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Lands with Wilderness Characteristics: Sand Gulch, Falls …€¦ · Lands with Wilderness...

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Lands with Wilderness Characteristics: Sand Gulch, Falls Gulch Mountain Sand Gulch, Falls Gulch Mountain, Royal Gorge Field Office Photo: James Howe The intent of this report is to present objective data to illustrate that the area in question qualifies as Lands with Wilderness Characteristics (LWC), in accordance with Bureau of Land Management (BLM) Manuals 6310 and 6320. The information presented in this report meets the minimum standards for review of new information per Manual 6310, and accordingly BLM must review this information and make its findings and documentation of the review process available to the public as soon as practicable.
Transcript

Lands with Wilderness Characteristics:

Sand Gulch, Falls Gulch Mountain

Sand Gulch, Falls Gulch Mountain, Royal Gorge Field Office Photo: James Howe

The intent of this report is to present objective data to illustrate that the area in question qualifies as Lands with Wilderness Characteristics (LWC), in accordance with Bureau of Land Management (BLM) Manuals 6310 and 6320. The information presented in this report meets the minimum standards for review of new information per Manual 6310, and accordingly BLM must review this information and make its findings and documentation of the review process available to the public as soon as practicable.

Lands with Wilderness Characteristics: Sand Gulch, Falls Gulch Mountain

BLM Royal Gorge Field Office, Front Range District BLM Unit Identifier: CO-020-056 (North of Cotopaxi)

Submitted by:

Wild Connections 2168 Pheasant Place, Colorado Springs, CO 80909

[email protected]; (719) 686 - 5905

Prepared by:

John Sztukowski, Wildlands Inventory Coordinator, Wild Connections [email protected]; (817) 939 – 4239

James Howe, 2013 Summer Mapping Intern, Wild Connections

Report Date:

March 2015

Table of Contents

Map of Sand Gulch, Falls Gulch Mountain LWC .............................................................. 3

Overview ...................................................................................................................................... 4

Discussion of Wilderness Characteristics including Boundary Delineations ..... 6 I. The Sand Gulch, Falls Gulch Mountain proposed LWC meets the minimum size criteria for roadless lands. ............................................................................................................... 6 II. The Sand Gulch, Falls Gulch Mountain proposed LWC is primarily affected by the forces of nature. ................................................................................................................................ 11 III. The Sand Gulch, Falls Gulch Mountain proposed LWC provides outstanding opportunities for solitude and primitive recreation. ............................................................ 12 IV. The Sand Gulch, Falls Gulch Mountain proposed LWC has supplemental values that would enhance the wilderness experience and should be recognized and protected. ............................................................................................................................................ 13

Summary Conclusion ............................................................................................................ 15

Sand Gulch, Falls Gulch Mountain Proposed LWC Waypoints ............................... 17

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Map of Sand Gulch, Falls Gulch Mountain LWC

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Overview

The Sand Gulch, Falls Gulch Mountain proposed Lands with Wilderness Characteristics (LWC) unit totals approximately 17,600 contiguous acres in central Colorado. This highly diverse area parallels the iconic Arkansas River in Bighorn Sheep Canyon, and extends northward encompassing rugged canyon lands, dense gulches, thick woodlands, and high-elevation mixed forests.

The Sand Gulch, Falls Gulch Mountain proposed LWC area lies in the heart of the Bighorn Sheep Canyon in the Arkansas Canyonlands, about 12 miles east of Salida, CO. The proposed area’s southern and southwestern boundaries are primarily comprised of private property and the Union Pacific Railroad, which parallels the Arkansas River and US Highway 50, from east of Howard, CO to Cotopaxi, CO. Just east of Howard, Sand Road and then Sand Gulch Road head roughly northeast, representing the western and northern boundaries. Much of the eastern boundary is bordered by private land north of Cotopaxi.

This unit supports a wide variety of plant and wildlife habitats. The proposed LWC offers rich riparian gulches in the lower elevations teamed with rugged rock formations, mid-elevation woodlands, and high-elevation mixed forests and montane grasslands as elevation exceeds 10,000 ft in the northern portion of this unit.

The proposed LWC possesses extraordinary biological values. The Colorado Natural Heritage Program (CNHP) recognizes three Potential Conservation Areas (PCA), for high to very high biodiversity significance, that are partially contained in the proposed LWC. Sand Gulch is one of the PCAs, distinguished for containing global riparian natural communities. The southeast portion of the unit is recognized for very high biodiversity significance for the excellent occurrence of the globally imperiled species, the Arkansas Canyon Stickleaf (Nuttallia densa), endemic only to this region of Colorado.

The Conservation Science Partners (CSP) recognizes over half of the unit, 9,105 acres, as a core area possessing conservation values: important ecologically based indicators of high biodiversity, resilience to climate change, and landscape connectivity, one of only six areas identified in the RGFO region. This core area is completely contained in the proposed LWC, encompassing the northern and central portions. High habitat and range values for a number of wildlife species can be found in the Sand Gulch, Falls Gulch Mountain proposed LWC, including black bear, elk, deer, pronghorn, Rocky Mountain big horn sheep, and mountain lion. Valued bird species are abundant in the proposed LWC, including wild turkey, great blue heron, osprey, and the Colorado BLM sensitive species bald eagle. Opportunities for solitude and primitive recreation are abundant in the 17,600 acre contiguous roadless area that forms the proposed Sand Gulch, Falls Gulch Mountain LWC. The many gulches surrounded by steep ridges, dense vegetation, and mid-elevation forests provide extensive opportunity for solitude in the forms of isolation, remoteness, and vegetative screening. Primitive recreation is also available in all seasons, including hunting, backpacking, hiking, wildlife viewing,

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and photography. Additionally, with the proximity of the Arkansas River to this unit, it provides a scenic natural viewscape for gold medal fly-fishing and world-class white water rafting.

In 2013 the BLM inventoried this area (delineated by the yellow line in the above map), consisting of 17,460.2 acres and identified as COF-020-056 (North of Cotopaxi). The boundaries identified by the BLM generally align with Wild Connections inventory for this unit. However the BLM asserts that this unit does not possess wilderness characteristics because the area does not appear natural due to man-made features. Cited in the BLM’s report are an open pit mine, prospecting pits, smaller mines and associated routes in the south-central unit, other evidence of mining activity such as mining pits, tailings, and access routes throughout the unit, vegetation treatment projects including prescribed burns, mechanical treatments, and hand thinning projects, and rangeland management improvement projects (p 2-3).

This unit does have two open pit mines with an access road in the south-central unit, however based on Wild Connections’ inventory of the area, the road and mines can be excluded from the proposed LWC without affecting the natural integrity or the apparent naturalness of the unit overall (BLM Manual 6310, p 6-7). The BLM reported that this unit’s topography is “rugged, mountainous, with many rock outcroppings.” Wild Connections’ extensive on-the-ground and aerial inventory confirms BLM’s topography assessment, which supports our conclusion that isolated man-made features do not affect the overall naturalness of the 17,600 acre proposed LWC as viewed by the average visitor.

The area has a rich mining history and some old mining activity and a former homestead were observed within the unit, however nothing egregious was observed to conflict with the overall naturalness of the proposed LWC. Similarly, fire mitigation with marked signs were observed in the northern portion of the unit, however these “human-made features,” are substantially unnoticeable and thus do not hinder wilderness characteristics (BLM Manual 6310, p 6). Furthermore, the BLM’s report for unit COF-020-056 does not provide photographic or geo-data to support the claims for this unit not possessing naturalness characteristics. The BLM did not inventory for wilderness characteristics beyond naturalness.

BLM's Manual 6310 states that the boundary delineation for a LWC unit "is generally based on the presence of Wilderness Inventory Roads" but can also be based on property lines between different types of land ownership or on developed rights of way (Manual 6310, p 4). Only after the true boundaries of the contiguous roadless unit are identified can an objective and thorough assessment of that unit's wilderness characteristics be made. In the spring of 2013, Wild Connections did a preliminary boundary delineation for this unit based on the size and contiguity requirements stated in Manual 6310 (p 6). During the following months in the summer and fall of 2013, Wild Connections' mapping teams visited the unit several times to conduct in-depth, on-the-ground (and aerial) inventories of this unit. Our goal was to assess this area for wilderness characteristics, based on BLM's Manual 6310, and report our findings to the BLM's Royal Gorge Field Office in efforts to identify potential wilderness areas to expand "wildlands" corridors in central Colorado. Additionally we have reviewed the 2013 BLM RGFO inventory and boundaries and have made assessments and adjustments based on our in-depth field inventories.

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Wild Connections’ report offers new in-depth data and information, including photo, narrative, and geo-referenced data, supporting the Sand Gulch, Falls Gulch Mountain proposed LWC. The boundary delineations and narratives describing the wilderness characteristics found within this unit are detailed below. Waypoints (with photos) are referenced throughout this report; the photos with geo-data, time and date stamp, description, and page number can be found at the end of the report, akin to the one shown below.

Sand Gulch, Falls Gulch Mountain (8) - S

Aerial view of unit interior near the N boundary (p. 8)

Discussion of Wilderness Characteristics including Boundary Delineations

I. The Sand Gulch, Falls Gulch Mountain proposed LWC meets the minimum size criteria for roadless lands.

The Sand Gulch, Falls Gulch Mountain proposed LWC encompasses a unit of approximately 17,600 contiguous roadless acres, well surpassing the minimum size criteria of 5,000 acres to qualify for wilderness, as specified in BLM Manual 6310 (p 6). The manual states that a "way" maintained solely by the passage of vehicles does not constitute a "road" for purposes of inventorying wilderness characteristics. A "way" that is used on a continuous and regular basis still does not constitute a road. Additionally, a vehicle route that was constructed by mechanical means, but is no longer being maintained by mechanical methods is also not a road. By comparison, a Wilderness

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Inventory Road (WIR) is a vehicle road that has "been improved and maintained by mechanical means to ensure relatively regular and continuous use" (Manual 6310, p 11). Wild Connections' inventory of this area has used the above definitions to determine what are or are not considered WIRs. Routes that did meet the criteria for WIRs were removed from the unit as cherrystems. The Union Pacific Railroad forms or runs parallel to a large portion of the south and southwest boundary of the Sand Gulch, Falls Gulch Mountain proposed LWC, which runs from just east of Howard, CO to Cotopaxi, CO. This is represented in Waypoints 14 to 47, with the railroad serving as the unit boundary between Waypoints 34 and 36, and also a large section in the southern part of the unit between Waypoints 45 to 46. Other portions of these boundaries are bordered by private property just north of the highway along County Road 45. Many of the possible routes into the unit from the south and southwest are gated due to the private property that borders the unit. Examples of these gated routes can be viewed in Waypoints 15, 32, 40, 41, and 43. Waypoint 44, taken at the boundary of the proposed LWC, shows a revegetated former route leading into the unit, which will remain within the unit as a way, leading from the gated access point seen in Waypoint 43. Due to the physical boundary of the Arkansas River, and the natural cliffs above it (as seen in Waypoint 47), public access is rather difficult from the south and southwest. There are a few mining sites near the Sand Gulch, Falls Gulch Mountain proposed wilderness, particularly around the south-central boundary. Waypoint 33 shows a gated entrance for the Fremont County Gravel Pit, which borders the unit to the southwest. Another gated access point near the southwest, Waypoint 16, has signs for “Mine Property” and “No Trespassing.” Unlike the Fremont County Grave Pit, this mining site is within the boundaries of the BLM inventoried unit. This mining road, identified by the BLM as CO-020-056-K, appears to have been constructed by mechanical means and also shows signs of current use. Waypoints 17, 18, 19, 20, 21, capture the condition of the road as it heads northeasterly toward the interior mine site. Waypoint 22 shows the primary mining site that BLM Road CO-020-056-K leads to, with the many construction vehicles and excavating equipment illustrating its current use. This southwest mining road continues a little bit north of the mining sites as seen in Waypoint 23 but ends a short distance at Waypoint 24. Waypoint 25, taken a little bit further north, illustrates that this route no longer appears regular and continuous or maintained, showing heavy revegetation on the former route. At Waypoint 18, referenced above, there is a junction off this southwest mining road with an offshoot route that appears constructed and maintained by mechanical means (Waypoint 30). This leads to a deposit site a short distance south at Waypoint 31. Both of the aforementioned mining roads are considered WIRs and will be excluded from the proposed LWC as cherrystem roads. Both of the mine sites will be excluded from the unit as well so that the natural integrity of the overall proposed LWC is not compromised. Just southeast of this mining road along County Road 45, is another access point into the interior of the proposed LWC into a gulch at Waypoint 26. Although this entrance is not in BLM’s Arkansas River Travel Management Plan (TMP), it does show signs of ATV use, which can be viewed in Waypoint 27. Given that there should be no legal motorized access into this gulch, this is considered a way. Furthermore we recommend that the BLM post this gulch as closed to motorized use at Waypoint 26, where the gulch meets County Road 45.

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The only other route to access the interior of the Sand Gulch, Falls Gulch Mountain proposed LWC from the south is an administrative route, closed to the public, marked at Waypoint 36. This administrative route splits into two different cherrystems at a juncture where two gulches split, however neither administrative route goes more than a mile into the interior (endpoints marked at Waypoints 37 for the northeasterly cherrystem and Waypoint 38 for the cherrystem that travels north). Both of these cherrystems are considered WIRs up to the aforementioned endpoints, and will be removed from the proposed LWC. These routes follow natural gulches and are not visible in the nearby unit, thus they do not impact the overall naturalness of the proposed LWC. The southwest corner of the Sand Gulch, Falls Gulch Mountain proposed LWC consists of a designated ATV trail half-loop, marked by Waypoints 13 to 14, where the trail ends into Sand Road. Sand Road, also designated route BLM Road 5980 in the Arkansas River Travel Management Plan (TMP), represents the proposed LWC boundary from Waypoint 13 to Waypoint 12, and again from Waypoint 11 to Waypoint 9. The Sand Road western boundary can be seen aerially in Waypoint 10, viewed right, along with Sand Gulch itself. This view faces south with Sand Gulch Road paralleling the right side of the frame. At Waypoint 9, Sand Road intersects Sand Gulch Road, with Sand Gulch Road becoming the boundary all the way to the northeast corner of the unit, marked by Waypoint 2. Much elevation is gained as Sand Gulch Road climbs northeast. Access into the interior is difficult along this route as Sand Gulch Road travels up a valley, rendering a backcountry traverse up a steep ridgeline as the only way into the western portion of the unit. An aerial photograph (Waypoint 8) from above Sand Gulch Road shows an excellent view of the rolling forested ridgelines that make up much of the interior of the Sand Gulch, Falls Gulch Mountain proposed LWC. The steep ridgeline along Sand Gulch Road can be seen in the foreground, with the Arkansas River and Sangre de Cristo mountains in the distance. This road is also maintained and shows continuous use, as viewed in Waypoint 7, and is open to all vehicles as per the Arkansas River TMP. At Waypoint 6, there appears to be a fire mitigation site as marked trees have been cut down, deadwood and branches piled, with signs stating “No Firewood Cutting.” Note that the Wild Connections’ proposed LWC extends north of the BLM inventoried area COF-020-056 near Waypoint 7, and again from Waypoint 2 to the vicinity of Waypoint 6.

Sand Gulch, Falls Gulch Mountain (10) - S Aerial view of W boundary, Sand Gulch &

Sand Rd, and western unit interior (p. 8)

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Sand Gulch Road ends into a junction in the northeast corner of the proposed LWC at Waypoint 7. As seen in the photopoint, there is an unlocked gate that allows access east along the boundary. This route turns south along the eastern boundary of the proposed LWC, however access is only possible for approximately one-quarter mile as the road heads southeast away from the unit into a gated area with signs stating “Private Property” and “No Trespassing” (Waypoint 1). The other branch from the junction is BLM Road 5996A, a designated trail open to all vehicles and heads southwest into the interior (Waypoint 3). The Arkansas River TMP shows this route ending at Waypoint 4, however motorized use continues southwest along a ridgeline until the ridge ends at a primitive campsite with an overlook of the Sand Gulch, Falls Gulch Mountain proposed LWC and the Sangre de Cristo mountains in the background (Waypoint 5). BLM 5995A is considered a WIR and will be excluded from the proposed LWC as a cherrystem to Waypoint 4. The eastern boundary of the proposed LWC roughly parallels County Road 12, directly north from Cotopaxi, however the boundary itself is bordered by private land just west of the road. Approximately one and a half miles north of Cotopaxi, there is an access route that heads west to the proposed unit. Waypoint 48, taken at the boundary where this route meets BLM land, shows that this way is not regular or continuous, nor was it constructed or is currently maintained by mechanical means. Nevertheless, this serves as a great access point to explore one of the many untrammeled gulches in the proposed wilderness. The primary access into this unit from the east is a little bit further north at Spruce Basin Dr, approximately 4 miles north of Cotopaxi. The boundary of the proposed unit shifts west at this juncture, with Spruce Basin Dr serving as the boundary road from Waypoint 49 to Waypoint 50, where BLM Road 6126, found in the Arkansas TMP and open to all motorized use, heads south into the unit. About one mile south of Spruce Basin Dr, BLM Road 6126 takes a ninety-degree turn west for a mile and a half until it meets a motorized loop marked at Waypoint 53. The motorized loop heads south then west until it comes to a three-way junction at Waypoint 54. Two cherrystem roads in the Arkansas River TMP head south into the interior of the proposed LWC. BLM Road 6126 C heads east to Falls Gulch Mountain, however vehicle access ends before the summit at Waypoint 55, due to a barricade installed by the BLM. Nevertheless, access to the top of Falls Gulch Mountain (9,042 ft summit) is still attainable as a horse and hiking trail, offering excellent views of the interior wooded wilderness as seen in Waypoint 57 looking southeast and Waypoint 56, viewed right, facing west. The other cherrystem from this three-way

Sand Gulch, Falls Gulch Mountain (56) - W View W of interior and Sangre de Cristo Mountains atop Falls Gulch Mtn (p. 9,15) 9

junction, BLM Road 6126 B, heads south to Waypoint 59. As the motorized loop zigzags north past the aforementioned cherrystems, it comes to another junction at Waypoint 60, where another cherrystem route, BLM Road 6126 A, heads west. This route does not appear to have continuous or regular use, nor to be maintained, as seen in Waypoint 61. However due to its inclusion as a motorized route in the Arkansas River TMP it will be excluded from the proposed wilderness as a WIR. Along this route, the biodiversity of the proposed LWC is exemplified with old growth Douglas fir (Waypoint 63) and cottonwood, aspen, and pine (Waypoint 65). This cherrystem route ends at a campsite, marked and shown in Waypoint 64, just northeast of the Sand Gulch State Trust Land #3 block (Waypoints 66-69) that will be excluded from the proposed LWC. Continuing north on the loop, another junction is encountered at Waypoint 70. Heading east completes the motorized loop BLM 6126 back at Waypoint 53. However for the purposes of the LWC inventory, the route north – Basin Dr – will continue as a boundary road until it meets the BLM boundary line at Waypoint 71. This is of note as the Arkansas River TMP shows that motorized access ceases just before Waypoint 71, however our on-the-ground inventory reveals that this route is regular and continuous as it heads north out of BLM land. This revelation is of great importance as our initial desktop inventory labeled this route as a cherrystem, in accordance with the Arkansas River TMP. Basin Dr being a regular and continuous road to and past the boundary line, along with the other aforementioned TMP routes in this section of the unit, has caused us to exclude the entire Arkansas Mountain area from the proposed LWC. Waypoint 72 shows an aerial view of this section of the unit, with Basin Dr in the forefront of the picture heading south into the proposed LWC. In sum, our boundary delineation matches that of the BLM’s with regard to the Arkansas Mountain area in the northeast section of the unit. There is one more access point from the east into the proposed LWC just northeast of Basin Dr at Ponderosas Circle, conjoined by Overlook Road. However this circle road does not continue into the proposed wilderness, necessitating entrance by foot. Waypoint 73 gives a view from inside the proposed LWC at this entrance with shrubland, cacti, and rabbitbrush in the foreground and a mid-elevation mixed forest just beyond, with the Sangre de Cristo Mountains in the background. Waypoint 74 offers an aerial view from this same location, with an excellent view of the Sangre de Cristo Mountains and Wilderness. The remainder of the eastern boundary heads north, parallel to Spruce Mountain Road, however access to the proposed LWC is not feasible as there is a buffer of private land between Spruce Mountain Road and the eastern boundary of the unit. There are blocks of state land, as well as smaller blocks of private land, within the proposed Sand Gulch, Falls Gulch Mountain LWC that will be excluded from the proposed wilderness area. There is one large block of state land identified within the proposed LWC, Sand Gulch State Land Trust #3, with the corners of this exclusion marked by Waypoints 66-69. Such lands were endowed by the federal government to Colorado in 1876 upon Colorado’s admission to the union. They are considered state trust lands, originally set aside for state schools and public institutions. A Public Access Program lease agreement is in effect between Colorado Parks and Wildlife and Colorado’s State Land Board to allow public access to these lands, particularly those contiguous to BLM, including the Sand Gulch, Falls Gulch Mountain proposed LWC. Note public access may not be

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available year-round as these lands may have lease agreements for activities such as grazing, farming, mining, or logging. There are also a couple of smaller blocks of private land within the proposed LWC that will be excluded, identified on the map by Waypoints 76 and 77, each marking the centroid of a parcel of private land.

II. The Sand Gulch, Falls Gulch Mountain proposed LWC is primarily affected by the forces of nature.

The Sand Gulch, Falls Gulch Mountain proposed LWC is primarily affected by the forces of nature, with human impacts considerably unnoticeable within the unit. Motorized public access to the unit is limited to few public access points, with motorized use within the unit quite restricted. Other routes found within the unit showed a lack of motorized use and an overall apparent lack of regular use, with the forces of nature reclaiming many of the former routes. Human impacts that were observed in the proposed LWC were minor and will be detailed at the end of this section.

The proposed LWC offers a wide range of topographical relief, providing a diversity of vegetation types. Waypoint 75 illustrates this aerially, showing the high-elevation mountains on the left of the frame descend to mid-elevation forested hills with rich riparian gulches that flow all the way down to the Arkansas River. The highest elevation point in this proposed wilderness is Burned Timber Mountain at 10,082 ft. Most of the eastern section in the north is also at high elevation. Waypoint 5 referenced earlier, shows the diversity at this altitude, boasting a high-elevation mixed forest of aspen, ponderosa pine, and lodgepole pine. Unique plant species are also found in this unit, particularly the Arkansas Canyon Stickleaf, which can only be found in this region.

The southern section of this unit represents the lowest elevation in the unit, approximately at 6300 ft where the unit drains to the Arkansas River, separated by the Union Pacific Railroad boundary. Elevation gradually increases with rolling hills of juniper and pinyon pine mixed woodland, as well as shrubland with cacti, yucca, rabbitbrush, and sagebrush throughout, which can be viewed in Waypoint 48.

A healthy mix of new and old growth mid-elevation mixed forests blankets much of the proposed LWC as seen in Waypoints 51 and 58, the latter of which can be viewed to the right. The rolling hills in this unit are carved out by gulches teaming with life. Waypoint 28 shows new growth in an otherwise rocky canyon in the southwest section of this unit, whereas

Sand Gulch, Falls Gulch Mountain (58) - W Mid-elevation mixed-forest with the Sangre de Cristo Mountains in the background (p. 11)

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Waypoint 65 shows a lush mix of cottonwoods, aspen, pine, and spruce at a mid-elevation riparian area.

Much of Wild Connections’ inventory of the Sand Gulch, Falls Gulch Mountain proposed LWC is characterized by untrammeled naturalness, however there were some minor human impacts noted as well. For example, fire mitigation with marked signage were seen in the northern section of the unit, as documented in Waypoint 6. Fencing was observed within the unit (Waypoint 52), as well as the remnants of an old homestead foundation (Waypoint 62), which is now heavily revegetated. However the old homestead is considered historical, adding supplemental value to the proposed LWC. These are examples of “human-made features,” which are considered substantially unnoticeable and thus do not hinder wilderness characteristics (BLM Manual 6310, p 6).

Given the mining history in the area, signs of old and new mine sites are present in and around the proposed LWC. The largest and most noticeable human impacts have been excluded from the unit. As documented earlier, there is an administrative road, closed to the public (Waypoint 16) that services a current operational mine site (Waypoint 22), with an offshoot route to another mine site (Waypoint 31). However, given the localization of this area, the inaccessibility to the public, and Wild Connection’s decision to carve out the associates roads and mine sites out of the proposed wilderness, it does not affect the natural integrity or the apparent naturalness of the unit overall (BLM Manual 6310, p 6-7). Furthermore, the topographic variety and vegetative cover throughout the unit visually obstruct these impacts from being seen by the average visitor to the proposed LWC.

Motorized use in this unit appears to be decreasing, with former routes showing clear signs of revegetation, as referenced in Waypoints 25 and 44. This is supplemented by proactive measures by the BLM to close motorized access to critical areas, for example in Waypoint 55, where motorized traffic is no longer allowed to traverse to the top of Falls Gulch Mountain.

The BLM did not find naturalness characteristics in this unit due to the accumulation of man-made features within the unit that affect the natural character of the unit – namely the mining activity, vegetation treatment projects, and a few rangeland management projects. However the BLM does not provide photo or geo-data in their LWC report to support these claims. The major human impacts – the mining activity – have been removed from the proposed LWC. Furthermore as evidenced in this report, the other human impacts are minor, consistent with impacts okay for naturalness, are spaced out over 17,000 acres, and go largely unnoticed from the ground due the topographic and vegetative screening provided by the proposed LWC. In sum, this unit is primarily affected by the forces of nature, thus qualifying as land with wilderness characteristics.

III. The Sand Gulch, Falls Gulch Mountain proposed LWC provides outstanding opportunities for solitude and primitive recreation.

The Sand Gulch, Falls Gulch Mountain proposed LWC offers ample opportunities for solitude as well as primitive and unconfined recreation. Given the topographic variety, the few entry points and interior trails, and the modest size of the unit, there are vast opportunities for solitude. Much

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of this unit consists of heavily vegetated rolling hills and gulches that screen the visitor from unnatural sights and sounds. Waypoint 11 illustrates this type of terrain in an aerial view. The interior gulches offer easy opportunities for respite and ability to find seclusion without having to venture far into the unit, as demonstrated in Waypoint 29.

Consisting of over 17,000 acres of contiguous unroaded wilderness land, the proposed LWC offers a variety of opportunities for primitive and unconfined recreation. There are outstanding opportunities for hiking, backpacking, camping, hunting, wildlife viewing and photography. In regard to camping, there are primitive campsites with excellent views throughout the unit, with examples at Waypoints 11 and 64, both referenced previously.

Additionally, given the proximity of the Arkansas River in the southern section of this unit, there are outstanding opportunities for world-class fly-fishing and white-water rafting. There are also excellent opportunities for hunting within this unit; high value animal species and habitat are documented in the section below.

IV. The Sand Gulch, Falls Gulch Mountain proposed LWC has supplemental values that would enhance the wilderness experience and should be recognized and protected.

Wild Connections’ inventory of the Sand Gulch, Falls Gulch Mountain proposed LWC identified numerous supplemental values that contribute to the overall experience of visiting this area and provide additional evidence that this unit has unique qualities that should be recognized and protected. The supplemental values presented below are not intended to be exhaustive, but rather are a summarization of some of the widely known significant values for which basic data was available to complement our on-the-ground inventory.

The Sand Gulch, Falls Gulch Mountain proposed LWC offers extraordinary biological values. It partially contains three Potential Conservation Areas (PCA), recognized for high to very high biodiversity areas identified by the Colorado Natural Heritage Program (CHNP). The Sand Gulch region in the northwest, which essentially runs parallel to Sand Gulch Road within the unit, is identified as a high biodiversity area (Sand Gulch at Copper Mountain) for good occurrences of the global riparian natural communities: narrowleaf cottonwood - Douglas-fir (Populus angustifolia - Pseudotsuga menziesii) woodland and narrowleaf cottonwood / river birch (Populus angustifolia / Betula occidentalis) woodland.

The southeastern section of the proposed LWC is part of a greater PCA (Cotopaxi), recognized as having very high biodiversity significance by CNHP. This PCA has an excellent occurrence of the globally imperiled, Colorado endemic species, the Arkansas Canyon stickleaf (Nuttallia densa), which has multiple sub-occurrences.

A third PCA (Falls Gulch), partially contained in the eastern portion of the unit below Falls Gulch Mountain, is identified by CNHP as having high biodiversity significance due to good occurrence of a globally vulnerable riparian shrubland, water birch / mesic graminoids (Betula occidentalis / mesic graminoids) natural community. Additionally, there is an excellent occurrence of an

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apparently globally secure, but state vulnerable wetland natural community, analogue sedge (Carex simulata) herbaceous vegetation.

The Conservation Science Partners (CSP) recently concluded an extensive study on unprotected roadless BLM land in the west that possess important ecologically based indicators of high biodiversity, resilience to climate change, and landscape connectivity. The indicators used included species richness, vegetation community diversity, surface water availability, topographic complexity, landscape naturalness, landscape permeability, and eco-regional protection. CSP’s approach is aimed at quantifying conservation value of BLM lands. CSP’s computations recognize the central and northern portions of the unit – including Falls Gulch Mountain and Burned Timber Mountain – consisting of 9,105 roadless contiguous acres, to be a core area possessing these conservation values, one of only six areas identified in the entire RGFO region.

High habitat and range values for many animal species have been identified in the Sand Gulch, Falls Gulch Mountain proposed LWC. Rocky Mountain Wild’s (RMW) Assessment of Biological Impact (ABI) documented habitation and associated values within the unit for the following mammals: mountain lion (Puma concolor) overall range; black bear (Ursus americanus) overall range, summer concentration, and fall concentration; Rocky Mountain bighorn sheep (Ovis canadensis Canadensis) overall range, production area, water source, summer range, winter range, severe winter range, summer concentration, and winter concentration area; mule deer (Odocoileus hemionus) overall range, summer range, winter range, severe winter range and winter concentration area; pronghorn (Antilocapra americana) overall range, winter range and severe winter range; elk (Cervus Canadensis) overall range, winter range, severe winter range, and winter concentration area; and Brazilian free tailed bat (Tadarida brasiliensis) overall range. The Brazilian free tailed bat is a Colorado state ranked critically imperiled species.

A photo of a mule deer near the unit can be viewed in Waypoint 42. This area is also home to numerous reptiles, including a bull snake shown on the right in Waypoint 39, which was spotted by one of our inventory mapping teams.

Many critical and valued bird species have also been identified in the area. Of note, this unit provides winter forage, winter range, winter concentration area, roost sites, and winter roost sites for the bald eagle (Haliaeetus leucocephalus), which is listed as Colorado BLM Sensitive, CWCS Species of Most Concern, and Partnership in Flight Priority Bird. RMW also identifies wild turkey (Meleagris gallopavo) overall range, winter range, and winter concentration area; great blue heron (Ardea Herodias) nesting area; and osprey (Pandion haliaetus) foraging area.

Sand Gulch, Falls Gulch Mountain (39) - NNE Bull Snake near S boundary (p. 14) 14

Scenic views of nearby and distant mountain ranges are abundant in the proposed LWC given the high elevation points in the area, particularly Burned Timber Mountain (10,082 ft) and Falls Gulch Mountain (9042 ft). The Sangre de Cristo Mountains and the Arkansas River can be viewed to the south (Waypoint 74), the Sawatch Mountain Range to the west (Waypoint 56), and the Front Range to the east.

The geology in this area is exceptional. Much of the rock that makes up the Sand Gulch, Falls Gulch Mountain proposed LWC is some of the oldest in Colorado – consisting primarily of granite – from the Early Proterozoic Age. Gneiss from this same age can be found west of the Burned Timber Mountain ridgeline. Limestone and sandstone are present in the Falls Gulch area, with basalt, tuff, conglomerate, and sandstone found in the southwest section of this unit. Sandstone, shale, gravel, and alluvium are found in the very southern section of the proposed LWC, near the Arkansas River. This data was obtained from the United States Geological Survey's (USGS) Mineral Resources on-line spatial data, selected for Colorado's geology.

Summary Conclusion

Based on Wild Connections' on-the-ground and aerial inventory, the proposed Sand Gulch, Falls Gulch Mountain LWC qualifies as Land with Wilderness Characteristics (LWC) according to BLM's Manual 6310. This unit far exceeds the 5,000 contiguous roadless acreage minimum as the proposed LWC offers more than 17,500 contiguous roadless acres. Given the relatively large size of the unit, lack of significant human impacts, and disparate topography, the Sand Gulch, Falls Gulch Mountain proposed LWC offers outstanding wilderness characteristics - including apparent naturalness and outstanding opportunities for solitude and primitive and unconfined recreation. The proposed LWC is also supported by numerous supplemental values. Our extensive on-the-ground inventory, with photo, narrative, and geo-referenced data, of the Sand Gulch, Falls Gulch Mountain proposed LWC supports the claims made in this report, particularly the overall apparent naturalness of the unit. This is in conflict with the BLM’s inventory of unit COF-020-056. The outstanding opportunities for solitude and primitive and unconfined recreation as well as the supplemental values provided in this report should be considered new, as the BLM did not inventory for these characteristics. While much of the proposed LWC consists of untrammeled wilderness, some human impacts were found. As documented in the naturalness section, there are two mine sites in the south-central section of this unit that will be excluded from the proposed wilderness along with the administrative roads that lead to it. This is in concurrence with BLM Manual 6310, as the natural integrity and the apparent naturalness of the proposed LWC in total is not compromised. The BLM made note of additional human impacts within the unit in their 2013 inventory report for unit COF-020-056, however it did not provide photo evidence or geo-data to support it. Furthermore, these impacts were noted as minor or went unnoticed or unobserved in the multiple inventories that Wild Connections conducted in the unit.

15

Wild Connections’ inventory has documented the necessary boundaries as well as the wilderness characteristics within the unit. This overview provides new information, including narrative, photo, and geo data, and supporting maps, documenting that the 17,500 acre Sand Gulch, Falls Gulch Mountain proposed LWC meets wilderness criteria. This area possesses Lands with Wilderness Characteristic status and therefore its wilderness values should be protected and preserved. It is imperative that the BLM recognize and protect these values in their land management decisions, so that these unique and abundant wilderness qualities are sustained.

16

Sand Gulch, Falls Gulch Mountain Proposed LWC Waypoints

The following photographs correspond with the numbered Waypoints on the above Sand Gulch, Falls Gulch Mountain map and may be referred to in the report narrative describing the wilderness characteristics. The direction of view (16 point Cardinal) is indicated in the bolded caption. Below this is a short description of the photo, with the referenced page number(s) in parenthesis. The photos are also watermarked with the direction (degrees and cardinal) in the top right, date and time in the bottom right, elevation in the bottom center, and the latitude and longitude in the bottom left.

Sand Gulch, Falls Gulch Mountain (1) - SSE End of public access, NE boundary road (p. 9)

Sand Gulch, Falls Gulch Mountain (2) - E NE boundary gated access road (p. 8)

17

Sand Gulch, Falls Gulch Mountain (3) - SW Interior cherrystem road, 5996A, at NE boundary (p. 9)

Sand Gulch, Falls Gulch Mountain (6) - E Fire Mitigation along Sand Gulch Rd (p. 8,12)

Sand Gulch, Falls Gulch Mountain (5) - W End cherrystem road 5996A (p. 9,11)

Sand Gulch, Falls Gulch Mountain (7) - NNE

N boundary at Sand Gulch Rd (p. 8,9)

18

Sand Gulch, Falls Gulch Mountain (8) - S

Aerial view of unit interior near N boundary (p. 8)

Sand Gulch, Falls Gulch Mountain (10) - S

Aerial view of W boundary, Sand Gulch & Sand Rd, and western unit interior (p. 8)

Sand Gulch, Falls Gulch Mountain (9) - S

Intersection of Sand Rd & Sand Gulch Rd (p. 8)

Sand Gulch, Falls Gulch Mountain (15) - NE No public access from SW off CR 45 (p. 7)

Sand Gulch, Falls Gulch Mountain (16) - W

Administrative road to SW mine (p. 7,12)

Sand Gulch, Falls Gulch Mountain (18) - N SW Mine road, BLM CO-020-056-K (p. 87)

Sand Gulch, Falls Gulch Mountain (17) - W SW Mine road, looking back at S boundary

(p. 7)

Sand Gulch, Falls Gulch Mountain (19) - SW

SW Mine road, looking back at Sangre de Cristo Mountains (p. 7)

20

Sand Gulch, Falls Gulch Mountain (20) - N SW Mine road, BLM CO-020-056-K (p. 7)

Sand Gulch, Falls Gulch Mountain (22) - SE SW Mine, removed from proposed LWC (p. 7,12)

Sand Gulch, Falls Gulch Mountain (21) - E SW Mine road, mine in distance (p. 7)

Sand Gulch, Falls Gulch Mountain (23) - NW SW Mine road, N of mine (p. 7) 21

Sand Gulch, Falls Gulch Mountain (25) - ENE

SW Mine road ends (p. 7,12)

Sand Gulch, Falls Gulch Mountain (28) - SSW

Gulch continued, with carved out gully (p. 11)

Sand Gulch, Falls Gulch Mountain (27) - NE Gulch with ATV tracks from CR 45 in SE (p. 7)

Sand Gulch, Falls Gulch Mountain (29) - SSW

Alternate view of gulch with carved out gully (p. 13)

22

Sand Gulch, Falls Gulch Mountain (30) - NE SW Mine road offshoot (p. 7)

Sand Gulch, Falls Gulch Mountain (32) - NNW Gated road, no public access to SW unit (p. 7)

Sand Gulch, Falls Gulch Mountain (31) - WNW

SW Mine road offshoot deposit site, excluded from Proposed LWC (p. 7,12)

Sand Gulch, Falls Gulch Mountain (33) - S Fremont County Gravel Pit, no access (p. 7)

23

Sand Gulch, Falls Gulch Mountain (39) - NNE

Bull Snake near S boundary (p. 14)

Sand Gulch, Falls Gulch Mountain (41) - E

No public access, CR 45 S (p. 7)

Sand Gulch, Falls Gulch Mountain (40) - N No public access from CR 45 S (p. 7)

Sand Gulch, Falls Gulch Mountain (42) - NNE

Mule Deer near S boundary (p. 14)

24

Sand Gulch, Falls Gulch Mountain (43) - SE

No trespassing, private access from S (p. 7)

Sand Gulch, Falls Gulch Mountain (47) - WNW Rock formation at SE boundary (p. 7)

Sand Gulch, Falls Gulch Mountain (44) - NE

Revegetated route into interior from gate (p. 7,12)

Sand Gulch, Falls Gulch Mountain (48) - W Revegetated access road from CR 12 E (p. 9,11)

25

Sand Gulch, Falls Gulch Mountain (50) - ESE Intersection of Spruce Basin Dr and BLM Rd

6126, E of Arkansas Mtn (p. 9)

Sand Gulch, Falls Gulch Mountain (52) - SSW

Fencing off BLM Rd 6126, S of Ark Mtn (p. 12)

Sand Gulch, Falls Gulch Mountain (51) - E Mid-elevation mixed forest, SE of Ark Mtn (p. 11)

Sand Gulch, Falls Gulch Mountain (53) - SW BLM Rd 6126 Loop E junction (p. 9,10)

26

Sand Gulch, Falls Gulch Mountain (54) - SW

TMP Loop, second junction (S), BLM Rds 6126 B & 6126 C Cherrystem S (p. 9)

Sand Gulch, Falls Gulch Mountain (56) - W

View W of interior and Sangre de Cristo Mountains atop Falls Gulch Mtn (p. 9,15)

1 1

Sand Gulch, Falls Gulch Mountain (55) - SE End of motorized access BLM Rd 6126 C cherrystem route to Falls Gulch Mountain (p. 9,12)

Sand Gulch, Falls Gulch Mountain (57) - SE

View SE atop Falls Gulch Mtn (p. 9)

27

Sand Gulch, Falls Gulch Mountain (58) - W Mid-elevation mixed-forest with the Sangre de Cristo Mountains in the background (p. 11)

Sand Gulch, Falls Gulch Mountain (61) - SW Cherrystem BLM Rd 6126 A east toward Sand Gulch State Trust Land shows heavy revegetation

(p. 10)

Sand Gulch, Falls Gulch Mountain (60) - S BLM 6126 Loop third junction, BLM Rd 6126 A heading W (p. 10)

Sand Gulch, Falls Gulch Mountain (62) - SE Old homestead off revegetated route (p. 12)

28

Sand Gulch, Falls Gulch Mountain (63) - S

Old growth Douglas Firs in central interior (p. 10)

Sand Gulch, Falls Gulch Mountain (64) - NNW Campsite at end of revegetated route (p. 10,13)

Sand Gulch, Falls Gulch Mountain (70) - SSE

BLM 6126 Loop, fourth junction (N) with Basin Dr heading N (p. 10)

Sand Gulch, Falls Gulch Mountain (65) - WNW Rich riparian area with cottonwood, aspen, and pine (p. 10,12)

29

Sand Gulch, Falls Gulch Mountain (72) - S Aerial view looking S onto Ogden Loop (p. 10)

Sand Gulch, Falls Gulch Mountain (74) - SSW

Aerial view of interior and Sangres (p. 10,15)

Sand Gulch, Falls Gulch Mountain (73) - SSW

E non-motorized access with cacti and rabbitbrush shrubland (p. 10)

Sand Gulch, Falls Gulch Mountain (75) - S

Aerial View of eastern interior (p. 11) 30


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