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Date: 8/29/2018
Subject: NEED COMMENTS NOW - GMUG NATIONAL FOREST INVENTORY OF WILDERNESS CHARACTER WOEFULLY INADEQUATE
From: COLORADO OFF-HIGHWAY VEHICLE COALITION




NEED COMMENTS NOW! 
GMUG National Forest Inventory of Wilderness Character Woefully Inadequate

The GMUG National Forest is working towards recommending Wilderness areas in forest plan and they need to hear from you regarding your support for multiple use opportunities in the Forest. The current inventory and evaluation addresses why an area could be Wilderness, the evaluation completely fails to address why an area should not be Wilderness, including previous Congressional actions,  and fails to provide the reasonably broad and inclusive discussion around these issues to be provided in this stage of planning. 
 
More information on the Proposal
https://usfs.maps.arcgis.com/apps/MapSeries/index.html?appid=f79028627ef64aa49c906088b 59b6020  

Our position is:

1. The GMUG Wilderness evaluation does an exceptional job identifying why an area could be suitable for designation but fails to provide any information regarding federal legislative
conclusions and other uses weighing against designating the area as Wilderness. This falls well short of a transparent and open discussion with the public on these areas required by USFS regulations. 

2. While there are numerous activities, such as groomed winter trails in many areas inventoried for Wilderness, none of these uses are mentioned in the inventory. 

3. Forest Service Handbook 1909.12 §72.1(5)(c) mandates managers must evaluate specific federal laws relevant to the availability of the area as “Wilderness”. Congressional action on GMUG planning area has included  extensive discussions of why particular Wilderness area boundaries are in a particular location.  The previous release of an area or reasoning for a Congressionally drawn boundary are federal law and at no point are these actions even mentioned in the inventory despite this information being highly relevant to the availability of the area for future designation. 

4. In the 1980 and 1993 Colorado Wilderness Acts, Congress mandated  no buffer areas around Fossil Ridge, Collegiate Peaks, Uncompahgre, Powderhorn and Raggeds Wilderness areas but this restriction on Wilderness designation is omitted in the inventory. Many parcels such as G14, G15, and G24 which are adjacent to these Wilderness areas identify the parcels  ability to serve as a buffer to the adjacent Wilderness  areas as a positive factor for listing without even mentioning the Congressional restriction on buffers. 

5. Pursuant to section 101 of the 1980 Colorado Wilderness Act, lands on the GMUG not previously designated were to be made available for non-wilderness multiple use.  Clearly that is a provision of federal law that is relevant to the availability of lands for future designations.  This provision and areas subject to such a restriction is never mentioned in the inventory. 

6. The entire GMUG was inventoried for possible designation as upper tier roadless areas in 2012 and a significant portion of the GMUG was declined for this lower level of designation.  This reasoning for not listing is clearly an existing right that must be addressed under handbook section 72.1(5)(b).  Failure to address these conclusions opens the door for possible identification of areas as recommended Wilderness in the RMP that were recently identified as unsuitable for Upper Tier designation. 

7. Citizen Wilderness proposals designating Wilderness on the GMUG such as the San Juan Wilderness Legislation have been proposed for more than a decade and never moved.  This is evidence of the lack of support for the San Juan Legislation and this long history of Congressional inaction must be addressed in the evaluation.

8. While Managers fail to recognize previous Congressional Action and extensive USFS inventory for possible upper tier roadless designations on the GMUG inventory and evaluation processes, Gunnison Public Lands Initiative is recognized for evaluation, despite the fact there has been no analysis of level of support and no Congressional action whatsoever regarding this proposal. How did managers determine GPLI was suitable for inclusion in the plan while previous Congressional action was not?   

9. We are completely unaware of a “Citizens Conservation Proposal” Wilderness  for the GMUG.  Land managers need to explain what this document even is, how it was vetted and found sufficient to move forward in the evaluation and inventory process before listing it on the inventory mapping for the Forest.   

Written Comments:
GMUG National Forest
Att: Planning revision team 
2250 South Main Street
Delta, CO 81416

Electronic Comments via portal: https://cara.ecosystemmanagement.org/Public/CommentInput?project=NP1810

Email comments:
gmugforestplan@fs.fed.us

Deadline for comments September 5, 2018




Colorado Off Highway Vehicle Coalition
P.O. Box 741353
Arvada, CO 80006

518-281-5810

info@cohvco.org

 

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