Concerns:

• The draft rule’s preferred alternative doesn’t go far enough in protecting the most pristine roadless backcountry known as the “upper tier” category. The preferred alternative  simply designates lands as upper tier that  already had road building prohibitions in their respective forest plans.  There are up to two million additional acres home to native cutthroat trout, elk calving grounds, and other ecologically important areas.
• The prior version of the rule required a finding that the activity “would not diminish conditions in the water influence zone and in native cutthroat trout habitat” in native cutthroat trout watersheds. The latest version adds the words “over the long term” which could leave the door open to degrading activities and ambiguous interpretation by land managers which allows native cutthroat watersheds to deteriorate in quality for several undefined years, possibly causing the extermination of  fish in the area.
• The prior version of the rule limited “linear construction zones” (LCZs) in upper tier ares to only oustanding prior rights. The new proposal allows LCZs for water conveyances, utility corridors,  and oil and gas pipelines within all roadless areas. The proposal also fails to address the potential for diminishing roadless area characteristics with things like powerlines, pipelines that could be built within LCZs.
• The proposed rule does not require No Surface Occupancy (NSO) stipulations for Oil and Gas development in areas designated upper tier. This could allow well pads, roads, etc in the highest value roadless areas.
• The former Colorado petition would have required the Forest Service not to grant waivers for road-building and NSO stipulations while the new proposal only limits waivers.  
• The Pike-San Isabel National Forest has no upper tier acres in the preferred alternative. And, both the Routt and Rio Grande National Forests have less than five percent of their respective roadless acres proposed as upper tier in the preferred alternative.

Please submit detailed comments regarding your ideas for roadless management in Colorado. Here are some key concepts and points to mention (Information on where to send comments found on the Home page).

Recommendations:

• Tell the Forest Service to adopt the conservation alternative (Alt. 4). This alternative would protect 2.6 million acres in the upper tier category and safeguard fish and wildlife.  Tell them of your favorite places (use names), why they are important to you, and use anecdotal evidence i.e. stories of  hunting and fishing trips, the importance of these areas to your municipal watershed, family traditions, etc.
• Tell the Forest Service to protect roadless areas with NSO stipulation and not to grant waivers. This will keep development from disturbing the surface inside roadless areas and creating harmful impacts such as erosion, invasive species, habitat fragmentation, damage to waterways, and visual degradation.
• Tell the Forest Service to keep Linear Construction Zones (LCZs) out of upper tier areas.  Upper tier areas are the best of the best lands in the state of Colorado. These areas are too valuable to allow any new development. Tell the Forest Service that these areas should be off limits to any kind of development.
• Tell the Forest Service you want strong language that requires any project in a roadless area to maintain the viability of fish and wildlife populations throughout the duration of the project.  The above-mentioned language regarding cutthroat trout does not require that projects refrain from harming fish and wildlife during the project, only that they retain conditions over the long term. This could allow populations to be exterminated even if the conditions we’re returned to pre-project conditions years after the project was complete.
• Tell the Forest Service that any project approved in roadless areas should be required to restore roads and other disturbances to pre-project conditons  using native plants appropriate for the area and techniques that limit the impact on fish and wildlife.
• Relay the importance of the outdoor economy and the reliance of local communities on hunting, fishing and wildlife viewing dollars that wouldn’t be possible without pristine public lands. Hunting, fishing and wildlife viewing contribute nearly $2 billion and over 20,000 jobs annually to Colorado’s economy. Additionally, over 50% of all native cold water fisheries habitat in Colorado is in roadless areas and the to 15 most hunted game management units are all over 50% roadless.
• Remind the Forest Service that 16,000 streams originate in Colorado’s roadless backcountry and provide much of our drinking water, recreational opportunities, and fish and wildlife habitat.
• Remind the Forest Service that the Pike San Isabel, Routt, and Rio Grande National Forests have tens of thousands of high value roadless backcountry acres that are worthy of upper tier protections and not to leave them out of upper tier designation.