August 12, 2004

Mr. Steven Williams

Mr. Lance Brown

Tonopah Ranger District

1400 S. Erie Main St.

Tonopah, NV 89049-3940

Dear Mr. Williams,

Here are initial comments of Western Watersheds Project on the Elkhorn
Canyon Prescribed Burn Project. We are very concerned that the scoping
notice contains so very little information of any kind. The map is a
joke -- the contour lines are impossible to discern in the shaded areas,
as are the drainages and other features. Understanding of slope,
hydrology and other factors are necessary to allow the public to provide
adequate scoping comments. This has all the earmarks of a "Spend Federal
Fire Funds Anyway You Can" project. The Forest appears to have already
slammed the door on any course of action other than fire, in violation
of NEPA.

The Forest must prepare an EIS. The "MMA" is 15,135 acres. This is a
major federal action that will have significant direct, indirect and
cumulative effects on a wide range of environmental factors, including
soils, water quality, watersheds, native plant communities, cultural
sites, recreational values, aesthetic values, wildlife habitats, special
status species habitats. It involves a great deal of environmental risk,
and controversy.

The Forest can not tier this to the outdated Land Use Plan. Conditions
across the arid West have changed dramatically since it was finalized,
and the old data on which it was based was collected.

It is hard to understand the need for this -- it appears to be that you
have access to federal fire funds, and are trying to spend as much as
possible in an area where they are little needed. Have you already spent
taxpayer funds on this project before sending out a scoping notice? Has
a fuels assessment already been prepared, with taxpayer funds spent?

Will this process have a pre-ordained outcome -- so the NEPA is really
just a farce -- to endorse a course of action that the Forest is already
planning on conducting?

What human-urban interfaces exist in the Elkhorn area? Please provide a
detailed description of these areas, and their characteristics.

Please provide a detailed study of habitat fragmentation of all
vegetation communities) in the Tonopah Ranger District and surrounding
and interfacing BLM and private lands. How much juniper habitat has been
fragmented? How much sagebrush habitat? Mountain shrub habitat?

What is the name of the Wilderness shown on the near-featureless map?
How will you control fire that escapes into the Wilderness?

Please provide a detailed list, and collect site-specific information on
past vegetation "treatments" in the Tonopah Forest and BLM and private
lands, and their current condition. How many acres have been burned in
controlled or wild fires? Cut? Plowed? Sprayed? Seeded with exotics?
What species of exotics? What is the pattern of this disturbance across
the landscape?

The Forest must conduct a thorough weed inventory -- for both noxious
weeds and invasive exotic annuals in and near the project area. What
sites, soils, etc. presently suffer from invasives? What does this tell
you about the vulnerability of Elkhorn lands to invasions/spread of
weeds associated with any treatments?

Are these lands in or near any mule deer winter range, or other
recognized wildlife habitats? If so, how will this project impact these
habitats?

Please provide a detailed economic analysis of the cost of all phases of
this project.. Are you hiring outside contractors? Who? Please send us a
copy of nay fuels loading or other study that you may already have
prepared in support of this for review.

Please provide detailed information on the current ecological health of
these lands, and the impacts of ongoing livestock grazing on the values
of the lands within and surrounding the project area.

Please provide detailed livestock grazing monitoring information and
other data necessary to understand any ecological problems you claim to
address here.

Please provide current ecological information on the health of all plant
communities in the allotment. What information do the ESI sites provide?
Long-term trend or other monitoring data?

Detailed information on livestock grazing in all allotments should
include utilization, use pattern mapping, violations, trespass, any
other information related to ecological conditions here, We refer you to
Belsky and Blumenthal (available at
[www.onda.org](http://www.onda.org/)) describing the causal link between
livestock grazing and doghair thickets of trees and other conditions
that you may term "hazardous fuels" or "unhealthy".

The scientific literature overwhelmingly demonstrates the great harms
that domestic livestock grazing has done to the West's arid ecosystems
(Fleischner 1994). These harms include:

\* Spread and proliferation of exotic species;

\* Destruction of microbiotic crusts;

\* Soil erosion;

\* Harm and destruction of native plant communities;

\* Harm to native wildlife species through habitat alteration,
behavioral disruption and other factors;

\* Alteration of "natural" fire cycles - causing increased frequency of
fires in lands degraded by exotic species invasions or increases in
woody species due to grazing;

\* Destruction of cultural sites through trampling;

> \* Prevention of successful restoration with native species.

Please explain how your project, and its outcomes, will be affected by
livestock grazing, drought, and other factors and their associated,
intermingled direct, indirect and cumulative impacts.

It is now well known that domestic livestock grazing is the primary
cause of lack of aspen regeneration in nearly all areas across the arid
West. Please review the work of Dr. Charles Kay, including a report
prepared for Battle Mountain BLM in Nevada. Instead of burning or
cutting aspen, you must act to remove livestock grazing pressure. There
is absolutely no need to burn aspen stands. Are you burning any aspen?

The Forest may be using federal fire funds to kill woody vegetation in
an attempt to grow more forage for livestock. What is the current
productivity/carrying capacity of lands in the project area, and on all
allotments in or near the project area? What is the current stocking
rate on these lands? Has trespass occurred? Are wild horses present?

The scoping notice states that there are 3500-4500 acres of "primarily"
pj. Please provide a map of vegetation communities to us immediately --
as it is impossible to determine the accuracy of this claim without
examination of a detailed map.

We request that the Forest bring top fire personnel, and assess the need
for any actions to reduce fuels here, and the effectiveness of creating
a "mosaic" in lands that may vulnerable to cheatgrass or other weed
invasions.

As you may be aware, there is alarm over large die-off of pinyon
communities across the Wet. How much of the affected land contains
pinyon? Are mature or old growth trees present? Are pinyon jays or other
declining pinyon-juniper obligates species present, and how will this
affect habitats and populations? Do Native Americans harvest pine nuts
in this area?

We are not convinced that the Forest will be able to control fires, as
it is proposing to gash and scar these lands with fire breaks. If the
fuels situation here is "hazardous", how will you be able to control
blazes? What are the risks of escape? What is the health of the
watersheds and riparian areas and intermittent or ephemeral drainages in
the affected lands?

The Forest must rest any treated lands from livestock grazing for 5-10
years to ensure that healthy native plant communities, including
vigorous understories, result from any vegetation manipulation here. No
lands in less than "good" ecological condition should be burned.

The Forest must conduct comprehensive baseline inventories for all
important native wildlife and special status species here. These studies
must be undertaken for a minimum of 2 years, conducted during all
seasons of the year, and the data included and analyzed as part of an
EIS process.

Please provide detailed information on habitats and populations of
pinyon jay, sage grouse, black-throated gray warbler, Virginia warbler,
sage thrasher, Brewer's sparrow, pygmy rabbit, bats species, and other
native important native wildlife that inhabit these lands. Are spring
snails present in riparian areas?

The Forest must thoroughly assess the risks associated with all possible
treatments. What are the risks of weed invasion following fire, vs.
risks of weed invasion following hand cutting?

Please provide detailed studies of the effects of all proposed treatment
methods on all soil types found here. What is the current health of all
soils here? How much topsoil has eroded here due to livestock grazing
and other anthropogenic causes?

Please provide a detailed analysis (maps, rate of increase) of roads,
trails, and OHV paths in the project area and the Tonopah RD. The
treatment projects here will increase the potential for a proliferation
of roads and OHV trails to develop. This is a particular fire risk, as
OHVs are increasingly known to start wild land fires. All direct,
indirect and cumulative impacts and any environmental harms associated
with increased motorized use must be thoroughly studied.

The Forest must take a "hard look" at the environmental impacts of this
action. A wide range of alternatives must be prepared, including a
variety of restoration alternatives that remove or decrease disturbance
factors such as overstocking of domestic livestock, and that focus on
selective cutting of trees rather than large-scale disturbance of fire.

In addition, please provide a scientific study and alternatives based on
the efficacy of working with the "Urban" area inhabitants to create
defensible space. In the long run, this is the only real way to limit
fire possibility near human habitation. How much would this cost,
compared to the grandiose vegetation manipulation that you propose here?

The Forest claims its actions are being undertaken to reduce the risk of
fire. However, many of the proposed actions will open these lands to
weed invasions, especially exotic species that provide abundant fine
fuel that cause fires to flash rapidly across the landscape.

Sincerely,

Katie Fite

Biodiversity Director

Western Watersheds Project

PO Box 2863

Boise, ID 83701

208-429-1679