Basic Background

There are four alternatives, but a preferred alternative was not selected by the agency. Reading between the lines though, Alternative B is effectively the agency's preferred alternative. The alternatives include:

o   Alternative A (also referred to as the current plan in this document) is the no-action alternative, which reflects the 1983 forest plan, as amended to date, and accounts for current laws, regulations, and terms and conditions from biological opinions.

o   Alternative B, which can be broadly described as the “blended” alternative, was released for public feedback as the working draft revised forest plan, and it was subsequently updated in response to public feedback and internal Forest Service review. It proposes a very modest amount of additional wilderness, an active vegetation management program, and a balanced approach to competing uses and values on the national forests.

o   Alternative C can be broadly described as the “active management emphasis” alternative, with fewer special area allocations, more active vegetation and fuels management, less restrictive recreation use management, more motorized settings, and more areas allocated as suitable for timber production.

o   Alternative D can be broadly described as the “special area emphasis” alternative, with more special area allocations, a smaller vegetation and fuels management program, more active and restrictive recreation use management, more non-motorized settings, and fewer areas allocated as suitable for timber production.

Based upon the effects of the alternatives, and public comments on the draft environmental impact statement, the responsible official will select from amongst the action alternatives to blend and modify a final alternative for the draft record of decision.

General Issues to Include in Comments (With Some Specific Plan Component Recommendations)*

More – and Stronger – Plan Components Are Needed

o   The draft forest plan suffers from a lack of plan components – especially standards and guidelines – raising the concern that the proposed plan components are too weak to properly protect resources. Many guidelines need to be standards, and some management approaches need to be guidelines.

Recommend Additional Wilderness Areas

o   Alternative B’s 34,000 acres of recommended wilderness is a small reflection of lands that should be recommended. I support the wilderness area recommendations in Alternative D, and urge that those be included in the final plan.

• (Alternative D recommends 261,000 acres for wilderness. This includes all of areas recommended in Alternative B, plus the addition of all Gunnison County-recommended areas; and areas the GMUG evaluated as “high” (i.e. highly-qualified for wilderness) which are also recommended by a citizen proposal, i.e. Community Conservation Proposal and Outdoor Alliance Vision.)

o   To put this into perspective, the Forest Service in its proposed 2007 GMUG Forest Plan recommended approximately 125,000 acres in 19 areas for additional wilderness. That plan was developed under the Bush II administration. Today's draft plan, released under the Biden administration, recommends 34,000 acres in the preferred, or "blended" alternative. So the Bush II plan had 125,000 acres, and the Biden plan has 34,000 acres….

Recommend the Special Management Areas (SMAs) in Alternative D

o   Alternative B includes no SMA recommendations. I support the 246,000 acres of SMA recommendations in Alternative D.

• (Unique to alternative D, these areas were submitted by multiple citizen proposals and endorsed by the counties of Gunnison, San Miguel, and Ouray. Each SMA is also removed from the area suitable for timber production.)

Support Wildlife Management Areas

o   I strongly support the concept of Wildlife Management Areas (WMAs) in the revised forest plan and ask that those be retained and strengthened with additional plan components. This important management area designation could help protect habitat for a variety of wildlife species.

o   However, in places where Alternative D’s wilderness and SMA recommendations overlap with the WMA-base identified in Alternative B, I support the stronger management prescriptions that Alternative D’s wilderness and SMA areas provide.

o   An additional component for WMAs is needed to ensure retention of security habitat for big game. I recommend a standard or guideline that requires or encourages maintenance of habitat blocks at least 500 acres in size having no roads or other human intrusions in big game habitat in all areas assigned to this management area.

• (This standard or guideline is needed to allow achievement of MA-DC-WLDF-01: “Large blocks of diverse habitat are relatively undisturbed by routes, providing security for the life history, distribution, and movement of many species, including big-game species. …”)

Protect Big Game

o   I support the protections for big game and wildlife habitat that are most pronounced in Alternative D. According to the DEIS, “Alternative D would likely provide the most connectivity benefit due to providing the greatest extent of recommended wilderness, special management areas, and wildlife management area categories ….”.

o   GDL-SPEC-15 and Table 4, establishing restrictions on activities that could disturb big game during their reproductive periods or while on winter range, should be a standard.

Protect At-Risk Species

o   I am concerned that the Forest Service may have misinterpreted direction in the planning rule and planning directives in selecting species of conservation concern (SCC). As such, several imperiled species that likely meet the criteria for being identified as SCC were not designated SCC for planning purposes, such as the American marten, bighorn sheep, northern goshawk, boreal owl, Lewis’s woodpecker, flammulated owl, several species of potentially imperiled bats, ptarmigan, western bumblebee, and bighorn sheep.

o   Bighorn Sheep

• I am particularly concerned that bighorn sheep has been left off the list, given its vulnerability to disease passed from livestock and habitat fragmentation The plan does not provide adequate justification for not designating this and other species as SCC.

• In addition, GDL-SPEC-13, separation of bighorn sheep and domestic sheep, must be a standard. Disease transmission from domestic sheep to bighorns is considered one of the biggest, if not the biggest, threat to continued viability of Colorado’s bighorn sheep herds.

The Draft Plan’s Analysis of Timber Suitability is Unacceptable

o   Every alternative in the draft plan posits a significant increase in suitable timber, which is a designation that interferes with consideration of responsible management of the forests for uses other than timber production. The draft plan’s analysis of timber suitability does not comply with the National Forest Management Act, the Planning Rule, or Forest Service policy. It seems designed to maximize the possibility of future timber harvest, even though the GMUG National Forest is much more valuable for conserving biological diversity and recreation than it ever could be for timber production.

o   Far too much land is found suitable for timber production in all action alternatives.

o   Numerous acres that should be unsuitable for timber production are instead found suitable.

o   Steep slopes should not be found suitable.

o   Lands uneconomical to harvest should not be found suitable.

o   Some critical habitat for Gunnison Sage Grouse is found suitable. This acreage must be removed from the timber-suitable lands.

o   Finding suitable those lands that cannot be harvested economically, or in some cases, that cannot be harvested at all during the life of the revised plan, leads to artificially inflated calculations for sustained yield limit, projected timber sale quantity (PTSQ), and projected wood sale quality (PWSQ). It misleads the timber industry and the public, as well as present and future agency staff, about how much timber can or should be cut on the GMUG. It could lead to lands with trees actually suitable for timber production being overcut to meet an inflated PTSQ or PWSQ that was based in large part on thousands of acres of lands that cannot be harvested during the life of the plan and likely long afterward.

The Plan Must Balance Recreational Growth with Conservation Values

o   I appreciate the GMUG’s commitment to addressing recreation impacts. The standards in the draft plan provide a good starting point for tackling growing recreational impacts and issues. However, there are some areas that need to be strengthened.

o   Recreation Opportunity Spectrum (ROS)

• The GMUG’s explanation of ROS fails to mention that ROS should reflect desired future conditions. This is necessary to ensure that any current recreational uses that do not comply with the desired setting are phased out over a set period of time. An objective should be added that specifies a timeframe for accomplishing this.

• The draft plan defines winter semi-primitive non-motorized by distance from designated routes open to motorized use, but there aren’t any officially designated routes because there is no Over-Snow Vehicle (OSV) plan. As such, this is unduly influencing future decisions.

o   Recreation Plan Components

• Draft forest plan OBJ-REC-06 states: “Within 10 years of plan approval, to reinforce semi-primitive non-motorized settings, eliminate at least two unauthorized motorized travel routes.” If the GMUG is serious about enforcing semi-primitive non-motorized settings, it should close many more than two unauthorized routes in 10 years.

• The plan components for recreation do not address OSVs at all. This omission is problematic and must be addressed in the final plan and EIS. The travel Management Rule requires designations of routes and areas for OSVs.

• Draft forest plan GDL-REC-12 makes the prohibition of motorized use off of designated routes a guideline. This must be a standard.

• Why does GMUG’s analysis of potential impacts from motorized recreation only consider impacts from illegal use? Even legal use has potential, and in some cases considerable, impacts.

o   Recreation Emphasis Corridors

§  While I support the concept of a management area for emphasizing recreation, the Corridors are very focused on dispersed camping. Please identify and include direction for other recreation needs that could be addressed through a management area.

o   Drones

• Drones need to be restricted or prohibited in some areas because they can harass wildlife and interrupt key functions such as reproduction and brood rearing. Also, people recreating do not want to hear the noise of drones or see them. STND-REC-09 would ban flights of “unmanned aircraft systems”, or drones, in five management areas and some other areas. However, it would allow exceptions for special use permits “under certain circumstances”. The latter are not specified or described. We recommend that there be no exceptions to this prohibition in MAs 1.1, 1.2, 2.1, and 4.2 other than for emergency search operations and law enforcement. Drones should also be banned from the following MAs:  2.3, Fossil Ridge Special Management Area; 3.1, Colorado Roadless Areas; 3.2 Wildlife Management Areas; and 3.3, Special Management Areas in alternative D.

o   Alternative D is the best alternative for balancing wildlife and recreation. Statements from the DEIS include:

• “Alternative D would likely provide the most connectivity benefit due to providing the greatest extent of recommended wilderness, special management areas, and wildlife management area categories ….”

• “The recreational structure of alternative D would be the most protective of wildlife because it would include less motorized use and less developed use than any other alternative. This would likely equate to less harassment of wildlife, less accidental wildfire ignition, and less human-wildlife conflict associated with animals becoming accustomed to human food.”

• “Alternative D may result in the greatest economic benefit related to wildlife-related recreation because it proposes the greatest amount of wildlife management areas, recommended wilderness, and special management areas, which would likely benefit wildlife, fishing, and hunting recreation opportunities and associated spending in the local economy. However, it would also result in more restrictions on future trail development, with fewer opportunities potentially resulting in less trail-based recreation spending.”

• “Outdoor recreation, especially fishing and hunting, was identified as a key ecosystem service. Alternative D provides the greatest acreage of wildlife management areas, recommended wilderness, and special management areas combined to support the wildlife for these recreation activities. This could result in greater visitor spending for hunting and fishing, which would contribute to social and economic sustainability.”

• “Alternative D is the most restrictive management option for recreation. Non-motorized, wildlife-dependent activities would be enhanced under alternative D.”

• “Finally, in alternative D most of the GMUG would be managed as non-motorized, preserving a large amount of habitat.”

The Plan Must Protect Watersheds

o   Protection of watersheds and water resources must be prioritized in this forest plan. The GMUG only identifies one priority watershed in the draft forest plan. Given the extent of water-related uses and the importance of the GMUG as a headwaters water supplier for the Colorado River, additional watersheds should be examined for inclusion as priority watersheds. 

o   Riparian management zones (RMZ), STND-RMGH-07, needs to be strengthened. The minimum width should include wetlands less than one-quarter acre. It is likely that a considerable portion of the wetlands on the GMUG are smaller than one quarter acre, even within the 100-foot minimum RMZ.

o   The management approach for incorporating the Watershed Conservation Practices Handbook and National Core Best Management Practices should be rewritten as a standard to require application of the provisions of these documents, or the best available science, to all projects and activities. That would ensure that these practices, which are already agency direction, or more recent best science, will be applied at the project level to protect watersheds.

o   The GMUG should include specific plan components to reduce road density, and should limit road density in Riparian Management Zones.

Retain – and Add – Wild & Scenic-Eligible Segments to the Plan

o   I support eligibility findings for all the stream segments included in the draft revised forest plan. At the same time, there are several streams that were previously found eligible but have been left out of the revised draft forest plan, and those should be included. These are: Taylor River, Slate River, Daisy Creek (Poverty Gulch), Escalante Creek, Bear Creek, Bridal Veil Creek, and Ingram Falls.

o   A number of streams not previously studied for Wild & Scenic eligibility are free-flowing and possess at least one outstandingly remarkable value. I specifically recommend that the following additional streams and stream segments be evaluated for Wild & Scenic eligibility and determined eligible: Monitor Creek, Potter Creek, Cottonwood Creek, Beaver Creek, Horsefly Creek, Upper Brush Creek and West Brush Creek tributary, Cement Creek, Curecanti Creek, Coal Creek, Lamphier Lake, Big Blue Creek and Slide Lake, North Clear Creek, and Dry Fork of the Escalante.

Additional Thoughts and How to Comment

Conservation groups are not alone in having these concerns. Gunnison, Ouray, San Miguel, and Hinsdale Counties have already united to submit a letter to the GMUG stating that “at this time we cannot support the pre-Draft plan and Preferred Alternative B as presented.” That letter includes the following statements:

o   “We strongly oppose the substantial increase of suitable timber proposed in this pre-Draft Plan.”

o   “The Preferred Alternative must include the Wilderness and the Special Management Area designations included in the [CORE Act].”

o   “The Gunnison Public Lands Initiative (GPLI) is also a result of lengthy collaboration, negotiation and compromise and the designations and land use proposed in the GPLI must be included in the Preferred Alternative.”

How to Comment

o   Please submit a comment by November 12 to the Forest Service sharing these – and any other – recommendations that you might have. Commenting is not voting – you can submit as many comments on as many issues as you’d like, as long as they are substantive. Submit your comments at US Forest Service NEPA Projects Home (ecosystem-management.org). 

o   Personalize your comments. Even if you are just an occasional user of the GMUG, describe your uses and say why you want to see the national forest managed primarily for wildlife, watershed protection, sustainable recreation, etc.