March 23, 2000

Dear Interested Citizen:

The Bureau of Land Management (BLM) has completed the Roadless Review and Wilderness Character Inventory for 3 Units on the Roan Plateau northwest of Rifle, Colorado. An analysis of the public comments received is enclosed and the final inventory results are shown below.

After the field inventory two minor changes in the preliminary findings were made by the BLM inventory team in the Northeast Cliff Unit.

1. A small boundary adjustment was made along the JQS Rd in the southwest corner of the unit due to a mapping error. The total acreage of the Northeast Cliff unit was increased by 22 acres because of this adjustment
2. In addition, 5 new vehicle routes were identified and determined to be ways along the western boundary. The new routes did not affect the overall findings for this unit.

The inventory findings do not change current BLM management direction for these areas. However the collected inventory information will be used when the Glenwood Springs Field Office amends the Resource Management Plan for the Roan Plateau.

Currently, we plan to initiate focus group discussions in June with community residents, community leaders, and interest groups as part of our preplanning process for the Roan Plateau planning area. We plan to publish the Notice of Intent to prepare an EIS and RMP amendment this October and initiate formal public scoping.

The land use plan will consider many options for management of these areas, including the possibility of administrative Wilderness Study Area designations. There will be numerous opportunities for public involvement during this process. Public meetings and comment periods will be announced through mailings, news releases and Federal Register Notices.

If you would like to receive a copy of the final Roadless Review and Wilderness Character Inventory for these areas, or if you have questions, please contact Kay Hopkins at the address above or phone 970-947-2812. The final Wilderness Character Inventory findings, along with maps and photographs are also available on BLM’s internet web site @ http://www.co.blm.gov/news/gswildinven.htm

Sincerely,

Steve Bennett
Acting Field Office Manager

ANALYSIS OF PUBLIC COMMENTS

Roadless Review and Wilderness Character Inventory

for the Roan Plateau including:

East Fork Unit, Trapper Creek Unit, and Northeast Cliff Unit

March 22, 2000

Introduction: Copies of the preliminary findings were mailed to 94 individuals and organizations. The comment period for the Roan Plateau Roadless Review and Wilderness Character Inventory was from September 20 to October 20th. An open house was held on October 4th in Rifle, Colorado. The open house provided the opportunity to share information, answer questions, and gather comments relating to the inventory findings (25 people attended).

In order to ensure that the inventory considered all current and relevant data, the BLM asked for information that may not have been considered in the preliminary findings regarding:

1) the presence or condition or use of man-made structures, facilities, or vehicle routes:

2) outstanding opportunities for solitude or primitive and unconfined recreation; and

3) supplemental values such as rare or endangered plants or animals, unique natural features, or scenic values.

A web site was also available for review on September 20th . This site provided wide exposure to the same information as the mailing.

SUMMARY:

While the BLM requested specific information as described above, only 3 letters out of the 78 letters received specifically responded to those three types of information. All three comments were related to vehicle route maintenance.

Most comments received addressed future land use planning decisions. The inventory is NOT a decision making process but is simply information acquired for use in future planning and decision_making. Land use allocation decisions will be made in the Resource Management Plan (RMP) amendment process. In the analysis for the amendment, tradeoffs can be more accurately assessed and interests or opinions can be more appropriately considered (in an appropriate range of alternatives).

Although outside the scope of the information requested the preliminary findings showed ninety two percent of the comments supported management of all 4 units as WSA’s, and felt the areas needed to be managed for wilderness values. They also supported managing all lands in the Citizens’ Wilderness Proposal (CWP) for wilderness values. Six percent were opposed to the Wilderness Character findings and/or WSA status. One percent did not indicate a preference either favoring or opposing.

Eighty three percent of the responses came from people out of the county but within the state, Six percent of the responses were from within Garfield county, Four percent were from out of the state and Six percent did not include a mailing address.

Subsequent to the comment period, two ranchers and one commercial outfitter have provided additional information and documentation specific to road determinations regarding maintenance actions that have been disputed. Such information is consistent with the team’s findings to date.

SPECIFIC COMMENTS AND RESPONSES:

COMMENT: Many comments were received regarding the lack of a comprehensive management plan for the Roan Plateau and past management practices.

RESPONSE: The Roan Plateau formally known as the Naval Oil Shale Reserve was recently transferred from the Department of Energy(DOE) to the Bureau of Land Management(BLM) in November of 1997. Prior to this transfer BLM cooperatively managed only some surface uses(ie grazing and recreation). Since the transfer, the BLM is now directed to manage these transferred lands for multiple uses under Federal Land Policy and Management Act of 1976 (FLPMA).

An inventory of wilderness characteristics for the Southeast portion (also known as the SE Cliff Unit) of the NOSR including the Production Area was already completed by the BLM and documented in a Final Supplemental Environmental Impact Statement (SEIS) for Oil and Gas Leasing and Development, dated January, 1999. The NOSR Production Area will be managed consistent with those findings and the Record of Decision and Resource Management Plan Amendment dated March, 1999. In accordance with those findings and legislation transferring these lands to the BLM the Production Area was leased for oil and gas in 1999.

However, in the upcoming land use planning for the Roan Plateau the BLM will look at all existing data for the lands being included in the RMP amendment outside of the Production Area. Consistent with increased public interest the BLM will re-inventory lands within the Southeast Cliff Unit not included in the NOSR production area. The additional inventory will be conducted in May of 2000 and will be limited to that portion of the Southeast Cliff Unit outside of the NOSR Production Area.

Until the land use plan for the Roan Plateau area is completed, all remaining lands outside of the Production Area will be managed under the current Resource Management Plan (RMP) for the Glenwood Springs Field Office. Certain actions not addressed in the current RMP, like oil and gas leasing and designations of WSA’s will be deferred, pending the RMP amendment.

Current plans are to initiate focus group discussions in June with community residents, community leaders, and interest groups as part of the preplanning process for the Roan Plateau planning area. The BLM plans to publish the Notice of Intent to prepare an EIS and RMP amendment this October and initiate formal public scoping.

COMMENT: How will the BLM manage all the CWP areas in federal legislation included in the Colorado Wilderness Act of 1999(H.R. 829), in the interim until Congress decides on an action or until the land use planning process is completed?

RESPONSE: Given the pending RMP amendment, BLM will defer any management decisions that may preclude appropriate protection measures for natural and supplemental values found within any of these areas meeting the roadless and wilderness character criteria.

Specifically, CWP areas that were found to have Wilderness Character (WC) will be managed to prevent irreversible and irretrievable impacts and to maintain present natural and supplemental values. The BLM will use a notification process defined in Colorado BLM policy IM-CO-99-013, dated February 10, 1999. This policy requires BLM to notify a list of wilderness constituents on any proposed action within CWP areas or WSA’s.

For areas that were found not to have Wilderness Character (NWC), the BLM will notify all interested parties when NEPA documents are being prepared for proposed projects. For new actions proposed the BLM will also consider an appropriate range of alternatives through the NEPA process to address issues raised during the inventory. The BLM will address impacts of all proposed actions on natural and supplemental values. Any decisions to implement new proposed actions will depend on impacts and the ability to address issues raised in a timely manner.

COMMENT: A number of comments questioned the findings that some areas lacked wilderness character because of isolated range developments and/or infrequently used and non-maintained routes.

RESPONSE: The BLM supported a team process that involved a spectrum of knowledgeable participants. The team followed the same criteria and process used in all other BLM wilderness inventories. These procedures were defined in the 1978 BLM Wilderness Inventory Handbook and elaborated on in the 1997 Colorado Wilderness Review Procedures. The findings were developed by the BLM based on the criteria defined in this handbook and statewide guidance which are available for review at any BLM office.

Areas that did not meet the naturalness criteria at the time of the inventory cannot, by definition, be said to have wilderness character. Naturalness as defined in the review procedures is an area that has been affected "primarily by the Forces of Nature." and an area that "...generally appears to have been affected primarily by the forces of nature with the imprint of man’s work substantially unnoticeable." The presence of 85 developments in East fork and 56 in Trapper Creek unit did affect the teams findings. Some portions of the units were found to have substantially noticeable imprints based on range developments and their associated routes, while in other areas the cumulative effects of numerous developments, routes, or other substantially noticeable imprints impacted an areas naturalness as a whole.

The road definitions used were the same definitions used in all other BLM wilderness inventories. Determinations were made on 41 routes in Trapper Creek Unit and 55 in East Fork Unit and 5 within the Northeast Cliff Unit.

The impact of a route on naturalness is independent of it being determined to be a road or way. Of the 31,540 acres reviewed, the team concluded that 27,299 acres, nearly 87%, were determined to be roadless. The determination that certain areas did not possess wilderness character was based primarily on the cumulative impacts of routes and range-related developments(41 in TC and 55 in EF). Thus, the team’s road/way determinations had little bearing overall on the wilderness characteristics evaluated on the Roan Plateau.

COMMENT: Several comments were received regarding current OHV and travel management problems and the need for future transportation planning.

RESPONSE:

The determination of routes, as roads or ways, does not decide their future designation as part of the transportation system. The inventory only identifies "roadless" areas that may be considered for WSA designation through the land-use planning process. Decisions on which vehicle routes will be open and which will be closed will be made in future planning and through environmental analysis. Numerous opportunities for public involvement will be provided at that time.

To protect resources from off-route, cross-country travel, the BLM is planning to implement a temporary travel order this year. The emergency travel order will be in effect until completion of a land use plan amendment that analyzes travel needs in accordance with a preferred management strategy.

COMMENT: Numerous comments recommended the restoration or rehabilitation of areas so they would meet the Wilderness Criteria.

RESPONSE: A wilderness character inventory identifies only the current on-the-ground condition of the lands in question. In the upcoming land use planning process many options for management of these areas will be analyzed.

COMMENT: Most comments referred to the global significance of the diverse ecological values present on the Roan Plateau and wanted these valuable resources protected.

RESPONSE: Through the land use planning process the BLM will analyze ways to protect these valuable resources. Some possible designations could include but are not limited to Areas of Environmental Concern(ACEC), Wild and Scenic River and Wilderness Study Area(WSA) and Research Natural Area(RNA).

COMMENT: One comment asked the question about access to a private inholding within areas being considered for wilderness.

RESPONSE: Access to a private inholding would be permitted because it is a valid existing right. New rights-of-way may be approved to private inholding’s. The BLM is required by law to provide reasonable access. In determining adequate access the BLM has discretion to evaluate some of the following: reasonable alternatives, methods of construction and degree of development, reasonable terms and conditions that will protect the public interest.

COMMENT: What possible effects could Wilderness designation have on air quality issues around the Roan Plateau?

RESPONSE: The 1977 Clean Air Act established 120 mandatory Class I areas (existing Wilderness Areas at the time of the act); most of the remainder of the United States was designated as Class II. An amendment in 1990 to the Clan Air Act established procedures for state air regulatory agencies to re-designated areas. Nationally only four areas have been re-designated to Class I areas, which were done by tribal governments.

The management of Federal lands as Wilderness does not change those lands air quality status. Of the nearly 625 current Wilderness Areas, only 120 were designated as mandatory Class I areas back in 1977 and over 500 Wilderness Areas have no special air quality regulatory status.