July 2015 United States

Department of

Agriculture

Forest Service

Rocky Mountain Region

White River

National Forest

White River National Forest, Eagle-Holy Cross District Garfield County, Colorado

Wild and Scenic River Suitability Study For National Forest System Lands on the

Colorado River and Deep Creek

Record of Decision

Eagle – Holy Cross Ranger District, White River National Forest County: Garfield County, Colorado

Lead Agency: U.S. Department of Agriculture, Forest Service Cooperating Agencies: Bureau of Land Management, Colorado River Valley Field Office Responsible Official: Scott Fitzwilliams, Forest Supervisor White River National Forest, 900 Grand Ave.,Glenwood Springs, CO 81601 For More Information: Kay Hopkins, WSR Team Lead White River National Forest, 900 Grand Ave., Glenwood Springs, CO 81601 Phone number: 970-945-3265 Abstract: The United States Forest Service (USFS) has conducted an environmental impact statement (EIS) to evaluate the suitability of 4 eligible river segments (17.25 miles) on the White River National Forest (WRNF) to determine the suitability for inclusion in the National Wild and Scenic Rivers System (NWSRS). The USFS Wild and Scenic River (WSR) suitability study included 2 segments of the Colorado River in Glenwood Canyon and 2 segments of Deep Creek located in Garfield County, Colorado. The USFS evaluation was part of an interagency WSR suitability study of river segments managed by the WRNF and Colorado- Bureau of Land Management (BLM), Colorado River Valley and Kremmling Field Offices. This Record of Decision (ROD) is the official administrative document containing the decision on which river segments are suitable for inclusion into the NWSRS. It is the determination of the USFS that 2 river segments on Deep Creek totaling approximately 10.77 miles of National Forest System lands administered by the WRNF are suitable for inclusion into the NWSRS. The USFS is deferring a suitability determination for 2 Colorado River segments within Glenwood Canyon. The USFS has made the decision to rely upon the Upper Colorado River Wild and Scenic Stakeholder Group Management Plan (stakeholder plan) in concert with USFS land management authorities, to protect the free flowing condition, ORVs, classification, and water quality of Colorado River segments 1 and 2. As part of the suitability planning process, the BLM and FS received a proposal from the Upper Colorado River Wild and Scenic Stakeholder Group for a management plan designed to protect the ORVs associated with the Colorado River between Gore Canyon and No Name. The stakeholder plan included an alternative management scenario for BLM’s Colorado River segments 4 through 7 and USFS Colorado River segments 1 and 2. The USFS and the BLM analyzed the stakeholder plan in the EIS under Alternative B (B2 in the Draft EIS). All Colorado River segments addressed in the stakeholder plan USFS segments 1 and 2) will maintain its eligibility status and will be managed by the agencies existing administrative authorities.

Record of Decision

Wild and Scenic River Suitability Study USFS Segments on the

Colorado River and Deep Creek

USDA Forest Service Eagle –Holy Cross Ranger District, White River National Forest

Garfield County, Colorado

Project Area:

• USFS managed segments on the Colorado River, Glenwood Canyon (USFS boundary East end of Glenwood Canyon to USFS boundary West end of Glenwood Canyon)

• USFS managed segments on Deep Creek (Deep Lake downstream to USFS Boundary) The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, gender, religion, age, disability, political beliefs, sexual orientation, or

marital or family status. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should

contact USDA's TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, Room 326-W, Whitten Building, 14th and Independence Avenue,

SW, Washington, DC 20250-9410, or call (202) 720-5964 (voice and TDD). USDA is an equal opportunity provider and employer.

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TABLE OF CONTENTS

I. Summary………………………………………………………………………………….. 2

II. Background……………………………………………………………………………… 2

III. Map………………………………………………………………………………………… 4

IV. Supplemental Information………………………………………………………………. 5

V. Decisions and Rationale………………………………………………………………… 5

a. Deep Creek Description and Rationale…………………………………… 5

b. Colorado River Description and Rationale………………………………… 7

c. Suitability Summary-Table 1. ………………………………………………… 9

Vl. Other Alternatives Considered……………………………………………………… 10 Vll. Forest Plan Goals and Objectives………………………………………………… 10 Vlll. Management Area Boundary………………………………………………………….. 10 IX. Findings Required by Other Laws and Regulations……………………………… 11 X. Public Involvement……………………………………………………………………… 11

a. Clarification of Wild and Scenic Rivers Suitability Decisions ……. 11

b. Clarification on Evaluation of Plan……………………………………. 12

XI. Implementation………………………………………………………………………….... 14

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l. Summary__________________________________________________ The White River National Forest (WRNF) has completed a Wild and Scenic River (WSR) Suitability Study for 2 segments on the Colorado River in Glenwood Canyon and 2 segments on Deep Creek. This Record of Decision (ROD) serves as the final finding of suitability for inclusion into the National Wild and Scenic Rivers System (NWSRS). The White River National Forest (WRNF) joined as a cooperator with BLM in 2008 in an interagency WSR Suitability study that is incorporated into the BLM’s Colorado River Valley (CRVFO) Field Office, Resource Management Plan (RMP) Revision EIS. The USFS portion of the WSR study evaluated the suitability of 4 river segments (totaling 17.25 miles) that were previously found to be eligible in the WRNF Land and Resource Management Plan (Forest Plan) in 2002. II. Background_______________________________________________ In accordance with the WSR Act section 5(d) (1), both BLM and USFS conducted the WSR study processes during their land use planning processes. The WRNF joined the BLM’s CRVFO in 2008 for the purpose of completing a suitability study on 2 rivers. The forest engaged in the interagency study due to numerous factors including; the USFS segments are directly adjacent to BLM segments being studied, the agencies share the same stakeholders and interest groups, and the benefits of integrating the process into one EIS. By jointly assessing suitability in the BLM’s EIS the USFS met its requirements under NEPA. This ROD is specific to the WRNF portions of the study and does not result in a Forest Plan amendment.

All four USFS segments evaluated for suitability were previously found to be eligible. Two Deep Creek segments were determined eligible as part of a joint study conducted by the WRNF and the BLM in 1995. In 2002, the USFS determined as eligible 2 segments on the Colorado River as part of the WRNF’s Forest Plan (2002). These 4 segments are now being brought forward for the last part of the WSR study process, the suitability phase. The WSR studies were done in accordance with Forest Service Handbook 1909.2.12 Land Management Planning Handbook, Chapter 80 Wild and Scenic River Evaluation; and incorporated recommendations from the Interagency Wild and Scenic Rivers Coordinating Council (1999). A determination of eligibility includes identifying the river segment’s outstandingly remarkable values (ORV’s), free- flowing nature, and identification of preliminary classification of the river corridors. Details of the WRNF eligibility process and findings can be found in the 2002 Forest Plan. The suitability phase is to determine whether eligible segments would be appropriate additions to the NWSRS by considering tradeoffs between corridor development and river protection. The suitability evaluation does not result in actual designation but a determination of suitability, which in turn provides the basis for determining which rivers, should be considered for inclusion into the NWSRS. The USFS cannot administratively designate a river via a planning decision. Only Congress can designate a WSR. In some instances, the Secretary of Interior may designate a WSR when the governor of a state, under certain conditions petitions for a river to be

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designated. Members of Congress will ultimately choose legislative language if any suitable segments are presented to them. Water protection strategies and measures to meet the purpose of the WSR act will be the responsibility of Congress in any subsequent proposed legislation.

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Map 1.

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V. Supplemental Information ______________________________ The WSR suitability study for National Forest System Lands on the WRNF is contained in the interagency Final Wild and Scenic Rivers Suitability Report dated February 2014. The study includes determinations for the BLM’s; Kremmling Field Office (KFO) and Colorado River Valley Field Office (CRVFO), and the USFS’s, White River National Forest (WRNF). The BLM’s CRVFO Final Environmental Impact Statement (FEIS), Draft Environmental Impact Statement (DEIS), and Summary of Public comments represents the analysis and summary of the USFS project record of the evaluation of 4 eligible segments for suitability as required in the Forest Service Handbook (FSH) 1909.12, Chapter 80 – “Wild and Scenic River Evaluation”. Supplemental information related to eligibility is contained in the WRNF Forest Plan (2002). V. Decisions and Rationale____________________________________ My decision is an administrative determination that will receive further review and possible modification by the Chief of the Forest Service, Secretary of Agriculture, and the President of the United States. Congress has reserved the authority to make final decisions on designation of rivers as part of the National Wild and Scenic Rivers System (NWSRS). This Record of Decision is the official administrative document which can be used as the basis for making eventual recommendations to Congress. This decision is based upon a review of the analysis in the EIS, the Final WSR Suitability Report (2014), public scoping and comments, and information garnered from public meetings. I have selected Alternative B (B2 in the Draft EIS) and believe this alternative provides the best method of protection for the 4 river segments under study and incorporates the essential aspects of the collaborative public involvement process. This decision does not amend the White River Forest Plan (2002).

a. Deep Creek Description and Rationale

It is my decision that 2 Deep Creek river segments totaling approximately 10.77 miles of National Forest System lands in Colorado administered by the WRNF are determined to be suitable for inclusion into the NWSRS.

Deep Creek Segment 1: This 0.24 mile segment is classified as “Scenic” and begins the Deep Lake outlet to 0.25 miles downstream. It is located on the Eagle-Holy Cross Ranger District, Garfield County, Colorado in Congressional District 3. There are approximately 16.96 acres within this corridor located on National Forest System land.

Courtesy of John Fielder

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Deep Creek Segment 2a: This 10.53 mile segment is classified as “Wild” and begins at eastern end of segment 1 and ends downstream at the USFS/BLM boundary. It is located on the Eagle-Holy Cross Ranger District, Garfield County, Colorado in Congressional District 3. There are approximately 5,023.28 acres within this corridor located on National Forest System lands.

Current management area standards and guidelines prescribed under the 2002 Forest Plan would remain in place and guide management of these corridors. A detailed explanation of management area standards and guidelines can be found in Appendix B in the Final WSR Suitability Report (2014). Management area (MA) prescriptions are as follows:

• Deep Creek segment 1: 3.4 Scenic Rivers- Designated and Eligible. • Deep Creek segment 2a: 1.5 Wild Rivers- Designated and Eligible

The following rationale describes Deep Creek segments 1 and 2a: The ORV’s identified within the corridor include Scenic, Geologic and Ecologic. For a complete description of the ORV’s refer to 2002 Forest Plan, Appendix F. A suitable determination for Deep Creek addresses the corridors long history and recognition of this special place needing long term protection. Deep

Creek is a rare example of an ecologically intact lower elevation watershed. There are no private lands within the USFS segment corridor and existing water rights would not be affected by designation. Colorado Natural Heritage Program described Deep Creek as having one of the most pristine, intact canyon landscapes in Colorado. The corridor contains high quality significant riparian communities, with several state and globally rare species. The entire USFS segment is under federal ownership and the BLM determined the 2 adjacent downstream segments as suitable. No opposition was voiced during public comment period. There are no conflicting or incompatible land uses or water rights within the segment which have the potential to degrade the ORV’s or prevent the agencies from effectively managing the segments. Protecting adequate stream flows is essential to preserving the identified water-dependent geologic (karst) and ecosystem ORVs. For a detailed description of suitability factors refer to the Final WSR Suitability Report (2014).

Courtesy of John Fielder

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After careful consideration of all alternatives, this alternative would ensure continued long-term conservation of the canyon’s outstanding and unique natural characteristics as well as its social and scientific values. Deep Creek’s lower elevation intact ecosystem would contribute to diversity of the national Wild and Scenic River system. Deep Creek and the associated environs is an ecological rarity in the State of Colorado and should continue to remain as such in perpetuity. There are simply few places like the Deep Creek corridor and as such, we have an affirmative responsibility to ensure they remain as such in the public trust. In this decision I have considered the long-term benefits of designation and believe this serves the public in the best way possible. I believe the impacts of this decision are best for the American public in the long run. Future generations will have the opportunity to enjoy and experience this unique landscape as past generations have done.

b. Colorado River Description and Rationale

It is my decision to rely on the Upper Colorado River Wild and Scenic Stakeholder Group Plan (Appendix Q, EIS) and I have elected to defer suitability determinations for the 2 USFS Colorado River segments addressed by the stakeholder plan (USFS segments 1 and 2 are referred to and included as segment 7 in stakeholder plan). As analyzed in Alternative B, I am deferring suitability decisions and determining that the both the USFS Colorado River segments 1 and 2 will continue to be managed as eligible.

Colorado River Segment 1: The 3.35 mile segment (2.97 miles on USFS lands) is classified as “Recreational” and begins at the WRNF boundary on the east end of Glenwood Canyon and ends at the upstream end of the Shoshone Dam. This segment is adjacent to and within BLM segment7 being studied for suitability as part of this process. USFS segments are located on the Eagle Ranger District, Garfield County, Colorado in Congressional District 3. The total of both segment 1 and 2 is approximately 6,526.23 acres within this corridor located on National Forest System land. The WRNF 2002 Forest Plan prescribed management area standards and guides for the entire corridor continuous with Segment 2.

Forest Service File Photo

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Colorado River Segment 2: The 3.13 mile segment (2.46 miles on USFS lands) is classified as “Recreational” and begins at the Shoshone Hydroelectric Power Plant and ends at the WRNF boundary on the west end of Glenwood Canyon. This segment is adjacent to and within BLM segment 7 being studied for suitability. It is located on the Eagle Ranger District, Garfield County, Colorado in Congressional District 3. The total of both segment 1 and 2 is approximately 6,526.23 acres within this corridor located on National Forest System land. The WRNF plan manages the entire corridor consistently with Segment 2.

Current management area standards and guidelines prescribed under the 2002 Forest Plan would remain in place and guide management of these corridors. A detailed explanation of management area standards and guidelines can be found in Appendix B in the Final WSR Suitability Report (2014). Management area (MA) prescriptions are as follows:

• Colorado River segment 1: 4.4 Recreation Rivers-Designated and Eligible • Colorado River segment 2: 4.4 Recreation Rivers-Designated and Eligible

The following rationale describes Colorado River Segments 1 and 2:

The ORV’s identified within the corridor are: Geologic, Scenic, and Recreational. For a complete description of the ORV’s refer to 2002 Forest Plan, Appendix F.

Relying on the Upper Colorado River Stakeholder Group Management Plan (stakeholder plan) complies with USFS policies regarding implementation of the WSR Act. Both the USFS and BLM WSR manuals specifically require the agencies to evaluate various river management options to identify the method that will best support the ORV’s while acknowledging other uses of the river corridor.

Relying on the stakeholder plan in concert with USFS administrative management authorities I believe will provide the best level of protection for the rivers free flowing condition, ORVs, classification, and water quality of Colorado River segments 1 and 2. I believe this decision will also provide certainty for stakeholder’s water yield and flexibility for future management on such a complex river system as the Colorado River. The stakeholder plan recognizes that

Forest Service File Photo

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the Upper Colorado River serves a very broad range of economic interests and demonstrates a remarkable cooperative effort which could produce substantial benefits for the Colorado River corridor. The proposed plan also allows BLM and USFS, in a cooperative manner with the stakeholders, to address flow management issues. The stakeholder plan can be found in Appendix Q of the EIS.

The USFS will rely upon the Upper Colorado River Wild and Scenic Stakeholder Group Management Plan (Appendix I), in concert with forest land management authorities, to protect the free-flowing condition, ORVs, classification, and water quality of Colorado River segments 1 and 2. While the stakeholder plan is in operation, eligibility determinations for the two stream segments will remain in place.

The USFS will make a suitability determination for these stream segments only under the following conditions: • The USFS, after consulting with the stakeholder group, conclude the stakeholder group

plan is not sufficiently protecting free-flowing condition, outstandingly remarkable values, and water quality in the river segment to comply with USFS; or

• The stakeholder group plan is terminated by the members of the stakeholder group.

If USFS concludes that a suitability determination is required under the conditions above, the suitability determination will be made through a standard land use plan amendment process, which affords full opportunity for public comment. For a detailed description of suitability factors refer to the Final WSR Suitability Report (2014).

Table 1. WRNF Suitability Determinations Summary

Segment Name

Suitability Determinations

Segment

Total

Segment Length (miles)

Length

on National Forest

Preliminary

Classification

Outstandingly Remarkable Values

Colorado River

Suitability Determination Deferred- Maintain

Eligibility Status

Segment 1 3.35 2.97 Recreational Recreation, Scenic, Geologic

Colorado River

Suitability Determination Deferred-Maintain Eligibility Status

Segment 2

3.13

2.46

Recreational

Recreation, Scenic, Geologic

Deep Creek Suitable Segment 1 0.24 0.24 Scenic Ecologic, Scenic, Geologic

Deep Creek Suitable Segment 2a 10.53 10.53 Wild Ecologic, Scenic,

Geologic

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VI. Other Alternatives Considered_______________________________ In addition to the selected Alternative B, I have considered 3 other alternatives, which are briefly summarized below. A more detailed comparison of these alternatives for USFS segments can be found in the EIS in Chapter 2 and 4.

Alternative A (Current Condition- No Action Alternative): • All (4) stream segments ((2) Colorado River and (2) Deep Creek) would maintain

eligibility status.

Alternative C (All segments analyzed as suitable): • Determine all 4 eligible river segments as suitable.

Alternative D (All segments analyzed as not suitable): • Determine all four eligible rivers as not suitable and release them from interim

management area protections afforded to eligible segments. This alternative would conclude the suitability study phase for these segments.

VII. Forest Plan Goals and Objectives____________________________

This decision does not result in a Forest Plan amendment. This decision does not alter the multiple-use goals and objectives for long-term land and resource management established during the forest land and resource planning process for the WRNF in 2002. Existing management area prescriptions for the 4 river segments under study will remain in place. There are no ground-disturbing activities associated with this study determination, nor will this change preclude or necessitate additional projects.

Any additional projects proposed within the river corridors would be analyzed in a separate site-specific NEPA document. VIII. Management Area Boundary________________________________ This project does not alter management area boundaries on the WRNF. The determination of Deep Creek segments as suitable for the inclusion in the NWSRS does not change or affect current management prescription boundaries.

Forest Service File Photo

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The decision to defer suitability determinations for Colorado River segments 1 and 2 does not change or affect current management prescriptions or boundaries. The multiple-use goals and objectives for long-term land and resource management identified in the 2002 Forest Plan for these 2 river corridors remains unchanged. IX. Findings Required by Other Laws and Regulations______________ Numerous laws, regulations and agency directives require that the decision be consistent with their provisions. This decision is consistent with all laws, regulations and agency policy relevant to this study as described in the EIS Chapter 4. X. Public Involvement________________________________________ Public involvement for the eligibility phase was conducted as part of the WRNF 2002 Forest Plan. On October 31, 2008, the Forest Service mailed letters to potential stakeholders, including individuals from the public, federal, state, local, and county governments, water conservancy districts, elected officials, and organizations with information about the WSR suitability study process, open houses, and various ways to submit public comments. The formal public scoping process for the WRNF WSR suitability study and associated EIS began on November 7, 2008, with the publication of the Notice of Intent in the Federal Register. The Notice of Intent began a 30 day public scoping process and notified the public of the USFS intent to complete a WSR suitability study on four stream segments on the WRNF that previously had been found to be eligible. The forest entered into a formal cooperative agreement on December 4th, 2008 with the BLM for the purposes of collaborative planning and production of an EIS that would include the WSR suitability study process for both BLM and USFS river segments. The Draft EIS was released on September 16, 2011. The Final EIS includes responses to all substantive public comments as well as all appropriate revisions. This decision was subject to the objection process pursuant to 36 CFR 218, subparts A and B. Publication of legal notice of and the Draft ROD was released on April 7, 2014. No objections were received; however a request for clarification was received by the Upper Colorado River Stakeholder Group and is provided as follows.

A. Clarification of Wild and Scenic Rivers Suitability Decisions In Chapter 2 of the Proposed RMP/Final EIS, the BLM and USFS decided to rely upon on an alternative river management plan proposed by the Upper Colorado River Wild and Scenic Stakeholder Group for Colorado River Segments 5 and 6 (BLM) and Colorado River Segments 1 and 2 (USFS, page citation). The stakeholder group sent a letter to BLM and USFS dated May 1, 2014 that requested clarification of the BLM and USFS suitability decisions. The BLM and USFS provide the following clarifications for these river segments:

1. Suitability determinations these segments have been deferred. The “deferred” status

applies even though there may be locations in the text of the planning documents that

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erroneously referred to these segments as “suitable” after the decision is made to rely upon the stakeholder plan. The “deferred” status applies even though there may be locations in the planning documents that did not clearly identify Alternative B-2 as the Proposed Plan.

2. Even though a suitability determination has been deferred, the river segments will remain under “eligible” status.

3. The BLM and USFS will make a suitability determination for these stream segments

only under the following conditions:

• The BLM and USFS, after consulting with the stakeholder group, conclude that that the stakeholder group plan is not sufficiently protecting free-flowing condition, outstanding remarkable values (ORVs) in the river segments to comply with USFS and BLM policy regarding eligible rivers; or

• The stakeholder group plan is terminated by the members of the stakeholder group.

4. If BLM and USFS conclude that a suitability determination is required under the conditions above, the suitability determination will be made through a standard land use plan amendment process. The land use plan amendment process will allow members of the public and the stakeholder group to provide comment and feedback to the BLM and USFS on the merits of suitability, including comments expressing opposition to or support of a finding of suitability.

B. Clarification on How the USFS Intends to

Interact with the Stakeholder Group and Evaluate the Success of the Upper Colorado River Wild and Scenic Stakeholder Group Management Plan

The stakeholder group sent a letter to the BLM and USFS dated May 1, 2014, that strongly supported BLM’s decision to adopt the stakeholder plan, but that also requested clarification of how the BLM and USFS intend to interact with the stakeholder group and evaluate the success of the stakeholder plan. The BLM and USFS set forth procedures for interacting with the stakeholder and evaluating the success of the stakeholder plan as part of the Wild Scenic Rivers Suitability Report. The following clarifications are made to the procedures outlined in the suitability report:

Courtesy Richard Rhinehart

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1. The Suitability Report contains a provision for “certification” of the stakeholders’ intent to make contributions to the Endowment Fund within six months of the report. [See Final Suitability Report pp. 3-55, 3-68, 3-120, 3-133, 8-20, and 8-32]. The BLM and USFS clarify that this provision would be satisfied by execution of a “Memorandum of Understanding for Participation in the Upper Colorado River Wild and Scenic Stakeholder Group Management Plan” (SG MOU) by a sufficient number of entities that all interest groups specified in the stakeholder plan would be represented.

2. The Suitability Report states that the Endowment Fund will be “used exclusively for projects and studies that protect and enhance the ORVs.” [See p. 3-51 and p. 3- 55]. The BLM and USFS clarify that the endowment fund will be used in a manner consistent with the limitations on use contained in Sections VIII.A.3 and VIII.A.4 of the stakeholder plan, which state that the endowment fund will be used for projects and associated efforts which will further the preservation, protection, or enhancement of the ORVs.

3. The Suitability Report refers to development of an ORV indicator for the botanical

ORV in Colorado River Segment 6. [See Final Suitability Report pp. 3-54, 3-67, 3-119, 3-132, 8-19, and 8-31]. The BLM and USFS clarify that the stakeholder group annual monitoring report should address how the stakeholder group is proceeding to periodically assess and confirm that the management measures under the stakeholder plan, in coordination with the BLM and USFS other land management actions, are protective of the botanical and other ORVs.

4. The Suitability Report and CRVFO Proposed RMP/Final EIS refers to the stakeholder group development of cooperative measures that “comprehensively address the status and trends of the ORVs present within Glenwood Canyon” that “are supported and implemented by major water users within the Eagle River watershed, such as City of Aurora, Colorado Springs Utilities, and other participants in the Eagle River MOU.” [See Final Suitability Report pp. 3-55, 3-68, 3-120, 3-133, 8-20, 8-32; CRVFO Proposed RMP/Final EIS, p. 4-705]. The BLM and USFS clarify that the long term measures and cooperative measures process should be implemented within the Eagle River watershed consistent with the requirements of the stakeholder group plan, and the status and trends in Segment 7 will be addressed in the stakeholder group annual report to the BLM and USFS.

5. The documents establish an interdisciplinary team to conduct an annual review to

determine progress and concerns related to Plan effectiveness. The BLM and USFS clarify that the agencies envision this as an interactive process whereby the interdisciplinary team will work with the stakeholder group and would bring any preliminary concerns to the stakeholder group before finalizing their recommendations to BLM and USFS management.

6. The Suitability Report states that the stakeholder group plan contains provisions for elevating certain issues to BLM and USFS. [See Final Suitability Report pp. 3-51, 3-

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