Write Your Own Letter – Writing Points
Send comments to:  Roadless.Comments@state.co.us, or send hard mail comments to:  Roadless Comments, Colorado Department of Natural Resources, 1313 Sherman St. Room 318, Denver, CO 80203.  Your comments should be e-mailed or postmarked by October 2, though comments arriving a few days later will probably be accepted. Consider making the following points in your letter:

• State why national forest roadless areas are important to you. Note values such as wildlife habitat for wide-ranging wildlife species, outstanding recreation, and watershed protection. if you visit such areas, describe them by name and/or location and also describe what activities you undertake there.

• Request that the following improvements be made to the proposed Colorado Rule:

1. Logging and road construction in roadless areas can be allowed only where treatment would truly help protect communities from wildfire, i.e., those areas within several hundred feet from communities.

2. New electrical lines, pipelines, dams, and reservoirs must be prohibited in roadless areas.

3. An entirely new coal mine and associated roads and structures in the Currant Creek Roadless Area must not be allowed.

4. Roadless lands with potential to be made into ski areas must remain in the roadless inventory and be protected, as with other roadless areas. You can specifically mention that the Game Creek Roadless Area near Vail, which has very important wildlife values, must remain in the roadless inventory.

5. All lands that qualify as roadless must be included in the inventory and be protected.

• With reinstatement of the 2001 Rule, which strongly protects roadless areas everywhere except Idaho and part of Alaska, there is no need for a state rule. Ask Colorado to abandon its   rule unless it provides protection equal to or greater than that of the national rule. Such a State rule must include, at a minimum, all of the provisions listed above. Note that the current state rule would provide Colorado’s roadless areas with less protection than those in almost any other state.

Background:
Conservationists, hunters, and anglers rejoiced recently when a Federal court in California reinstated the 2001 Roadless Rule nationwide. This rule provides strong protection for National Forest roadless areas. Even so, Colorado is still preparing a separate Rule, which contains broad loopholes that would allow a variety of destructive activities. We need your letter to help prevent the State’s rule from ever becoming final.

The State’s latest rule is an outgrowth of a Bush Administration regulation under which states were allowed to craft their own rules for management of national forest roadless areas within each respective state. That replaced a Clinton Administration rule, the 2001 Roadless Area Conservation Rule, which provided a good deal of protection for all roadless areas nationally. The recent court ruling invalidated the Bush Rule and reinstated the 2001 Rule; however, Colorado can still legally develop its rule, and it could go into effect some time in the future.

There are five main components of the proposed Colorado Rule that we oppose, and that illustrate how the proposed Rule is significantly weaker than the 2001 Rule that we support.

1. Unlimited Logging for Community Wildfire Protection: While we strongly support appropriate science-based fuels reduction to reduce the threat to people and property, the proposed Colorado Rule instead allows virtually unlimited logging and road building under the guise of fire risk reduction far (up to 1½ miles) from homes and infrastructure. Additionally, a separate loophole could result in logging and road building even farther into the backcountry. These overly broad exemptions could allow more than 660,000 acres of roadless areas to be roaded and logged statewide.

Research conducted by the Forest Service and independent scientists suggests that only a small portion of this area needs treatment to provide sufficient protection for adjacent communities. The Colorado Rule unnecessarily places more than a half million acres of roadless forests under threat of industrial logging and road construction in areas where it could increase fire risk to communities, pollute water sources, and destroy wildlife habitat, in addition to diverting scarce resources away from areas where treatment would reduce the wildfire risk to communities.

2. A New Coal Mine in the Currant Creek Roadless Area: The proposed Colorado Rule would create a special exemption for coal mining and road construction on specific lands on the Grand Mesa, Uncompahgre, and Gunnison National Forests (GMUG), including the Currant Creek roadless area near Cedaredge in Delta County. The Currant Creek area is distant from existing coal leases and for the past sixteen years has been recognized by the U.S. Forest Service to be a high-quality roadless area deserving protection from mineral development.

Despite the recommendation of local Forest Service staff on the GMUG National Forest, this ecologically important and undisturbed area has been sacrificed as a special hand-out to industry under the proposed Colorado rule. This exception is inappropriate and is an artifact of the Bush Administration’s improper manipulation of this process. Consistent with the local district’s recommendation, the area needs full roadless protection.

3. Oil and Gas Leases: Also of particular concern are oil and gas “gap” leases issued after the 2001 National Roadless Rule became effective. The proposed Colorado Rule would allow roadbuilding associated with these leases – roughly 100 in number and impacting tens of thousands of acres – and would lead to an intensive spider web of roadbuilding in the middle of some of Colorado’s most prized backcountry, like the Springhouse Park and Thompson Creek Roadless Areas. Such activity would not have been permitted under the 2001 Rule. This exception undermines the years of hard work that led to the carefully crafted and balanced approach of the national Roadless Rule.

Stipulations prohibiting roads should be applied to all oil & gas leases in roadless areas issued since January 2001, or these leases should be retracted, allowed to expire undeveloped, or otherwise removed before any Colorado-specific rule proceeds.

4. Water and Utility Infrastructure: Yet another example of the significant degradation of roadless values could occur under the proposed Colorado Rule is the allowance of road-building for water and utility infrastructure.  This would place Colorado’s roadless areas indefinitely at risk of development of roads and infrastructure associated with water and utility pipelines, electrical transmission lines, and even reservoirs.

5. Ski Areas: Locations where ski areas could be built, or existing ones expanded, have been removed from the roadless inventory, even though some of these areas, such as the Game Creek area near Vail, have very important wildlife connecting corridors. Key wildlife habitat could be destroyed.

More Information:

• Maps of Colorado Roadless Areas and text of the proposed Colorado Rule can be found here.
• More on the legal situation surrounding the 2001 Roadless Rule can be found here.
• More on Oil and Gas leases in Colorado Roadless Areas can be found here.
• A letter of support for the 2001 Rule from more than 100 US Scientists ishere.