Lands with Wilderness Characteristics: Sangre de Cristo Foothills Contiguous Units

Transcription

1 Lands with Wilderness Characteristics: Sangre de Cristo Foothills Contiguous Units Sangre de Cristo Foothills Contiguous Units, Royal Gorge Field Office Photo: John Sztukowski 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 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.

2 Lands with Wilderness Characteristics: Sangre de Cristo Foothills Contiguous Units BLM Royal Gorge Field Office, Front Range District BLM Unit Identifiers: COF (Pole Gulch), COF (Kerr Gulch), COF (Bear Creek), COF (East Kerr Gulch), COF (South Howard), COF (Cottonwood Creek), +5 Contiguous Units Not Inventoried by the BLM Submitted by: Wild Connections 2168 Pheasant Place, Colorado Springs, CO (719) Prepared by: John Sztukowski, Wildlands Inventory Coordinator, Wild Connections (817) Report Date: March 2015 Table of Contents Map of Sangre de Cristo Foothills Contiguous Units... 3 Overview... 4 Discussion of Wilderness Characteristics including Boundary Delineations... 9 I. The Sangre de Cristo Foothills Contiguous Units proposed LWC meets the minimum size criteria for roadless lands II. The Sangre de Cristo Foothills Contiguous Units proposed LWC is primarily affected by the forces of nature IV. The Sangre de Cristo Foothills Contiguous Units proposed LWC has supplemental values that would enhance the wilderness experience and should be recognized and protected Summary Conclusion Sangre de Cristo Foothills Contiguous Units Proposed LWC Waypoints

3 Map of Sangre de Cristo Foothills Contiguous Units 3

4 Overview The Sangre de Cristo Foothills Contiguous Units proposed Lands with Wilderness Characteristics (LWC) is comprised of BLM lands contiguous with United States Forest Service (USFS) Roadless Recommended Wilderness, contiguous to USFS Sangre de Cristo Wilderness of the San Isabel National Forest. The proposed LWC is made up of 11 units that comprise approximately 8,700 acres. The proposed LWC units are all located to the east of the northern Sangre de Cristo Mountains, and south of US Highway 50 and the Arkansas River between Salida, CO and Cotopaxi, CO. All of the units are located in Fremont County with one unit straddling the county border with Chaffee County. The Sangre de Cristo Foothills Contiguous Units support a diversity of vegetation, particularly given the topographic variety. The lower elevation areas primarily consist of pinyon-juniper woodlands and Gambel oak scrublands. Other conifers including ponderosa pine, Douglas fir, white fir, and Colorado blue spruce and quaking aspen mix into the vegetation at higher elevations. Montane grassland meadows are also located in the higher elevation areas. Natural drainages creeks, tributaries, and gulches are quite common in these units, encompassing rich riparian life. The proposed units also offer extraordinary biological values. The Colorado Natural Heritage Program (CNHP) recognizes seven Potential Conservation Areas (PCA) that encompass or overlap with eight of the units. These PCAs were identified for biodiversity significant values, which will be covered in depth in the supplemental values section of this report. The Sangre de Cristo Foothills Contiguous Units are largely bordered by private property, where they do not share a boundary with USFS Roadless Recommended Wilderness. Nevertheless, most of the units at least have a section that is somewhat easily accessible to the public. While none of the units meet the size requirement of 5,000 acres, they may qualify for Lands with Wilderness Characteristics (LWC) protection as they are contiguous with lands which have been formally determined to have wilderness or potential wilderness values, or any Federal lands managed for the protection of wilderness characteristics (BLM Manual 6310, p 5). All 11 of the proposed units are contiguous with USFS San Isabel National Forest Sangre de Cristo Roadless Recommended Wilderness. The BLM inventoried six of these units contiguous to the Sangre de Cristo Roadless Recommended Wilderness as part of their overall LWC inventory for the region. Much of the BLM s assessment of the LWC boundaries for these six units appears to be largely accurate, however the BLM did not find LWCs on any of the six units that they inventoried five due to human impacts impeding naturalness and one due to a lack of opportunity to find solitude or recreation. A brief overview of these units follows. COF (Bear Creek) is the northernmost and westernmost of the BLM inventoried units. It comprises acres. The BLM did not find wilderness characteristics because outstanding opportunities for solitude do not exist, citing the parking lot within the unit is a popular recreation site to access forest service land. It is regularly used and is likely to encounter other people at the parking lot or Columbine trail. The BLM report adds, The limited recreation opportunities and 4

5 confined recreation to trails and designated parking lot affect the opportunities for primitive recreation (p. 3). The BLM s assessment of a lack of outstanding opportunity for solitude or primitive and unconfined recreation does not align with BLM Manual The BLM referenced parking lot and through route (County Road 49) are located at the very southeast corner of the Bear Creek unit and have been removed from the proposed LWC unit. The popular Columbine hiking trail straddles the southern boundary of the unit with contiguous USFS Recommended Wilderness. These more frequently used areas of the unit constitute a small portion of the overall 278 acre unit, therefore still allowing outstanding opportunity for solitude in the remainder of the Bear Creek unit, as demonstrated in this report. This is in agreement with BLM Manual 6310, which states, Do not disqualify an area based on a finding that outstanding opportunities exist in only a portion of the area (p. 7). BLM Manual 6310 further states, Determine if the area has outstanding opportunities for solitude or a primitive and unconfined type of recreation. The word or in this sentence means that an area only has to possess one or the other (p. 7). Therefore the unit does not have to possess both types of outstanding opportunities. Nevertheless this unit does possess outstanding opportunity for primitive and unconfined recreation hiking and horseback riding which is validated in BLM s report of the unit referencing the popular Columbine hiking trail. This unit also offers outstanding opportunities for other forms of primitive and unconfined recreation, such as photography and sightseeing. The BLM did not find wilderness characteristics in unit COF (South Howard), a acre unit contiguous to the east of USFS Recommended Wilderness. The BLM found that the impact of man-made features namely old mechanically constructed routes and vegetation treatment projects are noticeable and affect the naturalness to the unit; therefore, the unit does not have wilderness characteristics. However the BLM did not provide photopoints or geo-referenced data to support this assessment. Furthermore, while the BLM shows inventoried routes on their South Howard unit report map (p. 10), the agency did not complete the applicable Route Analysis forms for the inventoried routes. Public access to the South Howard unit is only available via the northern boundary road, Boreen Way. There is only one route that enters the unit from this access road, which is screened by vegetation and dissipates very quickly into the unit. The BLM referenced mechanically constructed routes and vegetation treatment projects were not observed on the ground, and this unit therefore looks natural to the average visitor (BLM Manual, p.7). BLM inventoried unit COF (Kerr Gulch) is located directly south of the South Howard unit. The BLM inventoried acres and did not find wilderness characteristics because the BLM did not find the area to appear natural. The impacts cited were mechanically constructed routes, some of which are currently being used for recreational and administrative use, and past mechanical vegetation treatments. Wild Connections inventory of the Kerr Gulch unit confirms the noticeable human impacts referenced in BLM s report for the area. Therefore Wild Connections has altered the boundaries of the proposed Kerr Gulch unit to remove the routes and vegetation treatment sites, concentrated in 5

6 the very northwestern and southern sections of BLM s inventoried unit. The remaining unit is primarily affected by the forces of nature and includes the Hamilton Creek drainage, which is recommended as a Potential Conservation Area by CNHP. The BLM inventoried unit COF (East Kerr Gulch) is located east-southeast of the Kerr Gulch unit. The BLM inventoried 1,949.4 acres and did not find wilderness characteristics, citing the same man-made impacts (verbatim) as for the Kerr Gulch unit. BLM s vegetation treatments are located in the very southwest section of BLM s inventoried East Kerr Gulch unit, and have been excluded from the proposed LWC unit. There are only two routes that extend into the unit, both of which are behind locked gates, not constructed by mechanical means, and show considerable revegetation, as evidenced in the following report. The altered East Kerr Gulch proposed LWC unit, still comprising approximately 1,850 acres, is primarily affected by the forces of nature. The BLM did not find wilderness characteristics in unit COF (Pole Gulch), 1,600.3 acres inventoried to the southeast of the East Kerr Gulch unit. The BLM cited man-made impacts affecting the naturalness of the unit consisting of mechanically constructed routes (still used for range use, mining activity, and BLM administrative use), two mine sites, and 2010 vegetation treatments. The BLM however did not provide photopoint or geo-referenced data of these man-made impacts in their report for the Pole Gulch unit. These impacts are not viewable to the average visitor as the BLM inventoried routes are only accessible through private property. This lack of public access also limited Wild Connections inventory of the unit. The only public access is located a short distance along the Cottonwood Creek drainage to the east, at which point the unit appears natural. Wild Connections deduces that at least portions of the unit contain wilderness characteristics and until the BLM provides the appropriate documentation of where the prominent man-made features are, the entire Pole Gulch unit is proposed for Land with Wilderness Characteristics. The final BLM inventoried unit contiguous to the Sangre de Cristo Recommended Wilderness is COF (Cottonwood Creek), separated from the Pole Gulch unit by Fremont County Road 40 in the Cottonwood Creek drainage. The BLM did not find wilderness characteristics in the acre unit due to man-made impacts that affect the naturalness of the unit closed mechanically constructed routes, evidence of timber harvesting, and evidence of old mining. Similar to the other BLM inventoried units, the BLM did not provide supporting photopoint or geo-referenced data that is specified in BLM Manual The BLM inventoried routes are only accessible via private property. The only public access to the unit is along the Fremont County Road 40 western boundary, which borders the unit for a very short distance, where the unit appears largely natural. Again, Wild Connections deduces that at least portions of this unit contain wilderness characteristics and propose the entire unit as an LWC until the BLM provides the necessary documentation of the manmade impacts so that Wild Connections can alter the boundaries of the proposed unit if necessary. Wild Connections inventoried an additional six units contiguous with USFS Sangre de Cristo Roadless Recommended Wilderness and found wilderness characteristics on five of them. Three of them are located near the BLM inventoried Bear Creek unit, south of the Arkansas River and US Highway 50 between Salida and Wellsville, CO. The Castle Gardens unit is the northernmost and westernmost of the Sangre de Cristo Foothills Contiguous Units proposed LWC, northwest of the BLM s inventoried Bear Creek unit. The Castle 6

7 Gardens unit consists of 713 acres and is the only unit that extends into Chaffee County. The Box Canyon unit, comprising 1,449 acres, is located east of the Bear Creek and Castle Gardens units. The Taylor Gulch unit is located south of the Box Canyon unit, comprising 1,109 acres. The remaining two units that comprise the Sangre de Cristo Foothills Contiguous Units proposed LWC, in which the BLM did not inventory, are located to the southeast of the BLM inventoried Cottonwood Creek unit. These two proposed units, Palmer Gulch unit and Mosher Creek unit, are separated by a private access boundary road. They make up 71 acres and 225 acres respectively. Due to the lack of public access, Wild Connections was not able to conduct complete on-the-ground inventories of these units. Nevertheless, these units are contiguous with USFS Recommended Wilderness and the lack of public access does not disqualify these units from being Lands with Wilderness Characteristics. Wild Connections inventoried one other unit contiguous with the Sangre de Cristo Roadless Recommended Wilderness. The Cottonwood Creek East unit, consisting of 496 acres, is located to the east of the BLM inventoried Pole Gulch and Cottonwood Creek units. Wild Connections did not find LWCs on this unit due to man-made impacts that affect the overall naturalness character of the unit. The unit has numerous mechanically constructed routes that have served vegetation treatment projects and mining and prospecting activity. The mining activity represents noticeable human impacts to the unit. Therefore this unit has been withdrawn from the Sangre de Cristo Contiguous Units proposed LWC. The Sangre de Cristo Foothills Contiguous Units support high habitat and range values for many wildlife species, as they share a large connectivity corridor with the greater Sangre de Cristo Wilderness and Roadless Recommended Wilderness. Such species include Canadian lynx, black bear, elk, mule deer, black bear, mountain lion, Gunnison s prairie-dog, and wild turkey. Opportunities for solitude and primitive recreation are abundant in the 8,700 acre contiguous roadless units that form the proposed Sangre de Cristo Foothills Contiguous Units LWC. The steep rocky terrain, mid-elevation and high-elevation mixed forests, and natural drainages provide extensive opportunity for solitude in the forms of isolation, remoteness, lack of visitation, and vegetative and topographic screening. Similar to the contiguous USFS Recommended Wilderness, primitive recreation also abounds in all seasons, including hunting, backpacking, hiking, wildlife viewing, bird watching, photography, and snowshoeing. 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). These were the parameters Wild Connections used to define the boundaries of the Sangre de Cristo Foothills Contiguous Units proposed LWC. 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 produced a preliminary boundary delineation for this unit based on the size and contiguity requirements stated in Manual 6310 (p 6). In 2014, Wild Connections' mapping teams visited the Sangre de Cristo Foothills Contiguous Units proposed LWC several times to conduct in-depth, on-the-ground inventories of these units. Our goal was to assess 7

8 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. Note, Wild Connections will use the same unit names as the BLM inventoried units for clarity and transparency in this report. Wild Connections report offers new in-depth data and information, including photo, narrative, and geo-referenced data, supporting the Sangre de Cristo Foothills Contiguous Units proposed LWC. The boundary delineations and narratives describing the wilderness characteristics found within these units are detailed below. Waypoints (many 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. Sangre Foothills (19) - SW Sangre de Cristo Mountains over Bear Creek unit and contiguous USFS Recommended Wilderness (p. 16,23) 8

9 Discussion of Wilderness Characteristics including Boundary Delineations I. The Sangre de Cristo Foothills Contiguous Units proposed LWC meets the minimum size criteria for roadless lands. The Sangre de Cristo Foothills Contiguous Units proposed LWC comprises approximately 8,700 roadless acres contiguous with the USFS Sangre de Cristo Recommended Wilderness. While none of these lands meet the minimum size criteria of 5,000 acres for a potential LWC, all of the units meet the size requirements for wilderness characteristics as they are contiguous with lands which have been formally determined to have wilderness or wilderness potential values, or any Federal lands managed for the protection of wilderness characteristics (BLM s Manual 6310, p 5). USFS Sangre de Cristo Roadless Recommended Wilderness meets these qualifications and shares a common boundary with all 11 contiguous units. With regard to route determination, BLM s Manual 6310 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 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 these units assesses routes that are or are not considered WIRs based on the above definitions from Manual Routes that did meet the criteria for WIRs were removed from the unit as cherrystems. For the Sangre de Cristo Foothills Contiguous Units proposed LWC, the BLM s assessment of the LWC unit boundaries appears to be largely accurate for those units that they did inventory. This report will outline each unit s boundaries, including the non-blm inventoried units, beginning with the northwesterly unit, Castle Gardens. The Castle Gardens proposed LWC unit was not inventoried by the BLM. However this unit meets BLM s size requirements as it wraps around USFS Recommended Wilderness, which borders it to the south and west. The northern boundary of the unit is composed of BLM designated motorized routes BLM 5672, T5670B, 5670, and 5670A and a transmission line. The remainder of the unit, the eastern boundary, is bordered by private property. The BLM routes that border the northern portion of the unit likely serve as administrative routes to access the transmission lines that they parallel, however they are also designated for motorized use to the public. Waypoint 3 views the transmission line boundary at BLM designated route T5670B, open to motorized ATVs and single-track, which becomes the boundary intermittently. BLM 5672 and the transmission line make up the unit s northern boundary west of here to Waypoint 1, representing the unit s northwest boundary corner. This photopoint views the unit s western boundary, an administrative route closed to the public and power line that extends all the way up to Methodist Mountain to the south. 9

10 BLM T5670B ends at BLM 5670 at Waypoint 5, atop a ridgeline that overlooks BLM s Castle Gardens area to the north. BLM 5670 continues east as the unit s northern boundary for a short distance to Waypoint 8 and BLM 5670A, which becomes the boundary along with the transmission lines (in view) for the remainder of the unit. BLM 5670A and the transmission line boundary end at Waypoint 11, into a locked unmarked gate, presumably at private property. A fence line continues south from here as the unit s eastern boundary. There are very few routes into the interior of the Castle Gardens unit. Waypoint 10 views a BLM closed road with barriers on the ground at BLM 5670A in the northeast unit. The route continues into the contiguous USFS Recommended Wilderness at Waypoint 13, however does not appear to have been constructed by mechanical means, is not regular and continuous, and is no longer maintained as evidenced by the vegetation extending into the route. Faint vehicle tracks were observed on portions of this route, nevertheless it will remain within the unit as a way. Two non-motorized routes were observed in near proximity off of BLM T5670A. Waypoint 4 views one of these trails with BLM signs. The other trail appears very similar, and is located just east along T5670A. Neither trail is easy to follow on the ground as they quickly are enveloped by the surrounding naturalness. It is likely that they are the same trail, forming a small loop with BLM T5670A. Regardless these routes do not meet WIR specifications and will remain within the unit as ways. The Bear Creek unit (COF ) was inventoried by the BLM. This unit borders the USFS Sangre de Cristo Recommended Wilderness on its south and west. The remaining boundaries of this unit are bounded by private property, with the exception of County Road 49 and the Columbine Trail parking lot, which border the unit for a short distance at its southeast corner. The BLM did not remove these impacts from their inventoried Bear Creek unit. The Columbine Trail parking lot and trailhead provide the only public access to the unit and can be viewed at Waypoint 15. County Road 49 continues into the USFS National Forest, as viewed in the left hand side of the photopoint. The Columbine Trail is a designated non-motorized route and straddles the unit s southern boundary as it traverses in and out of the contiguous USFS Recommended Wilderness. Waypoint 17 views the hiking and horseback riding trail in the unit at one of these points where it borders and briefly crosses into USFS (with boundary sign). The Columbine trail will remain within the unit as a way. One other potential route into the unit was observed at the Columbine Trail parking lot at Waypoint 16, however this is marked by BLM as Not A Designated Route, with wood stakes and a rock barricade behind it to prevent unauthorized motorized use. Motorized use was not observed on this route, which was not constructed by mechanical means and does not appear regular and continuous. It will remain within the Bear Creek unit as a way. The Box Canyon proposed LWC unit was not inventoried by the BLM, however it is contiguous to the USFS Sangre de Cristo Recommended Wilderness on its south, qualifying for lands with wilderness characteristics. A block of state land also makes up the eastern part of the unit s southern boundary. Private property borders the unit to the west, and much of the eastern portion of the unit. The Box 10

11 Canyon unit is publically accessible briefly to the northeast, beginning at Waypoint 21 where Box Canyon Road meets a gulch that forms the unit s northern boundary. Box Canyon Road borders the unit to the east for a short distance except where quarries to the southeast (and east) have been excluded from the unit, effectively removing much of the Box Canyon Road boundary as well. The referenced gulch to the west of Waypoint 21 partly forms the northern boundary of the Box Canyon unit. There is a BLM No Dumping sign at the gulch, as viewed in the photopoint. However motorized access into the gulch is limited immediately due to natural topographic barriers. Waypoint 22 views this natural drainage and boundary a short distance west onto the route. The northern boundary gulch comes to an unmarked route for BLM 5971A at Waypoint 23. This route, a designated route partly constructed by mechanical means, will continue west as the unit s northern boundary to Waypoint 38, where it comes to the private property western boundary. The only sign on the ground for this route is located at Waypoint 31 for BLM designated 5971A, open to all motorized and non-motorized use. However the motorized public point of access is unknown as natural barriers prevent motorized use from the east and the route from the west is not publicly accessible, as viewed by the locked gate at Waypoint 39, just west of the unit from County Road 101. A few short routes were observed traversing into the unit from the northern boundary route 5971A. Waypoint 36 views an old route closed with logs and branches. This route does not show any use and dissipates quickly into a possible prospecting pit at Waypoint 37. This route does not appear to have been constructed by mechanical means, is not maintained, and is not regular and continuous. It showed no signs of use and will remain within the unit as a way. Vegetation screens this route and any man-made impacts from affecting the overall naturalness of the unit. Another old closed route was observed at Waypoint 34 along the northern boundary road, BLM 5971A. This route has a BLM Not A Designated Route sign with barriers blocking the route as well. As evidenced in the photopoint, this route is being reclaimed by the forces of nature. It ends a short distance into the unit and will remain as a way. There is a similar closed route at Waypoint 33. This route is closed with branches as barriers and shows considerable revegetation on the route thereafter. The route shows even more vegetation as it reaches its end a short distance into a prospecting pit at Waypoint 32. Although this route appears to have been constructed by mechanical means, it is no longer maintained or regular and continuous, and will remain within the unit as a way. There is also a route just east of here that enters the unit at Waypoint 27, ascending Spring Gulch. As viewed in the photopoint, there is a BLM Closed Road sign in the middle of the route with rocks and branches in the route to deter use. An old route junction was observed a short distance along this route at Waypoint 28, however as evidenced in the photopoint, both routes have been considerably reclaimed by nature. The spur route ends a short distance into a probably prospecting area. The Spring Gulch route traverses in and out of the gulch, however dissipates quickly, overtaken by the surrounding naturalness. Waypoint 29 (below) views Spring Gulch up the drainage at a point where the route could no longer be located. 11

12 One other route was observed traversing into the Box Canyon proposed LWC. Waypoint 24 views a barely discernible route atop a ridgeline at BLM 5971A. This route shows partial evidence of mechanical construction, however is not maintained or regular and continuous. It ends a short distance into the unit at a prospecting pit and overlook, and will remain within the unit as a way. The Taylor Gulch proposed LWC unit, located southsoutheast of the Box Canyon unit, was also not inventoried by the BLM. However this unit qualifies as a LWC as it is bordered by USFS Sangre de Cristo Recommended Wilderness on its south and west. The unit is bordered on the northwest by state land, with the remainder of the unit bordered by private property, to the north and east. There are no routes that lead into the unit. The South Howard unit (COF ) is bordered by USFS Sangre de Cristo Recommended Wilderness on the southern portion of its western boundary. The northern boundary consists of private property and local road, Boreen Way. The remainder of the unit is insulated by private property. Sangre Foothills (29) - S Old route dissipates into surrounding naturalness of Spring Gulch (p. 11) Boreen Way makes up the South Howard unit s northern boundary. This route appears primarily used for private property access to the north and west, however it is publicly accessible, and provides access to the unit. Boreen Way can be viewed in Waypoint 46, with a BLM Entering Public Lands sign. This route becomes impassible by vehicle as it continues west, as evidenced in Waypoint 49, however it will remain as the unit boundary as it meets private property just to the west. One route was observed entering the unit from Boreen Way, a faint route at Waypoint 47 that was not constructed by mechanical means. This unmarked route ascends south into the unit, however becomes impassible to full-sized vehicles in a short distance at Waypoint 48. The route continues to follow a natural drainage before dissipating into the unit. This unmarked route is no longer maintained and not regular and continuous; it will remain within the unit as a way. No other routes were observed in the South Howard unit. There is a BLM No Motor Vehicles sign at Boreen Way in the northeast unit at Waypoint 45, however no route or indications of motorized activity were observed on the ground. The Kerr Gulch unit (COF ) is bordered by USFS Recommended Wilderness on its west. Wild Connections altered the boundaries of this proposed LWC unit to remove human impacts observed on the ground and referenced in BLM s report for the unit, concentrated in the northern 12

13 and southern parts of the BLM inventoried Kerr Gulch unit. Wild Connections proposed northern and southern boundaries now border BLM land, drawn along the boundary of vegetation treatment projects. BLM designated route 6110, open to all motorized vehicles, remains as the unit s eastern boundary and public access point. BLM 6110 begins the unit s eastern boundary to the north at Waypoint 51, which marks the perimeter of BLM s northern vegetation treatment projects that have been excluded from the unit. BLM 6110 comes to a locked gate with a Closed Road for Soil and Wildlife Protection sign at Waypoint 53, which forms the new southern boundary. This route, open to foot and horse travel, appears to have been constructed by mechanical means. It was likely constructed for vegetation treatment projects as this route and spur routes lead to tree thinning areas in the high elevation mixed forest. The perimeter of these vegetation treatment sites serves as the Kerr Gulch unit s southern boundary west to the contiguous USFS Recommended Wilderness. The East Kerr Gulch unit (COF ) is southeast of the Kerr Gulch unit, separated by BLM The southern boundary of this unit is contiguous with USFS Sangre de Cristo Recommended Wilderness. From west to east, the unit s northern boundary consists of BLM land, Short Creek Baldy State Trust Land, and private property, with private property also bordering the unit to the east and southeast. BLM designated routes 6110 and 6110A comprise the unit s western boundary, along with a primitive route in the southwest part of the unit. The primitive route heads south from BLM 6110 at Waypoint 68 and is extended south to the contiguous USFS Recommended Wilderness boundary to exclude multiple routes and vegetation treatments projects located in the southwest section of the BLM inventoried East Kerr Gulch unit. BLM 6110 comes to a junction with BLM 6110A at Waypoint 55, a BLM designated route open to all motorized and non-motorized use. BLM 6110A exits the unit about one-half mile northeast into the Short Creek Baldy State Trust Land at Waypoint 58, marked by a fence line. There is one route into the interior from BLM 6110A, at Waypoint 56. The unnamed route is open to all motorized and non-motorized use as indicated in the photopoint. It ends less than 500 feet at a radio tower and facilities at Waypoint 57. The unmarked route is removed from the unit as a WIR cherrystem. The radio tower and facilities are excluded from the unit as well. Two other routes were observed entering the East Kerr Gulch unit from the west, via BLM Waypoint 59 views a closed road with a locked gate at BLM The BLM sign states, Closed Road for Wildlife and Soil Protection. It is open to foot and horse travel. This route appears to have been constructed by mechanical means in some portions, however is not maintained, not regular and continuous, and is being reclaimed by the forces of nature, as evidenced in Waypoint 60. This route ends a short distance thereafter at Waypoint 61, looking back at the revegetated route. It will remain within the unit as a way. The final route into the interior of the East Kerr Gulch unit is at Waypoint 62, also at a locked gate with a Closed Road for Wildlife and Soil Protection sign. This route was not constructed by 13

14 mechanical means, is not maintained, or regular and continuous. The forces of nature have reclaimed much of this route, as evidenced in Waypoint 65 atop the montane grassland and shrubland of the Hayden Baldy peak that this route traverses. The route completely dissipates into the surrounding naturalness a little further as observed in Waypoint 67, looking back on this route. It will remain within the unit as a way. The Pole Gulch unit (COF ) is bordered by USFS Sangre de Cristo Recommended Wilderness on its west and south. A block of state land also borders the unit on its south. County Road 40 also borders the unit to the southeast, for a short distance. The remainder of the unit is inaccessible to the public as it is bordered by private property. County Road 40 forms the southwest boundary of the Pole Gulch unit for about one-half mile from Waypoint 70 to Waypoint 73, where it continues southwest into privately leased state land. There are not any routes that enter the unit from boundary road County Road 40. The BLM inventoried one route into the unit, COF A, which enters the unit from the north via private property and continues south up Fox Canyon Creek to the state land block. The BLM map shows that this route splits as well west and east. The west branch traverses northwest to private property and then southwest along Pole Gulch to USFS. The east branch appears to end in a loop in the northeast unit. The BLM states that the purpose of this route is administrative access for the BLM and USFS, originally constructed to access timber, range, and a homestead. The BLM further states that the routes were likely constructed mechanically by a bulldozer however is no longer regular and continuous and does not qualify as a Wilderness Inventory Road. Therefore the routes identified by the BLM as COF A will remain within the unit as ways. The Cottonwood Creek unit (COF ) is bordered by USFS Recommended Wilderness on its south. It is separated from the Pole Gulch unit by County Road 40, which borders this unit to the northwest for a short distance. A block of state land borders the remaining western portion of the unit with private property bordering the unit to the north and east. Sangre Foothills (72) - SSW Primitive route ends a short distance into a campsite at Big Cottonwood Creek; excellent opportunity for fishing (p. 15,19,20) County Road 40 represents the only public access to the Cottonwood Creek unit, forming the boundary from Waypoint 70 to Waypoint 73; this is the same boundary as the Pole Gulch unit. 14

15 There is one route into the unit from County Road 40, at Waypoint 71. This route ends a very short distance into the unit at Waypoint 72 (above), a campsite along Big Cottonwood Creek. This route was not constructed by mechanical means and will remain within the unit as a way. The BLM inventoried two routes into the unit that begin from private property and are not accessible to the public. COF A, accessed from County Road 40, is a maintained road to a private property inholding located southeast of the unit. The BLM considers this a Wilderness Inventory Road and designates it as a boundary road where it intersects BLM land to the north, east, and southeast for short distances. The BLM inventoried another route, COF B, that enters the unit through private property from the north and dead-ends into the unit interior. The BLM also inventoried two routes that spur from COF B. COF C traverses southwest into the contiguous USFS and COF D dead-ends a short distance to the north in the unit interior. The BLM concluded that none of these routes were constructed by mechanical means, are not maintained, and not regular and continuous. Furthermore they are closed in the Arkansas River Travel Management Plan (TMP). They will remain within the Cottonwood Creek unit as ways. The Palmer Gulch proposed LWC unit was not inventoried by the BLM, however is contiguous with USFS Recommended Wilderness to its west. This small unit forms a triangular shape with private property bordering the unit to the north and an unnamed private access road bordering the unit to the southeast. The unnamed road is accessed via County Road 35 however this is only attainable via private property, severely limiting public access to the unit. Waypoint 74 views the end of public access on County Road 35 at a locked gate with No Trespassing signs, northeast of the unit. The Mosher Creek proposed LWC unit was not inventoried by the BLM, but qualifies for LWCs as this unit is contiguous with USFS Recommended Wilderness on its west. Private property insulates the unit to the north and east, with unnamed private property routes forming the northeast and southeast boundaries. This unit is separated from the Palmer Gulch proposed LWC unit by the unnamed route from County Road 35, which composes the Mosher Creek unit s northwest boundary. As referenced for the Palmer Gulch unit, this route is not accessible to the public, limiting public access to the unit. II. The Sangre de Cristo Foothills Contiguous Units proposed LWC is primarily affected by the forces of nature. The Sangre de Cristo Foothills Contiguous Units proposed LWC is primarily affected by the forces of nature, with human impacts considerably unnoticeable within the units. These units share the same naturalness characteristics as the greater contiguous USFS Sangre de Cristo Wilderness and Roadless Recommended Wilderness. Motorized public access to any of the units is limited, with nearly a complete lack of motorized use into any of the units. Units that do have routes in question, which are primarily private or administrative, have been altered to use the motorized routes as unit 15

16 boundaries or short cherrystems, as documented in the above section. Similarly, prominent human impacts have been excluded from the unit so that they do not affect the units natural integrity. Many of these units have very little human impact, particularly due to their remoteness, inaccessibility, and proximity to the greater USFS Sangre de Cristo Wilderness and Recommended Wilderness. Human impacts that were observed in the proposed LWC units were minor and are detailed below. The Castle Gardens unit is primarily affected by the forces of nature. This is one of the lower elevation units below 8,000 feet and consists primarily of a pinyon-juniper woodland. Waypoint 7 views this vegetation over the rolling hills in the central and eastern interior unit, from the southern boundary road BLM Ponderosa pine mix into this unit as well in the higher elevations and natural drainages, as evidenced in Waypoint 9 in the eastern interior. A vegetation treatment area was the only human impact observed in the Castle Gardens unit, concentrated in the western portion of the unit. The treatment area can be viewed in Waypoint 2, in the form of old stumps and tree branches. However as evidenced in the photopoint, healthy pinyon pine and junipers and an understory of rabbitbrush, sagebrush, yucca, grasses, and other plants are also consistent in this area, appearing natural. Furthermore the vegetation treatment is only viewable in the immediate area as it is screened by the wooded rolling hills that make up this unit, and therefore does not impact the overall naturalness of the Castle Garden unit. For the Bear Creek unit (COF ), Wild Connections agrees with BLM s report that the area appears to be natural. The vegetation consists of pinyon pine, juniper, ponderosa pine, and Gambel oak in the hilly unit, with narrowleaf cottonwoods lining the Columbine trail drainage in the southern portion of the unit into the contiguous USFS Recommended Wilderness. Waypoint 19 provides a great view of the vegetation and naturalness of the interior unit and contiguous USFS Recommended Wilderness from a ridgeline in the southwest part of the unit, overlooked by the nearby Sangre de Cristo Mountains. The Bear Creek unit has very little imprint of man. The parking lot and County Road 49 (Waypoint 15) are excluded from the unit to the southeast. The non-motorized Columbine trail that traverses the southern boundary is a minor human impact. Otherwise only a BLM cadastral survey marker (dated 1963) was observed at the BLM/USFS boundary fence line at the southwest corner of this unit, viewed in Waypoint 18. The Box Canyon proposed LWC unit is primarily affected by the forces of nature. This unit ranges from approximately 7,000 feet to 9,000 feet, offering a variety of ecosystems. Rolling hills of pinyon-juniper woodland and Gambel oak scrubland are consistent throughout the unit. This is captured in Waypoint 35, viewing the unit interior from the northwest. Ponderosa pine and other conifers mix in at higher elevations to the south. Narrowleaf cottonwood, willows, and other riparian vegetation can be found in the unit s many gulches and drainages, as exemplified in Waypoint 30 in Spring Gulch. The major human impacts large exposed mine sites have been excluded from the unit. The two sites are both located to the east, accessed from Box Canyon Road. Waypoint 40 views the mining site that is excluded from the northeast proposed LWC unit. Waypoints 41 and 42 view the sites 16

17 excluded to the southeast of the unit, removing most of the hillside in this section of BLM land. These excluded sites are all located on steep eastern facing hill-slopes, out of view from the Box Canyon proposed LWC unit, and thus do not affect the natural integrity of the unit. There were some minor human impacts observed in the Box Canyon proposed LWC that remain within the unit. A couple of prospecting holes were observed off a short revegetated route in the southern portion of the unit at Waypoint 25. A couple of the routes reclaimed by nature may have led to possible prospecting pits as well, but nothing noticeable was observed on the ground. Regardless these prospecting sites and revegetated routes are screened by the dense vegetated woodlands and rolling topography of the unit, and do not impact the overall naturalness of the unit. The Taylor Gulch proposed LWC unit is primarily affected by the forces of nature. This unit has no motorized access, public or private, strictly limiting human impact. Outside of a long backcountry hike via the USFS Sangre de Cristo Recommended Wilderness, this unit is only accessible through a natural drainage from contiguous state land to the north. This unit ranges in elevation from 8,200 feet to approximately 9,400 feet, supporting dense mixed forests and montane grassland as viewed in Waypoint 43 (right) in the northern portion of the unit. No human impacts major or minor were observed in the Taylor Gulch unit. Sangre Foothills (43) - SW High elevation mixed conifer forest over montane grassland in the Taylor Gulch unit (p. 17) The South Howard unit (COF ) is also primarily affected by the forces of nature. This unit is centered on a Sangre de Cristo foothill (from Red Mountain to the southwest) that slopes north and south in the unit. The entire unit is below 8,000 feet, primarily supporting a pinyon-juniper woodland. The BLM did not find wilderness characteristics in this unit due to old mechanically constructed routes and vegetation treatment projects that affect the naturalness of the unit, however the agency did not provide supporting geo-referenced or photopoint data to support this claim. Public access is available in the northern portion of the unit from boundary road, Boreen Way. However there were no vegetation treatment sites observed on the ground and the only route into the interior does not appear to be mechanically constructed and is not maintained as evidenced in Waypoint 48. Furthermore it is hidden from view from the rest of the unit by the dense wooded vegetation, which can also be observed in the above photopoint. The Kerr Gulch unit (COF ), with redrawn boundaries, is primarily affected by the forces of nature. The entire unit is above 8,000 feet, supporting a mixed forest, including alpine fir, Douglas fir, Colorado blue spruce, Ponderosa pine, and pinyon pine. Waypoint 52 views the dense mixed coniferous forest of the interior unit as it leads to the contiguous Roadless Recommended 17

18 Wilderness, from the BLM 6110 eastern boundary road. The Hamilton Creek drainage that flows through the central part of the unit provides a riparian ecosystem, supporting large old growth narrowleaf cottonwoods. The BLM did not find naturalness characteristics in this unit due to the large vegetation treatment projects and constructed routes to access these sites. Wild Connections concurs with BLM s inventory and report that these large human impacts affect the naturalness of the BLM inventoried COF unit. However these impacts are concentrated in the very northwest and southern sections of the inventoried unit, and have been excluded from the proposed Kerr Gulch LWC unit. Waypoint 50 views an example of a route and treatment site to the northwest that has been excluded from the unit. Waypoint 54 views a similar area that has been excluded from the southern portion of the unit. The redrawn Kerr Gulch proposed LWC unit has no observed human impacts. Furthermore, the excluded vegetation treatment sites and routes are isolated to the extremities of the unit, and are not visible impacts as they are largely screened by the unit s dense vegetation and rolling topography. The East Kerr Gulch unit (COF ) has also been altered to remove human impacts. Similar to the Kerr Gulch unit, the BLM did not find wilderness characteristics in this unit due to the impacts of vegetation treatment projects and associated routes affecting the naturalness character of the unit. Wild Connections on the ground inventory confirms BLM s assessment of impacts in the East Kerr Gulch unit. However most of the human impacts are concentrated in the very southwest section of the BLM inventoried unit, which has been excluded from the proposed LWC. The other prominent human impact the radio facilities located in the northeast unit at Waypoint 57 has also been excluded from the proposed LWC, along with the short designated route that leads to it. Other human impacts in this unit are minor, consisting of two closed roads being reclaimed by nature, as documented in the previous section. Waypoints 61 and 67 view the natural reclamation process, looking back from the end of these routes. These photopoints also capture the vegetation in this unit: high elevation mixed coniferous forests and montane grassland and shrubland respectively. The altered East Kerr Gulch proposed LWC unit is primarily affected by the forces of nature. The Pole Gulch unit (COF ), which is largely inaccessible to the public, has overall apparent naturalness. County Road 40 borders the unit for a short distance to the southeast however access into the interior is difficult given the steep wooded hillsides of the unit. Much of the unit consists of a pinyon-juniper woodland and Gambel oak scrubland. This unit also supports cottonwoods, fir, and spruce in the drainages, at least what was observed along Big Cottonwood Creek in the southeast unit. The unit can also be viewed (but not accessed) from west of the unit via Hayden Creek Road. Waypoint 69 views the apparent naturalness and vegetation of the western Pole Gulch unit. The BLM did not find wilderness characteristics in this unit due to mechanically constructed routes, two mine sites, and vegetation treatment projects affecting its natural character. However the BLM failed to provide supporting geo-referenced and photopoint data of these human impacts. Furthermore these routes and other impacts are only accessible via private property and appear to 18

19 primarily follow natural drainages. However since these areas are not accessible and visible to the public, the unit appears natural to the average visitor (BLM Manual 6310, p 7). The entire Pole Gulch unit will be considered for natural character until the BLM provides the necessary supporting data for their reported human impacts, as specified in BLM Manual The Cottonwood Creek unit (COF ), similar to the Pole Gulch unit, is only accessible to the public for a short distance via the western boundary road County Road 40. The only observed impact from the boundary road is minor: a short non-mechanically constructed route to a campsite at Waypoint 72. This photopoint also views Big Cottonwood Creek, which flows through the unit, and the dense vegetation of narrowleaf cottonwoods and mixed conifers consistent in the unit. The BLM did not find naturalness in this unit due to mechanically constructed routes, timber harvesting, and evidence of old mining. However the BLM did not provide supporting documentation of these human impacts that is required in BLM Manual These routes and impacts that they lead to are only accessible via private property and thus are not viewable to the average visitor. As is the case for the Pole Gulch unit, the entire proposed Big Cottonwood Creek unit will be considered for natural character until the BLM provides the necessary supporting data for their reported human impacts, as specified in BLM Manual The Palmer Gulch unit and the Mosher Creek unit, separated by a private access route, were not accessible to Wild Connections due to private property, and therefore were not inventoried on the ground for wilderness characteristics. The BLM did not inventory these units either. Nevertheless, both units are contiguous to USFS Roadless Recommended Wilderness and qualify for lands with wilderness characteristics. The lack of public access likely mitigates human impacts in these units. They will remain a part of the Sangre de Cristo Foothills proposed contiguous units, however an inventory of the units naturalness features is recommended. III. The Sangre de Cristo Foothills Contiguous Units proposed LWC provides outstanding opportunities for solitude and primitive recreation. The Sangre de Cristo Foothills Contiguous Units proposed LWC offers ample opportunities for solitude and primitive and unconfined recreation. These units offer vast opportunities for solitude given the topographic variety, vegetative cover, few public entry points, and limited interior routes (motorized and non-motorized). All of these units consist of rugged rolling hills, wooded and/or forested, cut by steep drainages providing excellent screening from unnatural sights and sounds. The BLM did not find opportunities for solitude in the Bear Creek unit (COF ), however it appears their inventory did not venture into the unit, as their report only references the parking lot and County Road that have been excluded to the southeast and the Columbine Trail that straddles the southern boundary. However when one ventures into the interior of the 277 acre unit, there are outstanding opportunities for solitude in the natural interior. For example, Waypoint 14 views the wooded interior unit over one of the many drainages from the eastern Bear Creek unit. In Wild Connections inventory, no other visitors were observed, providing ample opportunity for respite and remoteness just about anywhere in the unit. 19

20 The Sangre de Cristo Foothills Contiguous Units proposed LWC also offer a multitude of primitive and unconfined recreational opportunities. There are outstanding opportunities for hiking, backpacking, camping, rock climbing, hunting, wildlife viewing, bird watching, horseback riding, and photography. Waypoint 64 (right) views one of the many outstanding opportunities for hiking in these units. This photopoint is along a revegetated closed route open to hiking and horseback riding in the East Kerr Gulch unit, on a montane grassy ridgeline in the otherwise forested interior. This excellent hike also provides outstanding scenic opportunities (fog permitting) of the nearby Sangre de Cristo Mountains to the south and east, as well as the Arkansas River Canyonlands to the north-northwest. Sangre Foothills (64) - E Outstanding opportunity for hiking and wildlife viewing in the East Kerr Gulch unit (p. 20) The Bear Creek unit also provides outstanding opportunities for primitive recreation, contrasting BLM s report of the area. The BLM acknowledges that there is opportunity for hiking and horseback ridging along the Columbine Trail, examples of outstanding opportunities for primitive and unconfined recreation listed in BLM Manual 6310 (p 8). This unit also provides outstanding opportunity for photography and sightseeing for geological features given the high vantage points in the western portion of the unit. For example, Waypoint 20 encapsulates these opportunities, viewing the iconic Sawatch Range and Collegiate Peak 14ers Mount Shavano, Mt Antero, and Mt Princeton to the northwest. There are also excellent scenic views of the Buffalo Peaks and Castle Gardens to the north, Arkansas River Canyonlands to the northeast, and of the nearby Sangre de Cristo Mountains to the south. The Cottonwood Creek unit (COF ) may be the only unit that offers outstanding opportunity for fishing. Waypoint 72 views Big Cottonwood Creek in the western portion of the unit beyond a primitive campsite, providing for excellent primitive and unconfined recreation. Additionally there are excellent opportunities for hunting within all of these units; high value animal species and habitat are documented in the section below for supplemental values. IV. The Sangre de Cristo Foothills Contiguous Units proposed LWC has supplemental values that would enhance the wilderness experience and should be recognized and protected. 20

21 Wild Connections inventory of the Sangre de Cristo Foothills Contiguous Units proposed LWC supports the existence of numerous supplemental values that contribute to the overall experience of visiting these areas and provide additional evidence that these units unique qualities should be recognized and protected. The majority of these values support the area s regional ecological importance and rich biodiversity. The supplemental values presented below are not intended to be exhaustive, but rather are a summary of some of the widely known significant values for which basic data was available to complement our on-the-ground inventory. These 11 units are all contiguous with the greater USFS Sangre de Cristo Wilderness and Roadless Recommended Wilderness, a vast corridor of connectivity for flora and fauna. 220,803 acres comprise the rugged Sangre de Cristo Wilderness, not accounting for the contiguous Recommended Wilderness. The Sangre do Cristo Foothills Contiguous Units can expand this connectivity core 8,700 acres to the northeast lower elevation foothills, critical habitat for many species. The Colorado Natural Heritage Program (CNHP) recognizes numerous Potential Conservation Areas (PCAs) in the Sangre de Cristo Mountains and foothills, many of which overlap with the proposed LWC units. The Castle Gardens PCA, adjacent to the north of the Castle Gardens unit, has outstanding biodiversity significance due to an excellent to good occurrence of the globally critically Brandegee wild buckwheat (Eriogonum brandegeei), a Colorado endemic species restricted to Chaffee and Fremont counties. CNHP found this site to contain one of the three largest quality occurrences of the species known to date. The Castle Gardens PCA also has good occurrences of the globally imperiled plant species, Fendler s townsend daisy (Townsendia fendleri). The Bear Creek below Simmons Peak PCA, ranked for high biodiversity significance, encompasses most of the Bear Creek unit and the southwest portion of the Box Canyon unit. This site contains an excellent to good occurrence of a globally vulnerable riparian natural community, quaking aspen / thinleaf alder (Populus tremuloides / Alnus incana) woodland and a good occurrence of a globally vulnerable riparian natural community, narrowleaf cottonwood / thinleaf alder (Populus angustifolia / Alnus incana) woodland. The Box Canyon unit also contains a portion of the Box Canyon at Wellsville PCA, in the northeast unit. This site ranks for high biodiversity significance for a good to fair occurrence of the Arkansas Canyon Stickleaf (Nuttallia densa), a globally imperiled plant species restricted to the Arkansas River drainage in Chaffee and Fremont Counties. The entire Kerr Gulch unit is contained within CNHP s Hamilton Creek PSA. This site is attributed high biodiversity significance for an excellent to good occurrence of a globally vulnerable riparian community narrowleaf cottonwood / thinleaf alder (Populus angustifolia / Alnus incana) woodland. The Stout Creek PCA, located to the northwest, is no longer contained in the Kerr Gulch unit due to boundary adjustments, however it ranks for high biodiversity significance due to excellent occurrences of numerous riparian communities and natural communities, including excellent occurrences of the globally vulnerable quaking aspen / river birch (Populus tremuloides / Betula occidentalis) woodland, and the globally vulnerable (G4T2/S2) Colorado larkspur (Delphinium ramosum var. alpestre). This vulnerable plant community and species can likely be found in the Kerr Gulch unit as well. 21

22 CNHP s Hayden Creek PCA overlaps with the southern portion of the East Kerr Gulch unit and western portion of the Pole Gulch unit. CNHP ranks this site for very high biodiversity significance. The Hayden Creek PCA encompasses an excellent occurrence of a globally imperiled riparian natural community, white fir - blue spruce - narrowleaf cottonwood / Rocky Mountain maple (Abies concolor - Picea pungens - Populus angustifolia / Acer glabrum) forest, an excellent occurrence of a globally vulnerable riparian natural community, quaking aspen / thinleaf alder (Populus tremuloides / Alnus incana) woodland, and a good occurrence of a globally vulnerable riparian natural community, narrowleaf cottonwood / thinleaf alder (Populus angustifolia / Alnus incana) woodland. The Big Cottonwood Creek at Battle Mountain PCA overlaps with the southern and eastern sections of the Pole Gulch unit, and encompasses most of the Cottonwood Creek unit. This site offers high biodiversity significance due to an excellent occurrence of a globally vulnerable riparian natural community, Douglas-fir / river birch (Pseudotsuga menziesii / Betula occidentalis) woodland. There is also a good occurrence of the globally vulnerable narrowleaf cottonwood / river birch (Populus angustifolia / Betula occidentalis) woodland and an excellent occurrence of the globally apparently secure Douglas-fir / red-osier dogwood (Pseudotsuga menziesii / Cornus sericea) woodland. High habitat and range values for many wildlife species have been identified in the Sangre de Cristo Foothills Contiguous Units proposed LWC. Rocky Mountain Wild s (RMW) Assessment of Biological Impact (ABI) documented the following mammals and associated values within the unit: Canadian lynx (Lynx canadensis) potential habitat; mountain lion (Puma concolor) overall range; black bear (Ursus americanus) overall range, summer concentration, and fall concentration; elk (Cervus Canadensis) production area, overall range, summer range, summer concentration area, winter range, and winter concentration area; mule deer (Odocoileus hemionus) overall range, summer range, winter range, severe winter range, winter concentration area; Brazilian free tailed bat (Tadarida brasiliensis) overall range; Aberts squirrel (Sciurus aberti) overall range; and Gunnison s prairie-dog (Cynomys gunnisoni) overall range. A few of these species garner additional recognition. The most noteworthy is the Canadian lynx, which is listed as a threatened species by the US Fish and Wildlife Service (FWS), an endangered species by the CDOW, and a species of most concern by the US Wildlife Conservation and Restoration Program s (WCRP) Comprehensive Wildlife Conservation Strategy (CWCS). RMW also reports that there is a small overlap of lynx denning and winter habitat into the proposed LWC from the contiguous USFS wilderness and Recommended Wilderness. Gunnison s prairie-dog is also listed as a species of most concern by WCRP s CWCS, as well as listed as Colorado BLM sensitive. The Brazilian free tailed bat is a Colorado state ranked critically imperiled species. RMW also identifies valued bird species in the proposed LWC, which provides wild turkey (Meleagris gallopavo) overall range, winter range, winter concentration area, and roost sites. Gangs of wild turkey were observed in a couple of the proposed LWC units. Waypoint 63 views a rafter of wild turkey in the high elevation montane grassland of the East Kerr Gulch unit. A covey of dusky grouse (Dendragapus obscurus) was also observed in this unit, in a similar habitat to the east atop Hayden Baldy. Waypoint 66, right, views a close-up of one of these birds. 22

23 There are exceptional scenic views from within the proposed LWC, given the many high vantage points found throughout the units. The nearby Sangre de Cristo Mountains are visible from all of the inventoried units. For example, Waypoint 12 views this range over the Castle Gardens interior unit. Waypoint 19 views the northern Sangre de Cristo Mountains over the Bear Creek unit. There are also excellent views of the Sawatch Range Collegiate Peaks to the northwest, as evidenced in Waypoint 44 over the Taylor Gulch unit, Waypoint 26 over the Box Canyon unit, and Waypoint 20 from the Bear Creek unit. Sangre Foothills (66) - SW Dusky grouse observed in the montane grassland and scrubland atop Hadyen Baldy in the East Kerr Gulch unit (p. 23) Many of these units offer scenic views of other areas as well, particularly of the Arkansas River Canyonlands to the north. The Castle Gardens unit views over Castle Gardens Park, adjacent to the north, and can be viewed in Waypoint 6. The Sangre de Cristo Foothills Contiguous Units offer interesting geology as well, representing varying geological ages. The Castle Gardens unit, Bear Creek unit, and western portions of the Box Canyon unit consist of sandstone and siltstone from the relatively young Tertiary Age. However much of the Box Canyon unit consists of very old rock gabbro, diorite, felsic gneiss, and mafic gneiss from the Early Proterozoic Age. This also makes up the western portion of the Taylor Gulch unit. Limestone and sandstone from the Missisippian-Ordovician Period make up the eastern portions of the Box Canyon and Taylor Gulch units. The southeastern units are primarily comprised from the Pennsylvanian Period with rock types of sandstone, siltstone, and shale. This makes up most of the Kerr Gulch, East Kerr Gulch, Pole Gulch, and Cottonwood Creek units. Some much younger geology exists in this region as well. The South Howard, Palmer Gulch, and Mosher Creek units are primarily from the Tertiary Age; however still consist of siltstone and sandstone. The eastern Mosher Creek unit also offers gravel and alluvium from the Quaternary period, the youngest recognized geological age. Lastly, the western portion of the Pole Gulch unit consists of plutonic rock phaneritic from the Tertiary Age. The above geological data was obtained from the United States Geological Survey's (USGS) Mineral Resources on-line spatial data, selected for Colorado's geology. Summary Conclusion 23

24 Based on Wild Connections' extensive on-the-ground and aerial inventories, the Sangre de Cristo Foothills Contiguous Units proposed LWC qualifies as Land with Wilderness Characteristics (LWC) in accordance with BLM's Manual These 11 units are contiguous to USFS Sangre de Cristo Recommended Wilderness, comprising over 8,700 contiguous roadless acres. Given the contiguity of the units, lack of significant human impacts, disparate topography, outstanding biodiversity, and abundant wildlife, the Sangre de Cristo Foothills Contiguous Units proposed LWC offers outstanding wilderness characteristics - including apparent naturalness and outstanding opportunities for solitude and primitive and unconfined recreation. The boundaries and wilderness characteristics identified by the BLM generally align with Wild Connection s inventories of the units. However Wild Connections did alter some of the units boundaries to exclude human impacts. Wild Connections also inventoried an additional five units contiguous with USFS Sangre de Cristo Recommended Wilderness. 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 approximately 8,700 acre Sangre de Cristo Foothills Contiguous Units proposed LWC meets wilderness criteria. These units possess Lands with Wilderness Characteristic status and 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. 24

25 Sangre de Cristo Foothills Contiguous Units Proposed LWC Waypoints The following photographs correspond with the numbered Waypoints on the above Sangre de Cristo Foothills Contiguous Units 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. Sangre Foothills (1) - S Castle Gardens unit: power line and administrative route western boundary (p. 9) Sangre Foothills (2) - NE Signs of vegetative treatment among old growth pinyon-juniper woodland in western Castle Gardens unit (p. 16)

26 Sangre Foothills (3) - E Castle Gardens unit transmission line southern boundary at BLM T5670B (p. 9) Sangre Foothills (4) - SSE Non-motorized route into interior Castle Gardens unit, from BLM T5670B southern boundary (p. 10) Sangre Foothills (5) - SSE BLM T5670B at BLM 5670, Castle Gardens unit southern boundary (p. 10) Sangre Foothills (6) - NNE View of Castle Gardens, from Castle Gardens unit southern boundary BLM 5670 (p. 23) 26

27 Sangre Foothills (7) - E Rolling hills of pinyon-juniper woodland comprise the Castle Gardens unit (p. 16) Sangre Foothills (8) - E BLM 5670 at 5670A, Castle Gardens unit southern boundary (p. 10) Sangre Foothills (9) - S Ponderosa pine mix into the pinyon-juniper woodland in the drainages of the Castle Garden unit (p. 16) Badito Cone (10) - S Closed road with barriers at southern boundary BLM 5670A in southeast Castle Gardens unit (p. 10) 27

28 Sangre Foothills (11) - WSW Southern boundary BLM 5670A at Castle Gardens unit eastern private property boundary (p. 10) Sangre Foothills (12) - SSE Sangre de Cristo Mountains over Castle Gardens unit (p. 23) Sangre Foothills (13) - NNE Closed route being reclaimed by the forces of nature in the Castle Garden unit (p. 10) Sangre Foothills (14) - WSW Wooded Bear Creek unit over one of several interior drainages; excellent opportunity for solitude (p. 19) 28

29 Sangre Foothills (15) - SSW Columbine trail parking lot and trailhead at SE Bear Creek unit; parking lot and CR 49 excluded from unit (p. 10,16) Sangre Foothills (16) - WNW Not a designated route with barricade behind, at Columbine trail parking lot (p. 10) Sangre Foothills (17) - SW Columbine Trail at BLM/USFS boundary, southern boundary of the Bear Creek unit (p. 10) Sangre Foothills (18) - NE 1963 BLM cadastral survey marker at southwest boundary of the Bear Creek unit, contiguous to USFS (p. 16) 29

30 Sangre Foothills (19) - SW Sangre de Cristo Mountains over Bear Creek unit and contiguous USFS Recommended Wilderness (p. 16,23) Sangre Foothills (20) - NE Scenic view of Swatch Mountain Range from the southwest Bear Creek unit (p. 20,23) Sangre Foothills (21) - SW Northeast boundary corner of Box Canyon unit: Box Canyon Rd at unnamed gulch (p. 11) Sangre Foothills (22) - WNW Northern boundary drainage of the Box Canyon unit (p. 11) 30

31 Sangre Foothills (23) - SSW Northern boundary gulch at BLM 5971A, which continues as Box Canyon unit s northern boundary (p. 11) Sangre Foothills (24) - SSE Former route reclaimed by nature at Box Canyon unit northern boundary BLM 5971A (p. 12) Sangre Foothills (25) - S Prospecting holes from short revegetated route in northern Box Canyon unit (p. 17) Sangre Foothills (26) - WNW Sawatch Mountain Range over wooded Box Canyon unit (p. 23) 31

32 Sangre Foothills (27) - SW BLM Closed Road sign at revegetated route into Spring Gulch (p. 11) Sangre Foothills (28) - NNE Revegetated route junction at Spring Gulch route, in northern Box Canyon unit (p. 11) Sangre Foothills (29) - S Old route dissipates into surrounding naturalness of Spring Gulch (p. 11) Sangre Foothills (30) - ENE Rocky hilly pinyon-juniper woodland over Spring Gulch riparian drainage in the Box Canyon unit (p. 16) 32

33 Sangre Foothills (31) - NW Northern boundary BLM 5971A designated route sign, open to all motorized use (p. 11) Sangre Foothills (32) - WSW End of short revegetated route from Spring Gulch in northern Box Canyon unit (p. 11) Sangre Foothills (33) - E Closed route being reclaimed by nature, at Box Canyon unit s northern boundary BLM 5971A (p. 11) Sangre Foothills (34) - S BLM closed route at Box Canyon unit s northern boundary BLM 5971A (p. 11) 33

34 Sangre Foothills (35) - E Wooded rolling interior of the Box Canyon unit (p. 16) Sangre Foothills (36) - SSE Former route closed with logs and branches at Box Canyon unit s northern boundary BLM 5971A (p. 11) Sangre Foothills (37) - E End of closed route from BLM 5971A (p. 11) Sangre Foothills (38) - S Box Canyon unit s northern boundary BLM 5971A at western private property boundary (p. 11) 34

35 Sangre Foothills (39) - S No motorized public access to BLM 5971A and western Box Canyon unit (p. 11) Sangre Foothills (40) - W Mine site excluded from northeastern Box Canyon unit (p. 16) Sangre Foothills (41) - N Mine site and hillside excluded from southeastern Box Canyon unit (p. 17) Sangre Foothills (42) - WNW Mine site and hillside excluded from southeastern Box Canyon unit (p. 17) 35

36 Sangre Foothills (43) - SW High elevation mixed conifer forest over montane grassland in the Taylor Gulch unit (p. 17) Sangre Foothills (44) - NW View of the Sawatch Mountain Range over the Taylor Gulch unit (p. 23) Sangre Foothills (45) - SSW No Motor Vehicles Sign in vegetation at South Howard unit s northern boundary, Boreen Way (p. 12) Sangre Foothills (46) - W BLM Entering Public Lands sign at South Howard unit s northern boundary, Boreen Way (p. 12) 36

37 Sangre Foothills (47) - SW Faint unmarked route into South Howard unit at northern boundary Boreen Way (p. 12) Sangre Foothills (48) - SSW Unmarked route is non-maintained and dead-ends into the wooded interior of the South Howard unit (p. 12,17) Sangre Foothills (49) - WNW Boreen Way is not maintained at the northwestern South Howard unit (p. 12) Sangre Foothills (50) - ENE Vegetation treatment area and access routes removed from northern Kerr Gulch unit (p. 18) 37

38 Sangre Foothills (52) - SW Dense mixed coniferous forested interior of the Kerr Gulch unit (p. 18) Sangre Foothills (53) - NW Closed route at BLM 6110; closed route is southern Kerr Gulch unit s adjusted boundary to exclude vegetation treatment areas to the south (p. 13) Sangre Foothills (54) - NNE Vegetation treatment area excluded from the southern Kerr Gulch unit (p. 18) Sangre Foothills (55) - NNE BLM 6110 at 6110A, northeast boundary junction for the East Kerr Gulch unit (p. 13) 38

39 Sangre Foothills (56) - SSW Short motorized cherrystem route at BLM 6110A, removed from the northwestern East Kerr Gulch unit (p. 13) Sangre Foothills (57) - SW Short motorized route to radio facilities, excluded from the East Kerr Gulch unit (p 13,18) Sangre Foothills (58) - NE East Kerr Gulch unit s northern boundary, BLM 6110A, exits into Short Creek Baldy State Trust Land at fence line (p. 13) Sangre Foothills (59) - SE Closed route with locked gate at East Kerr Gulch unit s western boundary, BLM 6110 (p. 13) 39

40 Sangre Foothills (61) - NW Looking back at the end of the revegetated closed route, amid a mixed coniferous forest (p. 13,18) Sangre Foothills (60) - ESE Closed route is being reclaimed by nature in the interior East Kerr Gulch unit (p. 13) Sangre Foothills (62) - E Closed revegetated route to Hayden Baldy Peak of the East Kerr Gulch unit (p. 14) Sangre Foothills (63) - E Rafter of wild turkey observed in the western East Kerr Gulch unit (p. 22) 40

41 Sangre Foothills (64) - E Outstanding opportunity for hiking and wildlife viewing in the East Kerr Gulch unit (p. 20) Sangre Foothills (65) - W Closed route being reclaimed by natural forces atop the montane grassland of the East Kerr Gulch unit (p. 14) Sangre Foothills (66) - SW Dusky grouse observed in the montane grassland and scrubland atop Hadyen Baldy in the East Kerr Gulch unit (p. 23) Sangre Foothills (67) - WNW Naturalness of the East Kerr Gulch interior, looking back at the closed revegetated route (p. 14,18) 41

42 Sangre Foothills (69) - SE View of the western Pole Gulch unit, no public access due to private property boundary (p. 18) Sangre Foothills (70) - NE Begin County Road 40 boundary road for eastern Pole Gulch unit and western Cottonwood Creek unit (p. 14,15) Sangre Foothills (71) - S County Road 40 at unmarked primitive route into the Cottonwood Creek unit (p. 15) Sangre Foothills (72) - SSW Primitive route ends a short distance into a campsite at Big Cottonwood Creek; excellent opportunity for fishing (p. 15,19,20) 42

43 Sangre Foothills (73) - WSW End County Road 40 boundary road for eastern Pole Gulch unit and western Cottonwood Creek unit, at privately lease state land (p. 14,15) Sangre Foothills (74) - W Locked gate at County Road 35; no public access to the Palmer Gulch and Mosher Creek units; (p. 15) 43