Delta County commissioners recently submitted their comments on the Grand Mesa, Uncompahgre and Gunnison National Forests (GMUG) Preliminary Draft Revised Land Management Plan.
Prior to being released to the public on June 28, the plan was released in April to cooperating agencies.
Comments reflect several areas of the proposed plan, which will guide land use decisions for 20 years.
Approaches are delineated in the Plan but are optional and may be changed administratively.
Suitability criteria are inclusive rather than exclusive: projects or activities may occur in an area unless specifically identified as unsuitable. If the plan is silent with respect to the suitability of a project, it is assumed to be suitable.
The plan states GMUG will provide forest goods and services. Delta County advocates language that recognizes the agency's active role in providing these goods and services, and that it makes a commitment to do so.
Lease and permit holders are not included in the list of partnerships and coordination to be prioritized. Delta County contends that citizens and businesses that hold leases or permits on the GMUG should be formalized in the plan.
The plan identifies air quality preservation in Class 1 wilderness areas as a priority, specifying that visibility be set on a path toward natural conditions. The county recommends inclusion of language specifically addressing and exempting normal agricultural activities, including ditch burning, tilling and harvesting, from consideration.
The plan specifically references oil and gas projects as items of concern for critical pollutant loads. The county is concerned that air quality management for the Class 1 West Elk Wilderness may preclude oil and gas development in the North Fork Valley area and other nearby areas such as the Plateau Valley.
The plan proposes to revise oil and gas leasing within three years. Delta County supports the goal of revision as quickly as possible.
The plan proposes a regular, comprehensive monitoring program to track performance and evaluate management prescriptions. The concern is that existing grazing permit holders be considered in this process and that economically-viable grazing operations on the GMUG be allowed to continue.
This objective stipulates that "climate refugia" be identified and monitored. Delta County is not in support of additional land management designations that entail additional restriction and redundant regulation and contends that existing management plans and designations are adequate to provide functional equivalency, such as wilderness and roadless areas.
Water Quality and
The BoCC is not in support of the riparian management framework which identifies a protective zone extending across the entire "inner gorge" of perennial and intermittent streams. This blanket application could have the effect of curtailing most or all surface-disturbing activities in large portions of the GMUG.
Restriction on all activities that do not maintain or improve long-term stream health within the riparian management zone could preclude large numbers of economically-important activities, including water diversions, grazing management, road construction, and timber harvest.
At a minimum, Delta County suggests that the restriction be limited to those activities that demonstrably harm water quality and/or provide the ability to minimize and mitigate potential impacts.
Delta County appreciates and approves the Forest Services' commitment to work with stakeholders to provide water supplies to surrounding communities and suggests amended language to highlight the role that stakeholders have in water quality issues, such as well as supply concerns.
Delta County is concerned with the suggested guideline that "30 to 100%" of a sub-watershed should provide wildlife security habit. Concern is that any management guideline that proposes to place up to 100% of a given watershed under restrictive management and requests additional clarification on this item.
Concerns exist over guideline requiring no heavy equipment be allowed to operate within 1.6 miles of boreal toad breeding ponds except under snow and ice. This amounts to a de facto ban on all construction in these areas, since heavy equipment operation is generally not feasible in winter on the GMUG.
Delta County is not in support of a management policy that would so drastically limit potential activities on the forest, in the absence of more information about the number and extent of these breeding ponds, and which appears to be reactionary while not addressing actual cause and effect issues related to boreal toad declines.
Delta County recognizes travel management is not a part of this plan revision; however, the county wishes to re-emphasize the continued commitment to providing public access to the GMUG and is not in support of management goals or targets that would lead to additional route closures at a later time.
The utility terrain vehicle (UTV) category should be addressed in the plan revision, either explicitly including UTV in the full-size vehicle category or by creating a new vehicle category for UTV.
Delta County is concerned that the standard alteration of grazing practices does not stipulate "if grazing is determined to be the causal factor for non-attainment through quantitative measurement."
The guidelines suggest that grazing should be limited and rotated "to allow plants time to recover (grow)." The county suggests the language be altered to a more flexible and general goal such as "to improve rangeland health and resiliency."
The annual assessment and adjustment to grazing "when necessary to respond to changing ecological conditions or resource concerns" does not include a stipulation to the effect, "if grazing is determined to be the causal factor for non-attainment through quantitative measurement."
The county supports the Forest Service proposal to increase suitable timber acreage on the GMUG and its proposal to prioritize salvage timber sales in the initial years of the plan.
Delta County advocates that all salvage timber in suitable locations be available for sale, taking into consideration the supply needs of local dimensional lumber and whole-log timber processors.