July 28, 2006

Mr. Dave Rosenkrance\
Field Manager\
801 Blue Mountain Road\
Challis, Idaho 83226

Dear Mr. Rosenkrance,

Please include this letter as part of WWP's comments on the development
and analysis of livestock grazing analysis and permit issuance and the
NEPA process underway in the Burnt Creek allotment.

I visited the Burnt Creek allotment over the 4^th^ of July weekend, and
am appalled at the amount of roading that exists in the allotment,
including in areas of the Burnt Creek WSA where WSA maps show that no
roads are supposed to exist.

While a few WSA signs are present, there is no information that clearly
tells the public not to drive many of the new roads. In fact, some of
the signing seems to legitimize the new roads. How many miles of new or
expanded roading now exists in the WSA, and why has BLM taken no action
to control it.

We believe that constant tinkering with the existing fences, and
placement of maintenance of electric fencing has only served to expand
roading in the WSA.

WWP is also very concerned that much of the roading is related to
livestock permittees driving to place salt, examine fences, commute
between allotments, etc. Please fully assess the role of livestock
grazing activities in promoting this roading. Please also develop, as
part of the EA/EIS, actions to restore road-damaged areas and to limit
motorized access, including by permittees who have horses and can use
them.

As the letter pasted below also demonstrates, there are serious problems
with degradation of spring, seep, stream and other habitats in the
Pahsimeroi watershed that must be considered in NEPA analysis as part of
the environmental setting and cumulative impacts.

I am also very concerned that roading will case increased disturbance of
bighorn sheep, sage grouse, pygmy rabbit and other important native
biota in this area. Plus, sediment production from roading is another
concern, as well as the spread of invasive species.

Sincerely,

Katie Fite

Biodiversity Director

Western Watersheds Project

PO Box 2863

Boise, ID 83701

**PASTED BELOW** is the letter referenced above that describes concerns
about roading intrusion in to portions of the WSA, and roads now
connecting between Burnt Creek watershed and East Fork Pahsimeroi
watershed.

July 5, 2006

Ralph Rau

District Ranger

Challis Ranger District

Salmon-Challis National Forest

RE: Cattle Grazing and Neglect of Public Lands in the Upper Pahsimeroi
Allotment

Dear District Ranger Rau,

I visited the Upper Pahsimeroi allotment and surrounding area including
both Forest and BLM lands on July 3, 2006. I was shocked at the level of
current livestock grazing and trampling use and the damage being
inflicted on springs, seeps, streambanks, and increasingly intermittent
side drainages and the upland in the lower pasture of the allotment. The
cattle have gouged and trampled banks of the Pahsimeroi River,
delivering sediment directly into the stream and bull trout waters.

Here are my quick observations:

Cattle were present in all three pastures. The West Fork Pasture had
been heavily grazed earlier, and some cattle were still present. The
pasture near and downstream from the shack was severely grazed, and
cattle were still present. The upper East Fork Pasture fence (separates
downstream pasture from the upper East Fork) had not been maintained,
and some cattle were in that pasture, too.

The downstream pasture, including portions of the BLM WSA, is heavily to
severely grazed even in this exceptional precipitation year. Did the
Forest count cows turned out onto this or other pastures in the Upper
Pahsimeroi allotment?? How many cattle were grazed, and for how long?
What monitoring information has the Forest collected, and may we please
receive a copy? (Stubble height, willow browse, bank trampling upland
utilization, upland browse). How does this compare to any requirements
of the permit or AOI?

The hummocked springs and seeps have suffered fresh 2006 damage, with
moist soil conditions leading to even more severe pugging, hummocking
and desiccation. Willows struggling to survive in hummocked springs and
seeps suffered severe browse use, and are dying.

Stream banks in many areas of the downstream pasture are severely
trampled, collapsing into the stream, and eroding sediment directly into
the water. I note that heavy thunderstorm activity last night in the
vicinity of the Lost River Range (if it rained in the upper Pahsimeroi)
will have delivered even more plumes of sediment into the bull trout
stream. We had previously written to you (2004) expressing concerns
about the lack of ANY trampling standard on the permit/AOP. Have you
placed any standards on the permit? If so, what are they?

The streambank - both where accessed by the horses in the pasture right
on the bank, as well as all surrounding the horse pasture is hideously
trampled and collapsing into the stream. First, why in the world is it
necessary to have horses kept there? I never see any rancher activity of
any kind here, except for junk and junk wire appearing. Cattle are free
to go wherever they want, with fences unmaintained. Why doesn't the
Forest simply require that horses used in potential management
activities here be kept on non-Forest lands? It appears that the
permittee is just getting horse pasture for free -- right on the banks
of a bull trout stream.

While the horses have access to the river in a confined mud wallow area,
cattle grazing and trampling activity surrounding the horse pasture is
causing severe damage to banks of the Pahsimeroi River, which are
eroding away.

There is loose and junk wire and twine thrown about in the area just
north of the horse pen. Why is such littering of public lands by
ranching entities allowed to occur here? It is a hazard to wildlife, the
public, and even the cattle themselves.

The fence that separates the lower Pahsimeroi pasture from the upper
East Fork pasture has not been at the location maintained where it
crosses the river (approximately 1/10 th mile upstream from the cabin).
Cattle are walking in the river and across the unmaintained fence where
it crosses the river, and thus accessing the upper pasture. I observed
20-25 cattle in a draw on the east side of the river in the upper East
Fork pasture. Cow hair is snagged on the downed wire where they are
walking over the fence. Why was the fence not maintained, yet cattle
allowed to be turned out? Isn't it a Term and Condition of the permit
that facilities must be maintained prior to Turnout? Did upi inspect the
allotment prior to turnout?

As just mentioned, I observed 20-25 cattle in a tributary draw/drainage
in the lower portion of the upper East Fork pasture. Plus, some cattle
recently had left fresh manure piles along the road leading to the upper
East Fork trail, and have already been grazing in a few places along the
East Fork banks - including right up to the trailhead sign.

When were cattle turned out in the pastures? Soils in both the
downstream and West Fork pasture appear to have been far too moist -
especially in the beleaguered spring and seep areas here -- when cattle
were turned out.

This whole area receives significant recreational use from the public,
and the public deserves better than to have the stream and uplands in
this area turned into a stinking, polluted cattle feedlot. I spoke to a
fisherman who was leaving in disgust, as bellowing cattle clambered up
and down the streambanks in front of him. Cattle were also loafing by
the gate at the shack, causing members of the public attempting to
access the public lands to step over stinking cow flops and flies, and
shoo off dozens of cows on both sides of the fence to even access public
lands beyond.

I also walked up the East Fork trail to the helicoptered piles of
fencing material in the upper pasture. The situation there has only
deteriorated. The paper boxes of nails have decomposed, and rusty spike
nails are spilling all over the trail as well as on the slopes below.
Likewise, rusty fencing washers are spilled all over the ground. We ask
that this mess be cleaned up, and the materials removed. How many
thousands of dollars did the public spend on air-lifting these materials
in -- only to see them be wasted and decay? Fencing is not a solution
here -- as illustrated by the situation near the shack and with the lack
of maintenance of even the existing fences (such as the ill-maintained
pasture division fence at the stream crossing described above) close to
the road. It is time to take permit action, and get the cows out of this
critical habitat and beautiful wild land area before they cause even
more damage to soils, vegetation, and important habitats. These lands
are grossly overstocked, and highly unsuitable for grazing, as well as
having few capable acres. Conflicts - with scenic wild lands, high rec
use, bull trout, critical big game ranges - are extreme here and grazing
is seriously impacting this wealth of other public lands values.

I also encountered a utilization cage sitting on top of vegetation that
had already been grazed to ground level in the downstream pasture. It
appears to have been yanked out of its original position, and placed to
obscure any understanding of the utilization that actually has occurred.
Who did this?

In addition, I visited the eastern portion of the upper Pahsimeroi
pasture from the Burnt Creek watershed by walking over the drainage
divide.

I was deeply disappointed to see the extent of new roading that had been
carved into this supposed-to-be-BLM WSA and Forest area. What actions is
the Forest taking to control roading -- both in the upper Burnt Creek
and upper Pahsimeroi area?

On the Burnt Creek side, BLM has permitted extensive roading in WSA
lands, and this is leading to increased motorized access onto Forest
lands. I am very concerned that permittee driving may be responsible for
this route pioneering -- as the roading accesses salting sites.

The condition of the spring complexes and drainages in the upper East
Fork pasture on the east side of the East Fork is appalling- they are
eroding, downcut, and contain large hummocks, just like the spring
complexes on the flatter areas in the other pastures. What utilization
and other standards are applied to these riparian areas? These sites
contribute sediment and livestock waste to the Pahsimeroi River. Their
degradation by livestock is also reducing the areal extent of wetted
areas, and sustainable and perennial flows in tributary drainages. Plus,
lack of willow and shrub cover (due to cattle browse) results in
elevated water temperatures. The same applies to grazed spring complexes
throughout the watershed.

Has the Forest ever consulted with USFWS over the impacts of cattle
grazing and the extremely degraded condition of these spring/seep
tributary drainages -- and the arge volume of sediment and cattle waste
that is delivered to the river in runoff events from these severely
hummocked and dying spring and gully areas? If so, when? Conditions may
have deteriorated since such consultation took place. What standards of
grazing, browse and trampling use are applied here?

In speaking to Jon Marvel after repeatedly trying to talk to you on the
phone yesterday, I learned that despite WWP's requests, we still had not
been provided with a copy of the Annual Operating Plan/Instructions for
the Upper Pahsimeroi allotment. Why in the world would the Forest set up
so many obstacles to the public obtaining information about the
livestock grazing schedule and standards here?

Please also let us know if trespass has occurred, or use outside any
authorized period, and the results of any monitoring.

Please respond to our concerns in writing.

We also request a site visit with you and the U. S. Fish and Wildlife
Service as soon as possible to examine the degradation.

Sincerely,

Katie Fite

Biodiversity Director

PO Box 2863

Boise, ID 83701