shall be harmonious with the primary values of wildlife movement, habitat connectivity, and habitat condition for at-risk species.

       New permanent roads within the corridor will not be constructed in order to maintain un-fragmented habitat for wildlife migration and dispersal.

       Temporary roads will only be constructed if necessary, and with the smallest impact possible, and will be reclaimed and obliterated within one year of the termination of the project for which they were authorized to protect watershed condition, minimize wildlife disturbance, and prevent illegal motorized use.

       New or reconstructed fencing shall allow for wildlife passage and prevent wildlife entrapment, taking into consideration seasonal migration and access to water resources (except where specifically intended to exclude wildlife -- e.g., elk exclosure fence -- and/or to protect human health and safety).

       New rights-of-way for energy development that would negatively impact wildlife, their habitat and its connectivity will not be issued.

       Projects will consider the cumulative impacts of ground-disturbing projects that are occurring or will occur on adjacent lands and will strive to minimize as possible the spatial, temporal, or other design features can mitigate impacts to connectivity.

       The area is not suitable for timber production.

      The area is not suitable for oil and gas leasing with no surface occupancy.

GUIDELINES

      Do not exceed a motorized route density of one mile per square mile generally, or a threshold                     determined by best available science for specific at-risk species.[4]

MANAGEMENT APPROACHES

       Where motorized route densities exceed one mile per square mile, develop and implement a strategy to reduce the densities to below this threshold level.

       In coordination with the Colorado Department of Transportation, develop and implement a strategy for mitigating highway related barriers to wildlife movement.

       As possible, augment wildlife values through purchase from willing sellers, exchange, transfer, or donation of additional acreage of crucial wildlife habitat for their migration, movement and dispersal.

       Work with livestock permittees to identify fencing that is not critical for livestock operations. Remove fencing that is not critical for livestock operations and that is impeding wildlife movement. As possible, modify existing fencing that is not wildlife friendly.

C.  Jim Creek Special Interest Area:

This 9,500-acre tract has native Rio Grande cutthroat trout. Protecting this area in the forest plan will ensure preservation and restoration of the Rio Grande cutthroat trout, which is a management priority.

Site-specific plan components and management approaches should include:

DESIRED CONDITIONS

.    Long-term connectivity and integrity of habitat utilized for fish and wildlife movement through the area is maintained and, where necessary, restored to provide for ecological integrity.

       This SIA is managed for wildlife movement and habitat connectivity and for the enjoyment of the public as they hunt, fish, recreate, learn about, and observe wildlife. Natural conditions prevail in the area while providing an opportunity for interpretation, education, and research.

       Wildlife habitat connectivity provides an essential ecological condition for supporting viable populations of at-risk species and offers educational and research opportunities.

       Interpretive signing is used to explain major features of the area and explain protection of sensitive ecosystems.

       Management activities will limit the surface disturbance footprint temporally and spatially to minimize adverse impacts to wildlife.

      The Forest Service in cooperation with permittees, Colorado Department of Transportation, Colorado Department of Parks and Wildlife, and other stakeholders implement projects to reduce and minimize barriers to wildlife movement such as fences and dangerous road crossings.

Site by Chico Web Design