January 28, 2017

Re: BLM Little Snake Field Office Travel Management Area 2 Scoping Comments

Attn: Outdoor Recreation Planner
Bureau of Land Management
Little Snake Field Office
455 Emerson Street
Craig, CO 81625

Dear Sir/Ma’am:

Below you will find comments from the Colorado chapter of Backcountry Hunters & Anglers (COBHA), a non-profit 501(c)(3) group of sportsmen and women who share the common goal of preserving traditional hunting and angling activities and conserving our wild public lands, waters and wildlife. Our mission is to ensure America’s outdoor heritage of hunting and fishing in a natural setting through education and work on behalf of wild public lands and waters. We appreciate this opportunity to provide scoping comments on the BLM Little Snake Field Office’s Travel Management Area 2 planning process.

The TMA 2 planning area encompasses significant critical habitat (including the majority of winter range) for the largest mule deer herd, largest pronghorn herd, and second largest elk herd in all of Colorado. This area also provides the core habitat for the largest greater sage-grouse population in Colorado, as well as numerous other species of wildlife. These wildlife populations are a public resource and represent resources of regional and state-wide significance. Hunting and angling support a $3 billion per year industry in Colorado and rural communities in northwest Colorado depend on the annual economic benefit provided by hunters and anglers that come here to enjoy the area’s world-class wildlife-related recreational opportunities.

COBHA understands the importance of providing motorized access for a variety of authorized uses on public lands, including recreation, energy development, and livestock grazing. However, management of motorized recreational opportunities needs to be done in a manner that provides meaningful protection for fish and wildlife habitat, as well as leaving some areas undeveloped altogether to provide wildlife with core/undisturbed habitat and people with undisturbed areas to recreate. COBHA strongly believes in science-based decision making and the science on this subject is clear: roads and motorized vehicle use affect wildlife and wildlife habitat negatively in a variety of ways. Numerous published studies have shown that wildlife, particularly big game species, tend to avoid roads and areas with high road density. In addition, BLM’s multiple use mandate should accommodate primitive (non-motorized) recreational opportunities, including non-motorized hunting opportunities. There is a strong and growing community of sportsmen and women that BHA represents that seek quiet, non-motorized hunting and angling experiences on the vast public lands found in Colorado. It is these guiding principles that underlay our specific comments (below) that COBHA requests be implemented in order to conserve wildlife habitat as well as protect opportunities for primitive, non-motorized hunting, angling and recreational opportunities on public lands within the LSFO TMA2.

Routes in General
• There are numerous locations within TMA2 that have parallel or redundant routes. We request that BLM identify these parallel or redundant routes and close those that are not needed in the public transportation system.
• There are numerous dead-end spur roads/routes found throughout TMA2 that are likely less preferred by OHV recreationists than loop routes. These numerous spurs represent an opportunity to selectively close routes that likely represent little value to the public while effectively reducing overall road densities and increasing the number of patches across the landscape that are free of roads and which can offer habitat security to wildlife.
• We recommend that BLM consult with Colorado Parks and Wildlife to identify those big game winter ranges within TMA2 with the highest value to mule deer, elk, and pronghorn and implement seasonal closures (closed to all motorized use) in areas with the highest density of wintering big game. In particular, CPW data indicate that the following areas are disproportionately important to wintering elk herds (they include an overlap of winter concentration areas and severe winter range designations) and warrant seasonal closures to provide refugia and reduce stress from human intrusion during the critical winter period from January to April:

1) The east side of Sevenmile Ridge
2) The Bald Mountain, Godiva Rim, Shaffers Draw, and Red Wash Butte area
3) BLM lands north of the Maybell State Trust Land on either side of Moffat County Road 19

In addition to these three areas for elk, CPW data indicate that the following area is disproportionately important to wintering mule deer herds (they include an overlap of winter concentration areas and severe winter range designations) and also warrants seasonal closure to protect mule deer:

1) The Dry Gulch and Thournburgh Gulch areas west of Moffat County Road 9 and south of County Road 4

• We request that all off-route travel be restricted in TMA2. Off-route travel can quickly damage habitat in this high desert environment and take years or decades to rehabilitate. Allowing off-route travel can also tempt shed antler hunters to chase big game animals in the late winter/early spring period causing unnecessary stress and displacement from preferred habitat.
• Craig is the “Elk Hunting Capital of the World” and prides itself on drawing elk hunters from near and far to pursue these herds while boosting economic activity. However, to secure the long-term viability of these herds they need quality, intact, functional winter range. Lack of habitat security can negatively impact elk survival and productivity. While many studies have assessed the impacts of roads on elk in forested environments, one recent study on BLM-managed lands in the high desert of southwestern Wyoming reported on elk use in relation to roads that is highly relevant to the current LSFO planning effort for TMA2. This study (Sawyer et al. 2007, Journal of Wildlife Management 71:868-874) found that even in an area with relatively low road density, elk still strongly selected areas away from roads during the summer and winter. In summer the most highly-selected areas were approximately 2.8 km from a road while in winter the most highly-selected areas were approximately 1.2 km from a road. Based on our preliminary analysis of route occurrence in TMA2, there is only one patch of BLM-managed land (just south of South Nipple Rim STL) of significant size (greater than about 400 acres) that is >1.2km from an existing road (BLM or County). BLM has the opportunity with this travel management effort to create additional high-quality and secure patches of elk winter range by managing road networks using the best available science – particularly within the three areas identified above as being of great importance to wintering elk.

Lands with Wilderness Characteristics Polygons
• BLM has identified 15 parcels that meet criteria for Lands with Wilderness Characteristics within TMA2. As alternatives are developed for this Travel Management Plan, COBHA would like BLM to consider management of the following LWC potential areas that emphasizes protection of wilderness characteristics as a priority over other multiple uses. We have identified these areas because they provide the highest degree of manageability and also currently offer opportunities for primitive recreation and solitude:

21: Reservoir Draw
22: Spence Gulch
23: Upper Little Snake
29: West Sevenmile
30: Sevenmile Draw
31: Lower Little Snake
33: Deep Canyon

Collectively, these seven areas total approximately 54,000 acres and represent
about 15% of the total acres administered by BLM in TMA2. We believe this
represents a minimal level of commitment to managing for wilderness
characteristics in this area. Management of these seven areas should emphasize
reduced road densities and provide an opportunity for foot and horseback travel in
the absence of motorized uses.
• COBHA believes that new discretionary routes should not be created in any areas that currently meet criteria for LWC and that routes created for specific management purposes (e.g. oil and gas routes) be reclaimed once their purpose has been fulfilled.

COBHA again appreciates the opportunity to provide scoping comments on BLM’s planning effort for TMA2. This area is important to many species of wildlife with populations of statewide and national significance. We encourage BLM to develop travel management strategies that account for this amazing wildlife resource and we look forward to continued involvement in planning for this area.

We also know that your jobs are difficult and you are faced with both overly limited resources and a broad array of oftentimes competing (political or otherwise) interests, and we thank you for your tireless public service and know that you will do your best to protect the wildlands and wildlife that are dependent on great public lands estate.

Sincerely,

David A. Lien
Chairman, Colorado
Backcountry Hunters & Anglers