CWF Comments re Proposed CO Roadless Rule

July 14, 2011

The proposed Colorado Roadless Rule was released on April 14.  The 90-day public comment period ended on July 14. The proposed rule, Revised Draft Environmental Impact Statement and related materials are available at http://www.fs.usda.gov/goto/coroadlessrule.  The revised draft environmental impact statement and the proposed rule covers 4.2 million acres of national forests in Colorado. It contains 4 alternatives: the 2001 roadless rule - which is alternative 1; the state's proposed rule (via petition by Gov. Owens, as amended by Gov. Ritter) - which is alternative 2; an alternative that reflects the current USFS plans in each forest including 562,200 "upper tier" acres; and a proposed alternative rule that includes additional "upper tier" acres that are very important wildlife habitat - which is alternative 4.   

Here are the comments submitted by CWF on the draft rule for Colorado's roadless national forests. Also note that Congressional H.B. 1581 (and S. 1087), the Wilderness and Roadless Area Release Act of 2011, likely would undo the work in Colorado during the last several years to develop a Colorado roadless rule.  CWF opposes this bill.

July 14, 2011

Colorado Roadless Rule/EIS

                         CRR Comments Transmitted by email:  COComments@fsroadless.org

Please accept these comments from the Colorado Wildlife Federation (CWF) and the National Wildlife Federation (NWF) regarding the proposed Colorado Roadless Rule (CRR).

The Colorado Wildlife Federation is a statewide tax exempt 501(c)(3) nonprofit, membership based, mainstream wildlife conservation organization.  CWF’s mission is to promote the conservation, sound management, and sustainable use of Colorado’s wildlife and wildlife habitat through education and advocacy.  CWF understands that wildlife habitat is critical to conserving Colorado’s unique wildlife, hunting and fishing heritage and wildlife viewing opportunities.  These wildlife-related recreation pursuits enrich the well-being of Colorado’s residents and out-of-state visitors and form a substantial segment of Colorado’s economy.

The National Wildlife Federation (NWF) is a national member-supported non-profit conservation, education, and advocacy organization.  NWF is associated with conservation organizations in 47 states and territories, including CWF in Colorado.   NWF is dedicated to conserving wildlife and other natural resources, and believes that hunting and fishing are useful wildlife management practices as well as recreation that contributes substantial economic benefits. NWF works to promote responsible management of wildlife on public lands.

We appreciate that since our comments submitted on October 6, 2009 concerning the proposed rule of July 28, 2009, several important improvements have been made and are reflected in Alternative 2 of the proposed rule.   In our 2009 comments, CWF and NWF  had taken exception to application of standards for fire safety to prevent or suppress an insect or disease epidemic.  CWF and NWF are pleased that this provision has been eliminated.  We also had advocated that the Regional Forester level must authorize tree cutting outside of 0.5 miles of the CPZ and applaud the U.S. Forest Service (USFS) and Department of Natural Resources (DNR) for making this adjustment.  In addition, the USFS and DNR accepted the 2009 recommendation by the Division of Wildlife (now Division of Parks and Wildlife) to add acres of high wildlife quality to the roadless inventory.

Our comments are divided into four sections:

1. Recommendations of additional improvements to Alternative 2 language.

2. Recommendations of improvements to Upper Tier protections/exceptions language in Alternative 2.

3. Recommendations of additional Upper Tier parcels for Alternative 2.

4. Protection of the Currant Creek Roadless Area with the Upper Tier designation. 

On balance, we support Alternative 2 if a substantial portion of our recommendations become incorporated into the final rule and Currant Creek roadless area receives Upper Tier designation.

1.Recommended Additional Improvements to Alternative 2 Language

Linear Construction Zone (LCZ) definition does not keep LCZs within rights of way.

LCZs should be located within right of ways to minimize surface disturbance and conserve the surface values of roadless areas.  Allowing LCZs to be constructed outside of rights of way creates a situation where land managers could create temporary roads under the category of LCZs.

To allow LCZs within rights of ways, we propose the following regulatory language:

§ 294.44 Prohibition on linear construction zones.

(c) Linear construction zone decommissioning. Where a linear construction zone is constructed in a Colorado Roadless Area, installation of the linear facility will be done in a manner that minimizes ground disturbance and shall be located entirely within rights of way.  

We also urge that the definition in §294.41 of the proposed Colorado rule for an LCZ be changed to read: “A temporary linear area of surface disturbance located within a right of way that is used for motorized transport by vehicles or construction equipment to install a linear facility. It is not used as a motor vehicle route and is not engineered to road specifications.” 

Substantially greater environmental damage language in LCZ requirements is vague and lacks clarity.

Without a clear definition of “substantially greater environmental damage,” it could be difficult for the USFS to make consistent decisions when denying and allowing LCZs and those decisions could be legally vulnerable.   One can envision a situation where a roadless mountain range lies between one utility installation and another; the company would have to go all the way around the mountain range, negotiate with multiple land owners and agencies, and incur much greater costs than if building the utility directly over the range. The company could argue that by going over the range directly it would cause less environmental damage. If the USFS disagreed, the agency would have no supporting language in the rule to substantiate its position.   

Our recommendation is to clarify the regulatory language by defining the term “substantially greater environmental damage.”

High Quality Fish and Wildlife Habitat Not Assured After Timber Cutting

Colorado’s roadless areas provide world-class fish and wildlife habitat and it is important that those values are maintained and enhanced over the long term. Requiring coordination with the Colorado Division of Parks and Wildlife will provide additional assurance that fish and wildlife receive due consideration in the planning and implementation of timber cutting projects.  All projects under §294.42(c)(1) through (3) should include the following language: “Be developed in coordination with the Colorado Division of Parks and Wildlife.”

No requirement that the Regional Forester document in writing the reasons for authorizing tree cutting outside of 0.5 miles of the CPZ

We understand the USFS manual provides some guidance. For purposes of transparency and to educate the public, we urge that the final rule specify that the Regional Forester document the reasons when authorizing tree cutting beyond the 0.5 miles of the CPZ.

Language to safeguard cutthroat trout populations during development activities has been weakened in Alternative 2.  

The amended Colorado roadless rule petition required that activities within native cutthroat catchments not diminish watershed conditions. Alternative 2 adds the language, “over the long term.”   We believe this ambiguity could lead to extirpation of small distinct cutthroat populations during activities because there is no prohibition on impacting trout populations, only that watershed conditions be retained over the long term. Even if conditions are restored over the long term, there are no requirements that sustainable native trout populations are retained during a project.  Does “over the long term” mean 5 years, 20 years, or 100 years?  If this language is to remain in the final rule, the long term should be defined and additional language should require the sustainability of native trout populations.  We recommend removal of the language “over the long term” and add language stating that “activities cannot alter, damage, or destroy native cutthroat trout populations” at § 294.43(b)(2)(iii), § 294.43(c)(2)(iv), and § 294.44(b)(4)(iii).

Language in §294.43(b)(2)(iii) as to determination of whether activities will diminish conditions for native cutthroat trout is problematic.  The rule does not address what will occur if it were determined the project would diminish conditions.

Without adding language as to how to proceed in the event a project diminishes conditions in the water influence zone and/or in native cutthroat habitat, there is no assurance that a project would not drastically damage or even destroy a cutthroat population. This omission leaves the USFS legally vulnerable and does not adequately protect native trout populations.

We recommend that the following be added to the regulatory language:

“If it is determined that a non-discretionary project would diminish conditions in the water influence zone and/or in native cutthroat habitat, the Regional Forester will require a plan for protecting native cutthroat populations and their habitat during project activities that insures activities will not alter, damage, or destroy native cutthroat trout populations.”

 

2. Upper Tier Protections/Exceptions Language Improvements Needed for Alternative 2

LCZs are allowed in Upper Tier areas, threatening the highest value Colorado roadless areas with transmission corridors, water projects, and oil and gas pipelines.

The Upper Tier category will not conserve the highest value roadless areas if the linear LCZ language as currently appears in Alternative 2 exists for this category of lands.  LCZs should be prohibited in areas designated as Upper Tier.  We recommend the following change to § 294.44: 

§ 294.44 Prohibition on linear construction zones.

(a)  General. A linear construction zone may not be constructed or reconstructed in Colorado Roadless Areas except as provided in paragraphs (b) and (c) of this section.

(b)  Upper Tier Acres. Notwithstanding the prohibition in paragraph (a) of this section, a linear construction zone may only be constructed or reconstructed in Colorado Roadless Area upper tier acres if the Responsible Official determines that:

(1)  A linear construction zone is needed pursuant to reserved or outstanding rights, or as provided for by statute or treaty.

(c)  Non-Upper Tier Acres.  Notwithstanding the prohibition in paragraph (a) of this section, the

Regional Forester may authorize a linear construction zone within a Colorado Roadless Area outside upper tier acres for: ….

The proposed Colorado rule does not require no-surface occupancy (NSO) stipulations for oil and gas development in areas designated as Upper Tier, placing at risk the characteristics of high value roadless areas.  

Colorado roadless areas designated as Upper Tier should receive maximum safeguards from surface developments that would endanger their primitive character.  (We note that  upper tier areas in the Idaho roadless rule received NSO protections.)

 We recommend the following language be included in Alternative 2:

§ 294.46 Other Activities.

For mineral leases, contracts, permits, and other associated activities authorized after the effective date of this subpart the Forest Service will not recommend, authorize, or consent to road construction, road reconstruction, linear construction zones, or surface occupancy associated with mineral leases in Colorado Roadless Areas designated as upper tier.

Common variety mineral entry is allowed in upper tier areas, jeopardizing the characteristics of high value roadless areas.

Colorado roadless areas designated as Upper Tier should receive maximum safeguards from surface developments that would jeopardize their primitive character.  (Upper tier areas in the Idaho roadless rule were withdrawn from common variety mineral entry.)

Alternative 2 allows LCZs in Upper Tier areas, threatening the highest value Colorado roadless areas with transmission corridors, water projects, and oil and gas pipelines.

We recommend that Upper Tier areas be withdrawn from entry for common variety minerals with language inserted into Alternative 2 along these lines:

            § 294.46 Other Activities

Common Variety Minerals. After [final rule effective date], the Forest Service will not authorize the sale of common variety mineral materials in Colorado roadless acres designated as upper tier.

A very narrowly tailored exception for improvement of big game habitat may be inserted into Upper Tier provisions under Alternative 2. 

We acknowledge that in some circumstances, a portion of an Upper Tier parcel might benefit from limited tree-cutting to improve big game habitat.  Therefore, we would not oppose inclusion of such limited exception to the protections provided to Upper Tier acreage, so long as the Division of Parks and Wildlife has a significant role in specifying the acreage and appropriate treatments, coupled with meaningful public input.

3. Recommended Additional Designated Upper Tier Parcels for Alternative 2

The Upper Tier category in Alternative 2 does not include 1,296,333 roadless acres of very important fish and wildlife habitat.

The Upper Tier category has been created to balance narrowly defined exceptions in the Colorado rule such as coal mining, ski area development, and CPZ protection from wildlife to communities at risk.  Alternative 2 Upper Tier acres are confined to those areas where forest plans (and draft plans) already prohibit road building.  Limiting the Upper Tier designation to these acres excludes 1,296,333 acres of key fish and wildlife habitat.  The status of forest plans at the time of the draft operates to arbitrarily define designation and limits it to approximately 14 percent of the roadless acres.  ( Idaho upper tier areas represent about 33 percent of the overall acreage.)

The Upper Tier designation of acreage should be increased significantly in Alternative 2.  The Alternative 2 lands already designated as Upper Tier should remain so.  In addition, those 1,473,200 acres of Upper Tier lands that appear in our Table 1, selected from Alternative 4 (equaling 1,296,333 acres, after noting the overlap of 176,867 Upper Tier acres in Alternative 2 – see Table 2) that are important for fish and wildlife habitat, hunting and fishing should be moved into Alternative 2 and given an Upper Tier designation.  Table 1 lists the recommended Upper Tier parcels in order of priority, according to a weighted criteria system developed and applied by TRCP, BCHA and CWF. The weighted criteria are explained in Appendix A.  Appendix B describes key features of each Colorado roadless area recommended for inclusion in Alternative 2 as Upper Tier.  In addition, maps of each forest, showing elk, deer and sheep winter range and migration corridors, and the composite map, including shape files, are included in electronic transmission of comments submitted by TRCP on July 14. 

 4. Designation of Currant Creek as Upper Tier

In addition to the list of prioritized Colorado roadless areas for inclusion in Alternative 2 Upper Tier category shown in Table 1, CWF and NWF view the 10,780-acre Currant Creek roadless area in the Grand Mesa National Forest (“GMUG”) as a very important candidate for such status.   Attached is a map prepared by the Colorado Division of Wildlife (now Division of Parks and Wildlife) in 2009.  It depicts the key elk winter concentration areas and the elk production areas.   This parcel, ranging from 7,500 to 10,200 feet in elevation offers highly diverse vegetation and forage.  It includes migration corridors and has important deer fawning and is important to black bear in the fall when bears consume choke cherries, acorns and other food sources almost 21 hours a day in preparation for hibernation.   We also recall that in addition to our 2009 comments, the USFS had received almost 30,000 comments from Coloradoans and visitors, highlighting the importance of Currant Creek and urging strongly that it not be subject to the coal exception of the North Fork coal mining area.   In the survey conducted last year by TRCP, BCHA and CWF, we found that Currant Creek was cited by local sportsmen as an area of important value to them. 

Thank you for your consideration of these recommendations.

Suzanne O’Neill
Executive Director
Colorado Wildlife Federation
1410 Grant Street, Suite C-313
Denver, Colorado  80203
303- 987-0400
cell 303-919-3949

Michael Saul
Associate Counsel
National Wildlife Federation
2260 Baseline Road, Suite 100
Boulder, Colorado  80302

Table 1- Prioritized Colorado roadless areas for inclusion in Alternative 2 "Upper Tier" category of the Colorado roadless rule.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 2- Comparison of Colorado roadless areas recommended for inclusion in the alternative 2 "upper tier" category and those Colorado roadless areas already included in the alternative 2 “upper tier”

 

 * Currant Creek is discussed separately in the narrative.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

APPENDIX A – Colorado roadless “Upper Tier” recommendation criteria

(Developed by TRCP, CWF, BCH)

The following criteria (no particular order) were used to evaluate Colorado Roadless Areas (CRA) suitable for inclusion in an “upper tier” category of the Colorado roadless rule. A points system was used to place a quantitative on each roadless area. Points for each criterion are indicated parenthetically below. Also see table Table 1 for a breakdown of scoring criteria.

1.      Colorado sportsmen input (3 pts.): Sportsmen who live, work and are considered experts on local hunting and fishing in communities throughout Colorado identified areas with important fish and wildlife habitat and outdoor recreation values. 

2.     Species data: Fish and Wildlife GIS data from the Colorado Division of Wildlife (CODOW) NDIS system was assessed to identify ecologically important roadless areas for game species (information source: http://ndis.nrel.colostate.edu/index.html).

·      Bighorn sheep (Ovis Canadensis)(2.5 pts.): migration corridors/patterns (0.83), production area (0.83 pts.), severe winter range or summer concentration area or summer range or water source or winter concentration area or winter range (0.83 pts.).

·      Black bear (Ursus Americanus)(0.5 pts.): Summer concentration or fall concentration.

·      Cutthroat trout (Oncorhynchus clarki)(4 pts.): occurrence.

·      Elk (Cervus canadensis)(2 pts.): migration corridors/patterns (0.67 pts.), production area (0.67 pts.), limited use area or resident population area or severe winter range or summer concentration area or winter concentration area or winter range (0.67 pts.)

·      Grouse (Centrocercus minimus, Centrocercus urophasianus)(1.33 pts.): brood area or production area (0.67 pts.), overall range or severe winter range or winter range (0.67 pts.)

·      Moose (Alces alces)(1.5 pts.): migration pattern (0.5 pts.), breeding areas (0.5 pts.), concentration area or priority habitat or summer range or winter range (0.5 pts.)

·      Mountain goat (Oreamnos americanus) (1 pt.): migration corridor (0.33 pts.), production area (0.33 pts.), concentration area or mineral lick or winter range (0.33 pts.)

·      Mule deer (Odocoileus hemionus)(2.2 pts.): migration corridors/patterns (1.1 pts.), critical winter range or severe winter range or winter concentration area or concentration area (1.1 pts.)

·      Pronghorn antelope (Antilocapra americana) (1 pt.): migration corridors/patterns (0.33 pts.), concentration area or limited use area or perennial water or resident population area or severe winter range or winter concentration or winter range (0.33 pts.)

·      Wild turkey (Meleagris gallopavo)(1 pt.): production area or roost sites, (0.33 pts.), winter concentration area or winter range (0.33 pts.)

 

3.     Gold-medal fisheries (1 pt.): Colorado roadless areas were evaluated to determine if they fall within a Colorado Division of Water Resources district that encompasses a gold medal fishery.

 

4.     Motorized use (1.5 pts.): Roadless areas considered for upper tier generally have few to no motorized routes within CRA boundaries (based on U.S. Forest Service motor vehicle use maps).

 

5.     Colorado Division of Wildlife "high-priority habitat for threatened and endangered and economically important species" (0.75 pts.) were given special consideration (darkest overlay only, see link below). (data from:  http://wildlife.state.co.us/NR/rdonlyres/1E85758E-04EE-411F-957D-074641B0B715/0/StatewideAllHybrid1122.pdf)

 

6.     Hunter participation rates: CRAs that fall within game management units in the top 70th percentile for total harvest or total recreation days in 2009 were weighted in favor of upper tier (data from CODOW: http://wildlife.state.co.us/Hunting/BigGame/Statistics/).

 

·      Bighorn sheep (Ovis Canadensis): 0.83 pts.

·      Black bear (Ursus Americanus): 0.5 pts.

·      Elk (Cervus canadensis): 0.67 pts.

·      Moose (Alces alces): 0.5 pts.

·      Mountain goat (Oreamnos americanus): 0.33 pts.

·      Mule deer (Odocoileus hemionus): 1.1 pts.

·      Pronghorn antelope (Antilocapra americana): 0.33 pts.

 

7.     Connectivity (1.5 pts.): CRAs that are part of known wildlife migration corridors were considered for their landscape-scale wildlife connectivity values.

 

8.     Wilderness adjacency (1 pt.): CRAs connected to existing wilderness

 

 

APPENDIX B: Key features of each Colorado roadless area recommended for inclusion in alternative 2 of the upper tier category of the Colorado roadless rule**

 

1.     All South San Juan Wilderness Adjacent- Elk winter range and summer concentration area, bighorn sheep summer range, mule deer winter range and concentration area, black bear summer concentration area and cutthroat trout habitat. Migration route for elk and mule deer. Key habitat for elk reproduction. Very little motorized use. Identified by local sportsmen as a high value area. Very high hunter participation in 2009 for elk, mule deer and black bear.

 

Mount Lamborn- Elk winter range, winter concentration area and severe winter range, Mule deer winter range, winter concentration area, severe winter range and critical winter range, Black bear fall concentration area and cutthroat trout habitat. Elk and mule deer use it as a migration corridor. The gold medal portion of the Gunnison River flows through the same water district as Mount Lamborn. Identified by local sportsmen as a high value area. Cutthroat trout habitat. Very high hunter participation in 2009 for elk, mule deer and black bear.

 

Lower Piney- Elk winter range, severe winter range and summer concentration area, moose summer range, mountain goat summer range, wild turkey winter range and cutthroat trout habitat. Migration area for elk and mule deer. Key habitat for elk reproduction. Identified by local sportsmen as a high value area. Very high hunter participation in 2009 for elk.

 

Sugarloaf South- Elk summer concentration area, pronghorn antelope overall range, black bear summer concentration area and cutthroat trout habitat. Elk, mule deer and pronghorn antelope migration corridor. Very high hunter participation in 2009 for elk, mule deer and pronghorn antelope.

 

Spanish Peaks- Bighorn sheep winter range and summer range, wild turkey winter range and winter concentration area, mule deer winter range and black bear summer and fall concentration area. Migration route for bighorn sheep and mule deer. Very high hunter participation in 2009 for elk, bighorn sheep and black bear. Identified by local sportsmen as a high value area.

 

Crosier Mountain- Elk winter range, mule deer winter range, moose winter range, bighorn sheep winter range, winter concentration area and summer range, black bear summer and fall concentration area and cutthroat trout habitat. This CRA also provides necessary habitat for bighorn sheep and elk migrations. High levels of hunter participation in 2009 for mule deer and black bear. Very little motorized use.

 

Bristol Head- Elk winter range and summer concentration area, moose winter range, summer range, priority habitat and concentration area and mule deer winter range. Migration corridor for bighorn sheep and elk. Key breeding area for elk. Lies within the water district of a gold medal fishery. Identified by local sportsmen as a high value area. Very high hunter participation in 2009 for elk.

 

2. Turkey Creek- Elk summer concentration area, mule deer winter range, wild turkey winter range and cutthroat trout habitat. Migration route for elk. Key habitat for elk and bighorn sheep reproduction. Very little motorized use. Identified by local sportsmen as a high value area. Very high hunter participation in 2009 for elk, mule deer and black bear.

 

Mendicant- Elk summer concentration area and winter range, black bear fall concentration area and cutthroat trout habitat. Elk use this area for breeding activities and migration. There is a great deal of elk, mule deer and black bear hunting participation in Mendicant and the surrounding area. Lies within the water district of a gold medal fishery. Identified by local sportsmen as a high value area. Very high hunter participation in 2009 for elk, mule deer and black bear.

 

Mamm Peak- Elk winter range and summer concentration area, black bear fall concentration area and cutthroat trout habitat. Migration area for elk and mule deer. Key habitat for elk reproduction. Identified by local sportsmen as a high value area. Very high hunter participation in 2009 for elk, mule deer and black bear.

 

Purgatoire- Elk winter range and summer concentration area, mule deer winter range, bighorn sheep winter range, winter concentration area, summer range and severe winter range, wild turkey winter range and winter concentration area and black bear summer and fall concentration area. Migration route for bighorn sheep, elk and mule deer. Breeding grounds for bighorn sheep and elk. Identified by local sportsmen as a high value area. Very high hunter participation in 2009 for elk, bighorn sheep and black bear.

 

Sugarloaf North- Elk summer concentration area, pronghorn antelope overall range, black bear summer concentration area and cutthroat trout habitat. Migration route for mule deer and pronghorn antelope. Elk breeding area. Very high hunter participation in 2009 for elk, mule deer and pronghorn antelope.

 

Antora Meadows/Bear Creek- Elk winter range and summer concentration area bighorn sheep winter range and summer range, black bear summer and fall concentration area and cutthroat trout habitat. Bighorn sheep, elk and mule deer migration routes and bighorn sheep and elk breeding area.

 

All Comanche Peak Wilderness Adjacent- Elk winter range, moose winter and summer range, bighorn sheep summer range and black bear summer concentration area and cutthroat trout habitat. Elk use this land for migration and breeding. Turkey breeding areas also occur in this CRA. Very high hunter participation in 2009 for mule deer and black bear.

 

3.Graham Park- Elk winter range, moose winter range, summer range and concentration area, wild turkey winter range, black bear summer and fall concentration area and cutthroat trout habitat. Migration area for bighorn sheep, elk and mule deer. Key habitat for elk reproduction. Identified by local sportsmen as a high value area. Very high hunter participation in 2009 for elk and mule deer.

 

Clear Fork- Elk winter range, moose concentration area and cutthroat trout habitat. It is used by elk as a migration corridor and breeding area. Elk and black bear hunting participation is high. Lies within the water district of a gold medal fishery. Identified by local sportsmen as a high value area. Very high hunter participation in 2009 for elk and black bear.

 

Elk Creek B- Elk winter range and winter concentration area, bighorn sheep winter range, winter concentration area, severe winter range and summer range, mule deer winter range, wild turkey winter range, Black bear summer and fall concentration area and cutthroat trout habitat. Migration area for elk and mule deer. Key habitat for bighorn sheep, elk and wild turkey reproduction. Very high hunter participation in 2009 for elk and mule deer.

 

All Greenhorn Mountain Wilderness Adjacent- Bighorn Sheep winter range, elk winter range and severe winter range, mule deer winter range, black bear summer and fall concentration area and cutthroat trout habitat. Key breeding area for elk and wild turkey. Very high hunter participation in 2009 for mule deer and black bear.

 

Troublesome North- Elk summer concentration area, moose summer range, priority habitat and concentration area, black bear summer concentration area and cutthroat trout habitat. Migration area for elk, mule deer and moose. Important area for moose reproduction. Lies within the water district of a gold medal fishery. Very high hunter participation in 2009 for moose.

 

Deep Creek/Boot Mountain- Elk summer concentration area, moose winter range, summer range, priority habitat and concentration area, pronghorn antelope and black bear summer and fall concentration area and cutthroat trout habitat. Important area for elk reproduction. Lies within the water district of a gold medal fishery. Very high hunter participation in 2009 for elk.

 

White Pine Mountain- Elk winter range and winter concentration area, mule deer winter range, black bear summer concentration area. This area allows very little motorized use, provides uninterrupted habitat and provides excellent opportunities for backcountry enthusiasts.

 

4.Hermosa- Elk winter range, winter concentration area and summer concentration area, black bear summer concentration area and cutthroat trout habitat. Migration route for elk and mule deer. Key habitat for elk reproduction. Very little motorized use. Lies within the water district of a gold medal fishery. Identified by local sportsmen as a high value area. Very high hunter participation in 2009 for elk and mule deer.

 

Woods Lake- Black bear summer and fall concentration area and cutthroat trout habitat. Migration area for elk and mule deer. Key habitat for elk reproduction. Identified by local sportsmen as a high value area. Very high hunter participation in 2009 for elk and mule deer.

 

Huntsman Ridge- Elk winter range and winter concentration area, moose concentration area and cutthroat trout habitat. Mule deer migration corridor and important habitat for elk breeding activities. Lies within the water district of a gold medal fishery. Identified by local sportsmen as a high value area. Very high hunter participation in 2009 for elk and black bear.

Troublesome South- Elk winter range and summer concentration area, moose winter range, summer range and priority habitat, mule deer winter range, black bear summer concentration. Elk, mule deer and moose migration route. Elk breeding area. Lies within the water district of a gold medal fishery. Very high hunter participation in 2009 for elk, mule deer and moose.

Wason Park- Elk winter range, winter concentration area and winter range, mule deer winter range and severe winter range, Moose winter and summer range and black bear summer and fall concentration. Elk, mule deer and moose migration route. Elk breeding area. Lies within the water district of a gold medal fishery. Very high hunter participation in 2009 for elk, mule deer and moose.


Highline- Crucial habitat for elk winter range, severe winter range and summer concentration area, mule deer concentration area and winter range, bighorn sheep winter range, winter concentration area, summer range and summer concentration area, black bear summer and fall concentration area and cutthroat trout habitat. Used by bighorn sheep as a migration corridor. High hunter participation for mule deer and pronghorn antelope. Very high hunter participation in 2009 for mule deer and pronghorn antelope.

5.     Treasure Mountain- Elk winter range, wild turkey winter range and cutthroat trout habitat. Migration area for elk and mule deer. Key habitat for elk reproduction. Very little motorized use. Identified by local sportsmen as a high value area. Very high hunter parti

Site by Chico Web Design