December 19, 2004

Wendy Reynolds

Burley Field Office Manager

15 East 200 South

Burley, ID 83318

Dear Manager Reynolds,

Here are components for all EA Alternatives for the FRH processes and
associated FRH processes, TNR processes, and other EAs currently
underway -- including Dairy, Sand Springs, Jim Sage, Clear Creek. Saddle
Hoorse Basin, Jones Goat Springs, Walcott, Schodde, Dairy Springs,
Meadow Creek, etc., Please also provide us with these and all allotment
FRH, EAs, proposed decisions, etc. -- as you are required to do under
the CCC for Interested Publics. The following standards should be part
of ALL alternatives analyzed in the EAs for these allotments. Components
of these standards must be incorporated into analyses in the
Decisionmaking process.

SUITABILITY, CAPABILITY, PRODUCTION\< CARRYING CAPACITY ASSESSMENTS

A current grazing suitability assessment/determination must be conducted
on all lands, and its results and findings be a basis for changes in
stocking rates. Lands should be evaluated on the basis of slope,
distance from natural water, rockiness (canyons, low sagebrush tables),
severity of current livestock damage, erosion susceptibility,
rare/unique/important ecological values or habitats that are impaired by
livestock, lack of forage due to weed invasion (halogeton, cheatgrass,
bur buttercup, etc.). Capability, productivity, carrying capacity
studies are all necessary to determine the sustainability of livestock
grazing on these lands under nay alternatives.

CRITICAL AND IMPORTANT HABITATS FOR SPECIAL STATUS SPECIES MUST BE
IDENTIFIED, PROTECTED AND ENHANCED

Protection of habitats for all federal candidate and special status
wildlife species must include recovery of livestock-damaged native
vegetation, soils, waters, watersheds and habitat for native biota.

BLM must develop measures to protect ALL components of declining species
habitats. For example, big sagebrush inclusions embedded in larger
expanses of low sagebrush must have specific protective standards and
monitoring. Dense big sagebrush provides necessary habitat structure for
sage thrasher, pygmy rabbit, gray flycatcher and other declining
species. Utilization and structural damage by livestock must be measured
here, as these are deeper soiled sites where livestock differentially
congregate and inflict damage.

Juniper and pinyon-juniper habitats must have special protections from
damaging livestock grazing practices. A thorough assessment of livestock
as: causal factors in conifer increase in number and density must be
undertaken; as causal factors in soil loss and damage to native
vegetation and microbiotic crusts that may render these communities more
susceptible conifer increases. Please review Belsky and Blumenthal 1997,
available at [www.onda.org](http://www.onda.org/) . A series of
alternatives aimed at minimizing such livestock impacts must be
assessed. What is the current ground cover of native grasses, forbs, ad
microbiotic crusts in juniper communities in allotments to which this
pertains?

HABITAT FOR ALL WILDLIFE

The condition and special habitat features required for all native
wildlife species must be enhanced. Thorough baseline studies of habitats
and populations must be conducted.

BLM must commit to monitoring stubble heights on all sage grouse
habitats, pinyon jay, Virginia's warbler, black-throated gray warbler,
juniper titmouse, loggerhead shrike, pygmy rabbit habitats, etc.

BLM must commit to monitoring livestock structural damage to woody
vegetation in all vegetation communities.

Maintain all good/excellent condition wildlife habitat, and improve all
poor/unsatisfactory condition habitat to good or excellent condition.

NO GRAZING DURING CRITICAL GROWING PERIODS FOR NATIVE FORBS AND GRASSES

BLM's own data and analyses (see Anderson 1991, BLM Technical Bulletin)
have long demonstrated that irreparable damage/and or long-term harm is
caused to native grasses and forbs by livestock grazing during critical
growing periods for native grasses and forbs. There should be NO grazing
during growing periods for native grasses and forbs.

Maximum allowable utilization must be 30% or less on all sites, unless,
(as is the case with sage grouse or pygmy rabbit sites), lower levels of
utilization are necessary to protect and enhance native species habitats
and provide cover needed for nesting or other protection. Please review
the recent Conservation Assessment for greater sage grouse (Connelly et
al. 2004). Available on-line at Nevada Division of Wildlife's Website:
[www.ndow.org](http://www.ndow.org/) .

A RISK ASSESSMENT MUST BE CONDUCTED TO EVALUATE VULNERABILITY OF ALL
LANDS AND VEGETATION COMMUNITIES TO EXOTIC SPECIES INVASION AND/OR
INCREASE

These very significant lands and unique resources are at grave risk of
accelerated exotic species invasion and spread. As Belsky and Gelbard
(2000) demonstrate (this paper is available for your review on-line at
[www.onda.org](http://www.onda.org/) ), livestock are a primary cause of
weed invasion, spread, and loss of ecological integrity.

Halogeton, cheatgrass, bur bttercup, Russian thistle - Have spread to
large areas of the allotments as a direct result of livestock
degradation of native understories and damage to microbiotic crusts, as
well as ill-conceived vegetation manipulation schemes carried out by BLM
in the past. These species have virtually no forage value, and are very
poor and ineffective soil stabilizers. Bulbous bluegrass and exotic
mesic site species may occur at the margins of riparian areas that are
shrinking and dying due to livestock grazing and trampling.

White top knapweed, leafy spurge -- Occur increasingly across Burley
lands. A thorough current inventory and study of weed infestations,
areal extent, causal factors, must be conducted. Please pay particular
attention to livestock facilities and associated disturbance or roading
as cuases of weed problems in BFO lands. Many exotic weeds spread in
areas where livestock concentrate, (under juniper shade, watering sites,
salt licks, livestock trails, flats near water) and as has occurred in
the similar volcanic soils of the Malheur watershed, can rapidly spread
into areas of relatively intact native vegetation. Livestock-damaged wet
meadows and spring margins are at grave risk of infestations.

Cheatgrass -- Disturbed soils on certain aspects in western juniper
communities at all elevations are vulnerable to cheatgrass invasion. It
is already present in livestock-disturbed sites even at higher
elevations in the BFO lands.

Medusahead -- Medusahead has increased at an alarming rate in livestock
and/or fire disturbed lands for large areas in southern Idaho. Like
cheatgrass, medusahead is an imminent threat to many lands.

Annual exotics are just the first stage in a wave of exotic species
moving into livestock-disturbed wild lands. This will be the death knell
for sage grouse over large areas of southern Idaho.

LIVESTOCK CONFLICTS WITH SAGE GROUSE, MIGRATORY BIRD, BIGHORN SHEEP, ALL
SPECIAL STATUS AND IMPORTANT WILDLIFE SPECIES MUST BE MINIMIZED

20-25% or less utilization on native bunchgrasses must be standard in
all sage grouse habitats. This is necessary to provide residual nesting
cover, and longer term enhanced forb composition.

No grazing must occur during sensitive nesting and early brood rearing
periods for sage grouse, nor during nesting periods for migratory birds.
Livestock cause significant behavioral disturbance to sage grouse and
shrub-steppe and riparian area nesting birds, as well as native
ungulates like mule deer. Livestock disturbance includes direct
disturbance of nest/brood/clutch. Flushing females from nests increases
the female bird's vulnerability to predation and may reveal nest
locations to predators. Grazing strips necessary protective herbaceous
cover. Cattle frequently bash and batter sagebrush, thus altering shrub
nesting sites for migratory birds, and/or overhead cover. Note: Tall,
dense herbaceous ground cover is necessary to screen scent and protect
from ground based predators, and provides visual screening from aerial
or ground-based predators.

No grazing during antelope fawning periods. Disturbance of antelope
fawns or removal of cover can result in increased predation rates, or
exposure to elements (rain-chilled fawns often die).

No grazing in any California bighorn sheep habitat at any time. Research
conducted by Elroy Taylor in the Owyhee Canyonlands demonstrates that
bighorn sheep move out of areas when cattle are turned in.

AQUATIC, RIPARIAN AND WET MEADOW HABITATS MUST BE ENHANCED AND
RE-ESTABLISHED/RE-CONNECTED

Livestock grazing management actions in ALL alternatives must focus on
enhancing and re-connecting and restoring damaged riparian habitats.
Increasing stream or spring flows by achieving watershed-wide
improvement of native vegetation through lessening of livestock impacts
is essential.

We ask that you carefully review the series of excellent reports that
Miriam Austin of Red Willow Research prepared and gave to your office.
These reports documented the often appalling condition of springs,
seeps, streams, wet meadows, aspen groves and other riparian or mesic
areas in BFO and neighboring Forest lands.

All springs, seeps, and stream segments must be in PFC in 5-8 years. You
must assess their current condition as part of this process -- this
includes lentic assessments as well as lotic assessments.

Please also measure flow rates, and assess impacts of any existing
livestock facilities on flow rates. Act to restore flows to diverted,
piped or otherwise altered springs.

We are also very concerned that BLM may ignore the condition of
intermittent or ephemeral drainages.

Throughout, BLM must take a watershed-level view, and not shift impacts
to uplands in order to eke out some change in riparian areas. As you are
aware, uplands are often far less resilient than riparian habitats.

RIPARIAN AREAS: REMOVAL OF LIVESTOCK BY JULY 1 IS NECESSARY FOR ALL
RIPARIAN AREAS

Removal of livestock by July 1 must occur in all pastures with any
riparian areas (including springs, seeps).

Since many riparian areas show moderate to severe bank stabilization
problems, extended periods of rest will be necessary to and dramatically
reduced stocking rates are necessary to bring about recovery.

Eliminate livestock grazing on riparian sites with soil erosion
problems.

Riparian condition and hydrologic function must be improved to PFC in
all riparian areas.

Herbaceous and woody riparian vegetation must be in vigorous condition.

Water gaps and other areas of livestock use that are impacting water
quality must be eliminated.

Any livestock management facilities that are harming/impairing riparian
areas must be identified and removed within two years of completion of
the EA.

REMOVAL OF FENCES, PIPELINES/TROUGHS AND SPRING-/DEVELOPMENT GUTTING
PROJECTS AND RELIANCE ON COMMITTED PERMITTEE HERDING AS A PRIMARY
LIVESTOCK MANAGEMENT ACTION

The map of current "pastures" in these allotments shows innumerable
pastures and fences. A primary emphasis of all alternatives should be
removal of fences both because of the hazards they pose to wildlife
(kill sage grouse and migratory birds, posts are perches for nest
predators, sage grouse avoid fences -- see Sage Grouse Conservation
Assessment), and the fact that fences have not been shown to improve
conditions in many areas of the southern Idaho and also because ranchers
routinely trespass fenced pastures. Please review your files on Rice
Canyon and other long-time trespass problems in the BFO.

Existing livestock projects must be assessed for livestock disturbance
to soils, weeds (present or at risk), degradation of native vegetation,
conflicts with wildlife habitats. Removal of projects identified as
being in disrepair or causing harmful must occur.

Salt should not be used, as it causes intense zones of livestock use,
soil disturbance and degradation of native vegetation by livestock. All
existing salt sites should be restored using native vegetation.
Absolutely no new salt sites can be allowed. If salting continues, its
use should be authorized only with on-site clearances and in disturbed
sites.

The track record of maintenance of cattle developments in many
allotments is poor. Dilapidated, upside-down, rusted tanks, and masses
of mangled barbed wire are present in many areas. It is clear that the
public has already wasted a lot of money on developments in here, and
most have fallen into disrepair, or have led to significant degradation
of upland habitats for sage grouse, migratory birds and other important
species.

STRICT SIDEBOARDS BOUNDING GRAZING USE ARE NECESSARY

The nationally significant wild lands of the Jim Sage and other BFO
lands are increasingly grazed by private ranching CORPORATIONs or hobby
ranchers or the ag-conglomerate of J. R. Simplot. LLCs may have an
ever-shifting cast of grazers, and there is no guarantee whatsoever that
commitments/assertions made by present grazers will be upheld, unless
specific bounds, terms and conditions are required.

SHIFTING OF USE AND IMPACTS

BLM must not shift livestock use to new areas, and must instead protect
existing better condition lands while alleviating livestock damage to
degraded sites.

LONG-TERM REST/REMOVAL OF LIVESTOCK FROM LANDS WITH ACTIVE EROSION.

This is necessary for protection of watersheds, attainment of water
quality standards, health of native vegetation. Large-scale water
quality problems such as coliform bacteria, sediment, and temperature
exceedances are rampant, and livestock are often the primary cause.

BLM must sample surface waters in these allotments during and at the end
of the period when livestock are grazing, and conduct sampling under
protocols necessary to determine compliance or noncompliance with Idaho
water quality standards.

STUBBLE HEIGHT AND TRAMPLING STANDARDS MUST BE APPLIED TO ALL RIPARIAN
AREAS

A 6 inch stubble height must be placed on all springs, seeps,
intermittent drainages and streams in the allotments. As grazing use
approaches this level, it should trigger removal of livestock from the
area.

A 95% or less bank trampling standard should be applied to springs,
seeps, intermittent drainages and streams in the allotments. This must
be measured in areas accessible to livestock (i.e. no measuring in areas
too steep or rocky for livestock use). As grazing use approaches this
level, it should trigger removal of livestock from the area.

10% or less annual browsing of new willows must be a standard. This will
help establish woody species, and protect from temperature exceedances.
Establishment and growth of willows and other woody riparian vegetation
is necessary to bring about compliance with state water quality
standards.

Fencing is no solution to riparian grazing problems here - it is
impossible to fence all the important riparian areas in this allotment,
and only serves to shift use to new areas.

PENALTIES FOR VIOLATIONS OF STANDARDS

BLM must require specific penalties for failure to comply with stubble
height and other standards. Measurable standards of use must be Terms
and Conditions of grazing permits.

Permanent reductions in livestock numbers must be made for each failure.

LARGE-SCALE DISTURBANCE OF FIRE ON LIVESTOCK-DAMAGED LANDS IS NOT
CURRENTLY APPROPRIATE, AND IS NOT CONCORDANT WITH PROTECTION OF PUBLIC
LANDS AND WATERS

Existing burns, spray projects, chainings and other large-scale
disturbances in the Assessment and EA areas are invaded by weeds.
Snakeweed, rabbitbrush, have large areas of bare soil, or are in poor
ecological condition.

Impacts of large-scale disturbance of livestock grazing and/or other
planned treatments must be assessed in relation to existing disturbance
and fragmentation on each site as well as across the landscape.

BLM MUST STUDY AND MAP HABITAT FRAGMENTATION IN THE BFO AND SURROUNDING
LANDS

As part of this process, BLM must provide study fragmentation factors
and effects across the landscape.

Cheatgrass (found nearly everywhere) has exploded following fire in
burns in lower elevation sites.

There are many veg. treatments are sprinkled throughout BFO lands. These
areas are often characterized by a host of exotics. Some at higher
elevations have increased densities of woody vegetation - juniper and
or/sagebrush, and appear to have led to further loss of native
bunchgrasses, as Idaho fescue, and especially native *Stipas* can be
killed or damaged by fire.

Through grazing-caused loss of native understory vegetation and
microbiotic crusts, soil erosion, and other impacts, livestock grazing
has permanently altered the site potential of many areas that BLM now
considers "invaded" by junipers or other woody vegetation.

SOILS MUST BE PROTECTED FROM WIND AND WATER EROSION THROUGH LIMITATIONS
ON LIVESTOCK GRAZING AND TRAMPLING

BLM must manage native perennial plant communities to increase the level
of cover representative of a late seral stage. Large areas (crested
wheatgrass seedings, burns, intensively disturbed sites) are lacking in
native perennial cover and microbiotic crusts necessary to stabilize
soils.

What is the current rate of soil "production" on various sites in this
allotment? What level of soil loss is acceptable? How have you
determined this? What are wind or water erosion rates?

Livestock use must be removed from lands with accelerated soil erosion
(like the gullies) Native perennial vegetation necessary to protect
sites from erosion must be established.

No actions undertaken as a result of these assessments or EAs should
result in any accelerated soil erosion (localized or broad-scale).

Shifting, increasing or concentration of livestock use into new areas
must not occur.

Gullies on upland areas must be rehabilitated.

POST-WILDFIRE REHABILITATION

All burned areas or treatments must be rested a minimum of five years.
Rest must be strictly enforced, with trespass of burned areas resulting
in termination of grazing permits.

AN INTEGRATED WATERSHED LEVEL APPROACH MUST BE TAKEN

BLM must look at restoration of the watershed as a whole, and manage the
BFO lands and wildlife across artificial allotment boundaries.

MONITORING

As BLM has not conducted a current ecological site inventory, BLM's
assessment must commit to producing this within two years. All lands in
poor or fair condition must be improved to good condition within a
decade or less.

BLM must require permittees to monitor stubble heights, trampling
standards, etc. as a term and condition of grazing permits, throughout
the course of the grazing period. BLM must randomly check permittee
monitoring data.

MEASURABLE GOALS ARE A NECESSITY

BLM must set measurable, quantifiable goals for recovery within
specified periods of time. These are necessary to improve damaged
riparian areas, meet water quality standards, heal damaged uplands.

ALL riparian areas should be in PFC within 5-8 years.

BLM must restore 10,000-20,000 acres or more (under various
alternatives) of degraded crested wheatgrass, cheatgrass or other
exotic-infested lands to native vegetation annually, with a
proportionate acreage per allotment under these assessment processes.

VARYING LEVELS OF LIVESTOCK REDUCTIONS

As the assessments frequently show, widespread damage has occurred from
livestock here. Therefore, it is reasonable that ALL action alternatives
must include significant reductions in livestock numbers in order to
protect public land values and allow restoration of damaged areas.

CUMULATIVE IMPACTS MUST BE CONSIDERED

Cumulative and synergistic impacts of all activities and conditions of
adjacent lands must be fully assessed in all alternatives. Impacts
include those to soils, native vegetation, microbiotic crusts,
watersheds, native vegetation, wildlife, special status species,
cultural sites, recreational uses and other important uses of these
lands.

RE-VISIT ASSESSMENTS

BLM is increasingly ignoring current science and discounting the role of
current livestock grazing in land health problems. We ask that you
review the following literature, and revisit those determinations where
land health was not meeting standards, yet you somehow determined that
livestock were not a factor.

**All of the above** should be applied as Protest points.

**Below are separate**, specific comments/protest points on Sand
Springs. All are Protest points, too:

We are alarmed at the limited, shallow and cursory analysis. BLM appears
to not have collected necessary data in a systematic way.

BLM has not revealed how much of its data is simply from old records
(like for special status species) already on file. Did you visit and
inventory the allotment during periods when migratory birds were
present? If so, why are there no records for several sagebrush-steppe
obligates? Is the habitat SO EXTREMELY degraded that they are not
present?

It appears that BLM failed to collect necessary data so that it could
blithely assume that conditions were great, and so not find ANY
violations of the FRH. We believe this is unscientific and arbitrary.

BLM as failed conduct adequate FRH assessments. For example, even BLM"s
extraordinarily cursory discussion of special status species and native
veg. reveals serious deficiencies.

BL:M fails to reveal if it is increasing Active Use here. What were the
previous stocking rates? What was actual use for the past 20 years?
Please provide information on all monitoring that has been conducted --
such as utilization, use pattern, and maps showing these areas where
data was collected, where weed infestations occur, etc.

BLM is violating the RMP in allowing utilization and actions detrimental
to wildlife in violation of the Monument RMP.

BLM failed to prepare an EIS, which must be done because the RMP is so
old, and significant changes in habitats and vegetation communities
resulting in greatly expanded harms to native species have occurred
since it was prepared.

BL fails to assess direct, indirect and cumulative impacts - such as the
impacts of widespread habitat loss on private or other lands, the
impacts of the activities that are conducted on the private lands, etc.

BLM fails to conduct a suitability, capability, stocking rate,
productivity or any other study to determine where and if livestock can
be sustainably grazed on these lands. analysis.

BLM fails to reveal the location and condition and impacts of all
existing livestock facilities on these and surrounding lands, and how
these livestock facilities and associated use may be impacting soils,
watersheds, cultural sites, special status species, native wildlife, and
haw impacts may be fragmenting habitats. BLM fails to consider any
alternatives that would remove or decrease stocking rates, remove or
eliminate facilities, etc.

Sincerely,

Katie Fite

Western Watersheds Project

PO Box 2863

Boise, ID 83701

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