Comments on Proposed Roan Plateau Areas of Critical Environmental Concern Designations

Dear Ms. Connell,

Please accept the following comments on the Roan Plateau’s Areas of Critical Environmental Concern designations on behalf of the national Public Lands Program of Trout Unlimited. Trout Unlimited is especially interested in the Bureau of Land Management’s proposed actions on this unique treasure.

Trout Unlimited (TU) is a non-profit conservation organization that has more than 150,000 members dedicated to conserving, protecting and restoring North America’s trout and salmon fisheries and their watersheds. Since 1959, TU has dedicated staff and volunteers working toward the protection of sensitive ecological systems necessary to support robust native and wild trout and salmon populations in their respective ranges. Trout Unlimited, recognizes that the value of public lands is unparalleled in providing critical habitat to coldwater fisheries, wildlife habitat, the public’s drinking water, and public recreation businesses and opportunities. Trout Unlimited’s Public Lands program works specifically on public land management issues affecting the health of fish, wildlife, and their habitat as well as the quality of experience hunters and anglers expect when pursuing their passions on our public lands. In Colorado, TU has 10,000 members volunteering their time and energy to further the overall mission.

Though conservation is at the forefront of TU’s mission, we are not against oil and gas leasing and/or energy development as a use of our public lands. We support prescribed responsible development that does not recommend or impose oil and gas as the dominant land use. This prescription includes setting aside special areas, proper stipulations, effective mitigations, and enforcement of environmental safeguards so as to ensure the protection of fish, wildlife, and their habitats. We do have a significant concern that oil and gas leasing, and the exploration and development that naturally follows leasing, creates an irretrievable commitment of public resources that can have deleterious impacts on coldwater fisheries and wildlife habitat found on the Roan Plateau. We are specifically concerned about potential impacts from energy development that could harm coldwater aquatic habitats and watershed conditions necessary to support the long-term sustainability of native Colorado River cutthroat trout. In addition, as sportsmen and conservationists, we are concerned about the short-term and long-term impacts of oil and gas activities to fish and wildlife and the unique habitats found within the Roan Plateau Planning Area.

Finally, our overall fear is that the expansive and accelerated rate of development for oil and gas in Colorado and within this BLM Planning Area will ignore the devastating landscape scale consequences to fragile environments, to the cultural, the economic and the health of outdoor recreation for citizens of this state.

General ACEC Discussion.

1. Recognition of Roan’s Uniqueness.

The four proposed Areas of Critical Environmental Concern (ACEC) have been extensively described in both the Roan Plateau Plan Amendment (Management Considerations for Proposed Areas of Critical Environmental Concern, BLM, December 2002) and in the Roan Plateau RMP Amendment (Evaluation of Proposed Areas of Critical Environmental Concern, BLM, August 2002). Throughout both of these documents are phrases that describe the character of these ACEC’s as “rare”, “extremely vulnerable”, “high visual sensitivity”, “extremely fragile”, “unique niches”, “globally rare”, “only known populations to occur in the world”, “exceptional scenic qualities”, “irreplaceable significant viewshed”, “highly significant for biological diversity”, “providing critical and seclusion/security components…for many species”, “vulnerable to adverse change”, “biologically significant”, “national park quality scenic attraction”, “loss or impairment of this…would be irreplaceable”, “unusually rare”, “a rare community”, “found only in a handful of riparian areas…”, “rare community type”, “vulnerable to adverse change”, “unique and irreplaceable”, and “considered rare on a global and statewide scale”.

Based on the above samples of the many descriptions of the incredible attributes that occur within the Roan Plateau ACEC’s, TU would like to see that drilling be kept off the public lands atop the Roan Plateau. With the BLM’s assurances in the first Record of Decision for the Roan that authorize for an innovative and highly restrictive approach to oil and gas development, exploration and drilling can occur at the base of the Plateau and still contribute significantly to the revenue of Colorado and the nation’s energy supply. As a multiple use and natural resource management agency, there should be no reason why the BLM would allow the ultimate demise of such characteristics as those that occur on the Roan Plateau. That demise would most certainly occur, based on all the scientific and economic data thus far exhibited in countless testimonies and papers from citizens, communities, businesses, municipalities, organizations, and state and federal representatives.

2. Watershed and Fisheries Issues.

Trout Unlimited has strong concerns that development will affect the immediate and future watershed, the relationship of groundwater and surface waters, the fisheries component, and the overall health of an ecosystem currently untouched by the many insults that energy development will have in this area. More than 50 percent of our nation’s healthiest and most prized trout streams originate on public lands. And more dramatically, as of 2003, more than 15 percent of all trout habitat in Montana, Wyoming, Colorado, Utah and New Mexico falls within areas containing gas and oil reserves where could or is occurring (Gas and Oil Development on Western Public Lands, Trout Unlimited publication, Spring 2004).

In Colorado, more than 18 million acres (or 28 percent) could potentially be developed for gas and oil. The Roan Plateau is included in this figure. More than 90 percent of public comments received by the BLM and the leadership of six towns say they oppose large-scale drilling on the top of the Roan Plateau.

If the overall goal of the BLM’s management prescriptions for each potential ACEC is to “protect or enhance” the values for which the ACEC was defined, then it becomes apparent that the BLM will be challenged in meeting the criteria of Section 1613.22 if drilling is allowed on the top of the Plateau. BLM can still meet its mission by deferring leasing on top and allowing leasing at the base.

In its own document (RMP Amendment, August 2002) the BLM considers the entire Parachute Creek Watershed to be important to the long-term functionality of vital ecosystem processes which maintain upland and stream habitats important to the Colorado River Cutthroat trout (CRCT). Protecting the entire watershed and not just stream segments will be the only way to protect the populations of the sensitive CRCT. As has been described and recognized in many documents, including the BLM’s Planning document, the top of the Roan contains genetically pure populations of native, wild and naturally reproducing CRCT. These trout have been identified as core conservation populations and contain spawning areas that are extremely vulnerable to any sedimentation, water temperature fluctuations, and contamination.

This subspecies of cutthroat trout (Onchorhynchus clarkii pleuriticus) is the only native trout found in the upper portion of the Colorado River Basin and ranged at one time throughout the Colorado River Basin in coldwater streams and their reaches in Colorado, Wyoming, Utah, New Mexico and possibly Arizona (R. Behnke, 2002. Trout and Salmon of North America). The Colorado Natural Heritage Program (CNHP) includes the Parachute Creek Watershed in a Potential Conservation Area as well as ranking these streams/creeks within the watershed as “Very High Significance”. Headwater streams located in the Roan Plateau area are able to sustain these populations of cutthroat trout because the streams are very clear with low sediment loads and low turbidity. CRCT are highly sensitive to sedimentation and turbidity. Lack of or little data exists on impacts to coldwater fisheries from oil and gas productions. Further studies on wastewater discharges and sediment overloads associated with oil and gas activities are needed.(Confluence Consulting, Inc. “Annotated Bibliography of the Potential Impacts of Gas and Oil Exploration and Development on Coldwater Fisheries”, June 17, 2004. Prepared for Trout Unlimited.).

Development will cause increased turbidity, erosion deposition, and potential contamination from accidental spills. This would most likely eliminate the trout population, as witnessed by similar impacts on a pure CRCT stream in a tributary to LaBarge Creek, Wyoming in the 1970’s (Binns, Wyoming Game and Fish Department). An oil spill into the creek permanently removed the CRCT population and it has yet to recover. Spills are a common occurrence during energy production and reports to the Colorado Oil and Gas Commission reflect that. From 2005-2007 there were eight spill incidents in the Parachute Creek Basin that impacted surface waters. Multiply this amount with the increased planned drilling scenario and it becomes clear that even with current regulatory measures, there is the inevitable contamination factor that would lead to a decrease in CRCT survival and thus, eventual listing potential on the endangered species list.

Energy development means an intricate system of roads, pipelines, vehicle movement, dust pollution, noise pollution, storage facilities, loss of habitat, and water quality impacts. All of these factors impact the entire watershed planning area. Even with the proposed plan for tightly controlled energy development on top of the Plateau, the general topography and soil components of the Plateau will not be able to adapt to the impacts from energy development. Erosion from all of the above activity descriptions will occur and will deleteriously affect the quality of habitat and stream ecology of the area Energy development also means stream dewatering during the exploration and production process. The Roan contains many small perennial streams and in late summer and early fall, these stream flows are often less than 2 cfs. Removal of water for gas activities (either through wells or stream dewatering) would result in devastating effects to the populations of these sensitive trout species. Avoiding drilling on the top of the Plateau is the best choice for maintaining these critical fisheries and wildlife habitats.

The BLM also admits that the hydrology of the Roan Plateau is not well understood (BLM’s Evaluation of Proposed Areas of Environmental Concern, August 2002). This could easily spell catastrophe for an already defined Sensitive Species such as the CRCT, as well as for the entire watershed if drilling were to be allowed in an area that has such an unknown hydrologic background. Lack of knowledge on the impacts that drilling will have on the watershed’s hydrology will also impact the numerous sensitive plant species identified on the Roan Plateau. Many of these species (considered rare and unique) and their communities depend on the intricate hydrology that occurs on the Plateau. As stated in a recent TU publication (Gone to the Well Once Too Often, February 2007) it is a common misconception that ground water has no relation to surface water. It is extremely crucial to the survival of the entire Roan Plateau watershed system that the relationship of ground water and surface water be understood. Ground water provides much of the water that flows in streams and this is particularly true in semi-arid and low precipitation areas, such as those that exist on the Plateau.

The U.S. Geological Survey has noted that with the increase in the amount of ground water development for industrial purposes, impacts to ground water levels will result in significant declines. In fact, it was noted that in many areas of the West, ground water levels have declined 300 feet or more in the past 10 years (TU, February 2007; USGS). The over-pumping of ground water negatively affects fisheries and wildlife habitat by diminishing the surface water flows. Surface flows in the forms of rivers, streams, playas, and wetlands, provide important wildlife and fisheries habitat. This is especially true about the surface flow relationship on the Roan Plateau. Associated oil and gas (including proposed coal bed methane wells in the management area) development use vast quantities of water to assist in the extraction of the oil or gas product. Currently in Wyoming, coalbed methane (CBM) development is having a profound effect on water extraction. One well can produce 17,280 gallons per day and 6,307,200 gallons per year. This staggering amount of water extraction can be applied to proposed developments in CBM and oil shale development proposed in and near the Roan Plateau planning area.

3. Wildlife Impacts

Impacts from traditional oil and gas development to the ecology of an area are extensive. While the actual “footprint” of a well pad may be somewhat small, as mentioned earlier, the production of oil and gas involves by necessity, a wide-ranging and often massive infrastructure that includes roads, pipelines, transmission lines, heavy truck traffic, increased human population (including the most likely potential for man camps due to the area’s isolated nature), holding facilities and more. All this means wildlife will be impacted by the presence of this intrusion. Wildlife corridors and migration routes will be fragmented, ground and surface water supplies will be impacted, crucial riparian and meadow areas will feel the affects of this development. Important big game fawning and calving areas will be impacted and nesting raptors will not be able to avoid experiencing the impacts of such intrusion. All of these wildlife attributes are recognized and discussed as important elements within the proposed ACEC’s. The landscape scale interactions among wildlife, fisheries and habitat within the top of the Roan Plateau cannot be ignored.

Approximately 29 percent of Colorado’s mule deer habitat (14.5 million acres) falls within areas of potential gas and oil development (Colorado Division of Wildlife; TU Spring, 2003). Pronghorn habitat within Colorado is also impacted. More than 30 percent (or 9.6 million acres) of pronghorn habitat falls within areas of potential gas and oil development. Known for its largest population of elk in the Rocky Mountain West, more than 29 percent (or 15 million acres) of elk habitat falls within areas of potential gas and oil development. For the imperiled sage grouse, more than 28.1 percent (or 9 million acres) of sage grouse habitat falls within areas of potential gas and oil development.

The top of the Roan Plateau contains all of the above species as well as much of their transition routes, migration routes, nesting and brooding areas, cover and security areas. Placing the top of the Roan Plateau off limits to drilling makes environmental sense.

4. Economic Impacts

Healthy wildlife environments, including fisheries, are important parts of a healthy economy. Tourism, hunting, fishing, outfitting, and local businesses that benefit from those activities, all depend on healthy wildlife habitats. Without healthy habitats, wildlife would not exist, consequently affecting the economics of hunting, fishing and outdoor recreation.

Healthy fisheries, for instance, improves water quality, it mitigates droughts and floods, it increases ground water replenishment, improves wildlife habitat, maintains biodiversity and increases economic value through hunting, fishing, real estate and water availability. According to TU’s report The Economic Value of Healthy Fisheries in Wyoming (January 2005), healthy fisheries consist of the upstream and downstream waters of a flowing river; lands adjacent to the river, which include floodplains, riparian and upland areas; and ground water. These qualities can be applied to Colorado as well as quality fishing experiences are important to Colorado residents.

In 2002, hunting and fishing generated an estimated $1.5 billion for Colorado’s economy including $800 million in direct and $700 million in indirect revenues. According to the report Economic Impacts of Hunting, Fishing and Wildlife Watching in Colorado, the state fishing industry generated $460 million and hunting generated $340 million in direct revenues. Together, the industries supported some 20,200 jobs around the state. Wildlife watching, an activity often linked to other outdoor recreation, generated an estimated $560 million in revenues and an estimated $940 million in total economic impacts in 2002. Hunting on the Roan Plateau is an important activity for residents of Colorado. According to documents supplied by Garfield County, hunting is worth $3.8 million annually to the County.

In 2006, according to the U.S. Fish & Wildlife Service’s National Survey of Fishing, Hunting, and Wildlife-Associated Recreation, Preliminary Findings (May 2007), more than 87 million Americans or 38 percent of the U.S. population enjoyed some form of recreational activity relating to fish and wildlife. Expenditures for wildlife-related recreation by this group topped $120.1 billion. Close to 34 million people fished and hunted in 2006, spending $75.5 million on these activities. Nearly 30 million anglers spent $40.6 billion in 2006, with each angler spending an average of $1,357.

While the individual state data is not currently available, one can extrapolate based on Colorado’s hunting and fishing datasets. This is a significant economic contribution. And in many ways, the culture of hunting and fishing is more than about money and expenditures. It is about protecting and maintaining a culture and heritage associated with the past and the future of wildlife in our country.

Individual ACEC Discussion

1. Anvil Points

Anvil Points is comprised of 4,955 acres proposed as an ACEC for visual, wildlife, botanical and ecological values. Known for its “exceptional scenic quality”, the BLM recognized the public’s high sensitivity to landscape modifications to areas with high scenic values. Anvil Points is one of these places and the landscape alone is considered “extremely vulnerable to modifications”, according to BLM’s own documentation.

Anvil Points has wildlife values that are more than locally significant. The BLM considers this an important area due to the core of the area being identified as a Wildlife Seclusion Area in the 1999 Oil & Gas Forest Service FEIS. The Colorado Natural Heritage Program also identified this area as a Conservation Area due to its plant and raptor habitat values. The proximity to a variety of habitats found in the area, including the open, southern slopes which provides critical winter habitat for mule deer, make this area worthy of ACEC designation. Rare plants occur within this proposed ACEC and two of the five known (in the world) populations of Parachute penstemon occur in the Anvil Points area. Anvil Points’ grassland ecosystem is an important source for seed generation throughout northwestern Colorado. This economic contribution has impacts for the agricultural and reclamation field. Two stands of the aspen/Rocky Mountain maple community exist in this area and are considered rare due to the formation of a community between the two plant species.

The BLM described this area’s values in more detail, noting that, “most importantly, the unroaded nature of the area provides security among various habitat types that is important to many wildlife species. This area provides transitional and winter range for big game and is one of the few areas where migration routes exist from the top of the Roan cliffs to the lower slopes.”

“The entire area faces south, which is critical to mule deer during severe winters, as these areas are free from snow. The proximity of these open, southern slopes to higher density pinyon/juniper woodland habitats is also critical as a cover component. This mosaic of habitat types and their proximity to each other also provides important nesting areas for a variety of bird species and critical birthing habitats for many other wildlife species.” (Roan Plateau Planning Area Proposed Plan/Final EIS, pp. 3-112)

Anvil Points contains mesic aspen forests that are considered “globally rare” and provide good diversity and a productive understory crucial for wildlife survival, underscoring another reason why this is an incredibly important area for the big game populations that live atop and below the Roan Plateau. Providing winter, transitional and birthing habitat, along with one of the few migration routes between the high and lowlands, Anvil Points is an area that warrants full protection. Allowing development to occur in this area would be devastating to these populations. This area must be preserved and granted exclusion from leasing and development activities. Anvil Points should be off-limits for oil and gas leasing through a “no lease” decision.

2. East Fork Parachute Creek

The East Fork Parachute Creek area is comprised of 6,571 acres proposed as an ACEC for visual, wildlife, fisheries, botanical and ecological values.

The East Fork Parachute Creek is a small but biologically significant tributary to the Colorado River drainage. The creek flows westward across the plateau, and provides year-round habitat for Colorado River Cutthroat trout. The Colorado River cutthroat trout is the only native trout in the Colorado River basin, and has been designated a Special Status species by the BLM and is classified as a Sensitive species by Regions 2 and 4 of the US Forest Service, and the states of Colorado, Utah, New Mexico and Wyoming. This ACEC area is also identified as one of the five areas containing conservation populations identified in the Conservation Agreement and Strategy for Colorado River Cutthroat Trout in the States of Colorado, Utah, and Wyoming. This means these streams are given the highest priority for management and protection. Oil and gas development in this area will impact this Conservation Agreement.

The East Fork Parachute Creek ACEC contains two of the five conservation populations of Colorado River cutthroat trout found atop the plateau. These populations area at least 90% genetically pure, meeting the criteria for a conservation population, which is defined as follows.

“A reproducing and recruiting population of native cutthroat trout that is managed to preserve the historical genome and/or unique genetic, ecological, and/or behavioral characteristics within a specific population and within geographic units.” (Roan Plateau Planning Area Proposed Plan/Final EIS, pp. 3-114)

The BLM considers the entire watershed to be important to the long-term functionality of vital ecosystem processes which maintain upland and stream habitats important to these fishes (Roan Plateau RMP Amendment Evaluation of Proposed ACEC, pp. 16). Also, the BLM declared, “these streams are regionally and nationally important producers of native, genetically pure and naturally reproducing Colorado River cutthroat trout,” going on to proclaim that these streams should be given the “highest priority for management and protection.” (Roan Plateau RMP Amendment Evaluation of Proposed ACEC, pp. 16.)

Also within the East Fork Parachute Creek ACEC is First Anvil Creek. This tributary to East Fork Parachute Creek may have additional conservation populations of Colorado River cutthroat trout. (Roan Plateau Eligibility Report for National Wild and Scenic River System, pp.8)

The importance of these trout populations is clear, and in order to ensure that the subspecies continues to reproduce, recruit and ultimately exist, depends on the protection of this area. Moreover it is important to note that merely maintaining the status quo of these populations is not enough. Bolstering these populations of native trout by protecting habitat, improving water quality, and removing limiting factors on the rare and irreplaceable populations of Colorado River cutthroat trout is crucial to ensure the long term persistence of native trout on the Roan Plateau and throughout their historic range. Adding addition stresses from oil and gas drilling to this population of native trout, such as increased sedimentation, reductions in water quantity and quality, ground water flow alteration, and the increased likelihood of a spill, should not be authorized through leasing.

Other attributes contributing to this unique area include high scenic values that include a 200-foot canyon waterfall. The BLM has recognized the diversity of this area and described it on the level of a “national park quality scenic attraction”. Impacts from ground water extraction in this area have the potential to negatively affect this area and loss or impairment of this feature would be “irreplaceable”. A rare community of Mancos columbine and a BLM Sensitive plant (Eastwood’s monkeyflower) also are present in the unique hanging gardens that exist in this ACEC. Also rare are several plant communities such as the Colorado blue spruce/red osier dogwood and the boxelder, narrowleaf cottonwood, red osier dogwood community. These communities are considered rare on a global and statewide scale.

Restrictions, such as the NGD/NSO restrictions, especially with the two-year surface disturbing window allowed under the Final Non-ACEC RMP, are simply not adequate for the rare and irreplaceable fisheries, wildlife and plant resources present in this area. The only way to ensure that these Colorado River cutthroat trout populations are protected is to make the entire watershed off limits to oil and gas leasing through a “no lease” decision. This also means expanding the size of the ACEC to include the entire watershed, as sections of several tributaries and upland areas were left out of the proposed ACEC.

3. Magpie Gulch

Magpie Gulch is comprised of 4,698 acres of land proposed as ACEC for visual, wildlife, botanical and ecological values.

Exceptional scenic qualities contribute to this ACEC’s uniqueness. Again, Colorado’s public has indicated that full support is warranted for protection of this “irreplaceable significant viewshed” (BLM, August 2002). Old growth Douglas-fir, aspen, oakbrush, mixed mountain shrub, pinyon/juniper and sagebrush benches provide various habitat types which provide essential food, cover, water and security for wildlife. The Colorado Natural Heritage Program has ranked this ACEC area as a highly significant area for its biological diversity. High biological richness and diversity make these habitats important in providing summer, transitional, migratory, and winter range for Colorado’s big game species. The southern aspect of the area, along with pinyon/juniper and shrubs, provide critical habitats for mule deer during the winter months. Excellent raptor and cavity nesting bird habitat exists within this area. The area also provides habitat for nesting blue grouse populations.

The BLM has declared that, “Its unroaded nature provides seclusion among an array of habitat types important to a diverse grouping of species and is irreplaceable and exemplary in nature.” The BLM went on to conclude that, “This area is vulnerable to adverse changes, including habitat fragmentation and a resultant loss of species diversity.” (Roan Plateau Planning Area Proposed Plan/Final EIS, pp. 3-113)

The critical habitat that this area provides for mule deer and blue grouse, as well as a route from below the cliffs to atop the plateau, makes this area a top priority for conservation and preservation. The BLM has even stated that it is vulnerable to adverse changes and allowing any level of oil and gas leasing or development would compound the threat of these impacts. NGD/NSO restrictions and timing limitations are not adequate for protection of this area. This ACEC must be off-limits from oil and gas leasing.

4. Trapper/Northwater Creek

Trapper/Northwater Creek is comprised of 4,810 acres of land proposed as an ACEC for wildlife, fisheries, botanical and ecological values.

Trapper and Northwater Creeks are tributaries to the Colorado River drainage. The creeks flows westward across the plateau, and provide year-round habitat for Colorado River cutthroat trout. With the headwaters at the eastern edge of this ACEC, it becomes an important conservation area for the survival of the CRCT. Three of the five conservation populations of Colorado River cutthroat trout that exist atop the plateau are found within this ACEC. Included in these are Core Conservation Populations, identified by a genetic purity of 99% or higher.

The BLM considers the entire watershed to be important to the long-term functionality of vital ecosystem processes which maintain upland and stream habitats important to these fishes. (Roan Plateau RMP Amendment Evaluation of Proposed ACEC, pp. 19.) Also, the BLM declared, “these streams are regionally and nationally important producers of native, genetically pure and naturally reproducing Colorado River cutthroat trout,” going on to proclaim that these streams should be given the “highest priority for management and protection.” (Roan Plateau RMP Amendment Evaluation of Proposed ACEC, pp. 19.)

In 2002, the BLM declared that, “In addition to meeting the genetic purity criteria, fish located in Trapper and Northwater Creeks are thought to have significant biological adaptations unique to the habitat in which these fish reside. These populations of cutthroat are known to persist in the summer when water temperature in portions of the stream approach and exceed 80 degrees Fahrenheit.” (Roan Plateau Eligibility Report for National Wild and Scenic River System, pp.8.)

The nearly pure genetic populations of Colorado River cutthroat trout that exist in this area are irreplaceable, and cannot be dependent on NGD/NSO restrictions that are subject to exceptions allowing surface disturbances and waivers. Oil and gas leasing must be off-limits in this area.

It is important to note that while the Trapper/Northwater Creek ACEC has been proposed to help protect the rare and irreplaceable Colorado River cutthroat trout, for which this system is a stronghold, a vital element of protection has been left off of the proposed ACEC. Upstream from the parcel of private land located in the upper Northwater Creek drainage, the watershed is not included in the ACEC. This glaring omission threatens nearly all of the Northwater Creek and a significant portion of the Trapper Creek populations of Colorado River cutthroat trout. Aquatic insect and trout egg choking sediment caused by surface disturbing activities associated with oil and gas development, and toxic effluent in the event of spill, all flow downstream. For this drainage, downstream means the best Colorado River cutthroat trout habitat in the Trapper/Northwater Creeks drainage. It is here, after the confluence of Trapper and Northwater Creek, that Trapper Creek attains its greatest volume and provides necessary flows and depth to maintain suitable Colorado River cutthroat trout habitat in the face of higher water temperatures and low flows brought on by drought. Leaving the upstream portion of the Northwater drainage open to development without the protection of an ACEC would be irresponsible, and compromise the integrity of Colorado River cutthroat trout populations in the entire system. In order to protect this sensitive resource, TU recommends that a “no lease” decision be made for the entire Trapper Creek watershed, including the entire Northwater Creek watershed.

Furthermore, within the Northwater Creek watershed the parcel of private land is split estate with Federal minerals. The land management decisions applied to this area will directly affect most of Northwater Creek downstream and some of the best habitat for Colorado River cutthroat trout downstream in the Trapper Creek system. This parcel of private surface/Federal minerals is located near the headwaters of Northwater Creek, thus subjecting the watershed health of the Trapper and Northwater Creeks downstream to surface disturbances, including erosion, on these lands. Poor land management quite literally flows downhill and this area must be under the same consideration as the ACEC adjacent to it. While the BLM cannot manage the surface of this private land, BLM has the discretion not to lease the federal minerals under this split estate. Because of the downstream effects and harm posed to watershed health that drilling on this parcel of private land would have on Colorado River cutthroat trout, Trout Unlimited recommends that for this split estate, a “no lease” decision apply.

Conclusion

Trout Unlimited recognizes the vital role oil and gas activities have both to Colorado and the nation. However, citizens of the West are losing more and more valuable public recreation and wildlife habitat to oil and gas development with little emphasis on protection of these irreplaceable lands for the future.

It is important to TU and to its membership that the BLM seriously consider landscape scale protections that do not include patches of oil and gas development. Studies across the West are showing that oil and gas development negatively and often permanently impact wildlife habitats, wildlife populations, and eventual community and state economies. Permanent protection measures for the top of the Roan Plateau should be applied. There are some places that should be off limits to energy development.

Thank you for the consideration of these comments.

Corey Fisher

Cathy Purves