Lands with Wilderness Characteristics:

Backdoor Gulch

Backdoor Gulch unit, Royal Gorge Field Office Photo: Larkin McCormick

The intent of this report is to present objective data to illustrate that the area in question qualifies as Lands with Wilderness Characteristics (LWC), in accordance with Bureau of Land Management (BLM) Manuals 6310 and 6320. The information presented in this report meets the minimum standards for review of new information per Manual 6310, and accordingly BLM must review this information and make its findings and documentation of the review process available to the public as soon as practicable.

Lands with Wilderness Characteristics: Backdoor Gulch

BLM Royal Gorge Field Office, Front Range District BLM Unit Identifier: CO-020-054 (Race Path)

Submitted by:

Wild Connections 2168 Pheasant Place, Colorado Springs, CO 80909

info@wildconnections.org; (719) 686 - 5905

Prepared by:

John Sztukowski, Wildlands Inventory Coordinator, Wild Connections john@wildconnections.org; (817) 939 - 4239

Larkin McCormick, 2014 Summer Mapping Intern, Wild Connections

Report Date:

March 2015

Table of Contents

Map of Backdoor Gulch LWC .......................................................................................................................... 3

Overview ................................................................................................................................................................ 4

Discussion of Wilderness Characteristics including Boundary Delineations ............................... 6 I. The Backdoor Gulch proposed LWC meets the minimum size criteria for roadless lands. .................. 6 II. Backdoor Gulch proposed LWC is primarily affected by the forces of nature ......................................... 9 III. Backdoor Gulch proposed LWC provides outstanding opportunities for solitude and primitive recreation. ........................................................................................................................................................................ 11 IV. Backdoor Gulch proposed LWC has supplemental values that would enhance the wilderness experience and should be recognized and protected. ........................................................................................ 11

Summary Conclusion ...................................................................................................................................... 13

Backdoor Gulch Proposed LWC Waypoints ............................................................................................ 15 2

Map of Backdoor Gulch LWC

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Overview The Backdoor Gulch proposed Lands with Wilderness Characteristics (LWC) unit is an approximately 6,700 acre area in central Colorado. It is located in Bighorn Sheep Canyon in Fremont County. The unit ranges in elevations from 6,200 ft near the Arkansas River to 7,700 ft in the surrounding hills. The landscape is comprised of many steep rocky hillsides, meadows, and unique geologic rock features. In addition, within the proposed LWC are many drainages and gulches including Race Path Gulch, Backdoor Gulch, and East McCoy Gulch as well as the relatively fast flowing Texas Creek. This proposed LWC supports a great diversity of vegetation including pinyon-juniper woodlands, riparian areas along the gulches, Ponderosa pines in riparian areas and on north facing slopes, as well as scrub oaks and mountain mahogany along the many gulches. The Backdoor Gulch proposed LWC lies within Bighorn Sheep Canyon, approximately 20 miles west of Canon City, CO and 26 miles east of Salida, CO. US Highway 50 separates the unit from the Arkansas River and defines the northern Boundary of the unit. Colorado State Highway 69 and private property form the eastern boundary. The southern boundary is corralled by private property, and the western by Fremont County Road 37 as well as private property. The proposed LWC possesses extraordinary biological values. This unit encompasses a large Potential Conservation Area (PCA), as recognized by the Colorado National Heritage Program (CNHP). The northeastern section of the proposed LWC aligns with CNHP’s McIntyre Hills PCA, a very high biodiversity significant area that extends north and east along the Arkansas River and offers habitat for several globally rare plant species, including the largest known concentration of the globally imperiled species the Arkansas Canyon stickleaf (Nuttallia densa). There is also a BLM designated Area of Critical Environmental Concern (ACEC) in this same region, for the Arkansas Canyonlands. Many plant and animal species can be found in the Backdoor Gulch proposed LWC. High habitat and range value exist for many wildlife species, including the Rocky Mountain bighorn sheep, black bear, elk, mountain lion, mule deer, Brazilian free tailed bat, and Gunnison prairie-dog. Important bird species are identified as well in the proposed LWC including the threatened bald eagle, wild turkey, great blue heron, and Canada goose. Opportunities for solitude and primitive recreation are abundant in this 6,700 acre proposed LWC. The many gulches surrounded by dense vegetation and mid-elevation forests provide extensive opportunity for solitude in the forms of isolation, remoteness, and vegetative screening. There are many backcountry areas in this unit that are not accessible by routes or ways and require off-trail hiking. Primitive and unconfined recreation is also available in all seasons including hunting, fishing, backpacking, hiking, wildlife viewing, camping, bouldering, and photography. Additionally, with the proximity of the Arkansas River to this unit, it provides a scenic natural viewscape for gold medal fly-fishing and world-class white water rafting. In 2013, the BLM inventoried this area consisting of 6,751.2 acres and identified it as COF-020-054 or Race Path (delineated by the yellow line in the above map). The BLM claims that this unit does not possess wilderness characteristics because the area does not appear natural due to man- 4

made features. The BLM did not inventory for wilderness characteristics beyond naturalness. The man-made features referenced in the BLM report include multiple routes found within the unit, assumed to have been originally built for prospecting purposes. The BLM claims that, “mechanical construction is evident on the routes, and cut and fill is visible along hillsides.” While the BLM LWC report for this unit does inventory and provide analysis for some routes, these are solely for boundary roads. It is unclear if the BLM inventoried the interior routes. The BLM provided Google Earth (KML) files, however all of the routes are titled “NULL” and do not provide the supplementary narrative data found in other BLM inventories routes. Additionally, these routes are not referenced in the BLM’s report for this unit. Wild Connections on-the-ground inventory provides data and assesses all routes within the unit. In the following sections, this report will provide BLM with new information regarding the entirety of the routes in the proposed LWC. The BLM report also states that the mining activity in the area significantly impacts the naturalness of the unit. The report discusses a large mining site along the northeastern boundary that affects the naturalness of the overall unit. Wild Connections agrees that this could be a significant human impact within the unit. However, given that this mine is on the edge of the northeastern boundary, it can easily be excluded, along with the route leading to it. Therefore it will no longer be included within the proposed LWC and thus will not affect the natural integrity or the apparent naturalness of the unit overall (BLM Manual 6310, p 6-7). Wild Connections’ on-the-ground inventory also found another mine that the BLM report does not reference. It is in the southwestern section of the proposed LWC. This mine site is on the boundary of the BLM inventoried unit as well. Wild Connections makes a similar assessment and recommendation as above: to exclude the mine and route leading to it, thus minimizing impacts within the proposed LWC. The BLM reported that this unit’s topography includes, “rough, rocky terrain…steep hillsides” (p.2). Wild Connections’ extensive on-the-ground inventory confirms BLM’s topography assessment, which also supports that isolated man-made features do not affect the overall naturalness of the 6,700 acre proposed LWC as viewed by the average visitor (BLM Manual 6310, p 6). In the spring of 2013, Wild Connections produced a preliminary boundary delineation for this unit based on the size and contiguity requirements stated in Manual 6310 (p 6). During the summer of 2014, Wild Connections’ mapping teams visited the Backdoor Gulch proposed LWC several times to conduct in-depth, on-the-ground inventories of this unit. Our goal was to assess this area for wilderness characteristics, based on BLM’s Manual 6310, and report our findings to the BLM’s Royal Gorge Field Office in central Colorado. Additionally we have reviewed the 2013 BLM RGFO inventory and boundaries and have made assessments and adjustments based on our in-depth field inventories. Wild Connections’ report offers new in-depth data and information including photo, narrative, and geo-referenced data, supporting the Backdoor Gulch proposed LWC. The boundary delineations and narrative describing wilderness characteristics found within this unit are detailed below.

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Waypoints (many with photos) are referenced through out this report; the photos with geo-data, time and date stamp, description, and page number can be found at the end of the report, akin to the one shown below.

Discussion of Wilderness Characteristics including Boundary Delineations

I. The Backdoor Gulch proposed LWC meets the minimum size criteria for roadless lands. The Backdoor Gulch proposed LWC comprises approximately 6,700 contiguous roadless acres, surpassing the minimum size criteria of 5,000 acres to qualify for wilderness, as specified in BLM’s Manual 6310 (p 6). With regard to route determination, this manual states that a “way” maintained solely by the passage of vehicles does not constitute a “road” for the purposes of inventorying wilderness characteristics. A “way” that is used on a continuous and regular basis still does not constitute a road. Additionally a vehicle route that was constructed by mechanical means, but is no longer being maintained by mechanical methods is also not a road. By comparison, a Wilderness Inventory Road (WIR) is a vehicle road that has “been improved and maintained by mechanical means to ensure relatively regular and continuous use” (Manual 4310, p 11). Wild Connections’ inventory of this area assesses routes that are or are not considered WIRs based on the above definitions. Routes that did meet the criteria for WIRs were removed from the unit as cherrystems. US Highway 50 and the Arkansas River parallel the Backdoor Gulch proposed LWC at its northern boundary. A horse trail, as recognized by the Arkansas River Travel Management Plan (TMP),

Backdoor Gulch (20) - SSW Texas Creek provides excellent opportunity for fishing and swimming in unit interior (p. 9,11)

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enters the unit from US Highway 50 via a barbed wire gate at Waypoint 1. This trail does not impact the overall naturalness of the unit as the majority of it was not constructed or maintained by mechanical means. Additionally, the beginning of the trail is very hard to distinguish. It can initially be seen by tire marks over the grassy field in Waypoint 2, and in areas with slightly less vegetative growth such as in Waypoint 3. Farther down the trail, there are some sections along the hillsides that look constructed by cut and fill (Waypoint 5). However past that, the trail is again difficult to discern, as viewed in Waypoint 6. The trail comes to an end at Waypoint 7, with a view looking into the interior on the western side of the unit and providing a beautiful view of the juniper-pinyon hillsides and the Sangre de Cristo mountain range off in the distance. Given that this trail is recognized as a non-motorized trail in the TMP, coupled with the above findings, it will remain within the unit as a way. The junction of US Highway 50 and Colorado State Highway 69 at Waypoint 8 defines the northeastern boundary of the proposed LWC. Colorado State Highway 69 heads south along the northeastern boundary with several designated motorized routes entering the unit with opportunity for recreation and camping. BLM provides no data on the names of these routes, on the ground or in their reports, so Wild Connections has given them generic names for referencing purposes. The following routes are in the Arkansas River TMP, and thus are considered WIRs, and will be removed from the unit. Route 1 off of Highway 69 is the shortest of these WIRs, ending about 150 ft into the unit at Waypoint 9. Route 2 is located just south off Highway 69. It is graveled as evidenced in Waypoint 10. The use of this route does not appear regular and continuous, as further down the route it is overgrown with large brush (Waypoint 11). Route 2 ends a short distance into the interior at Waypoint 12. Despite these on-the-ground findings, Route 2 will be removed from the unit as a cherrystem due to its inclusion in the Arkansas River TMP. Following Route 2, there is another unmarked route that serves as an entrance to a parcel of private property. The next route off Highway 69 is BLM 6036, located at Waypoint 13. This route is recognized as a road and open to all motorized and non-motorized traffic as indicated on the BLM sign in the aforementioned Waypoint. This road leads to the northeastern mining site referenced in the BLM report, where it ends at Waypoint 15. This road and the mine it leads to are excluded from the proposed LWC, thus also excluding the associated significant human impact from the unit. The next route off 69 has no name or sign postings. It will be referred to as Route 3 and is accessed at Waypoint 17. This route, which will also be excluded as a WIR cherrystem, leads to several primitive and dispersed campsites along Texas Creek, as exemplified in Waypoint 18. The last route off 69 is at Waypoint 21 for a short loop that also leads to primitive dispersed camping near Texas Creek. This route is marked with a BLM sign posting as 6037 and ends a short distance at Waypoint 22. BLM 6037 will also be removed from this unit as a WIR. Continuing south along Highway 69 toward the southeastern section of the unit there are several longer administrative ways that extend into the interior of the unit. These ways are not publicly accessible off of Highway 69 because there are private properties that buffer the unit from highway access. However it appears that BLM is able to accesses these administrative ways through these properties.

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The first of these unnamed ways, which will be referred to as North Interior Trail, begins at Waypoint 23. This way was not constructed by mechanical means and does not appear to be maintained due to heavy revegetation, including trees growing in the route as evidenced in Waypoint 24. This way is navigable by motor vehicles and is used as an administrative route by the BLM. The North Interior Trail meets the South Interior Trail at a junction at Waypoint 25. At this point it is obvious that neither of these ways were constructed nor maintained by mechanical means. The North Interior Trail continues on past the South Interior Trail junction. The use of this route does not appear to be regular and continuous, however there were tire marks in the dirt that appeared recent at Waypoint 32. Our inventory team ran into BLM employees surveying springs in the area and using this route as well. However, because this route is not constructed or maintained by mechanical means, it does not have a significant impact on the overall landscape. Waypoint 33 views this route in the central interior of the unit. Continuing north, the primary interior trail ends into a grassy meadow at Waypoint 37, right. The South Interior Trail begins from the east at a gate located at Waypoint 26. The South Interior Trail heads west and then south until it reaches the unit boundary at a private property fence line, which can be viewed at Waypoint 39. This route does not appear to be constructed by mechanical means along any section of its entirety and thus will remain within the proposed LWC as a way. The way continues along the fence westerly for approximately 100 feet but peters out at Waypoint 40. The southern and southwest boundary of the Backdoor Gulch proposed LWC is entirely bordered by private property. The south-central edge of the unit is defined by wilderness inventory road (WIR), BLM 6141. Stemming from 6141 are two ways, at Waypoint 43 and Waypoint 44, that lead to a large open pit mine (Waypoint 49) as well as a mining shaft at Waypoint 48. These routes, mining pit, and associated impacted areas are removed from the proposed LWC so that they do not affect the overall naturalness of the unit. Moving north from the mining impact area along boundary road BLM 6141 is a locked gate at Waypoint 50. While this route allows public motorized use up to this point, the mine itself can only be accessed by foot from the west. This WIR shows evidence of being bladed.

Backdoor Gulch (37) - NE

Northern Interior Trail disappears into montane grasslands in the central interior unit (p. 8,9)

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Moving north along WIR 6141, the next junction is with the cherrystem route 6141A at Waypoint 51 and ends approximately one-fifth mile into the interior at Waypoint 52. This route is not constructed nor maintained by mechanical means, however will be removed from the unit as a cherrystem due to its inclusion as a motorized route in the Arkansas River TMP. WIR 6141 begins to border the unit at Waypoint 53, starting from Fremont County Road 37 to the north. Fremont County Road 37 defines the northwest edge of the unit in a couple of sections. A BLM sign stating travel restrictions for the area can be viewed along this road at Waypoint 54. Most of the information in this section will be new to BLM and should be carefully taken into consideration. BLM’s report CO-020-054, Form 3: Route Analysis, only discusses and provides information about the boundary roads, and does not provide any details about the interior “maintained routes” in which their report states significantly impact the naturalness of the unit. The BLM inventoried routes data are all displayed as “NULL” on the BLM inventoried routes Google Earth (KML) data, not displaying any of the key inventory route data. As Wild Connections on-the-ground inventory shows with photographic evidence, many of these interior routes are not being currently maintained and do not significantly impact the overall landscape.

II. Backdoor Gulch proposed LWC is primarily affected by the forces of nature The Backdoor Gulch proposed LWC is primarily affected by the forces of nature, with human impacts considerably unnoticeable within the unit. While there are seven points of public access into the unit, most do not extend far into the unit interior including all of the designated motorized routes, providing many acres of untrammeled land. Many of the routes in this unit show a lack of motorized use and an overall apparent lack of regular use, with the forces of nature reclaiming many of the former roads as evidenced in Waypoint 41 and Waypoint 45.

The proposed LWC offers many vegetation types, due to the topographic variety and diverse ecosystems found within this unit. Many gulches and creeks flow through the proposed LWC, offering rich riparian life, as viewed in Texas Creek at Waypoints 19 and 20. Pinyon-juniper hillsides are common throughout the rolling hills in the unit, as evidenced in Waypoint 7 in the northern interior and Waypoint 29 in the southern interior. Mountain mahogany and scrub oaks are also found throughout the region (Waypoint 28). In the higher altitudes, there are healthy montane grassland meadows that separate the woodlands, as viewed in Waypoints 31 and 37 in the central interior. There are a variety of wildflowers in the unit including yarrow, sunflowers, scarlet skyrockets, the Rocky Mountain bee plant and other unidentified species. The Rocky Mountain bee plant among other wildflowers can be viewed at Waypoint 35. Other plants in the unit include mullein, red currants, cacti, sagebrush, rabbitbrush, and various native grasses. Waypoint 34 views the varying vegetation common in the unit. The largest and most noticeable human impacts associated with the unit are the two mine sites located to the northeast and southwest of the proposed LWC. Waypoints 14 and 16 depict the 9

northeastern mine and its impacts. Waypoints 47, 48, and 49 view the southwestern mine, pit, and equipment that are excluded from this unit. A reclamation permit for the southwestern mine operation has been issued by the Colorado Mined Land & Reclamation board with permit No.M19779532SG, operated by Colorado Quarries, Inc., as evidenced in Waypoint 46. However given the localization of these areas, the inaccessibility to the public, and Wild Connections decision to exclude the mine sites and routes that lead to them from the proposed LWC, they do not affect the natural integrity or the apparent naturalness of the unit overall (BLM Manual 6310 p 6-7). Aside from these excluded impacts, much of Wild Connections’ inventory in the Backdoor Gulch proposed LWC consisted of untrammeled naturalness. However there were some minor human impacts observed as well. These minor human impacts include former roads now ways, gates, fences, fire pits and signs as documented in the previous section. Other than the mine sites, which Wild Connections recommends to be excluded from the unit, the other main reason BLM did not find naturalness is because of, “multiple routes found within the unit”. The BLM states that, “mechanical construction is evident on the routes, cut and fill is visible along the hillsides”. As previously discussed in the boundary delineations section, the forces of nature are reclaiming many of these routes. In our on-the-ground inventory we only found a few small stretches of interior trails where mechanical construction was evident and these did not significantly impact the naturalness of the 6,700 acre proposed LWC unit as a whole. Furthermore, the vegetative cover and topographic variety found throughout the unit screen the visitor from any of these minor human impacts, as evidenced in Waypoint 7, right, viewing the interior from a high point in the northern portion of the unit. While there are a few minor human impacts spread throughout the proposed LWC, these are examples of “human-made features” that are considered substantially unnoticeable and thus do not hinder wilderness characteristics (BLM Manual 6310, p 6). Furthermore what was found and inventoried does not affect the natural integrity or the apparent naturalness of the unit overall (BLM Manual 6310, p 6-7).

Backdoor Gulch (7) - SW Sangre de Cristo Mountain range over naturalness of unit interior (p. 7,9,10)

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III. Backdoor Gulch proposed LWC provides outstanding opportunities for solitude and primitive recreation. The Backdoor Gulch proposed LWC provides excellent opportunities for solitude. Waypoint 4 shows an example of the vegetative screening available throughout the unit that can provide complete solitude. The gulches and hillsides also provide dense brush and topographic screening, which further supports outstanding opportunities for solitude. In addition, there are not many public routes that extend into the interior of the unit, limiting visitation and providing easy availability for respite and remoteness. Outstanding opportunities for recreation are also present in the 6,700 acre unit of contiguous unroaded wilderness. There are great opportunities for camping at multiple primitive and dispersed campsites on the eastern side of the unit, including campsites with great access to Texas Creek as exampled in Waypoints 18 and 22. Texas Creek provides additional outstanding primitive recreational opportunities, including fishing and swimming (Waypoints 19 and 20). The proposed LWC also provides an incredible natural viewshed and enhances the primitive recreation of gold medal fly-fishing and world-class whitewater rafting on the nearby Arkansas River. There are also many great opportunities for hiking and backpacking both on and off trails, as viewed in Waypoints 30 and 42, offering a variety of terrains and scenic values. Waypoint 27 documents a hiking trail surrounded by unique and beautiful rock features. Other outstanding opportunities for recreation within this unit consist of hunting, wildlife viewing, bird watching, horseback riding, and photography. There are excellent opportunities for hunting within this unit; high value animal species and habitat are documented in the section below.

IV. Backdoor Gulch proposed LWC has supplemental values that would enhance the wilderness experience and should be recognized and protected. Wild Connections’ inventory of the Backdoor Gulch proposed LWC indicates numerous supplemental values that contribute to the overall experience of visiting this area and provide additional evidence that this unit’s unique qualities should be recognized and protected. The majority of these values support the area’s regional ecological importance and rich biodiversity. The supplemental values presented below are not intended to be exhaustive, rather a summarization of some of the widely known significant values for which basic data was available to complement our on-the-ground inventory. The northeastern region of this unit coincides with Colorado National Heritage Program (CNHP)’s larger McIntyre Hills Potential Conservation Area (PCA), a greater area (over 20,650 acres) that extends east along the Arkansas River corridor. This area was given the rank of B2, Very High Biodiversity Significance, due to the inclusion of many globally imperiled and vulnerable plant species, including the Arkansas Canyon Stickleaf (Nuttallia densa), Degener beardtongue (Penstemon degeneri), Fendler cloak-fern (Argyrochosma fendleri), and jeweled blazingstar 11

(Nuttallia speciosa). The Arkansas Canyon Stickleaf is endemic to this region, with this conservation area representing the largest known concentration in the world. There is also a BLM designated Area of Critical Environmental Concern (ACEC), Arkansas Canyonlands, that overlaps a similar region to McIntyre Hills PCA. The ACEC is recognized for it’s river related recreation (whitewater boating and fishing), scenic vistas, two resident bighorn herds, wintering bald eagles, and numerous other sites of historic and geologic interest. Both of these prioritized areas support Wild Connections claim that this unit is ecologically and environmentally important and should be designated as Land with Wilderness Characteristics. High habitat and range values for many wildlife species exist within the proposed LWC. Rocky Mountain Wild (RMW) produced an Assessment of Biological Impact (ABI), which documents the following mammals and associated values within the unit: Rocky Mountain bighorn sheep (Ovis canadensis Canadensis) production area, summer concentration, winter concentration, severe winter range, overall range, summer range, and winter range; black bear (Ursus americanus) overall range, summer concentration, and fall concentration; elk (Cervus Canadensis) migration corridor, overall range, summer range, winter range, severe winter range, winter concentration area; mule deer (Odocoileus hemionus) overall range, summer range, and winter range; mountain lion (Puma concolor) overall range; Gunnison prairie-dog (Cynomys gunnisoni) overall range; and Brazilian free tailed bat (Tadarida brasiliensis) overall range. The Gunnison prairie-dog is listed as Colorado BLM Sensitive and as a US Wildlife Conservation and Restoration Program’s (WCRP) Comprehensive Wildlife Conservation Strategy (CWCS) Species of Most Concern. The Brazilian free tailed bat is a Colorado state ranked critically imperiled species. This area is also of particular importance for the Rocky Mountain bighorn sheep. Bighorn Sheep Canyon is one of the last refuges for many of these mammals in Colorado. The Backdoor Gulch proposed LWC contains the perfect rocky, mountainous terrain for this species and provides a connectivity corridor for similarly protected land, including the nearby McIntyre Hills Wilderness Study Area. Many critical and valued bird species have also been identified in the area. Of note, this unit provides winter forage and range for the bald eagle (Haliaeetus leucocephalus), which is listed as Colorado BLM Sensitive, CWCS Species of Most Concern, and Partnership in Flight Priority Bird. RMW also identifies wild turkey (Meleagris gallopavo) overall range, winter range, and winter concentration; great blue heron (Ardea Herodias) foraging area; and Canada goose (Branta Canadensis) brood concentration area, foraging area, production area, winter concentration, and winter range. Scenic views are abundant throughout the proposed LWC given the rolling hills throughout the unit, as exemplified in Waypoint 29. There are beautiful views of the Sangre de Cristo mountain range from many of the high points within the unit, as viewed in Waypoint 38 (below) from the southern interior.

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The proposed LWC is also noteworthy for unique geological features in this region, including large boulder outcroppings, as exampled in Waypoints 27 and 34. The majority of the unit is from the Middle Proterozoic Age, with the main rock types consisting of granite and granodiorite. Along the edges of the unit at lower elevation, the geology is older, from the Early Proterozoic Age, adding in rock types of felsic and mafic gneiss. Tertiary siltstone and sandstone mix into the unit as well. The above geological data was obtained from the United States Geological Survey's (USGS) Mineral Resources on-line spatial data, selected for Colorado's geology. There is also evidence of soil similar to crypto-biotic soil or “biological soil crust” within the unit (Waypoint 36).

Summary Conclusion Based on Wild Connections’ extensive on-the-ground inventory, the Backdoor Gulch proposed LWC qualifies as Land with Wilderness Characteristics (LWC) according to BLM’s Manual 6310. This unit exceeds the 5,000 contiguous roadless acreage minimum as the proposed LWC is 6,700 contiguous roadless acres. Given the size of the unit, lack of significant human impacts, and unique topography, the Backdoor Gulch proposed LWC offers outstanding wilderness characteristics – including apparent naturalness and outstanding opportunities for solitude and primitive and unconfined recreation. There are also many supplemental values that support wilderness characteristics on the proposed LWC. The boundaries identified by the BLM generally align with Wild Connections inventory. The BLM however did not find wilderness characteristics in this unit due to lack of naturalness, based on two primary reasons. First and foremost was due to the significant human impact of the mine in the northeast unit. Wild Connections recommends excluding this mine, and the one located in the southwest section of the unit, from the proposed LWC. This will also exclude the associated mining impacts from the unit, thus mitigating any major human impacts from the unit. Furthermore, the steep and rocky topography in this area screens visitors from seeing these impacts throughout much of the unit. The second reason the BLM did not find wilderness characteristics is because of the multiple routes within the unit that were constructed by mechanical means. However as this report

Backdoor Gulch (38) - SSE View of Sangre de Cristo mountain range over interior from southern section of the unit (p. 12)

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documents, the only routes constructed by mechanical means that extend into the unit are on the eastern side, relatively short in length, and will be removed as cherrystems. As this reports’ photo points documents, most routes within the unit are being reclaimed by the forces of nature due to lack of use. These previous and fading routes blend in with the natural landscape and do not have a significant impact to the overall naturalness of the area. Other minor human impacts found and documented within the unit include fences, gates, fire pits and signs. Nevertheless these are minor human impacts, consistent with BLM Manual 6310, as the natural integrity and the apparent naturalness of the proposed LWC in sum are not compromised. Wild Connections’ inventory has documented the necessary boundaries as well as wilderness characteristics within the unit. This overview provides new information, including narrative, photo, geo data, and supporting maps, documenting the 6,700 acre Backdoor Gulch proposed LWC meets wilderness criteria. This area possesses Lands with Wilderness Characteristic status and its wilderness value should be protected and preserved. It is imperative that the BLM recognize and protect these values in their land management decisions, so that these unique and abundant wilderness qualities are sustained.

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Backdoor Gulch Proposed LWC Waypoints The following photographs correspond with the numbered Waypoints on the above Backdoor Gulch map and may be referred to in the report narrative describing the wilderness characteristics. The direction of view (16 point Cardinal) is indicated in the bolded caption. Below this is a short description of the photo, with the referenced page number(s) in parenthesis. The photos are also watermarked with the direction (degrees and cardinal) in the top right, date and time in the bottom right, elevation in the bottom center, and the latitude and longitude in the bottom left.

Backdoor Gulch (1) - E

US 50 at unlocked barbed wire gate, designated non-motorized route into interior (p. 7)

Backdoor Gulch (2) - WSW

Faint non-motorized route along northern boundary (p. 7)

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Backdoor Gulch (3) - SSE Designated non-motorized route into

interior (p. 7)

Backdoor Gulch (5) - N

Cut and fill observed on designated non-motorized route in NW unit (p. 7)

Backdoor Gulch (6) - SSW Non-motorized route becomes difficult to discern in interior unit (p. 7)

Backdoor Gulch (4) - S Vegetative and topographic screening provide outstanding opportunity for solitude (p. 11)

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Backdoor Gulch (7) - SW Sangre de Cristo Mountain range over naturalness of unit interior (p. 7,9,10)

Backdoor Gulch (11) - SW Dense vegetation shortly along route (p. 7)

Backdoor Gulch (12) - SW

Route ends shortly into gulch (p. 7)

Backdoor Gulch (10) - WSW Graveled way into interior at SH 69 in northeast section of the unit (p. 7)

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Backdoor Gulch (13) - WSW Cherrystem road BLM 6036, open to all use at State Highway 69 (p. 7)

Backdoor Gulch (15) - SSW End of BLM 6036 to northeast mine site

(p. 7)

Backdoor Gulch (14) - ESE

Remnants of northeast mine, excluded from unit (p. 9)

Backdoor Gulch (16) - SE Northeast mine quarry to be removed from unit (p. 9)

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Backdoor Gulch (17) - W Unmarked undesignated route into

interior at State Highway 69 (p. 7)

Backdoor Gulch (19) - NNW Rich riparian life of narrowleaf cottonwoods, willows and natural grasses along Texas Creek (p. 9,11)

Backdoor Gulch (20) - SSW Texas Creek provides excellent opportunity for fishing and swimming in unit interior (p. 9,11)

Backdoor Gulch (18) - SW Route ends at Texas Creek; excellent opportunity

for camping (p. 7,11)

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Backdoor Gulch (21) - N BLM 6037, open to all use, ends shortly

into interior (p. 7)

Backdoor Gulch (24) - ESE Trees taking form shortly onto North Interior Trail (p. 8)

Backdoor Gulch (23) - E

Northern Interior Trail from private property in southeast unit (p. 8)

Backdoor Gulch (25) - SE Northern Interior Trail junction at Southern Interior

Trail (p. 8) 20

Backdoor Gulch (26) - ESE South Interior Trail from private property in

southeast section of the unit (p. 8)

Backdoor Gulch (28) - ESE Gambel oak and mountain mahogany mix into the

pinyon-juniper woodland (p. 9)

Backdoor Gulch (27) - ENE

Outstanding opportunity for hiking on South Interior Trail; unique geological feature along route (p. 11,13)

Backdoor Gulch (29) - SE View of rolling rugged wooded hills common

throughout the unit (p. 9,12)

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Backdoor Gulch (30) - SE Excellent opportunity for hiking in unit interior

(p. 11)

Backdoor Gulch (32) - E Recent vehicle tracks observed on North

Interior Trail (p. 8)

Backdoor Gulch (31) - NE

Montane grasslands mix into the vegetation at higher elevations in the unit interior (p. 9)

Backdoor Gulch (33) - NE North Interior Trail shows considerably less

use in the central interior (p. 8) 22

Backdoor Gulch (34) - NNW View of unique geological feature over variety of wildflowers and other vegetation (p. 9,13)

Backdoor Gulch (35) - N Rocky Mountain Bee Plant among wildflowers in interior unit (p. 9)

Backdoor Gulch (36) - W Interesting soil construction in unit, similar to crypto-biotic soil (p. 13)

Backdoor Gulch (37) - NE

Northern Interior Trail disappears into montane grasslands in the central interior unit (p. 8,9)

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Backdoor Gulch (38) - SSE View of Sangre de Cristo mountain range over interior from southern section of the unit (p. 12)

Backdoor Gulch (40) - W Route along southern fence line dissipates a short distance in the unit (p. 8)

Backdoor Gulch (39) - S

South Interior Trail ends south at private property fence line with signs (p. 8)

Backdoor Gulch (41) - NNW Route along southern boundary disappears into vegetation (p. 9)

24

Backdoor Gulch (42) - NW Excellent opportunity for hiking in

southern section of the unit (p. 11)

Backdoor Gulch (44) - NNE Unmarked route to southwest mine site, excluded from the unit (p. 8)

Backdoor Gulch (43) - NE

Undesignated unmarked route into interior from the southern unit (p. 8)

Backdoor Gulch (45) - NNE Vegetation reclaiming route to southwest mine site

(p. 9) 25

Backdoor Gulch (46) - ESE Southwest mine site, operated by Colorado Quarries Inc (p. 10)

Backdoor Gulch (48) - NNE

Southwest mine site, excluded from unit (p. 8,10)

Backdoor Gulch (49) - NNE Southwest mine site and open pit excluded from unit (p. 8,10)

Backdoor Gulch (47) - N Construction equipment at southwest mine site, excluded from unit (p. 10)

26

Backdoor Gulch (50) - S Southwest boundary road, BLM 6141, at locked gate

(p. 8)

Backdoor Gulch (52) - ESE End of cherrystem road BLM 6141 (p. 9)

Backdoor Gulch (53) - SW

Boundary road BLM 6141, from County Road 37 (p. 9)

Backdoor Gulch (51) - ESE BLM 6141 at 6141A, open to all uses, into unit interior (p. 9)

27

Backdoor Gulch (54) - NW BLM Travel Restricted Area sign along western boundary road, County Road 37

(p. 9)

28