October 31, 2011
See News for the 10th Circuit decision that reinstated the 2001 Roadless Rule.
CWF's recommendations at this juncture for strengthening the proposed Colorado rule are generally:
We continue to advocate for more upper tier acreage. This is because the preferred alternative does not include much of the most important fish and wildlife habitat. We do support a narrow exception in upper tier areas for on-the-ground restoration projects (such as aspen regeneration) to maintain habitat diversity that benefits wildlife species that require early successional habitat. Note that we recognize any upper tier acreage we recommended in our July 14 comments which is adjacent to communities that are at risk from castastrophic wildfire (Community Protection Zones) should not be upper tier. At the time we submitted comments we did not have access to that particular mapping overlay. We also believe it is appropriate to require that any new oil and gas leasing in upper tier areas contain a "no surface occupancy" provision to safeguard its value to fish and wildlife. CWF continues to be concerned that provisions be crafted more carefully to protect native cutthroat trout. The preferred alternative uses the language "over the long term." Unfortunately, this term could allow shorter-term duration impacts leading to loss of small distinct cutthroat populations. We also continue to stress the importance of designating the 10,800-acre Currant Creek area as an upper tier area and excluding it from the North Fork coal mining exception. This area provides high value elk winter and summer range, elk and mule deer migration corridors, key breeding habitat for elk and wild turkey, and prime bear habitat.