Adobe Town is proposed by the conservation community for wilderness designation. The area proposed for wilderness includes all of the Adobe Town Wilderness Study Area, plus additional lands of wilderness quality in The Haystacks, along Willow Creek and the Willow Creek Rim, and south of the WSA to the Powder Rim and just beyond it.

The Adobe Town area is a remarkable expanse of high desert buttes and badlands and has long attracted attention for its mesmerizing landscapes. It is possibly the most spectacular and remote set of badlands and geological formation carved by water and wind in the entire state of Wyoming. Throughout the area, virtually untouched by human activity, wide patches of desert pavement and rolling sand dunes stretch across the open spaces between colorful rock formations and rugged canyons.

Adobe Town has been recognized on numerous occasions as having nationally significant and threatened natural-ecological-geological features and for potential inclusion as a national park, underscoring the outstanding natural attributes of the area. However, when the BLM developed its wilderness recommendations, natural gas potential was given priority over public recreation and environmental quality.

The Adobe Town WSA is part of the BLM's Washakie Basin proposed Natural Landmark. This designation is bestowed upon areas with outstanding geological and ecological features. The spectacular landforms of Adobe Town give the area scenery like no other in North America.

It is also one of the three most important paleontologic areas in North America. Fossils of long-extinct mammals, reptiles, and invertebrates erode from beds throughout the area. The palentological resources have been studied since the mid 1800's. This area has been occupied by humans almost continuously for the last 12,000 years, as shown by an estimated 4000 cultural resources sites, including rock shelters, quarries, shelter rings, and firepits.

The area is universally known for its trophy antelope and also contains trophy mule deer. In addition, Wyoming's largest herd of wild horses roams here. Due to an abundance of jack rabbits and other prey, this unit is prime raptor habitat. Golden eagles, prairie falcons, red-tailed hawks, burrowing owls, and ferruginous hawks all nest in these badlands. Horned toads, rattlesnakes and other small desert dwellers also abound.

The area is prime habitat for several high priority plant species, including Gibben's beardtongue, miners candle, fleabane, coewpen crownbeard, Colorado bedstraw, sheepcreek beardtongue, threadleaf rubber rabbitbrush, western hop-sage, and Torrey's desert

Proposed Expansions. During our intensive inventory we found a number of large areas which meet every criteria for wilderness designation and yet were excluded from Adobe Town WSA because of past vehicle routes. Many of the vehicle routes that form the boundaries of Adobe Town (and hence the basis for excluding adjacent roadless lands) either were never "roads" that significantly impact the naturalness of the landscape or have become so reclaimed through the passage of time and the processes of natural degradation that they no longer qualify as roads or significant impacts. These expansions of the WSA to include undeveloped lands that possess wilderness quality would enhance and protect the wilderness quality of lands within the current WSA while ensuring that surrounding wildnerness-quality lands do not fall victim to rampant oil and gas development.

The Haystacks
The Haystacks are a broad arc of deeply dissected badlands that extend northeast from the Adobe Town Rim. According to local tradition, it was in the Haystacks that Butch Cassidy and his gang hid their fresh horses, which helped them elude their pursuers following the Tipton train robbery. Today, visitors to the Haystacks can enjoy the same wild, remote, and pristine character that Cassidy found here in the 1800s.

This lofty chain of ridges and badlands is home to a juniper woodland whose isolated nature within the surrounding sea of sagebrush lends it great ecological importance. The unit is separated from Adobe Town WSA by the Manuel Gap "Road," a rugged jeep trail. We have found that much of this route was never constructed, those parts which received blading have since deteriorated, use is very light and sporadic (not regular), and maintenance has not been performed for such a long time that substantial portions of the route are no longer passable to vehicles of any kind. Hence, this route does not present an intrusion of significant magnitude to warrant the area's exclusion from wilderness.

This area is under "checkerboard" ownership. The Western Heritage Alternative proposes a program of land swaps in order to free up the potential wilderness from private inholdings.

Willow Creek Rim
This unit encompasses a sloping table land between the WSA and the Willow Creek Rim, an area of 20,000 acres including wilderness-quality lands in the badlands of Willow Creek itself, which lie immediately to the east of the rim. The Willow Creek Rim is a tall, vertical scarp that bisects the area from north to south, affording spectacular views of the surrounding country. At its foot lies a maze of badlands that invite exploration on foot or horseback. The spectacular scenery alone is sufficient to lend the area outstanding opportunities for primitive and unconfined recreation.

However, the BLM excluded this area from wilderness consideration because it contained intrusions (a pipeline and a road) and therefore did not meet wilderness criteria. But today, there is no visible evidence that the pipeline was ever laid, and the bladed "road" has been mechanically obliterated and reseeded in the intervening years.

Powder Rim
The Powder Rim is a broad swell of high country that rises at the south end of the Washakie Basin. It is robed in a mix of juniper woodland and sagebrush meadows, and provides nesting habitat for sage grouse. The northern side of the rim slopes down into the Skull Creek basin, where it is dissected into clay badlands. This area apparently escaped the BLM's attention, even though it possesses all of the required attributes. This area provides perhaps the finest opportunities for primitive and unconfined recreation in a juniper woodland setting available in Wyoming. It is separated from the Adobe Town WSA by an old jeep trail that received so little use that it has been completely obliterated by the forces of natural degradation over most of its length. Several jeep trails within this area have been improved by bulldozer blading, an impact that will heal over the course of time once these routes are abandoned. There is one reservoir within the area, which is breached and no longer functional.

East Fork Point
We recommend that all of the lands northeast of Pipeline AT-36 be incorporated into the Adobe Town WSA. This area is traversed by three vehicle routes: AT-9 (BLM Route "G"), which BLM has already classified as a "way," and route AT-8 which is essentially identical and visits a fully reclaimed drill site, and AT-37, a dead-end jeep trail that has fallen into disuse. The area includes three active reservoirs, comparable in every way with Blank, No Name, and Miserable Reservoirs which already are included within Adobe Town WSA. As it now stands, if Adobe Town were granted wilderness status, there would be no major rim summit that would not be vehicle accessible; the addition of this parcel would allow at least some of the rim tops to fall within a wilderness backcountry.

Wild Cow Creek, encompassing the drainages of both Deep Gulch and Wild Cow Creek, is proposed by the conservation community to be designated as wilderness.

The area is dominated by two deep canyons incised into the sloping sagebrush steppes, Deep Gulch and the canyon of Wild Cow Creek. A sparse mantle of vegetation covers the canyon walls, through which reddish sedimentary strata protrude in the steeper areas. In the upper reaches of each watershed, the canyons branch out onto a maze of draws, basins, and ridges. Here, islands of aspen and serviceberry dot the sagebrush steppe, particularly on north-facing slopes. Wildflower displays in May and June are so outstanding that a neighboring drainage was named "Garden Gulch." Elevations within the proposed wilderness range from a low of 6,520 feet to a high of 7,929 feet atop Cow Creek Butte. Snowdrifts persist at the heads of north-facing draws into June even in dry years, recharging aquifers that feed numerous springs and permanently-flowing stretches of stream throughout the area.

Wildlife abound in the proposed wilderness, an astonishing diversity of mammals, birds, and fishes once common throughout Wyoming's sagebrush deserts but now largely absent from most landscapes. The area offers calving/fawning grounds for elk, mule deer, and pronghorn antelope, and most of the area is considered Crucial Winter Range by the Wyoming Game and Fish Department. Sage grouse are abundant on the uplands above the rims. Several active prairie dog colonies are found along the floodplains of both Deep Gulch and Wild Cow Creek. Permanent streams and springs provide habitat for native fish species that are growing increasingly scarce statewide. Raptors, including northern harriers, golden eagles, merlins, and ferruginous hawks, find ideal nesting opportunities along the canyon walls and atop the high rims. The eastern half of the unit falls within the Grizzly Habitat Management Unit, managed by the Wyoming Game and Fish Department for big game and sage grouse.

This area is the best remaining example of the transitional uplands that form the ecosystem type between the Red Desert ecosystem and the forest ecosystem of the Sierra Madre Range. As such, it fills an important gap in ecosystem representation within the National Wilderness System.

A roadless portion of the Ferris Mountains, adjacent to the current Ferris Mountains WSA and encompassing Black Canyon and the hogbacks to the west of it, is proposed by the conservation community to be designated as wilderness.

The area is dominated by a series of low, sharp hogbacks trending northwest-southeast to the west of Black Canyon. The area also boasts pominent white limestone cliffs on the southern flank. While traversing these slope one may find high meadows, secluded rugged canyons, and panoramic views of the Ferris Sand Dunes, Seminoe Reservoir, Green Mountains, Sweetwater Rocks, and the broad Sweetwater Valley. While there are thick conifer strips in some areas, the unit is mostly sagebrush steppe and desert grassland. Several permanent streams flow down from the Ferris Mountains to traverse the proposed addition, sustaining rich bottomland riparian communities with lush growths of vegetation and diverse assemblages of wildlife. Bighorn sheep, antelope, green-tailed towhees, blue grouse, golden eagles, pine marten, and mountain lion all inhabit the area. Historical records indicate that the endangered gray wold and black-footed ferrets were found here. In addition Ferris Mountains provide crucial habitat for elk and mule deer. Unique and rare plants inhabiting the area include miners candle, smooth goosefoot, Bandegee's jacob's-ladder, Wyoming point-vetch, bun milk-vetch, and devil's gate twin pod.

According to the Wyoming Game and Fish Department, the proposed WSA addition provides winter/yearlong and summer range for elk and pronghorn antelope, and also includes crucial winter/yearlong range for mule deer as well as important migration corridors for this species.

The Pedro Mountains are an impressive and rugged chain of tall granite peaks that rise to the east of Pathfinder Reservoir. This area is remote and difficult to access, lending to its wilderness appeal.

Granite domes and slickrock rise sharply over 1000 feet above the surrounding plains. Pockets of pine and aspen grow hidden in moist draws, while cactus and sagebrush spring up in sandy crevices. From Iron Springs, to The Chimneys, to Pyramid Peak, the Pedro Mountains harbor astounding scenery and a mystical feel of primeval land.

The Pedro Mountains are an island of biodiversity and rocky, mountainous terrain amidst the surrounding plains. Visitors to the Pedro Mountains discover an unmistakable feeling of ancient secrets hidden deep within the rocks.

Although the area has not been thoroughly inventoried for archaeologic sites, evidence exists along the former North Platte River, on the area's western boundary, of human habitation as long as 10,000 years ago. And about 1934, a group of WPA workers found a tiny mummified adult human near the area (Barber 1947).

These mountains are unusual in that they provide winter roosting areas for approximately 20 bald eagles. The Pedro Mountains also provide crucial winter and yeat long habitat for about 800 elk (WG&F 1991). They also provide habitat for a wide variety of wildlife, including antelope, mule deer, and nesting poorwwills, and golden eagles and other raptors. Nesting habitat for endangered pergrine falcons exists in the area. The Pedros border a BLM National Back Country Byway and Watchable Wildlife Route, and overlook the Pathfinder National Wildlife Refuge.

At the eastern edge of the Seminoe Mountains, east of Miracle Mile, the landscape is equally primitive as the western side, where the current Bennett Mountain WSA was established. The Bennett Mountains lift abruptly from the prairie. Sheer layered cliffs of limestone, red beds and other sedimentary rock face south overlooking Seminoe Reservoir, while steep canyons and gulches cut the more gradually sloping north flank of this section of the Seminoe Mountains. The area ranges in elevation from 6600 to 8000 feet and features a variety of plant cover, from cushion plants and gnarled juniper, to sagebrush, to thick grassy meadows and draws of chokecherry, willow, and aspen.

This area offers visitors spectacular scenery and isolation. Views from the top feature the Pedro Mountains, Ferris, Sand Dunes, Seminole Reservoir, and mountain ranges of Wyoming and Colorado in the distance to the south. The Bennetts are also in clear view of BLM's National Back Country Byway.

Plant diversity in the area is unusually high, providing for outstanding botany studies. The area provides good summer habitat and crucial winter range for elk (WG&F Completion Report: 1991). Riparian zones in the area provide forage for deer. Pika, marmots, golden eagles, and other raptors, also call the area home. Historical verification of the endangered black-footed ferret were sighted in 1972 and 1979 in the area (WYNDD 1993).

Although a thorough archaelogic survey has not been completed, shelter rings and flint chips show that Native Americans came to these mountains. A pit house and other sites along the old river course west of the area indicate occupation dating to 10,000 years ago (Eakins 1991).

We seek an expansion of the WSA to include the entire ridge east of Kortes Dam.

Prospect Mountain encompasses a needed ecological addition to the Platte River Wilderness Area in the Medicine Bow National Forest. This area's steep canyon/mountain terrain, dense stands of lodgepole pine, and pockets of golden mountain aspen contrast sharply with the adjacent high, dry pastel desert. A large herd of bighorn sheep and about 200 elk are dependent on Prospect Mountain for their survival.

The area offers high quality mule deer and elk hunting along with exceptional scenic vistas. Adjacent nationally-renown portions of the North Platte River are popular with anglers and river runners. Outstanding botanical attributes and interesting geological features make the area important from a scientific and educational standpoint (BLM 198_).

Up to 200 head of elk from the Snowy Range elk herd use the Prospect Mountain WSA year round. The northern half of the WSA is part of a large crucial winter range that is considered essential for the survival of the herd (WG&F Completion Report: 1991). This area contains yearlong range for mule deer and riparian habitat for numerous species of wildlife. This distinctive area provides for a large, unique herd of approximately 130 bighorn sheep for crucial habitat throughout the year (WG&F 1991). Rock walls and grottoes within the area may provide habitat for Townsend's big-eared bat, a forest service sensitive species that is also on the Wyoming Game and Fish Department's watchlist.

The area is known for its concentration of raptors. Bald eagles and peregrine falcons, both listed under the Endangered Species Act, are found to be nesting in this area. The Northern goshawk and the boreal toad are also found here and are also quite rare. In addition, the wolverine and the black-crowned night heron are unique species found near the Prospect Mountain area (WYNDD 1993).

Several unique or rare plant species are found in this area. Listed by the State of Wyoming for protection are mountain muhly, Colorado tansy-aster, park milk-vetch, and Ward's goldenweed (WYNDD 1993).

Under the Western Heritage Alternative, all currently existing ACECs would be retained, and additional ACECs would be added as outlined below. We have attached GIS-generated maps for each of these areas. All of these areas should be withdrawn from surface disturbing activities, and leased only under No Surface Occupancy (NSO) restrictions. In addition to the special areas enumerated in the sections that follow, all crucial winter, crucial winter relief, and elk calving areas identified by WGFD should be granted ACEC status and restricted to NSO stipulations.

Shamrock Hills
The Shamrock Hills are currently managed as an ACEC under the original Medicine Bow - Divide RMP. A total of 284 raptor nest were surveyed in the Shamrock Hills in 2000, including 17 active ferruginous hawk nests, most of them on artificial nesting structures; nesting densities and successful nesting densities were significantly higher than in any other area surveyed within the Rawlins Field Office. In addition, successful nesting was also reported for 5 pairs of golden eagles, one pair of prairie falcons, three pairs of American kestrels, two pairs of burrowing owls, one pair of northern harriers, and one pair of Swainson's hawks in the Shamrock Hills area.

The BLM has noted in the past that raptor concentration areas should be granted special status as ACECs, and we agree. With this in mind, the Western Heritage Alternative supports the retention of the current Shamrock Hills ACEC, and other raptor concentration areas should be identified by and given ACEC status.

Plover ACECs
The mountain plover is proposed for listing as Threatened under the Endangered Species Act, and its rangewide decline appears to be continuing. Wyoming (along with Colorado and Montana) is one of three states that encompass the majority of plover's breeding population. Mountain plover nesting activity is widely dispersed across the Great Divide planning area.

Four plover ACECs have been proposed, at Mexican Flats, Eagle Rock Springs, and two in the Shirley Basin. These ACECs are centered around known mountain plover nesting concentrations. Plover nesting concentrations like these that are found through subsequent research also should be protected by granting them ACEC status.

Bates Hole/Chalk Mountain
This area contains cushion plant communities on limestone and sandstone rims, as well as sagebrush grasslands. It has 5 species of rare plants, including Spaeromeria simplex, a BLM Sensitive Species that is rated Globally Imperiled by the Wyoming Natural Diversity Database, as well as Phsaria eburniflora, rated also Globally Imperiled.

Shirley Basin West
This area contains cushion plant communities on limestone and sandstone rims, as well as sagebrush grasslands and greasewood communities on playas. It has four species of rare plants, including a large population of Spaeromeria simplex, a BLM Sensitive Species. It also contains graminoid-dominated wetlands and shrub-dominated riparian communities, of "highest priority" under the Wyoming Gap study (USGS 1996).

Chain Lakes
The Chain Lakes are an important Red Desert wetland that is a stopover for migrating shorebirds. It also contains mud volcanoes that are interesting from a geological standpoint. The graminoid-dominated wetlands found here are rated "highest priority" for conservation under the Wyoming Gap study. The local greasewood communities are made up of an extremely diverse array of species. The ponds provide rare habitat in the area for shorebirds such as avocets, ducks, killdeer, willets, and other waterfowl. This whole area is truly unique.

Powder Rim
The Powder Rim is a large and important juniper scrub woodland, which also boasts its own desert elk herd and seven species of rare native plants. Among these are two populations of Gibben's beardtongue, rated Globally Critically Imperiled by WYNDD. It also includes cottonwood riparian communities rated "highest priority" under the Wyoming Gap study, as well as xeric upland shrub, and desert shrub communities that are also of high concern.

There are 10 species virtually confined to Utah juniper communities in Wyoming: gray flycatcher, ash-throated flycatcher, western scrub jay, plain titmouse, bushtit, Bewick's wren, blue-gray gnatcatcher, gray vireo, black-throated gray warbler, and Scott's oriole. Nine of these ten (all except the gray vireo) have nest records along the Powder Rim. In the Great Divide area, Scott's orioles, blue-grey gnatcatchers, and plain titmouse have been recorded from Powder Rim.

Since juniper woodlands make up only approximately 2% of the land area in Wyoming, the Powder Rim juniper woodland bird community is quite unique and should be conserved. Designation as an ACEC would help realize this goal.

Ferris Dunes
The sand dunes south of the Ferris Mountains are a spectacular and fragile ecological community boasting a diverse assemblage of unique plants and animals, including the Endangered blowout penstemon. For the Great Divide Basin, scurfpea and ricegrass communities in the sand dunes contain the greatest kangaroo rat concentrations, a species that is almost exclusively restricted to the sand dunes and their adjacent areas in the Basin. The vegetated sand dunes, active sand dunes, and graminoid-dominated "vernal pond" wetlands in this area all are rated "highest priority" for conservation.

Both known Wyoming populations of the Endangered blowout penstemon occur within the proposed Ferris Dunes ACEC. The large degree of population fluctuation inherent to this species makes it imperative to employ a conservative approach in which potential threats that might contribute to population declines, or which might prevent population spreads, are prohibited in this area. In addition, pollinators of blowout penstemon appear to be limited to four species of solitary bees, only one of which would occur throughout Wyoming. Thus, the survival of the blowout penstemon may hinge not only on protecting the plant populations themselves but also on guaranteeing the persistence of its obligate pollinators to assure the penstemon's ability to reproduce.