A Petition to the Environmental Quality Council
for Designation of an Area Known as Adobe Town
as Very Rare or Uncommon
Under the Authority of the Wyoming Environmental Quality Act,
W.S. ?35-11-112
and
Chapter VII of the Wyoming Department of Environmental Quality
Rules of Practice and Procedure
Submitted to the Chairman of the Environmental Quality Council
on
November 6, 2006
Submitted by
Biodiversity Conservation Alliance
Erik Molvar, Executive Director rd215 South 3 Street, Suite 114/ P.O. Box 1512
Laramie, WY 82073
(307) 742-7978; Fax (307) 742-7989
This Petition is Endorsed by the Following Organizations:
Wyoming Wilderness Association Wyoming Outdoor Council
Liz Howell, Director Bruce Pendery, Program Director P.O. Box 6588 262 Lincoln
Sheridan, WY 82801 Lander, WY 82520
The Wilderness Society Center for Native Ecosystems Suzanne Jones, Regional Director Jacob Smith, Director
1660 Wynkoop, Suite 850 1536 Wynkoop St., Suite 302 Denver, CO 80202 Denver, Colorado 80202
Sierra Club, Wyoming Chapter Natural Resources Defense Council Kirk Koepsel, Regional Representative Amy Mall, Rock Mountain Representative 247 Coffeen Ave. 1809 Mariposa Avenue
Sheridan, WY 82801 Boulder, Colorado 80302
Friends of the Red Desert
Joy Owen, Statewide Coordinator
P.O. Box 1611
Lander, WY 82520
A. Location
The proposed Very Rare boundary encompasses 180,910 acres, as shown on the
accompanying map, but this petition applies only to the state and federal holdings
within this boundary. Because the boundaries follow pipelines and vehicle routes that
were not surveyed in along section lines, but rather randomly aligned on the
landscapes, legal descriptions at the Section level are approximate. The
accompanying maps (Attachments 1 and 2) should be considered the primary
authority in determining boundaries.
T17N R 97W: Approximately the south half of Section 36, bounded to the north by a buried pipeline;
T17N R96W: Bounded to the north by a buried pipeline, as follows: A portion of the southeastern third of Section 22; the southwestern third of Section 24; the southeast half (diagonally) of Section 28; the southern two-thirds of Section 30; and all of Sections 25, 26, 34, and 36.
T17N R95W: Bounded to the north by a buried pipeline, the southwest diagonal halves of Sections 30 and 32.
T16N R97W: Bounded to the northwest by a buried pipeline, the southeastern corner of Section 8; the southeastern third diagonally of Section 18; the southern Half of Section 25; the southeastern eighth of Section 23; the southeast ? of Section 33; and all of Sections 2, 10, 12, 14, 16, 20, 22, 24, 26, 28, 30, 32, 34, 35, and 36.
T16N R 95W: The southern ? of Section 29; the southeastern 7/8 of Section 27; and all of Section 2, 4, 6, 8, 10, 12, 14, 16, 18, 20, 22, 24, 25, 26, 28, 30, 31, 32, 33, 34, 35, and 36.
T16N R95W: Bounded to the east by a buried pipeline and a gas-field trunk road; the western 1/3 of Section 8; the western 1/3 of Section 20; the southeastern 5/8 of Section 19; the western 1/3 of section 29; and, bounded to the north by a gas-field trunk road, the southeastern 1/5 of Section 29 and southwestern 1/3 of Section 28; and bounded to the east by a gas-field trunk road, the western 2/3 of Section 33; and all of Sections 6, 18, 30, 31, and 32.
T15N R98W: Bounded to the west by a buried pipeline, the eastern 5/8 of Section 1; the eastern roughly one-half of Section 12; the southeastern ? diagonally of Section 13; the northeastern roughly ? of Section 24; the eastern 1/3 of Section 25; and the eastern 1/3 of Section 36.
T15N R95W: Bounded to the northeast by gas-field access roads, the southwest 7/8 of Section 4, the south half of section 3, the southwest 1/8 of Section 2, the southwest 2/3 of Section 11, the southwest ? of Section 13, the southeast corner and northwest ? of Section 14, the northwestern 7/8 of Section 15, the southwest 7/8 of Section 22, the southeast 2/3 of Section 23, the southwest 2/3 of Section 24, the southwest 15/16 of
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Section 25, and all of Sections 4, 5, 6, 7, 8, 9, 10, 16, 17, 18, 19, 20, 21, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, and 36.
T15N R94W: Bounded to the northeast by a gas-field road, the southwest 1/8 of Section 30 and the western 1/3 of Section 31.
T14N R94W: Bounded to the east by a gas-field trunk road, the northwest ? of Section 6.
T14N R95W: Bounded to the southeast by improved gravel vehicle routes, the northwest 7/8 of Section 1, the northwest 2/3 of Section 10, the northern 1/3 of Section 11, the northwest 1/8 of Section 12, the northwest 1/3 of Section 16, the northwest 7/8 of Section 17, the northeast ? of Section 19, the northwest ? of Section 20, and all of Sections 2, 3, 4, 5, 6, 7, 8, and 18.
T14N R96W: Bounded to the south and east by gas-field trunk roads, the northwest 1/3 of Section 24, the northwest 1/3 of Section 25, the northern 1/3 of Section 26, the northern 1/3 and southwestern corner of Section 27, the western ? (diagonally) of Section 34, and all of Sections 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 28, 29, 30, 31, 32, and 33.
T14N R97W: Bounded to the west by a buried pipeline and an improved gravel road, the northeast ? (diagonally) of Section 18, the northeast 1/16 of Section 19, the northeast 2/3 of Section 20, the northeast 1/3 of Section 29, the southern ? of Section 31, the southeast ? (diagonally) of Section 32, and all of Sections 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 21, 22, 23, 24, 25, 26, 27, 28, 33, 34, 35, and 36.
T14N R98W: Bounded to the west by a buried pipeline, the eastern 1/3 of Section 1, the eastern 2/3 of Section 12, the northeast 1/3 of Section 13, and the southeast 1/3 of Section 36.
T13N R98W: Bounded to the west by an improved gravel road, the eastern 3/8 of Section 1 and the northeast 1/8 of Section 12.
T13N R97W: Bounded to the west by an improved gravel road, the northeast 2/3 of Section 7, the eastern ? of Section 18, the northeast 1/8 of Section 19, the eastern ? of Section 29, the northeast 1/3 of Section 32, the northern 2/3 of Section 33, the northeast 15/16 of Section 34, and all of Sections 1, 2, 3, 4, 5, 6, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 20, 21, 22, 23, 24, 25, 26, 27, 28, 35, and 36.
T13N R96W: Bounded to the east by an improved gravel road and to the south by a well-worn two-track jeep trail, the western ? of Section 3, the northwest 2/3 of Section 10, the nborthwest ? of Section 15, the northern 2/3 of Section 16, the northwest 15/16 of Section 17, the western ? of Section 20, the western 1/3 of Section 29, the northeastern 7/8 of Section 31, the southwest 2/3 of Section 32, and all of Sections 4, 5, 6, 7, 8, 9, 18, 19, and 30.
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T12N R96W: Bounded to the south by a well-worn two track jeep trail, the northern ? of Section 5 and the northeast 1/8 of Section 6.
T12N R97W: Bounded to the south by a well-worn jeep trail, the northwest 1/8 of Section 1, the northern 1/3 of Section 2, and the northeast 1/6 of Section 3.
All of the following townships: T15N R97W; T15N R96W.
B. Names by which the area is known locally
The area described is known generally as Adobe Town, with portions of the area known as the Adobe Town Rim, The Haystacks, Manuel Gap, Horseshoe Bend, Haystack Wash, Sand Creek, Monument Valley, Skull Creek, the Skull Creek Rim, East Fork Point, Willow Creek, the Willow Creek Rim, Salazar Butte, and the northwest corner of the Powder Rim.
C. Distance to Nearest Town: The proposed Very Rare or Uncommon area is located in Sweetwater County, 20 miles south-southwest of Wamsutter, Wyoming.
D. Surface and Mineral Estate Owners:
Bureau of Land Management, owner of 167,517 acres within the boundary (including all
lands not specifically listed by legal description below), about evenly split between the Rock Springs and Rawlins Field Offices:
Rawlins Field Office, P.O. Box 2407, Rawlins, WY 82301;
Rock Springs Field Office, 280 Highway 191 North, Rock Springs, WY 82901.
Rock Springs Grazing Association, Rock Springs National Bank, P.O. Box 880, Rock Springs, Wyoming 82902.
Owners of 11,105.51 acres private surface within the boundary. These lands include T17N R97W Section 35; T17N R96W Sections 23, 25, 27, 29, 31, 33, and 35; T17N R 95W Sections 29, 31, and 33; T16N R98W Section 25; T16N R97W Sections 1, 3, 9, 11, 13, 15, 13, 15, 17, 19, 21, 23, 25 (N ? ), 27 (N ?, SW ?, SWSE, NWSE), 29, 31, and 33 (N ?, SW); T16N R96W Sections 1, 3, 5, 7, 9, 11, 13, 15, 17, 19, 21, 23, 27 (NWNW, SENW), 29 (N ?); T16N R96W Sections 5, 7, 17, and 19 (NW ?, NWNE, SWNE); T15N R98W Section 1; and T15N R97W Section 5 (N ?, NWSW, SWSW).
Anadarko Petroleum Corporation, 1201 Lake Robbins Drive, The Woodlands, Texas 77380.
Owners of 11,105.51 acres private minerals within the boundary. These private mineral interests include T17N R97W Section 35; T17N R96W Sections 23, 25, 27, 29, 31, 33, and 35; T17N R 95W Sections 29, 31, and 33; T16N R98W Section 25; T16N R97W Sections 1, 3, 9, 11, 13, 15, 13, 15, 17, 19, 21, 23, 25 (N ? ), 27 (N ?, SW ?, SWSE, NWSE), 29, 31, and 33 (N ?, SW); T16N R96W Sections 1, 3, 5, 7, 9, 11, 13, 15, 17, 19, 21, 23, 27 (NWNW, SENW), 29 (N ?); T16N R96W Sections 5, 7, 17, and 19 (NW ?, NWNE, SWNE); T15N R98W Section 1; and T15N R97W Section 5 (N ?, NWSW, SWSW).
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Raftopoulos Brothers Livestock Company, 893 Stout Street, Craig, CO 81625.
Owners of 162.86 acres of private surface within the boundary. These lands include T14N R97W Section 31 NWSE and SESW; T13N R 97W Section 6 SESW; and T13N R98W Section 1 SENE and small portions of NWNE.
th Street, State of Wyoming, Office of State Lands and Investments, 122 West 25rdHerschler Bldg., 3 Floor West, Cheyenne, WY 82002.
Owners of 2,124.7 acres within the boundary, including T15N R97W Section 16; T15N R96W Section 16; T14N R98W Section 36; T13N R97W Section 6 SWNW, NWSW, SWSW and Section 7 SWNW, and Section 36; T13N R96W Section 19 SENE and Section 20 SESW.
Federal mineral lease holders or part-holders (not required for Very Rare or Uncommon petitions), according to the Bureau of Land Management‟s LR 2000 database, are
nonetheless listed in Appendix A of this petition.
E. Very Rare or Uncommon Features of Adobe Town
The Adobe Town Area contains Very Rare or Uncommon Features including geological formations, abundant fossil resources, historical and prehistoric sites and features, rare and sensitive (including crucial) wildlife habitats, and scenic values comparable to or eclipsing existing national park units. All of these values are very rare nationwide and, if left unprotected, are at risk of elimination.
Historical, Prehistorical, and Archaeological Values
Adobe Town has a number of historical, prehistorical and archaeological values that meet the criteria for Very Rare or Uncommon designation. It is mentioned prominently in the thjournals of the Geological Exploration of the 40 Parallel (circa 1869), and was used as a
hideout for fresh horses by Butch Cassidy and his gang during the Tipton train robbery of 1900. The area has a high density of archaeological sites dating back 12,000 years, and is still used as an important religious site by Native Americans today.
Adobe Town is mentioned prominently in the Report of the Geological Exploration of the th40 Parallel, a federal document authored by eminent geologist Clarence King in 1869. This area was identified by King as the most superlative geological landscape found along the survey route. King described the general landscapes as follows:
“From twelve to fourteen miles southwest of the head of Bitter Creek are
seen exposures of the soft green clays, marls, and whitish-gray ands of
which the upper beds of the Bridger group are made. Passing eastward of
Pine Bluffs [known today as Pine Butte], the country is covered with more
or less drifting sand, which forms noticeable trains of dunes. The sand
suddenly gives way to the soft Bridger beds which are intricately eroded
into branching ravines [Adobe Town and Skull Rims]. This bad-land
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country extends southeastward to the mouth of a dry valley [Sand Creek] north of Cherokee Ridge [Powder Rim/Cherokee Rim], and from that point a chain of bluff escarpments extends northeasterly for twelve or fourteen miles.”
The Adobe Town and Skull Creek Rims received the highest praise from King:
“This escarpment is the most remarkable example of the so-called bad-
land erosion within the limits of the Fortieth Parallel Exploration...Along the walls of these ravines the same picturesque architectural forms occur, so that a view of the whole front of the escarpment, with its salient and reentrant angles, reminds one of the ruins of a fortified city. Enormous masses project from the main wall, the stratification-lines of creamy, gray, and green sands and marls are traced across their nearly vertical fronts like courses of immense masonry, and every face is scored by innumerable narrow, sharp cuts, which are worn into the soft material from top to bottom of the cliff, offering narrow galleries which give access for a considerable distance into this labyrinth of natural fortresses. At a little distance, these sharp incisions seem like the spaces between series of pillars, and the whole aspect of the region is that of a line of Egyptian structures. Among the most interesting bodies are those of the detached outliers, points of spurs, or isolated hills, which are mere relics of the beds that formerly covered the whole valley. These blocks, often reaching 100 feet in height, rise out of the smooth surface of a level plain of clay, and are sculptured into the most remarkable forms, surmounted by domes and ornamented by many buttresses and jutting pinnacles. But perhaps the most astonishing single monument here is the isolated column shown in the frontispiece of this volume. It stands upon a plain of gray earth, which supports a scant growth of desert sage, and rises to a height of fully sixty feet. It could hardly be a more perfect specimen of an isolated monumental form if sculptured by the hand of man.”
The wonders of The Haystacks are described by King as follows:
“To the south of the stage-road, west of Barrel Springs, is a narrow, east
and west ridge, whose irregular, serrated outline forms a striking contrast to the usual level summit line of the bluff ridges of this region….This
ridge rises toward the east, having its culminating point in Haystack Mountain, which has an elevation of about 900 or 1,000 feet above the surrounding plains.”
King also noted the prevalence of fossilized wood in the Haystacks area:
“On the northern face of Haystack Mountain was found the petrified trunk of a large coniferous tree, lying across one of the narrow ravines, a length of about 15 feet being thus exposed, either end being still imbedded in the
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sandstone. The woody appearance is very well preserved, the exterior
being whitened, so that the resemblance to the weathered trunk of a dead
tree is almost perfect; portions of the bark are covered with yellow spots,
apparently of exuding gum, retaining their original coloring. The interior
is a black, compact siliceous material, and, where the heart of the tree has
decayed out, is loosely filled by crystalline quartz, still preserving some of
the general fibre of decayed wood.”
The region surrounding the Willow Creek Rim, at the eastern end of the unit, is described by King as follows:
“In the region of Church Buttes outliers of the Bridger group constitute
detached bodies rising above the Plains in the most picturesque forms,
eroded in the characteristic bad-land shapes; domed mounds and
buttressed blocks remind one of a variety of architectural designs.”
In addition to the historical noteworthiness of the Geological Exploration, Adobe Town is also unusually rich in archaeological sites. According to BLM (1991, p. 188),
“Significant archaeological resources are found throughout the [Adobe
Town] WSA, representing continuous occupation from Paleo Indian
through late Prehistoric periods, that is, for the past 12,000 years. The
cultural site density of the WSA is estimated to be 30 surface sites per
square mile, which is unusually high.”
Geological Values
Adobe Town is a geological masterpiece, dominated by outcroppings of the Washakie formation, a deep bed of volcanic ash deposited 50 million years ago during the Yellowstone eruptions as airborne ash and fluvial desposits of ash interbedded with reddish sandstone that forms rimrock. BLM (1981, p. 4) describes the geology of the rims as follows:
“They are composed of green, gray, and red tuffaceous and arkosic
sandstone and minor beds of green shale, light-gray and green tuff, gray
siltstone and conglomerate. The exposed beds have created the colorful
landscape the Adobe Town Area is known for.”
These are the epitome of fragile lands, with highly erodible soils (both the tuffaceous sandstone and the stabilized sand dunes mantled with a fragile veneer of vegetation) and the towers, arches, and balanced rocks which would easily be toppled by mechanical disturbance.
Above the rims, unique geological features include desert pavement and stabilized sand dunes. The rims have been whittled by erosion into spires and pinnacles, solifluction caves (known locally as „mud caves‟) large enough to walk through (see Attachment 19),
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natural arches, lone towers, groups of castellated pillars, window rocks, grottoes, buttes, caprocks, mushrooms, hat rocks, and eroded badlands banded with pink, red, and purple tones (all of which are shown in photographs in Attachment 6). According to BLM (1991, p.184), “Skull Creek Rim, in the core of the area recommended for wilderness, contains
some of the most unique and extensive badlands formations in Wyoming.” BLM (1981, p.
4) described the effect of this surreal landscape as follows:
“Many of the spires take on strange life-like forms – stone sentinals (sic)
frozen in time standing guard over their silent desert domain. Walking
amidst groups of these strange spires gives one the eerie feeling of being
watched – by beings who have witnessed the evolution of Adobe Town for
millennia.”
The paleontological resources of Adobe Town are among the finest deposits of Eocene mammals and reptiles in the world. According to BLM (1991, p. 187), “The Adobe Town
area is known as one of the three most valuable sites in North America for certain types of mammalian fossils.” BLM (1991, p. 188) further noted,
“The WSA is nationally known for the educational and scientific study of
paleontological resources. Fossil remains of mammals are numerous and
widely distributed throughout the area. Two notable mammalian fossils
found in the area are the Uintathere and Titanothere. The Uintathere was a
large mammal about the size and configuration of an African rhinoceros.
The species of Titanothere found in the WSA was a tapir-like mammal,
about 40 inches in height. This area has been identified as one of the
premiere sites in North America for paleontological resources.”
The abundance of fossils in this area was first identified by the Geological Exploration of the Fortieth Parallel. Geologist Clarence King wrote in 1869,
“These bluffs are extremely rich in the remains of vertebrate fossils. At the
base of almost every cliff were observed the bones of Mammalia, and
frequent [turtle] shells of Testudinata.”
Several examples of reprinted scientific studies from the Adobe Town Very Rare or Uncommon area have been attached to this petition (Attachments 31 and 32). In addition, the paleontology of Adobe Town has been researched in a number of additional scientific studies (Turnbull 1978, Krishtalka et al. 1989, Turnbull 1993, Lillegraven 1993, Turnbull 1995, McCarroll et al. 1996a, b, Turnbull 2004); included in Literature Cited section of this petition.
Wildlife Values
The Adobe Town Very Rare or Uncommon proposed area has a host of sensitive wildlife habitats that are crucial or vital (including nest sites, sage grouse lek sites, prairie dog colonies, and big game crucial winter ranges) meeting very rare or uncommon designation criteria. The cliffs and pillars found throughout Adobe
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Town provide ideal nesting habitat for raptors, offering a myriad of nesting platforms out of the reach of ground-based nest predators. Raptor nest sites, sage grouse lek sites, and big game crucial winter ranges are exceptionally sensitive because even temporary disturbances can lead to nest failure (for the birds) or displacement of big game onto marginal ranges where they may not be able to survive. Avoidance of areas where industrial activity occurs has been shown for elk (Powell 2003, Sawyer et al. in press), sage grouse (Holloran 2005, Naugle 2006a, b, Kaiser 2006), mule deer (Sawyer et al. 2004, 2005) and pronghorn (Berger et al. 2006). The sensitivity of nesting raptors to disturbance has been shown by Parrish et al. (1994) and White and Thurow (1985).
The mountain plover is recognized as a BLM Sensitive Species and as a Sensitive Species by the Wyoming Game and Fish Department. Until recently, it was listed as Threatened under the Endangered Species Act. The Horseshoe Bend area south of The Haystacks contains vital mountain plover nesting habitat with a number of confirmed plover sightings (BLM 2003, Figure 3-2, p. I-10); see also attachments
and 4. Mountain plovers have also been sighted atop the Adobe Town Rim at 3
T15N R98W Section 25 NE ? (see photo, Attachment 33), and at the southern edge of the Adobe Town Rim (map, attachment 3).
The white-tailed prairie dog is a BLM Sensitive Species and also is recognized as a Sensitive Species by the Wyoming Game and Fish Department. There is a small white-tailed prairie dog colony observed at T 14N R97W sec. 12, SE ?, which has been active at least between 2001 and 2006; white-tailed prairie dogs were also observed in Section 13 NW ? of the same township in 2006. Active white-tailed prairie dog colonies also occur in Horseshoe Bend south of the Haystacks (BLM 2003, Figure 3-1, page I-7).
There are a number of known golden eagle nest sites within the proposed Very Rare or Uncommon area, including two nest sites along the western end of The Haystacks (T16N R97W Sec. 10 NE ? and T16N R97W Sec. 15 SW 1/4), one along Haystack Wash as it leaves the rimrock area (T16N R96W Sec. 30 NW ?), and one on the lower rim (T15N R96W Sec. 18 NW ?) (BLM 2001; see map, Attachment 4). In the Rawlins Field Office, two golden eagle nests occur in the southern end of the Wilderness Study Area, with additional nests known from the Willow Creek Rim in the eastern proposed expansion unit and on outcrops to the west of Sand Creek in the southeastern proposed expansion unit (see map, Attachment 3).
The greater sage grouse is a BLM Sensitive Species and also is listed as a Sensitive Species by the Wyoming Game and Fish Department. There are two known sage grouse leks (traditional breeding sites used year after year) in the Very Rare or Uncommon proposed area, one in the southeastern proposed expansion and one in the northeastern lobe of the Wilderness Study Area (see map, Attachment 3). Sage grouse leks are the hub of nesting activity, and
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typically most of the hens bred at a lek nest within 3 miles of the lek site. Thus, the area around each lek also constitutes important nesting habitat.
There is a desert elk herd, known to the Wyoming Game and Fish Department as the Petition Herd, which is one of the few true desert elk herds in North America, spending the entire year in the Red Desert. This elk herd is therefore very rare indeed.
Known prairie falcon nest sites within the proposed Very Rare or Uncommon area include one at T16N R95W Sec. 19 NW ?; two near Manuel Gap (T16N R97W Sec. 27 SW ? and T16N R97W Sec. 28 SW ?); and T15N R96W Sec. 19 NE 1/4 (BLM 2001, map Attachment 4). Prairie falcons with fledgling young were observed roosting on a pinnacle just off the Skull Creek Rim at T13N R97W during the early summer of both 2005 and 2006. Prairie falcons with fledgling young were also sighted at T15N R97W Section 19 SW ? on July 9, 2006. A known prairie falcon nest also was recorded by BLM on the bluffs above Willow Creek in the eastern proposed expansion (see map, Attachment 3).
Several other raptors are on the BLM and Wyoming Game and Fish Department Sensitive Species Lists. The burrowing owl, which is a prairie dog obligate species that nests in burrows of prairie dog towns, has one known nest location in the southwestern corner of the Adobe Town Wilderness Study Area (see Attachment 3). The ferruginous hawk, the largest hawk in Wyoming, has nest sites confirmed by BLM two miles south of Manuel Gap (see Attachment 3) and in the southeastern proposed expansion (see Attachment 4).
Due to the rugged and inaccessible nature of much of Adobe Town, no thorough and systematic inventory of nesting raptors has ever been performed. For instance, there are several known nest sites of ferruginous hawks active in recent years which are not in the BLM‟s database, even in accessible areas. An occupied and
active ferruginous hawk nest was observed by Erik Molvar and Joel Sartore on the eroded walls far below East Fork Point at T14N R96W Section 8 SWSE on May 4, 2004. In addition, an active and occupied ferruginous hawk nest was documented in the Haystacks at T17N R96W Section 33 SWSE by Liz Howell and separately by Erik Molvar during summer of 2005, and the same nest was found to be active again in 2006 by Erik Molvar.
The Great Basin gopher snake is listed as a BLM Sensitive Species. This species has been photographed along the Adobe Town Rim at T15N R97W Section 19, NW ? (see photograph in Adobe Town Briefing Book, Attachment 6 at page 9).
The Haystacks is identified by the Wyoming Game and Fish Department as crucial mule deer winter habitat (BLM 2001, see map at Attachments 3, 4). There is also a substantial amount of pronghorn crucial winter range south of Horseshoe Bend along the branches of Haystack Creek (Id., and see map, Attachment 4). In addition, portions of the Rare and Uncommon area on the north slope of the
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