Final Environmental Impact Statement Rio de los Pinos Vegetation ...

Jack Lewis
Conejos Peak RD
15571 CR T.5
La Jara, CO 81140
via e-mail: comments-rocky-mountain-rio-grande@fs.fd.us
January 13, 2010
Dear Mr. Lewis,
The following are the comments of Colorado Wild and WildEarth Guardians on the proposed
Rio de los Pinos Project, as described in the draft environmental impact statement (DEIS).
After reviewing the project, we believe it should not be implemented, or at least it must be
greatly reduced in size before approval.
I.. MUCH OF THE PROJECT AREA IS SO WET THAT SIGNIFICANT IMPACTS TO
AQUATIC RESOURCES AND SOILS WOULD BE UNAVOIDABLE.
According to the DEIS, 50.7 percent of the 7 th level watershed of concern within the analysis
area is in the water influence zone (WIZ). DEIS at 3-19. Heavy equipment used in logging
(harvesters, tractors, etc.) would cause considerable damage if used in wet areas. Thus this would
be a good area to stay out of altogether.
However, logging is proposed throughout the project area and appears to cover more than 50
percent of the project area. See Alternative 2 map at DEIS p. A-2. The 7 th level watershed
appears to include proposed treatment units 4 and 5. Compare DEIS map A-2 with Figure 3.6-1,
p. 3-13. Logging proposed in these units would unquestionably cover more than 50 percent of
the land within them. It would be impossible to log this area as proposed and stay completely out
of the WIZ. It is not even clear that proposed logging would stay away from fens. Compare map
at DEIS at 3-29 showing fens with the map of Alternative 2 (DEIS at A-2).
The Forest Service has a strong policy for protecting fens, which states, in part:
The U.S. Fish and Wildlife Service, Mountain-Prairie Region, has made
conservation and protection of fens one of their wetland priorities… Furthermore,
the Mountain-Prairie Region has determined that all functioning fens fall within their
Resource Category 1. This means that the goal is no loss of existing habitat value,
and that every reasonable effort should be made to avoid impacting these habitats.
Mitigation for loss of fens is problematic, as there are no known methods to create
new functional fens.
Colorado Wild/Rocky Smith ◊ 1030 Pearl St. #9 ◊ Denver, CO 80203
www.coloradowild.org