June 28, 2004

Jose Noriega

Humboldt-Toiyabe Forest

Santa Rosa Ranger Distrcit

1200 East Winnemucca Blvd.

Winnemucca, NV 89445

Dear Mr. Noriega,

Here are comments of Western Watersheds Project on the Martin Basin
Rangeland Project DEIS.

We are very concerned that the Forest has not considered the full and
damaging array of livestock grazing impacts to these significant wild
land areas in the 8 allotments spanning 191,000 acres that are covered
by the EIS. The biodiversity and recreational values of these public
lands are very important. They are being seriously harmed by livestock
grazing impacts. Livestock destroy vegetation necessary for native
wildlife, aid the proliferation of exotic species, and diminish
recreational experiences.

We believe the Forest places too much reliance on "adaptive management".
Both current ecological science and the Forest's long years of managing
livestock in arid mountain ranges provide a wealth of information that
should allow an agency to develop firm criteria, methodology, and
livestock use standards that need to be met on an annual basis in order
to protect the streams, watersheds, and wildlife habitats on public
lands. A specific set of management actions must be established, with
specific steps to be taken if these are not met laid in detail. The
Forest needs to establish specific actions to be taken if standards are
not met -- i.e. reductions in season of use, livestock numbers, or other
specific actions.

Weeds -- Noxious weeds and cheatgrass are spreading at an alarming rate
in the in Nevada wild lands. Livestock are a key factor in infestation
and spread of weeds in wild land settings. See Pyke (1999), and Belsky
and Gelbard (2000) - available on-line at
[www.onda.org](http://www.onda.org/). Weeds like white top, knapweed,
rush skeletonweed are able to very quickly spread into sites disturbed
by livestock or fire, and be spread outward by livestock and sweep
across large areas of the landscape very quickly.

We requested that the Forest provide actions that minimize spread and
infestation of weeds as part of all EIS alternatives. Methods involve
closing areas that are vulnerable to weed infestation and spread to
livestock use, closing weed-infested areas to livestock use and movement
until weeds are eradicated, quarantining livestock or several days
before entering Forest lands, and other measures. We requested that the
Forest conduct a risk assessment that assesses the susceptibility of all
lands to weed invasions, and provides methods of minimizing weed
invasion and spread. The DEIS has failed to do this. The Interior
Columbia Basin Ecosystem Mangement Project (ICBEMP) provides a
scientific template for determining risk factors and community
susceptibility associated with weed invasion. See, for example, USDA
1996 Map 10 "Areas Susceptible to Potential Exotic Weed Invasion"
--providing a landscape-level overlay. BLM Has long known that
cheatgrass understories dominate large areas of Nevada (Pellant and Hall
1992). As part of this EIS, a specific study of zones if disturbance
(livestock , livestock and fire) within the Martin Basin Area must be
conducted, susceptibility assessed, and measures identified to limit
infestation and spread, as well as to restore lands that re infested. We
believe that the Forest must incorporate actions as part o all
alternatives, as well as develop a range of "Minimize Weed
Spread/Restore Wild Lands Alternatives", and request that this be done.

The DEIS has failed to assess the role of livestock in altering fire
cycles, increasing woody vegetation, and creating hazardous fuel
situations, and the role of livestock grazing in destruction of
herbaceous understories that opens plant communities up to either weed
invasion or increases in woody species.

We had requested ask that the Forest conduct a grazing suitability and
capability analysis for all lands in the EIS area. Factors to be
considered in a suitability or capability determination are: steepness
of slope/erosion hazards/conflicts with water quality, conflicts with
native wildlife or T&E species, distance from natural, - not artifical
water, risk of weed infestation with grazing of the affected lands,
conflicts with recreational uses of the affected land, conflicts with
pygmy rabbit, sage grouse or other special status species habitats, etc.
The EIS fails to reveal if any previous study of this type conducted,
and nothing has been presented as part of the DEIS.

Many of the lands in the Santa Rosa Range are steep and highly erodible.
Often, present-day livestock stocking rates are based on the past
conversion of sheep to cattle allotments. Many of these conversions were
across-the-board 5 sheep AUMs = 1 cow AUM conversions, with no analysis
or reduction of the AUMs based on the ability of cattle to use most
steeper slopes and other factors. Cattle are notorious for loafing near
wetlands and riparian areas on flatter sites, and do not use steeper
terrain. Were any of the current cattle allotments/permits formerly
sheep permits? If so, were sheep AUMs converted across the board to
cattle AUMs? The Forest must assess the need for AUM reductions that
reflect the realities of grazing cattle in steep arid landscapes with
fragile soils --i.e. that lands stocked with livestock based on
conversion of sheep AUMs to cattle AUMs may be tremendously
over-stocked.

While the Forest spends a lot of time in the EIS describing past grazing
in broad terms, the details (such as AUM conversions, range project
development over time, etc.) necessary to understand and assess the
current situation in the project area are woefullylacking.

Big sagebrush uplands. Scientists have become increasingly alarmed at
the loss of sagebrush habitats in the arid West. We are very concerned
that your scoping notice, a recent project notice, and now the EIS
indicates that the Forest plans much use of prescribed fire/mechanical
manipulation in these fragile wild lands. The very LAST thing that any
sagebrush plant communities here need is more fire. Extensive acreages
have burned in the Quinn River watershed in recent years, as well as
other large areas of lands north of Winnemucca and Battle Mountain.
Cheatgrass has invaded many of these sites. Others have been seeded to
the exotic soil-depleting crested wheatgrass or the highly invasive,
weedy forage kochia. The Forest must honestly assess the conditions of
existing

It has also been our experience that many "hazardous fuels" and other
vegetation treatments being undetaken by agencies are the same as the
livestock forage burns of the past -- they are just being called
something else, as agencies seek to expand budgets under the fire
program. Sadly, this appears to be the case in the EIS, as nowhere does
the Forest develop a specific set o criteria for the resumption (if
ever) of livestock hgrazing post-"treatment". Plus, there is no study of
the effect of ongoing livestock grazing on weed, soil erosion, and other
problems here.

We have since received a notice that you are proposing a prescribed fire
in Martin Basin-- it appears prior to conducting analysis necessary at
the EIS level here. Please consider our previous scoping comments on the
EIS, and these comments, to also be comments on your "Martin Basin Fire"
proposal. The Forest must first complete the necessary analysis of all
environmental components - and that includes on-the-ground baseline
surveys for native biota in THIS EIS process before undertaking any new
vegetation alteration projects here. The disastrous state of many of the
wild land fire areas in and near the Santra Rosas demonstrates the
serious problems with fire. Please also note that cheatgrass and other
weeds are evolving to grow at higher and higher elevations (Monsen et.
al. 1994).

The primary goal of any vegetation management here should be maintaining
and truly restoring native plant communities, with emphasis on
"treatment" of burned or weed-infested lands, and lessening/removal of
sources of disturbance on remaining better condition lands that are not
yet infested. You have failed to identify the lands in poor, good, fair
or excellent ecological condition, or with significant weed problems.
The DEIS fails to provide a scientific framework for undertaking these
necessary actions, or for understanding the ecological outcome of any
vegetation manipulation/"treatments".

The Forest has failed to assess the health of current vegetation and the
ecological condition of all lands here, and identify specific measures
that will be taken to keep good or better condition lands in that shape,
and to improve degraded lands. The DEIS does not contain current
information on the ecological condition of the upland communities here,
that comprise nearly all of the land area.

We ask that you conduct baseline inventories for a broad range of native
wildlife -- lizards, bats, animals, birds -- as part of this process.
This is necessary to understand the impacts of your various
alternatives. The Forest has failed to identify critical or important
habitats for native wildlife species here, especially in upland
vegetation communities. Please describe the role of native vegetation
communities in providing habitat for declining species or species of
concern.

Please supplement the DEIS and describe how you will achieve a
functioning metapopulation of Quinn-Black Rock Lahontan cutthroat trout
here. How will you reconnect disconnected/fragmented habitats? What is
the estimated current LCT population here, by age class? What is the
current condition of all watersheds (INCLUDES UPLAND COMPONENTS) of LCT
watersheds. What are population recovery goals? What progress has been
made towards meeting them? What actions are necessary to provide habitat
and thus population connectivty?

What are the combined effects, as well as cumulative and synergistic
effects, of grazing, roads, irrigation diversions, fire, etc. on all LCT
streams and watersheds here?

Each time we visit the Santa Rosa Ranger District, we are alarmed at the
small volume of water in most streams. As you are aware, the health and
condition of watersheds determines the rapidity of runoff and erosion
events, as well as the fast or slow release of water over time. A
primary aim of your analysis must be addressing the integrity of the
whole watershed, and developing management actions that result in
significant and rapid watershed improvement. The DEIS fails to provide
necessary watershed-level analysis, and to provide any estimations of
flow, changes in flow over time, relations between watershed condition
and water quality parameters, etc.

Please provide as much data as possible on past stream flows, past fish
and other aquatic species presence and abundance, as well as collect
current data. This is necessary so that you can determine management
changes necessary to heal livestock-damaged watersheds that should be
quickly put into action upon completion of this decisionmaking process.

Attributes of the health of soils must be assessed. The include the
presence of microbiotic crusts, ground cover and litter, estimates of
topsoil loss, etc. Soil compaction, erosion, gullying and other impacts
caused by livestock must be fully assessed, and an outcome of the
assessment must be quantifiable trampling and soil compaction standards
for all riparian and upland sites. Such trampling standards are
necessary to ensure that soils are healthy and fully support native
vegetation and other biota.

We are quite concerned about the deleterious impacts of livestock
grazing, agency vegetation manipulation schemes (including the
prescribed fire for which the Forest sent out a separate scoping
notice), and other aspects of your proposed actions on declining native
wildlife and aquatic species, and MIS species. Yet, the EIS fails to
collect and analyze data necessary to understand the consequences of the
actions it proposes on these species. For example, no baseline surveys
have been conducted for pygmy rabbit and other declining species in the
Martin Basin Project area. You can not delay this and surveys for other
important species to piecemeal, project-by-project surveys -- as this
method will not allow an integrated assessment and study of direct,
indirect and cumulative impacts of actions proposed under this EIS.

The Forest's scoping notice categorized lands into riparian and
rangelands. We believe "rangeland' is a value-laden term, and implies
that these lands are best suited as "range" for alien livestock. We ask
that you take a far broader view here, and discuss upland vegetation,
sagebrush-steppe, etc., not rangeland.

You must conduct a comprehensive economic analysis that fully takes into
account all the ecological costs of livestock grazing -- diminished
water flow, less native wildlife for birdwatchers, hunters,
photographers, etc., to enjoy. Plus, you must fully account for the
operating costs of your office and any livestock projects in keeping
highly subsidized public lands grazing enterprises afloat on the
affected lands. How large a subsidy from taxpayers are all the ranchers
here actually receiving? How much will the various vegetation
treatment/fuels projects cost - as these are in many ways a further
subsidy to the livestock industry in removing woody vegetation in an
effort to grow grass.

Roading. As part of this analysis, you must fully assess the impacts of
roads, trails, livestock trails, livestock developments on impairing
upland and riparian health, and habitat for native wildlife. We ask that
you determine which roads need to be closed, or "ripped"/removed as part
of this process. In arid western lands, and especially the arid
Humbodt-Toiyabe orest alnds, often the primary reason for unplanned
roading is livestock permittees driving fencelines, driving to salt
licks, and other livestock-associated activities. All such unnecessary
roads need to be identified and closed. Stockmen have horses, and can
ride them to distribute salt, fix fences, etc. What roads do your
existing plans show exist here? How does this compare to the current
situation on the ground? How many of these roads appear to have
originated from salt distribution pipelines, fences or other livestock
purposes, and how many of these roads are causing resource damage?
Extensive Interior Columbia Basin ecosystem analyses demonstrate the
harmful impacts of roads on aquatic and upland wildlife. These impacts
may be additive or cumulative to those of livestock grazing.

Specific numeric standards must be established for upland utilization.
In no instance should upland utilization be allowed to exceed 25-30%,
and no grazing during critical growing periods should be allowed under
any circumstances. In areas in poor or fair condition, or where soils
are eroding, weed invading, etc. should have levels reduced below this.
Anderson (1991) BLM Technical Bulletin discusses the harmful impacts of
excessive utilization on native grasses like bluebunch wheatgrass, and
critical gorwing period grazing at almost any levels is shown to be very
harmul. Even one-time heavy grazing events on native bunchgrasses can
cause weakening or mortality. Galt et. al. 2000 describe the importance
of conservative stocking rates.

The Forest's proposed 60% upland utilization is extremely high, and
scientifically indefensible and out-dated. The EIS cannot just accept
this as a given, but must develop a science-based analysis of its
ecological effects. This extreme utilization is particularly
inapplicable in degraded lands, steep lands, allotments with ESA species
watersheds, lands at risk to weed invasions, etc. -- all of which apply
to the EIS Project area. It is often the areas nearest to water, or
which are already eroding, that suffer this level of use. Tracking use
at key areas, often remote from problem sites, fails to alleviate damage
to the areas that are most seriously impacted by livestock. There is no
scientific evidence presented to back up this extraordinarily high
proposed level of allowable use. Overwhelming scientific evidence
demonstrates the many harmful impacts of livestock grazing on arid
western lands, and the huge ecological problems ranging from weed
invasions to soil erosion to imperilment of native species - it causes.
See, for example, Fleischner 1994, Wisdom et al. 2000, PNW-GTR-405.

Specific numeric standards for utilization and trampling must be
developed and applied to all riparian communities, including meadows and
upland springs and seeps. A 6 " herbaceous stubble height must be
maintained at all times and serve as a trigger for livestock movement,
as must 10% bank trampling, measured in areas accessible to livestock.
As livestock near these use standards, these standards must serve as a
trigger for removal.

There must also be significant penalties for failure to meet any grazing
standards -- automatic 25% reductions in stocking use for failures.
Otherwise, each new grazing season just brings new damage, with often
irreversible erosion and other impacts.

As grazing permit buyout is likely to become a reality during the life
of the EIS, you should accommodate this in this planning process, and
authorize it as part of this EIS process.

We fully support NO development of springs and seeps. You are on the
right track here. Range projects like these destroy wild lands springs,
disrupt site straigraphy, and may cause water flows to diminish or dry
up entirely.

We fully support closing the entire Rebel Creek allotment. If it is
"vacant" it needs to be closed as part of this EIS process. You must
fully explain why you would ever want to open an area that is not being
grazed.

We do not support the creation of "riparian pastures" with fences.
Fences are hazards to native wildlife like sage grouse. They serve as
perches for nest predators, and songbird brood parasites. See Braun
1998, Connelly et al. 2000. Roads are also conduits for weed spread
(Gelbard and Belnap 2003). Permittees have horses. As an alternative to
fencing, require employment of 2 herders to effectively keep cattle
moved. The Forest should focus on measurable standards of use as
triggers for livestock movement. The use of herders, not structural
projects, must be the basis for livestock management here.

As part of this EIS process, you must fully tabulate all the existing
fences, spring-gutting/"development" projects, and other livestock
facilities and their condition, plus map salting locations. Plus, you
must assess their impacts on the health (soils, weeds, native
vegetation, habitats) of surrounding lands. This is necessary to
understand how much livestock infrastructure and zones of intense
disturbance already exist, to assess its impacts on native wildlife and
other important elements of public lands, and to assess the ecological
problems infrastructure has caused. All of this must be done as part of
this process. You must identify projects that are causing ecological
problems, remove them and act to restore sites that have been
damaged/clos roads that .

Rest-grazing system. As part of any rest-grazing system, you must
significantly cut livestock numbers in lands that are "grazed"/rotated.
A huge flaw in rest rotation is that in order to rest lands, the grazed
lands in a system are periodically inundated with large numbers of
livestock, to the detriment of native species, especially migratory
birds, sage grouse, pygmy rabbits, etc. If the Forest rests an area, we
ask that you ensure that areas being grazed do not face increased
numbers of livestock displace from the rested site.

No grazing should occur during nesting periods for birds and birthing
period for native mammals. Livestock attract predators, carry disease,
physically disturb nests, drastically alter habitat, trample nests,
devour nesting cover exposing nests to predators, etc.

A broad range of alternatives must be developed. Alternatives must
include significant reductions in livestock numbers, reliance on
nonstructural methods of livestock control/dispersion.

Alternatives and alternative components to address vegetation
health/restoration must include passive restoration techniques -- such
as cessations or reductions in livestock use, closure of roads.

All reseeding efforts here should involve only native species, and must
include native shrubs like sagebrush. What species were seeded in the
West Side/Granite Peak area?

As part of this process, you must develop standards to rest burned
allotments for a minimum of 4 years post-fire -- to enable native
species, or seeded native species, to recover/establish.

The Forest has failed to correct its inaccurate scoping notice, and is
constructing its EIS on myths of the livestock industry, and not
science. Sagebrush has not increased in density "to the detriment of
herbaceous vegetation". See Anderson and Holte 1982, Welch 2002, Welch
and Criddle 2003. Anderson and Holte (1982) describe increases in
desirable understory grasses at the same time that sagebrush canopy has
increased. In fact, livestock grazing has caused many of the detrimental
effects to herbaceous species that the Forest appears to attribute to
livestock. Grass is known to increase just fine at the same time as
sagebrush cover increases, as long as livestock grazing does not disrupt
this process. Your statement represents a fundamental misunderstanding
of ecological principles in western arid lands. Please also review
Belsky and Blumenthal (1997) for a description of the role of livestock
in increasing woody vegetation and fire problems.

We strongly oppose the use of prescribed fire in sagebrush wildlands
here. You must prepare detailed analysis of sagebrush loss at a regional
level -- and include surrounding and nearby Winnemucca, Elko and Battle
Mountain BLM Lands in this assessment. How much sagebrush (and other
vegetation types) have been lost to fire here within the past decade?
How much has been seeded to soil-depleting exotics like crested
wheatgrass? How much is now dominated by cheatgrass? All this is
necessary to understand the direct and indirect impacts of any
additional prescribed or wild land fire or mechanical treatment on
vegetation types, and wildlife populations that may be declining at a
local, regional or national level. Now-abundant federal fire funds must
be focused on recovering -- as best possible -- cheatgrass and
weed-dominated lands.

You point to heavy flooding as a case for cottonwood decline,
Regrettably, you fail to discuss the role of livestock in stripping and
de-stabilizing watersheds, retarding site recovery, and setting the
stage for flood damage. Please also explain why cottonwood seedlings are
not recovering on these sites -- the primary cause of lack of cottonwood
recruitment is often livestock consuming young trees.

It is odd that you the Forest focuses on "heritage resources" such as
old miner cabins, yet fails to discuss the full cultural heritage of
this region. You must fully describe and assess the harmful impacts of
livestock grazing, fire, vegetation manipulation and other disturbances
on cultural resources and values. For example, how does livestock
trampling activity, compaction and erosion affect site stratigraphy,
expose artifacts through erosion to looting and breakage by trampling of
livestock, etc.? How will the extrem utilization levels (60%) exacerbate
these processes?

You fail to mention bacterial contamination of streams by livestock
grazed in Martin Basin. As part of the data collected here, you must
collect water samples throughout periods of livestock use and analyze
them for coliform pollution in all pastures in all grazed allotments. We
have previously found astronomically high levels of pollutants in
livestock-grazed arid streams just to the north in Idaho and Oregon.

We ask that you prepare high quality maps that identify special status
species occurrence, weed infestations, existing livestock projects, all
roads, etc.

You must fully assess all the harmful impacts of cattle grazing on
soils, native vegetation, weed invasion, wildlife, recreational
experiences, solitude and other important elements of the Santa Rosa
Wilderness and surrounding lands. We have camped at Lye Creek
campground, and been disgusted at the levels of livestock use around the
area. The stench and noise, as well as disease organisms harbored and
spread by livestock are negative impacts that must be assessed here, on
the Wilderness, and all the affected lands.

We are also extremely concerned about the role of livestock in
proliferation and spread of weeds, as previously describe, and the
resultant threat to native biota. See Belsky and Gelbard 2000.

We ask that you use a full range of current ecological science to
develop any "desired conditions". The conditions, as stated, are heavily
biased to wards favoring human-imposed disturbances on wild land
systems. Please describe in detail, including with supporting science,
the determination process for "desired future condition".

Livestock grazing is seriously impacting the health of aspen and ALL
vegetation communities here! We want to make certain that you have a
copy of the aspen report conducted on Battle Mountain BLM lands. Please
contact Battle mountain BLM for a copy of this report, which
demonstrates that removal of herbivory, particularly in the case of the
Santa Rosa Mountain -- livestock herbivory - is key to aspen
sprouting/regeneration.

We asked that you include new information on the imperilment of various
sagebrush --obligate species, and their habitat requirements, and use
these in evaluation of all impacts, and this has not occurred.

Both wild and prescribed fire results in long-term habitat loss and
fragmentation of pygmy rabbit habitats. Both wild and prescribed fire
can result in death of native species. Big sagebrush killed by fire is
slow to reestablish on burned sites. On the Upper Snake River Plain, big
sagebrush did not recover to prefire densities until 30 years after an
August fire (Tesky 1994 citing Harniss and Murray 1993). Big sagebrush
is killed by fire, and does not resprout from roots. Big sagebrush may
be eliminated due to repeated fires. Prescribed fire can kill or and
harm native bunchgrasses (See Jarbidge Sage Grouse Plan fire chart). It
may weaken or kill bluebunch wheatgrass, Basin wildrye, and other native
grasses.

Fire cycles in sagebrush steppe are no longer "natural". Nearly all big
sagebrush habitats, 98% of which have suffered mechanical treatment by
cattle or sheep (Braun 1998), have been radically altered by livestock
grazing. Exotic species invade livestock-disturbed and fire-disturbed
sites and alter fire cycles (BLM 2000 Nevada sage grouse guidelines).
Post-fire grazing with minimal periods of rest leads to further declines
in native vegetation, as remaining native grasses formerly protected by
woody shrub structure, are now exposed to herbivory by livestock.

The displacement of native plants by nonnative species is a major
problem in sagebrush-steppe habitats of the Intermountain region, as
exotic annual species (especially cheatgrass) have invaded livestock
degraded sagebrush-steppe (67 FR 135 -- USFWS Proposed rule for listing
of slickspot peppergrass as an endangered species under the ESA, ///
Sage Grouse). The invasion of cheatgrass has shortened fire frequencies
from between 60 to 110 years to less than five years in some sites.
Cheatgrass provides a continuous, highly flammable fuel through which
fire can travel quickly (Whisenant 1991, 67 FR 135). The result has been
conversion of vast areas of the former sagebrush-steppe ecosystem into
nonnative annual grasslands. An estimated 2 to 2.43 million hectares (5
to 6 million acres) of sagebrush steppe in the western Snake River Basin
has been converted to nonnative annual vegetation dominated by
cheatgrass and medusahead (67 FR 135).

As early as 1992, agencies have been aware of the dramatically altered
ecosystems resulting from alien grass invasion of lands in the
intermountain area. At that time, 3.3 million acres were acknowledged to
be dominated by cheatgrass and annuals, and another 76.1 million acres
were classified as "infested" or "susceptible to invasion" (refers to
lands in Nevada, Oregon, Utah, Washington and Idaho), (Pellant and Hall
1992). Pellant and Hall (1994) Map figure 4 is important for FS to note
(plus add in cheatgrass dominance in understories and/or whole
community).

Federal wild land fire management policy threatens big sagebrush
habitats. The Forest must not allow this to lead them to destroy fragile
sagebrush lands. Nevada BLM Sage Grouse/Sagebrush Ecosystems guidelines
(2000) warn that the Federal Wild Land Fire Policy indicates that fire
**must** be reintroduced into the ecosystem, and that Congress passes
budgets for fuels management that enables the **increased use of
prescribed fire**.

It is now understood that most populations of sage grouse require large
wild land areas of intact sagebrush in annual movements. They require 9"
of herbaceous cover and dense sagebrush canopy cover for successful
nesting. Your actions here must be in compliance with this science, as
well as documents like the BLM 2000 Sage Grouse/Sagebrush Ecosystems in
Nevada Plan.

SPECIFIC COMMENTS

The Forest's list of Significant Issues overlooks the surge in mining
exploration that is occurring in these lands.

While you have a list of Significant Issues, you do not specify the
**conflicts** between livestock grazing and many of these issues --for
example --recreation. You must assess how livestock interfere (noise,
stench, depauperate wildlife communities, disease, etc.) with
recreational activities on public lands.

While the Forest draws a "major conclusion" that cottonwood stands have
been impacted from fires and flooding, the Forest fails to address the
role of livestock grazing in altering fire cycles and watershed-level
impacts (especially under the extraordinarily high 60% upland
utilization level, and excessive riparian use levels, as well as
policies to allow livestock grazing to resume far too soon following
fire) currently in place.

As we review Forest Plan Direction and Goals (1-3 to 1-4), it becomes
apparent the Plan requires strong steps be taken to significantly
improve conditions on these lands We are very concerned that the
Proposed Action fails to take necessary strong actions, and has no
teeth. Instead, it relies on uncertain "adaptive management", the same
excessive use standard, and proposes to now extend livestock damage to
vacant allotments.

1-4. The Forest can not be satisfied with merely maintaining the current
habitat of T&E species. The Forest must act to protect and enhance T&E
habitats. All riparian areas in watersheds that contain LCT streams
should be managed as in Category 1 streams, not just the stream sections
that are currently occupied. Please explain if this is the case, or if
some tributaries have lower protection -- and thus are allowed to suffer
greater livestock grazing damage. Are all tributaries in these
watersheds manages as Category I streams and uplands?

We are appalled that the Forest has not collected data required to
measure progress towards achieving Forest Plan goals. Example, improve
range conditions to 80% satisfactory. This must be done as part o the
EIS process, or it will never occur.

We are very concerned that the Forest relies on "maintain water quality
and soil productivity". Does this mean that if water quality is poor, it
is ok to maintain it -- just as long as it does not get worse? Please
clarify this.

It is very disappointing to see the Forest Service committing only to
"maintaining" habitat for wildlife and fish, and not enhancing it (1-5).
You have not presented baseline data to determine population and habitat
trends in MIS species, either. What data have you collected on ALL
Forest MIS species here? What are minimum viable populations for
non-aquatic MIS species? As above, does this mean if habitat is very
degraded, all that the Forest will do is maintain the degradation?
Likewise, the Forest only commits to soil productivity, instead of
improving or enhancing this critical elements of ecosystem health.

Range improvements. The Forest must consider the effect of these
projects on soils, vegetation, watersheds, weed invasion, etc. The plan
does not consider removal or elimination of projects that may be harming
watershed. This should be an essential component of management here, and
be the basis for a series of restoration alternatives.

Amendment #2 includes collection of macropore data (no more than 10%
reduction), cover of key species is to be 90% or greater of estimated
potential, fish production near potential. The Forest must reveal the
values for each of these parameters at "potential", and then provide
current site-specific data collected on Martin Basin streams that shows
that these conditions are being met. Where is this information?

1-5,6. You describe the Management Area prescriptions under Alt. 2.
Please provide data for all riparian areas (Categories 1, 2, 3, 4, 5) on
potential key herbaceous and woody species, composition, soil
productivity, macropore space, streambank stability, and fish
production.

This EIS should eliminate the application of the standards for riparian
areas 3, 4, 5 -- as they allow way too much damage to be done by
livestock to scarce riparian streams -- for example, only 45% of
estimated fish production potential is acceptable.

1-6 proposes the construction of new fences of unknown configuration.
Fences are almost always followed by extensive new water developments in
uplands and other range facilities. These projects have the potential to
drastically impact upland vegetation, cultural sites, and other
important values of these lands. We urge you to rely on non-structural
methods (herding, use standards as triggers for livestock removal) to
achieve management goals here, and not on constructing even more fences.

The EIS lacks current data on how many miles of fences, spring projects,
troughs, etc. currently exist here, their repair, effectiveness, and
analysis of cumulative imapcts.

We strongly object to the Forest combining (and thus it appears
authorizing grazing in) vacant allotments. Why are the Bradshaw and the
Buttermilk allotments vacant? Much of the land area of these vacant
allotments is highly unsuitable for livestock grazing. The Forest must
conduct a current study of the suitability of grazing these lands and
other studies. Please provide a detailed map that shows the portions of
all allotments where grazing is currently authorized, and those areas
where it is not. The Forest must clearly identify all the circumstances
that surround the vacating of the allotments, and the current
information that it has collected that enables it to understand the
ecological implications of opening these lands to grazing. Please also
describe the history of trespass, violations of Forest Plan standards
and all related information in and surrounding the Basin. We are alarmed
at the agency mindset that now also proposes increasing livestock use on
nearby Winnemucca BLM lands, with unassessed consequences for ecological
health and native biota. Our concerns are highlighted by the Forest's
acknowledgement of the many deleterious impacts associated with
livestock use -- such as page 3-6 discussions of soil compaction and
ground cover.

We are very concerned that the Forest has limited its consideration of
"Issues" related to Wildlife to only the most charismatic of species,
and is ignoring a wide range of other species that are important to
biodiversity, and whose populations are undergoing long-term regional
declines (Saab and Rich 1997, Paige and Ritter 1999, Wisdom et.al.
2000).

The Forest fails to discuss the importance of intermittent streams, and
does not provide protection necessary to ensure that these areas are
healthy, functioning and providing good or excellent habitat for aquatic
species. It does not apply standards that ensure necessary vegetative
cover and protection from grazing and trampling so that intermittent
drainages can trap sediments, reduce runoff of livestock waste. In many
areas, protection would allow increasing perennial flows, and in the
long-term help attain goals of watershed stability and habitat
connectivity.

The "Proposed Action"(2-4 to 2-8) has scarcely an substance at all. We
do not understand why you are preparing this document, if this is all
that you aim to do. All the Proposed Action really does is describe what
the Forest is supposed to already be doing -- like AMPs, and monitoring.
One of its primary actions is extending grazing use from damaged and
depleted allotments to others, and a fencing project.

The Forest's fixation on vegetation communities here fails to provide
for any assessment of the complex interspersion and interdigitation of
plant communities across the landscape. The plant communities you
describe separately often exist as a complex mosaic, following soil,
moisture and other gradients across the landscape. See Peterson 1995,
for example.

2-5. Table 1-T. We recommend that a 30% or lower utilization standard
should be applied across-the-board, and also should be used to prevent
communities from dropping below "Desired" Functioning Condition. By
allowing grossly excessive 50% on any Wyoming big sagebrush herbaceous
understory species, the Forest will ensure that more communities become
degraded, and drop below thresholds. This concern is exacerbated by the
Forest's goal (later discussed) to shift use to new areas -- as in the
vacant allotments or outside riparian pastures.

2-6. How will you determine a "reference area". As nearly all lands have
been grazed, will this provide a valid benchmark? Do you really mean
something more akin to the Key Area concept? If so, one site per pasture
is not sufficient.

2-7. In order to assess the appropriateness of the mitigation measures,
the Forest must conduct inventories for rare plants as part of this EIS
process, not wait until later. There is no way to understand cumulative
effects if surveys are delayed.

The Forest does not describe what is meant by "negative effects", so it
is impossible to understand the effectiveness of the mitigation
measures.

Why are most of the mitigation measures focused on rare plants, and why
do they not also include many more measures for wildlife, recreation,
cultural, fisheries and other mitigation measures?

3-5. Table 6-T. The Forest relies on old, stale data -- it is 2004, yet
you have presented as the most recent data one year 2001 survey, and all
the rest is from 2000, or even 1998.

Please provide additional information needed to understand the "ungulate
bank damage" presented -- including the date when the study as
performed, the dates of when livestock grazing occurred at that site, if
trespass occurred, etc.

We are very concerned that no data on spring, seep and most wet meadow
areas have been presented. What is the ecological condition of springs
and seeps throughout the project area? How many remain undeveloped? How
many of the developed sites have been harmed by this activity? How can
damaged sites be restored?

The Forest makes the assumption that water quality has been impacted
primarily on NF and FAR streams. WQ and many other parameters of stream
health have been/are being impacted in PFC systems, too. The condition
of the watersheds, rapidity of runoff, timing of release all are
impacted by condition of upland watersheds and intermittent drainages in
this steep, mountainous terrain.

2-6 lists currently and previously occupied LCT streams. Given that so
many streams (13) are no longer occupied by LCT, it is essential that
the Forest act to restore fish and other aquatic biota to these streams.
This will not be possible under the Proposed Action.

The EIS fails to describe the synergistic and cumulative effects of
grazing and mining (old, proposed, reasonably foreseeable) on streams,
water quality and watershed processes.

Water quality data indicates that there are serious problems with fecal
coliform contamination of waters. Why did the Forest, having collected
two samples on Cabin Creek, not collect the necessary number to show
definite violations of wq standards? It appears that the Forest here was
more interested in not documenting the full extent of livestock harm,
rather than in public safety and health.

Why was no turbidity data taken during periods of higher flow?

Was the North Nork Humboldt sample collected during a time when cattle
were present? Was it collected inside an exclosure?

We strongly object to your postponing establishing management standards
until 2010 or later These should be established NOW, as part of the EIS
process, and not postponed until later This is not a huge land area, and
this should be done as part of the EIS process. There is great
uncertainty in postponing it -- as you admit - any future action is tied
to funding. All vegetative groups and other parameters should be
categorized as part of this process -- otherwise, it is impossible for
you to conduct the necessary landscape-level analysis that this EIS
claims to undertake. Plus, the rapid rate of weed infestation, steep
slopes in jeopardy of erosion and stream-blow-outs during run-off events
from make it essential that action be taken now -- not in the far
distant future.

"Mitigation" includes grazing to reduce cheatgrass. You have failed to
scientifically assess the harmful impacts of grazing to levels extreme
enough to control cheatgrass -- and the effects on soils, watersheds
runoff, weeds, microbiotic crusts, etc.

We strongly support deferment of livestock grazing in sage grouse
nesting areas. You must also require upland utilization standards of 20%
or less that would provide adequate residual cover for sage grouse
nesting requirements. These are 20% or less utilization on bunchgrasses.

Please define what you mean by "livestock concentrating activities".
Does this include salt and mineral placement? These activities can
significantly degrade uplands --as they cause intense concentration of
livestock.

Large livestock-free reference areas, a detailed monitoring protocol
with methods, time frames, etc. should be established as part of this
process, not delayed.

BLM has failed to conduct the surveys necessary to determine locations
of sensitive plant populations and other factors it describes as
mitigation or that would be monitored. This must be done as part of the
EIS process, so that an adequate assessment of additive, synergistic and
cumulative impacts of livestock grazing on these environmental factors.

2-1 states that allowable utilization levels would remain the same.
Again, the Forest has presented no current analysis or science
supporting this.

2-12. The Forest unfairly, and without any science-based rationale,
discarded analysis of the "Restoration" Alternative, or any Alt. that
reduces sticking rates. Instead, the Forest appears to be planning on
using vacant allotments to accommodate livestock that have depleted the
other 6 allotments --thus extending use and shifting damage.

2-13. The "Comparison Table" fails to scientifically determine
implementation effects. For example, there is no evidence that fecal
coliform, nutrients, water temperature -- would decrease in all degraded
areas A vast number of springs, stream segments, etc. are to continue to
be grazed under this plan, and their condition has been completely
ignored. As riparian pasture fences are constructed, we can expect even
greater degradation of upland springs, seeps and wet meadows. Plus,
grazing is to be extended/shifted into portions of vacant allotments
with certain harm to riparian systems.

Soil erosion. There is no scientific basis for the conclusion that wind
and water erosion would be "unchanged" under the proposed action, or
that under Alt. 3 they might be "unchanged". The Forest has failed to
provide any current data or provide a science-based rationale for this.
IN fact, upland erosion may be increased, as use is shifted from
riparian pasture areas, and into now-vacant allotments.

3-13. Conditions are degraded and the Forest admits that there haves
been and are adverse effects on soil resources. Then why is the Forest
continuing such high allowable levels of use, i.e. grazing intensity?
Also, please describe how past grazing was "inappropriate" while current
grazing is not. Is there not inappropriate grazing currently occurring
in the Project Area?

Please provide evidence supporting your claim that increased native
ungulates significantly impacted riparian and other conditions here.

Map 6-m, 3-15 shows soil monitoring locations in only some watersheds,
and a large part of the project area has no soil monitoring locations at
all. This includes the entire western side of the Santa Rosa Range. Your
data focuses almost entirely on flat meadow areas. What are the
conditions of soils in steep uplands, in areas where you now propose to
denude sagebrush vegetation through burning, and the soils that are
associated with all the plant communities that you describe elsewhere in
this document?

"Mountain brush"- Why do you not describe this community as mountain
shrub? "Brush" has a negative connotation, due to the long-time fixation
of the livestock industry in removing "brush".

There are extensive areas of mountain mahogany that can not be lumped in
with "brush". Fire kills mahogany, many trees are very old. Mahogany
must be treated as a distinct community type. Likewise, why is there no
low sagebrush community? Why no cheatgrass-understory dominated
community? Soils associated with low sagebrush are different from those
commonly associated with other sagebrush types.

We are very concerned that your classification does not capture the
complexity of the plant communities present here, and that you are using
this simplistic community categorization to set the stage for
large-scale fire projects here. Why has this method been chosen?

3-17. What has been the recent (past 20 years) grazing situation
(stocking rate, season, trespass, etc.) on all sites with impaired
characteristics, such as impaired soils?

3-17. Describes erosion, sediment transport and rainfall runoff
increasing as vegetation and ground cover decrease. You provide a
sedimentation rate from riparian areas that fall below a threshold. What
is the sedimentation rate for upland areas that fall below a threshold?
How could this be altered by lowering allowable utilization? By removal
of livestock from slopes \> 20%? Please describe the relation between
livestock grazing and trampling damage to/loss of microbiotic crusts,
herbaceous cover, and erosion rates? How much would erosion increase in
all sites (riparian and upland) with fire? The Forest must understand
the current condition before it proposes imposing massive new
disturbance.

3-24 describes significant problems with mine runoff/tailings pollution.
What harmful materials have been documented here? What is being done to
control these? What are the cumulative impacts of this on top of
livestock grazing disturbance, new mining exploration, and other
activities?

Please describe in detail the current situation surrounding the Buckskin
mine. Is it operative, are other nearby mining perations contributing to
the problem? Has it been recommended for Superfund status? What is being
done to clean it up? How does grazing de-stabilize mine diggings,
increase pollutant release, etc.?

3-125. How much cheatgrass, bulbous bluegrass, and other shallow-rooted
exotic species are present? How did fire increase their presence? How
large an area did the fire burn?

Please present the fire history for the past 30 years for the project
area and its surroundings. EIS at 3-29 describes how fire may, at least
partially, cause high levels of cobble embeddness, and thus affect
aquatic species habitats. Very large areas in and ear the Santa Rosas
have burned within the past decade alone.

3-31. The Forest can not use sage grouse as a surrogate for pygmy rabbit
habitat characteristics. Pygmy rabbits require dense sagebrush, or
sagebrush-bitterbrush shrub cover, and a complex structurally diverse
canopy of big sagebrush We are attaching a copy of the pygmy rabbit
petition and accompanying bibliography, both to elucidate the specific
pygmy rabbit habitat requirements as well as to provide a basis for our
comments on the impacts of livestock grazing to all facets of the
sagebrush-steppe environment. We ask that you apply the information on
sagebrush-steppe and impacts caused by livestock grazing to this EIS.

3-33 describes leks concentrate in the north half. Are these leks on BLM
or Forest lands? Are there leks on BLM or private lands in the south? If
not, were there historic leks and has the habitat changed? Does Map 8-M
define sage grouse habitat as lands in proximity to leks? How have you
determined what is summer, fall, winter habitat? We frequently see sage
grouse in high elevation sagebrush areas --how are those of the Santa
Rosa different from other places? We really can not believe that sage
grouse do not occupy some of the lands you show as NOT being sage grouse
habitat on the map?

3-38-45. We appreciate the Forest discussing some habitat
characteristics of sensitive species. However, a discussion is no
substitute for baseline surveys. As part of this EIS process, you must
conduct surveys for Forest Service sensitive species, including northern
goshawk, spotted bat, Townsend's big-eared bat, flammulated owl, great
gray owl, peregrine falcon, three-toed woodpecker, Columbia spotted
frog, as well as other important wildlife species.

3-41. We are unaware of any spotted frog observations on the "49"
(shouldn't this be 45) Ranch on the South Fork Owyhee River??? In fact,
we believe the Columbia spotted frog has not been found there in recent
surveys.

3-43. We understand that there has been a large-scale die-off of bighorn
sheep in the Santa Rosa Range, and that it was caused by domestic sheep
being where they were not supposed to be. Please describe exactly what
happened here, and what enforcement actions have been taken against the
permittee who herded domestic sheep into bighorn habitats, and how this
will be prevented under the current grazing schemes. Please also
describe the behavioral interactions/displacement between domestic
cattle and bighorn sheep. How will this be affected under each
alternative? How will opening the vacant allotments result in more
bighorn-cow interactions?

3-47. Photos shows "increase in sagebrush" in a dry-to-moist meadow.
This is caused by livestock desiccation of wet meadows/riparian areas.
Page 3-48 describes "historical" grazing. However ONGOING grazing is
still causing these impacts, and site desiccation, gulling, erosion,
etc. are progressing in many areas and they are continuing to lose their
ability to support riparian vegetation. As part of this process, the
Forest should identify the extent of riparian area loss, as well as the
areas where such loss is continuing.

Hinkey Creek photos. How recently had fires burned the aspen communities
shown in photo18? As you may be aware, sheepherders, promiscuously
burned native vegetation. So -- is the "recovery" of the aspen a result
of a the area having been burned prior to 1938, and thus not visible in
the photo? It is difficult to determine anything from the copies in the
DEIS.

The aspen stand in photo 3-53 shows signs of ONGOING livestock
destruction of young aspen --none are visible.

DEIS at 3-54 admits that conversion of native vegetation to cheatgrass
is progressively moving up in elevation. How does this affect Forest
plans to burn higher elevation sagebrush types?

Page 3-56 discusses "overgrazing". How do you define "overgrazing"? How
do activities such as salting, livestock trailing, overstocking,
exceedance of use standards, etc. affect weed infestation and spread?
Please refer to Belsky and Gelbard 2000 (available at
[www.onda.org](http://www.onda.org/)). The Forest must take actions to
limit any additional weed spread, and restore infested lands.

3-63 "Rest rotation was implemented in late 60s and early 70s -- yet

3-63. Why is the Martin Basin allotment stocked at such a high AUM rate,
compared to other allotments? Please explain the basis for all stocking
rates shown here, and re-assess these. The "Vacant" allotments must
remain vacant as reference areas, and to provide some degree of habitat
where upland vegetation is not allowed to be grazed to the extreme level
of 60% utilization.

From the AUM level shown here, there is only a tiny economic impact
associated with livestock grazing on these lands. How do those values
compare to the recreational values? How much does it cost the Forest
Service to administer these gazing permits?

3-26. Is the Andorno Creek diversion screened? How does it affect
habitat or mortality of LCT. Please describe in detail the condition of
this diversion.

2-16. Please provide a detailed explanation and analysis of the
necessity to provide additional, or the same, habitat for those species
that "thrive in grazed areas". What are these species? How many are
native? For example, brown-headed cowbirds, thrive in grazed areas, and
these species are known nest parasites of declining migratory songbirds.

3-67 describes only 1% of the area having cultural inventories
conducted. Why are you not conducting more studies as part of this
process? A project-clearance by project-clearance approach to
discovering cultural resources NEVER allows assessment of indirect,
synergistic and cumulative impacts.

3-68. Please do not use the term"brush".

3-77 describes "dispersed recreation" as increasing annually. This
demonstrates the growing importance of recreation, compared to livestock
grazing.

3-77 --3-78 identifies roadless areas, but no maps are provided. Please
provide maps of these, and re-evaluate them for consideration. The DEIS
has just stated that recreation is increasing annually, so the values of
these areas for recreation has become much greater. Plus, as habitats
have been consumed by fire, converted to cheatgrass, etc. at lower
elevations, remaining enclaves of wildness and solitude on Forest lands
are even more important.

While the DEIS describes Wilderness, it fails to evaluate the impacts of
livestock grazing on wilderness characteristics -- naturalness,
primitive recreation solitude, other factors. Please provide data
monitoring livestock impacts to Wilderness areas. How has livestock
grazing changed here since Wilderness designation?

In order to understand the attributes of the lands shown I Maps M-15,
16, please provide a map of roads, roadless areas, etc. All roadless
areas should have protective Visual Quality Objectives.

We are very concerned that the Forest has categorized far too many lands
in the "partial retention" category that should be placed in the
Retention or preservation classes. Again, recreation use is increasing
rapidly, and you can not rely on old, out-dated views of the
recreational and other values of these lands, but instead must provide
new classifications based on growing importance of wildness to society,
This is directly related to livestock grazing, because much of the
roading and visual scarring on Forest lands is related to the
construction of livestock facilities, roads driven by ranchers to
salting sites that get pounded in, uglification from vegetation
treatment projects whose underlying motive is livestock forage
production, etc. The project area contains some very sensitive
watersheds, so0 placing protective standards o use on them is vital.

Why is there no map of roading associated with this DEIS? As part of
this process, the Forest should identify roads that are primarily driven
to salt sites, livestock projects, etc. and close those that may be
causing resource damage/problems such as weed invasion, erosion, visual
scarring. Public ands ranchers own horses, and can deliver salt, access
project on horseback. How many roads are related to livestock projects?

4-1. Please add in reduced flows, desiccation, desertification caused by
livestock grazing, which in turn exacerbates temperature, bacteria and
other wq problems.

We are very concerned that as part of the impacts here you must address
the shifting of use that will result from permanently authorizing
livestock grazing in the 2 vacant allotments.

You have also failed to assess the impacts of roading/disturbance from
mining exploration activities.

4-3. The Forest has failed to describe any actions that it is taking to
limit/ix the acid mine pollution. Should this be a Superfund site? How
does chronic livestock grazing exacerbate this problem? You must
consider as part of a limited grazing alternative, removal of livestock
from this watersheds so that aquatic species are not subject to
synergistic or cumulative harmful impacts.

The cumulative effects analysis is flawed, as you failed to consider the
degradation of water quality from shifting use to the riparian areas
(INCLUDING unassessed springs and seeps) in the vacant allotments. Any
improvement in one area will likely be canceled out in the others.

4-5. You have failed to limit roading/road use by ranchers that
contribute to soil problems.

Please correct 4-5 to say "grazing" - not only "improperly managed
grazing". Livestock, grazed at any levels, have significant impacts to
microbiotic cursts, soils, etc.

We have strong concerns that the Council for Ag Tenchnology source that
you cite may apply to Plains ecosystems, or humid regions -- It does not
apply to the Intermountain West, where dung beetles are largely absent.
Livestock waste is very slow to break down. The native flora evolved
with limited nutrients, and it is in reality cheatgrass and weeds that
grow in areas of livestock-urine-soaked soils, to the detriment of
native plants. Please make certain you are not misusing this reference
in a livestock-biased analysis effort.

4-9. It is impossible to understand the cumulative effects analysis for
soils.

While you claim "considerable areas are roadless", you do not manage
them as roadless areas -- instead, as the visual category map shows, it
appears that only the wilderness area is spared intrusions from
projects. Is that the case?

Please correct 4-10 -- as there are active mine exploration proposals
occurring now.

4-15. We are very concerned that you mix in native species with exotic
weeds (hemlock) with native species as indicators of soil compaction.

4-18. While the proposed action allows or reductions in allowable
utilization if streams are not meeting objectives, there is no similar
proposal to reduce grazing I uplands are not meeting objectives. Why
not?

We are extremely concerned about the impacts of your proposal to graze
Dutch John and Road Creek, and believe, as you have admitted in the
consequences here, it will be very harmful to aquatic species. We are
also extremely concerned about the impacts of shifting use to uplands
here and in the Rebel Creek allotment. You have not assessed
watershed-level impacts of the proposed action.

Here, the Forest states: "livestock use along streams ... would be
reduced through dispersing livestock numbers over a large area". The
Forest adopts the strategy "the solution to pollution is dilution".

4-19. You have failed to assess the potential impacts to sage grouse
here. Also, as you have failed to assess ecological conditions and take
action to provide protections for all springs, seeps and wet meadows,
you cannot assume that you understand impacts.

4-21. Why is Alt. 1 any different in impacts of the upland utilization
standard than Alt. 2? Throughout, you have ailed to evaluate a lower,
science-based upland utilization standard.

4-24. Are there bighorn sheep occupying (or is there potential habitat
in) the vacant allotments that you now propose to open up to livestock
grazing? You have failed to assess the impacts of
displacement/behavioral interference/disruption of native wildlife that
will be caused by grazing livestock in these allotments. Please evaluate
all impacts, including displacement of wildlife into less favorable
habitats, removal of nesting cover causing exposure of nests to
predation, etc.

4-25-27. We can find no discussion of the current population, or the
health and viability of populations, etc. of Forest Service sensitive
and MIS species here. What data has been collected, and what does it
show?

4-26. Which springs and seeps are not in desired condition? Please
identify these as part of this process.

4-27. These bat species forage over large areas if uplands -- so you
cannot assume that riparian utilization standards will adequately
protect their production of their prey in the expanses of uplands that
are subject to the extreme levels of utilization under the Forest Plan.

As previously discussed, allowing 50% utilization will shove more
communities across thresholds from which they can not recover. This
problem is particularly acute in the cheatgrass-prone lands of the Santa
Rosa - DEIS 4-25 discusses cheatgrass problems associated with 3 large
(10,000 acre+ fires) in the past 7 years .

4-31. Since the Forest has chosen to claim that the "no grazing"
alternative might result in ranchers subdividing private lands and that
this would impact mule deer and other habitats, the Forest must provide
data and analysis to back its assertions. The Forest must fully assess:
the ratio of private land to public land; determine how much mule deer
and other MIS, sensitive species and other important wildlife species
habitat occurs on private vs. public land; study and quantify the
benefits of not grazing public lands for mule deer and other MIS and
sensitive species.

Is 4-31 claiming that "No Grazing" will increase fire? If so, please
provide a detailed study of the interaction between livestock grazing
and weed spread; the impacts of livestock grazing at levels necessary to
"control" fire; the levels to which lands must be gazed to "control"
fire, etc. The Forest can not just repeat unsubstantiated myths of the
livestock industry without providing scientific information to back up
its analysis.

4-36. We are very concerned that the Forest has not assessed the harmful
impacts of "rotation" in rest rotation systems. While some lands are
being rested, other lands are being grazed with double/more cattle, with
resultant harmful impacts.

4-37. Please provide the scientific evidence on which the "fact sheet"
bases its claim that grazing has little adverse impact on cottonwoods
and willows, and is needed to "stimulate" growth".

You have failed to adequately assess the cumulative impacts of grazing
10,087 AUMs on ever-more depleted lands (converted to cheatgrass with
wildly varying fluctuations in productivity, native vegetation weakened
and killed over time by livestock, etc.). It is impossible for the
Forest to claim that impacts are less than in the past, if livestock
have degraded lands sufficiently the whole forage base is changed,
idealized site potentials no longer apply, remaining wetted areas
-much-reduced in areal extent from those of the past -- now bear all the
impacts of livestock concentration, etc.

4-38. As part of this EIS process, you must assess removal of livestock
water projects if they are negatively impacting springs and seeps (you
describe most springs having projects that altered flows).

4-38. You refer to flooding eliminating complete stands of cottonwoods.
Did any of this occur in the allotments that you now propose to open to
livestock disturbance? What was the condition of the watershed?

We strongly support the lower allowable utilization levels for streams
that are not in functioning condition. This should apply throughout the
watershed.

4-39. If Rebel Creek has not been grazed (a vacant allotment), why are
you predicting it to improve under grazing that will be authorized with
this EIS?

Under Alternative 2, you are not adequately protecting seeps, springs
and wet meadows. Why are these given less protection than streams?

4-40. We believe the Forest has not adequately considered the effects of
grazing in causing cheatgrass, weeds and continuous fine fuel and that
there is no basis for claiming that fires would increase with No
Grazing. You have provided no evidence of that here. With ubiquitous,
and often heavy, livestock grazing, northern Nevada has experienced
major fires in recent years. Healthier plant communities, with greater
amounts of native grasses will retain moisture and stay green longer,
thus reducing the length of the fire season, Plus, with healthier
understories, there will be less continuous fine fuel produced by
cheatgrass and other weeds with no grazing.

We have serious concerns about allowing the cutting of dead aspen, due
to the importance of nesting cavities to sapsuckers, woodpeckers, house
wrens, and some other species. Why is the Forest not taking active
measures to protect resident and migratory bird habitat? Why are you
allowing cutting of nesting trees, including during the migratory bird
nesting season?

4-42. In aspen stands that are not healthy, grazing should be removed
until aspen have reached heights (nine feet or \>) above which livestock
damage will be minimal. Dr. Kay also describes the harm caused by
ungulate browsing injury to young aspen -- wounds allow fungal pathogens
to enter trees.

4-43. Current stocking rates are causing unhealthy, non-regenerating
aspen stands, cheatgrass proliferation and many other ecological
problems. Thus, not only must utilization be lowered, but AUMs must be
concomitantly reduced.

4-44. While livestock grazing at times may increase the density of
sagebrush it also affects the structural characteristics. See pygmy
rabbit petition. Your discussion here is woefully inadequate.

4-44. The description of "brush" returning after 2 to 5 years is not
supported by an abundance of current science on the ecological effects
of cheatgrass invasion and its post-fire effects. This is not limited to
BLM lands, but also includes Forest lands.

4-49. The discussion of cumulative effects again repeats an
unsubstantiated claim that removal of grazing would increase grass, and
so fires would increase.

4-51. What is the basis for the belief that mountain big sagebrush
communities would receive "less" grazing?

Doesn't Osgood Mountain milkvetch occur in low sagebrush communities?
This is a plant community type that the Forest has left out of its
Community descriptions, planned reference areas, etc. Thus, the EIS
proposed action does little to protect this species.

4-57. Please provide evidence that the "annual value" of AUMs is
\$1,222,452. You are using a study by a livestock industry consultant
(RCI), and not economist independent of the livestock industry or land
grant colleges. Please have a non-biased party conduct a current
economic study here.

In Appendix A-1, it appears that the Forest has placed tributary streams
in LCT watersheds in lower value riparian area classification. Is that
the case? If so, this should be changed, as all streams in a watershed
should be protected in order to ensure healthy aquatic habitats. Does
this information accurately reflect the settlement agreement reached
between Western Watersheds and the Forest over stream Categories? Under
that Settlement, the Forest agreed to classify all springs, seeps also.
The EIS does not accurately categorize springs and seeps in accordance
with the Settlement Agreement. Please provide a comprehensive Table of
all springs and seeps, too.

All LCT streams should have more protective allowable herbaceous
vegetation standards. Plus, in degraded riparian areas with species like
Kentucky bluegrass, allowing even 35% utilization will not provide
sufficient residual cover for trapping sediment runoff, etc. What
stubble height will remain if there is 35% utilization on Kentucky
bluegrass?

We also believe it is necessary to place specific measurable bank
trampling standards on ALL riparian areas - in order to ensure
compliance with Forest Plan and Amendment 2 soil compaction and
macropore space values. Livestock trampling causes significant erosion,
bank sloughing and other harmful impacts, especially in degraded
riparian areas, and limiting trampling damage with specific standards is
necessary to protect and improve riparian habitats.

A separate "Group" should be established for springs and seeps, low
sagebrush (including low sagebrush- interspersed islands of big
sagebrush), mountain mahogany and other plant communities that are
missing.

We are concerned that the Forest is lumping exotic weedy species in with
"increaser"-type native species in its "forbs/species indicative of
management problems". Please differentiate between these plant types.

For example, in Cottonwood Group, native Wood's rose is considered
indicative of management problems. Woods rose always occurred at the
margin of riparian areas, and an explanation of its occurrence in native
systems must be included.

B-17 and throughout this section. "fire frequency is a broad average --
and a frequency of 30-100 years does not mean that every site has burned
within that time frame. "Idealized "fire frequencies" should not be used
as a basis for justifying prescribed fire.

Sincerely,

Katie Fite

Western Watersheds Project

PO Box 2863

Boise, ID 83701

208-429-1679

We also ask that you institute an upland trampling standard --with less
than 5% of the livestock accessible streambank area surface allowed to
be trampled in areas used by livestock, i.e. the Forest must ensure this
is not measured at inaccessible areas.

We are extremely concerned about the impacts of livestock trampling and
compaction damage here. You must adequately address this.