CWF-NWF has posted our comments on the State's revised draft Colorado Roadless Rule (CRR).  The full text of the comments is posted in their entirety at www.coloradowildlife.org   It appears on the home page under Our Stand. 

CWF believes the implementation of a roadless rule that is best for Colorado is essential for the conservation of wildlife, including threatened, endangered and sensitive species, U.S. Forest Service Management  Indicator Species terrestrial species, and aquatic species in Colorado.  The Colorado Division of Wildlife has noted the importance of roadless areas as necessary to conserve the values and characteristics essential to the success of the Division's wildlife management mission,  and the future of the state's wildlife resource and the sustainable economies dependent upon abundant natural resources.  There is strong public support for continued robust protection of roadless areas on National Forest System lands within Colorado, including the hunting, fishing and wildlife viewing public who rely on those lands not only for recreational use, but also for the habitat they provide to maintain populations of a variety of important wildlife and fish species.  Professional scientific data from the Division of Wildlife submitted to the Task Force provide overwhelming evidence of the value of roadless areas for a large number of game and nongame species important to Coloradoans and visitors.  The essential wildlife habitat values provided by Colorado's approximately 4.1 million acres of Inventoried Roadless Areas are irreplaceable.  

The 2001 Roadless Area Conservation Rule provided important, broad protection for these acres of roadless areas in Colorado. We strongly support the basic intent and purpose of the 2001 roadless rule. As wildlife conservation organizations, we also recognize that there have been important changes in the state's landscapes, forests and streams  that have inevitably occurred since the 2001 rule was developed nearly 9 years ago.  The 2009 proposed CRR addresses some of these new realities but also needs to undergo some strategic revisions.   New realities addressed by the CRR include: 

     -- The proposed CRR addresses the significant problem of roadless area impairment due to development of existing oil and gas leases, an issue that the 2001 Roadless Area Conservation Rule failed to fully address.

     -- The proposed CRR includes major boundary changes recommended by Division of Wildlife managers that would protect 410,000 acres not included in the 2001 rule.

     -- The CRR would allow additional boundary changes that are restricted under the 2001 rule.

     -- The CRR would eliminate the "construction zone exemption" identified in the 2001 rule by the 10th Circuit Court of Appeals.  The 2001 rule includes a loophole that potentially could be used to advance any kind of construction project that did not require a road. 

     -- Exceptions for roads to access grazing allotments also would be eliminated under the CRR.

For the 2009 proposed CRR to protect Colorado's roadless areas, however, it is important to make selected strategic revisions.   While we recognize and appreciate several significant improvements in the State's current version since the Forest Service's draft rule (July 2008), the proposed CRR is deficient in its use of some unsupported and ill-defined exceptions that undermine the stated goal of conserving roadless area values.  These necessary revisions include:

     -- Much stronger protections for roadless areas between 1/2-mile and 1-1/2 miles from communities at risk for catastrophic wildfire.

     --A much tighter definition of what an "at-risk community" is under the CRR.  The current language in the 2009 rule is much too vague.

     --Overly broad allowances for road construction for coal mining in the North Fork area.  We are especially concerned about mining the Currant Creek area, an area with intact wildlife habitat and a migration corridor that the Division of Wildlife has specifically recommended for roadless protection.

     --Removal of 8,200 acres from roadless protection for potential ski-area development.

See www.coloradowildlife.org for the comment letter's sections that address several specific issues in the proposed CRR, and recommend some alternative rules that we believe would better fulfill the State's stated purpose to "provide greater management flexibility under certain circumstances to address unique and local land management challenges, while continuing to conserve roadless values and characteristics."

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For information on the Clean Water Restoration Act and Little Snake Resource Management Plan, see the home page of this website and click on the issue.

Colorado Oil and Gas Rules

Wildlife gained minimum protections in "sensitive wildlife habitat" in new rules adopted by the Colorado Oil and Gas Conservation Commission on December 10.  The rules were approved by the General Assembly'in March and signed by Governor Ritter on April 22.    The new rules became effective for new applications for permits to drill on private land on April 1, 2009 and on federal public lands managed by the BLM and US Forest Service beginnning on July 1, 2009.  The rules are posted on the website of the Colorado Oil and Gas Conservation Commission.

Oil Shale Research, Development and Demonstration (RD&D) Program 

CWF supported Secretary  Salazar's decision in February to withdraw the second round of  RD&D leasing on federal public lands in the Piceance Basin [northwest Colorado] that the BLM had proposed in November 2008.    In his February announcement the Secretary decided to invite public comment as to whether a second round of RD&D leasing should take place.   CWF submitted its comments on May 27 in conjunction with the National Wildlife Federation and the Wyoming Wildlife Federation.  CWF believes that a second round of federal leases would be premature because oil shale research on the existing federal public lands leases aer still in an early stage.  Water requirements and impacts are a central issue.  Water requirements must be known for large scale commercial development of oil shale in terms of direct production and electric power.  In addition, what will be the impact on streams during cyclical droughts and otherwise? Energy companies have pruchased water rights in the Colorado and White River Basins.  These rights are located in the PIceance Basin.  What would be the effect on agriculture and communities in northwest Colorado?  As to wildlife, the Piceance Basin would experience cumulative impacts from gas development plus oil shale.  The Piceance Basin is home to rich wildlife resources.   The comments are posted on the CWF website www.coloradowildlife.org on the home page under News.

Big Thompson River Fishing Access

Larimer County officials had been moving at what seemed to be an alarming rate, to dispose of steam access along the Big Thompson River that is owned by the County.  many of these parcels have been available to the public for fishing access for more than 30 years.    Due to the hard work by CWF, in conjunction with Friends of the the Big Thompson led by Wlat Graul, who also is the CWF Issues Committee Co-Chair, the County agreed in late April to retain 700 feet of river at Drake, with a buffer strip to the east side.  Earlier the County agreed to retain six areas and a key gruop of parcels in another area on the North Fork of the Big T.   As adjacent landowners sought to gain control of all of the riverfront land, we all have succeeded in preserving a significant amount of river access. Stay tuned as this is not the end.  There are two areas on the North Fork and three on the main river that the County originally proposed to retain but remain at issue.

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