July 5th 2011
Re: Colorado Roadless Rule: Upper Tier Concept
To Whom it may concern:
The Colorado Mule Deer Association (CMDA) is very concerned with the proposed Colorado Roadless Rule in regards to the Upper Tier Concept. The Upper Tier Concept as proposed in Alternative #2 and Alternative #4 places restrictions on management of our national Forest in Colorado and puts Colorado communities at risk. Alternative #2, Upper Tier Concept proposal, which encompasses over 500,000 acres, restricts protection of towns and communities by reducing the fuels fire reduction safety barriers by 13%. With the constant threat of wildfires, the CMDA firmly believes that such restrictions on the ability of homes owners, townships and communities to protect themselves from such fires would be negligent on the part of the Forest Service. We are currently seeing the results of not implementing fuel reductions within this state with the number of wildfires destroying thousands of acres and a number of homes.
Alternative #4, which encompasses over 2.4 million acres, would endanger more than 200 townships and communities. It reduces the fire fuel reductions by 52%. With the Pine Beetle infestation covering over 3 million acres in Colorado and the fact that Pine Beetle killed forest lead to more dangerous wildfires (earthtimes.org article on Pine Beetle Forest), it would be improper to incorporate the Upper Tier Concept into the Colorado Roadless Rule.
The Upper Tier Concept also restricts the professional managers at the Forest Service from managing the forest that is in their charge. The Upper Tier Acres in Alternative #2, has not gone through any public involvement process concerning three of our states major forest, that being the San Juan, Grand Mesa and the Uncompahgre National Forest. Without public input Alternative #2 becomes invalid. The Forest Service must work collaboratively with the public on fire reduction plans in the above mentioned forest to keep our forest healthy.
In Alternative #4, the Upper Tier Concept prevents habitat improvements for T&E Species as well as Game Species. Many Colorado species depend on early and mid seral habitats and these habitats need active management. Big Game Species such as Elk, Deer, Bear and Turkey need habitat restoration treatments to ensure the availability of healthy forage. In this time human population growth, viable wildlife habitats become more crucial. Currently there are a number of Restoration Initiative projects planned within the proposed Upper Tier Areas. These Restoration Initiatives are important for reopening wildlife migration corridors and creating revitalized habitats.
Alternative #4 Upper Tier areas would prevent Public Water entities from reconstruction and maintenance of water reservoirs by prohibiting the construction of access roads. Those entities that hold Mineral Rights within the Upper Tier areas would be restricted from extracting them due to the prohibition on road construction. Some of the precious minerals and rare-earth-metals within the Upper Tier are essential to our Nationís economic lively hood and our National Defense. It is vitally important that they remain accessible. http://www.raremetalblog.com/2011/01/colorado-part-of-new-gold-rush-for-rare-earth-metals.html
In effect, Alternative #4 would turn 2.4 million acres into wilderness without the vote of a single Congressman.
The Colorado Mule Deer Association is in firm support of the 2008 Colorado Roadless Rule with the exclusions of the Upper Tier Concept.
Colorado Mule Deer Association
Board of Directors