January 22, 2006

Bryan Fuell/Lorrie West

EIS Co-Project Leads

BLM Elko Field office

3900 E. Idaho St.

Elko, NV 89801

Dear BLM,

Here are additional comments of Western Watersheds Project on the
Sensitive Species EIS for the Sheep Complex, Big Springs and Owyhee
allotments.

These comments serve to point out critical info in past BLM documents
that show evidence of great habitat loss and degradation for sensitive
species in the allotment lands.

Given the staggering weight of evidence of widespread degradation and
continued habitat loss for native biota, including important and special
status species, BLM must consider a range of alternatives focused on
actually decreasing stocking rates, and instituting rigorous and
mandatory conservative levels of livestock use. All Alternatives that
serve as the basis for any BLM action is actually a LARGE INCREASE over
the average levels grazed during the period when FRH violations and
widespread ecological problems shown in even BLM's limited analysis were
documented. This has been starkly emphasized by NDOW and other agency
comments, and by the public THROUGHOUT THIS SEVERAL YEAR PROCESS and is
still ignored by BLM, in defiance of a Court Order.

In the woefully deficient EAs and DNA, which were recognized by the
Court to be deficient, BLM approached its **limited analyses** --
including in the AEs, MASRs, MUDs - as if there would be an
on-the-ground reduction in livestock numbers or use. This was false, as
the MUDs enshrined grazing levels far above those shown to be
sustainable. BLM in those paperwork exercises NEVER considered the
ecological impacts of INCREASED livestock use, and more damaging
facilities, as its MUDs would authorize.

Now, BLM has wasted over \$100,000 of taxpayer funds, and still refuses
to provide current data and accurate and scientific analysis of a range
of reasonable alternatives that would reduce numbers and levels of
livestock grazing and trampling disturbance to the Owyhee, Big Springs
and Sheep Allotment Complex.

BLM's being hellbent on charging ahead on projects (or any aspect of
decisions) despite its having killed springs and created vast weedlands
of destroyed sagebrush-dependent wildlife species habitats in the past.
BLM makes a mockery of the EIS process. BLM must prepare an Supplemental
EIS, as the current effort is simply a re-massaging of limited, old
information.

BLM has steadfastly ignored many NDOW comments on cheatgrass and weeds
(which reflect current science), and impacts to wildlife and special
status species habitats. WWP has repeatedly provided BLM with references
that encompass current science on invasive species, sagebrush
ecosystems, wildlife habitats, "range" science, etc.

-   BLM hides from the fact that it all alternatives authorize AUMs
    greatly in excess of the average \# actually grazed.

-   BLM provides little to no current science on ecological condition of
    upland vegetation and habitats.

# WEEDS/INVASIVES

Livestock degradation causing cheatgrass and other invasive species
invasion and dominance of sites is largely irreversible or requires
tremendous funds and large-scale restoration with limited or no grazing
to reverse. BLM's old documents narrowly focused on "noxious weeds",
despite abundant information in the record concerning cheatgrass and
other invasives being much more widespread and significant habitat
problems across the allotments. WWP has provided abundant scientific
references, and Nevada-specific references about harms caused by
cheatgrass, halogeton, etc. and other "invasive" species, and many NDOW
comments, plus NNHP.

Whisenant 1991, Billings 1994, others describe catastrophic ecosystemic
change brought about by cheatgrass and the "extensive and disastrous"
range fires it causes, Fleischner 1994, Belsky and Gelbard 2000, Knick
et al. 2003, Federal Register Notices re: sage grouse, pygmy rabbits.
Connelly et al. 2004, Dobkin and Sauder 2004, Nevada-specific
references, including Nachlinger et al. 2004, Nevada Natural Resources
status Report.

All experts and current science agree these processes operate across the
arid West. This is precisely what IS now occurring in Nevada.

BLM had repeatedly claimed "stable" trends are a basis for claiming
habitat conditions are acceptable. BLM has NOT measured current
conditions -- even at the time of Allotment Evaluations, and most data
was old or quite limited. Also trend could start out very bad, and
remain bad and highly degraded. Just because a poor condition site
remains stably poor does not mean that management is proper. Many poor
condition sites were termed "stable" (under lower stocking rates that
occurred in the past). There is no analysis of how INCREASED use under
all DEIS alternatives will affect stable degraded or poor condition
sites.

BLM"s own pictures used for white sage/winterfat in the evaluations and
Administrative Record show there are often few if any bunchgrasses and
abundant bare soils -- providing for weed invasion following livestock
trampling disturbance, and then weed spread.

NDOW Big Springs letter (AR 98) at 9: "Data inferred from individual
pasture use indicates average actual use has been 10, 827 AUMs since
1987. If permittees were to stock up to the new proposed permitted use,
a 57% increase in actual use would be realized. Given the poor condition
of riparian habitats **and the trend toward invasion of the allotment by
exotic forbs and grasses**, we don't believe this allotment can sustain
this use without further resource damage.

AR at 324. Fire Closure Agmt. Big Springs: Describes East Pequop Bench
."the Big Springs fire burned through range sites **dominated by big
sagebrush with a cheatgrass understory in the East Pequop Bench pasture
..."**

NDOW AR at 44 (SAC): "**the invasion of cheatgrass is continuing at a
rapid rate on some other portions of the Complex"**

AR at 63 (SAC): Noxious weeds. Map. BLM: June 4, 2003.

NDOW AR at 44 (SAC): "the fact that **9 of 15 key area sites show a
downward** **ecological trend** does not provide a good argument for
potentially increasing actual livestock use on the allotment complex.
While horse numbers appear to be cut in half the recommendations and
permitted livestock use remains significantly higher ... than actual use
reported through the evaluation period. If operators stocked up to these
proposed new levels, we would see an average annual use increase of
60%".

Thus, there is a very GREAT likelihood of weed increase and spread and
degradation and loss of important and special status species habitats,
as MORE livestock will mean more disturbance to soils and vegetation, as
well as more vectors of weed introduction and spread under ALL
alternatives provided for ALL allotments.

Owyhee NDOW letter (AR 72), MASR (AR 75) at 9. "the invasion of
cheatgrass on uplands, the lack of woody riparian vegetation and lack of
residual herbaceous vegetation are **major** concerns". Yet, BLM failed
to provide data, assessment and analysis of the extent of such invasion
and its effects in important and special stats species habitats. across
these allotments.

Owyhee (AR 72) NDOW letter, "areas in close proximity to water ... which
now have **higher densities of cheatgrass**". This demonstrates the
impacts of new watering sites or other developments across the uplands,
and the drastic alteration in vegetation communities and fire frequency
that will result.

Owyhee Owyhee MASR (AR 75) at 14 Nevada Natural Heritage Program:
"evaluation fails to address noxious weeds and sensitive plant species
... both current conditions and status, and as to the effects
implementation of the Technical Recommendations may have on these
vegetative resources. Implementation of the recommended vegetative
manipulation measures has **the potential to increase the extent of
noxious and invasive weed infestation on the allotment** ... the known
population of grimy ivesia \[special status plant\] ... is bisected by a
fence, and "livestock concentrations along this fence could negatively
impact this population"

Owyhee MASR page 19 or 20 OAE discusses **'poor forage diversity' and
lack of perennial native vegetative cover" and "heavy composition of
cheatgrass**".

Owyhee EA (AR at 81) at 11: "**noxious weeds: "3 species were identified
and mapped at 59 sites**, "hoary cress "on 28 different sites" (map in
AR shows weeds widespread across eastern half of allotment).

Owyhee EA at 15 minimally refers to "soils", without any description or
assessment of microbiotic crusts that are critical to preventing weed
infestation. BLM in the DEIS continues to ignore the assessment and
inventory of microbiotic crusts, as well as assessment of impacts of
increased stocking rates and all associated management actions on them.
Microbiotic crusts are critical to preventing weed invasion of important
and special status species habitats in arid lands, including sagebrush,
salt desert shrub, and pinyon-juniper communities (USDI BLM 2000).

Owyhee EA at 17-18 recognizes that: "noxious weeds can be spread by
vehicle tires, livestock and wind", but only addresses noxious weeds --
but says nothing about invasive species, which are a gigantic problem
across these allotments. With more livestock, there will be more spread
of weeds, more loose and disturbed soils and wind erosion and spread of
weeds, and more management activity spreading weeds with vehicles
hauling water, trying to control herds, etc.

Owyhee EA (AR 81) at 27: "with no proposed range improvement activities,
a lower chance of noxious weed spread would be likely", yet this is
ignored in the DEIS and current analysis, and scope and scale of
invasive species linked to existing or proposed activities and the
degradation of important and special status wildlife species habitats
that will result is never measured, quantified or accurately described
by BLM.

Old analyses -- such as that for the Owyhee allotment -- used only very
limited citations, primarily from agencies, and of course the SAC was
even worse.

Big Springs MASR (AR 101) at 11: NDOW comment: "the invasion of
cheatgrass, **halogeton,** and other exotics are also **major** concerns
as these species may be reducing forage availability for our native
birds of prey". BLM's DEIS fails to map, detail, quantify, assess or in
any way allow reasoned analysis of the current extent of halogeton
infestation across these allotments or its impacts to important and
special status wildlife species and other species habitats or watershed
function and health.

BS MASR (AR 101) at 12: NDOW: "While healthy riparian habitats are
indeed critical to the life cycles of several species within the
allotment, the majority of wildlife in this allotment depend on healthy,
native habitats for their survival". Despite BLM long knowing this,

BS MASR at 20: Pequop Mtn. Pasture -- "**cheatgrass competition and
livestock grazing**". MASR at 20 erroneously and illogically concludes
"condition and trend met". Despite serious problems, BLM increased
(shifted) more use into this pasture under the MUD, and under Alts. 3
and 4.

Big Springs EA (AR 107) at 26 includes an "Invasive, non-native species"
section that only discusses noxious weeds. Yet, NDOW expressed concerns
re: cheatgrass. BLM ignored that , and only admits: black henbane,
Canada thistle, hoary cress, Scotch thistle. Then later, in cumulative
impacts, BLM only discusses "noxious weeds" under heading entitled
"Invasive, nonnative species". Thus was never an accurate inventory or
assessment of invasive species conducted, and BLM did not conduct such a
study as part of this EIS, so has no way to gauge impacts of any of its
management actions on important and special stats species habitats.

In Big Springs EA at 29, under the discussion of soils, there is no
mention of microbiotic crusts. BLM here admits that livestock spread
weeds, yet the EIS never reveals the impacts of increased livestock
numbers above actual use under all new action alternatives on livestock
spread of weeds into and through important and special status species
habitats and watersheds.

SAC DNA. Weeds. BLM admits that the "EIS \[Land Use Plan -- Wells RMP\]
was silent on the critical element of invasive, nonnative weeds". BLM
then claims element was "present, but not affected" by the proposed
action". This stance was continued in the BLM's Responses to WWP,
ignoring science, and continues to this day as BLM still has never
assessed invasive species/weed infestations and their effects on
important and special status species habitats across the allotments.

Owyhee MASR at 2: BLM states: "the Elko RMP/EIS contain the needed
elements for site specific analysis, i. e. specific levels of livestock
use are identified, forage conditions are projected into the future,
specific range improvements are identified, and the related impacts of
these proposals on other resources are specifically analyzed. The
specific design of each project is selected when each project is
analyzed more closely prior to approving construction". Well, scientific
understanding has changed! Large-scale fires, weeds, habitat
fragmentation, new science, species concerns are escalating. The old
LUPs no longer allow BLM to rely on them for baseline conditions,
current inventories or facility or other impacts analyses. BLM needed to
conduct such analysis in this EIS to understand the impacts of
facilities on fragmenting habitats and these impacts to local, regional
and nationally significant populations and habitats. BLM has failed to
do so.

# HARM FROM FIRE CYCLES/HABITAT FRAGMENTATION 

Big Springs EA at 11 describes "the Big Springs Fire of 2000", largely
ignored by BLM in its DEIS. Big Springs EA (AR at 107) 11 describes "the
Big Springs Fire of 2000", and maps show a large irregular fire pattern
in the North Pequop Pasture.

SAC FMUD, **Appendix 2**. SAC Fire Mgmt Plan. SAC contains 5 mgmt
polygons. B3 polygon is one of "areas of annual vegetation". These are
shown on Map 1, and constitute significant areas.

B3 Polygons are located:

White Horse allotment on West side of Goshute Range

Large area extending north-south from Leppy Hills to Utah-NV north to
Lead Hills allotment (= extensive areas of the valley edge/alluvial fans
along the eastern Toano and Goshute Ranges.

Wedge-shaped area in the northern Boone Springs allotment. Is this
cheatgrass dominance a significant factor in the extirpation of Boone
Springs leks???

"Current condition" of this polygon is described as: "**cheatgrass and
other annuals dominate these polygons"**. RNOs: "to restrict the
expansion of cheatgrass": "primary emphasis is on preventing the spread
of fire into areas of native veg."

"fire history in these areas is dominated by large acreage fast-burning
fires that often exceed 20,000 acres", and "these fires expand the
annual veg areas by burning native vegetation, which allows the annuals
to colonize the burned areas".

Fire history: "The SAC has a moderate number of wildland fires",
"surprisingly, \[many of the fires occurred in the low sage/desert shrub
community"... "most of the fires were small. However, there are a large
number of fires ranging from 300 to over 3000 acres in the low
sagebrush/salt desert shrub community. **The probable explanation for
this is that these areas have been invaded by cheatgrass, which has
altered the fire regime in this vegetation type, leading to more
frequent and larger acreage wildland fires**. Normally, this vegetation
type has low fire occurrence". "

Plus, in its FMUD at 31, BLM plans to establish 2 new Key Areas in burns
-- indicating they are a significant part of the landscape. And under
"other management" FMUD at 33: BLM plans to examine a large block of
land to see "if this area **should be changed to a cheatgrass
polygon".**

SAC AE at 63. **Lead Hills** allotment "much of Key Area 1014 (Ferguson
Flat) is **dominated by cheatgrass** **(BRTE) causing the ecological
status to decline**". SAC at 64. **White Horse allotment. "Much of key
area 1004 is dominated by rabbitbrush and cheatgrass".**

Plus, in discussions of antelope habitat in the AR show that in some
areas 99% of the land is cheatgrass! So yes, extensive cheatgrass and
weedland monocultures do exist, but nowhere in previous analyses or the
DEIS does BLM assess how extensive this is, or relate it to important
and special status species habitats and populations, and losses or
changes in habitats, sightings or populations over time.

NDOW has observed a "rapid rate" of cheatgrass invasion on portions of
the SAC. See AR No. 44. Cheatgrass invasion of the uplands here, along
with lack of residual herbaceous vegetation, is considered a "major"
concern by NDOW (See AR No. 75, at 9), and also notes its occurrence in
areas impacted by heavy livestock use.

Owyhee allotment fires affected 3.7% of acreage between 1986 and 1999.
Owyhee AE (AR 65) at 10: BLM termed \# of wildfires "moderate", based on
1996-1980 fires. See Fire Mgmt. Appendix. AE Appendix 3 at 4: Total
acres 1980-1996- 14,017 acres.

HOWEVER, Owyhee MASR (AR 75) at 24 shows there had been significant new
fires. "the **large fires that have occurred in this vegetation type in
the past two years** have been predominately in over-mature closed
canopy sagebrush stands **with an understory of cheatgrass**". "As an
example, the Cricket fire in 2000 burned **62,000** acres. The Owyhee
allotment encompasses 376,268 acres. Now, we have the Wilson Fire
burning 50,000 acres in or near the allotment in 2005. So, it is likely
that one third of the Owyhee allotment may be greatly lacking in
sagebrush and other shrubs required for sage grouse, jackrabbits as prey
of golden eagles, many small bird and mammal prey species of raptors,
etc. On top of this, BLM has destroyed areas of sagebrush with mowing.
And nowhere in the DEIS is the complete fire history and scale of shrub
loss revealed, nor is the cheatgrass dominance of the understory in
still unburned lands ever assessed.

These fires have resulted in widespread -- yet unrevealed by BLM and
unassessed -- increase in cheatgrass, an unsustainable forage.
Scientific literature is replete with info on cheatgrass causing
long-term, often irreversible changes and livestock grazing disturbance
being a causal factor in spread of cheatgrass and other weeds.

Big Springs FMUD (AR 108) Map 2. Map shows area of "West Pequop Fire"
2001. -- approx. 8 sections. Map 3 - shows Big Springs Fire -- 2000.

Owyhee AE at 19. Mule deer habitat conditions in the huge Star Ridge
Pasture **"heavy composition of cheatgrass**" at one of only 3 BLM
monitoring sites. Nowhere can a reader of the DEIS understand the
condition of any mule deer, sage grouse, or any other species current
habitats in any allotment, nor of the extent of cheatgrass occurrence
in, and dominance of, understories.

Owyhee AE at 46. C**heatgrass invading Key Area while native grass
decreased**.

Owyhee AE at 66: Cheatgrass "an undesirable annual grass that competes
with native vegetation and **effectively compromises forage diversity
and cover on the site".** This compromise of forage diversity and cover
on sites has never been adequately assessed, nor has the irreversible
harm it has caused to important and special status species habitats. By
increasing stocking rates above past use levels under all alternatives,
BLM will only ensure accelerated loss.

AR at 70 (Owyhee) letter. From NNHP, NV Clearinghouse: BLM's "evaluation
fails to address noxious weeds and sensitive plant species, both as to
their current conditions and status on the allotment, and as to the
effects implementation ... may have on these veg. resources"...
"**implementation of the recommended veg. manipulation measures has the
potential to increase the extent of noxious and invasive weed
infestations on the allotment if these measures occur in or near
existing infestations**".

Owyhee AR at 93. Noxious Weed Infestations in the Owyhee Allotment. Map
shows widespread infestations throughout eastern portion of allotment.
Dated June 10, 2003. Canada thistle: 220 acres, Hoary Cress 985 acres;
Scotch thistle 175 acres, thistle spp. 1500 acres. When this is compared
to the 1998 data, large-scale increases are seen. It must be emphasized
that BLM weed inventories in almost all instances are only concentrated
along roads, and do not reflect infestations in the hinterlands.

**STOCKING RATE**

BLM claims that conditions have been "stable", and trend stable. BLM has
NOT measured current conditions -- even at the time of AEs -- as most
data used was old or very limited. Regarding claims that Trend is
stable: trend could start out poor/very bad. A stable very bad site may
be very vulnerable to weed invasion. Conditions can be terrible, and
stable. Bad sites were "stable" under lower stocking rates of average
actual use. The DEIS provides no analysis of expected Trend under
INCREASED use of the DEIS Alternatives.

SAC stocking rate (now Alt. 2) under MUD was 10,547 higher AUMs than
average actual use reported during the period. Yet, SAC AR at 54:
"frequency of key forage species had **declined** over the evaluation
period" - during the same period when actual use was low!

The numbers now proposed for livestock are the result of old
adjudication AUMs that were not based on reality, but only fantastic
claims by ranchers. BLM describes the SAC adjudication: "**Adjudication
was based on vegetation whether it was available or not". The DEIS
carries this forward in all Alternatives.**

SAC Carrying Capacity (AR at 54): "To determine the grazing/carrying
capacity, we commonly analyze the levels of utilization of key forage
plants in relation to actual use for the year ... when there is
insufficient actual use and/or utilization data to determine the
carrying capacity for an area, we often refer to earlier vegetation
inventories ..."".... Where BLM had "insufficient info", BLM said "we
had insufficient information ... the carrying capacity was based on **a
pre-evaluation forage inventory**. = BLM used old, stale data and no
systematically collected forage inventory data was presented as part of
the analysis. Thus, in no way can it determine the proper stocking rate
in 2006, as it relies on decades old data.

BLM describes SAC key areas: "a key area is a relatively small portion
of a unit selected because of location, use, or grazing value ... if
properly located, will reflect current grazing management over similar
areas in the unit". Nowhere is there a systematic examination of whether
or not each Key Area that BLM's flimsy out-dated data is based on is
"properly located". BLM has very few Key Areas, and even if each one was
properly located, it would be impossible to determine the condition of
habitats, watersheds, etc. from Key Area data alone.

Big Springs EA (AR 107) at 35 falsely bases its analysis of livestock
impacts on the claim that "livestock AUMs would decrease". Big Springs
EA at 38, claims this for impacts to Wilderness, too, "due to the
decrease in cattle". Well, under the DEIS Alternatives, stocking rates
would increase greatly above the average Actual Use.

Big Springs EA (AR at 107) "range" cumulative impacts -- BLM again
claims that it would implement a reduction in active use in examination
of cumulative impacts. Of course, that is not the case.

See Big Springs Response to Protest (we \[CHD, WWP\] assert Big Springs
-- use has been increased in Holborn, Lower Squaw Ranch, East Squaw
Creek, Windmill Seeding, Railroad Field. BLM's Big Springs MUD (now Alt.
2) significantly increased the stocking rate of cattle on lands with a
known concentration of sage grouse leks. The "Pre-Evaluation Stocking
Rate" for livestock in the North Pequop Mountain Pasture was 1866 AUMs
of "Livestock Permitted Use". However, the "Post-Evaluation Stocking
Rate" is 1168 AUMs (West Side) and 1244 AUMs (East Side), for a total of
2412 AUMs, an increase in stocking rate of 546 AUMs (AR No. 108 at 4).
BLM's AE Map, AR No. 95, at 7 reveals that 4 of the 9 leks known to be
located within the allotment occur in this North Pequop area, which also
contains important mule deer, elk and other wildlife habitats. AR No.
108, at Appendix Map 2 "Big Springs Allotment Proposed Projects Northern
Pastures" Map shows that two new projects \# 3 (new water location, i.e.
a well to be drilled) and \# 14 (a pipeline extension from the new well)
are proposed for this lek concentration area. These projects would
extend heavy or severe livestock use into previously less grazed areas
-- and result in extreme new degradation and habitat fragmentation, as
has occurred in association with other water developments throughout
these three allotments. Such impacts (and this increased use is present
under all Alternatives), no matter how BLM tries to gloss over them,
would be greatly harmful to sage grouse.

NDOW BS letter (AR 98) at 9 refers to this increase: "Data inferred from
individual pasture use indicates average actual use has been 10,827 AUMs
since 1987. If permittees were to stock up to the new proposed permitted
use, a 57% increase in actual use would be realized. Given the poor
condition of riparian habitats and the trend toward invasion of the
allotment by exotic forbs and grasses, we don't believe this allotment
can sustain this use without further resource damage. It is our opinion
that **data does not support any increase in stocking rates for the
North Pequop Pasture ...".**

**TREND/CONDITION/PRODUCTION/NO DATA**

Under the stocking rates and grazing management, not much is very
different from what is now claimed to be great changes in the DEIS:

BS MASR (AR 101) at 4. "... **there are only a few white sage plants
remaining**". USE against BLM photos.

BS MASR at 8 (AR 101): "heavy use was recorded at some key areas"

BS MASR at 8 "the recommended stocking rate was based primarily on
actual use and utilization data from 1997, 1998, and 1999". Yet, those
were exceptionally wet years! The same occurred with the Owyhee
allotment data on utilization. Thus, BLM's data cherrypicks bumper
production years, and in no way reflects the impacts of prolonged
drought.

BLM is required to **"enhance wildlife habitat to the maximum extent
possible**", so being content with a trend of "stable" at a depleted
site is not ok.

BS MASR AR 101 at 12: NDOW (AR 98) comment **"Summaries of Studies Data.
There appears to be a consistent lack of data in the use pattern mapping
and pasture production arena from which one can draw legitimate
conclusions".**

BS NDOW letter (AR 98) at 10: **data critical for an appropriate
analysis of current livestock grazing systems is lacking".**

BS NDOW letter (AR 98) at 8, BS MASR NDOW AR 101 at 14:" Pages 67-70.
Allotment Specific Objectives. **It is hard to believe that any
legitimate conclusions can be drawn from the small pool of trend data
which was collected within many pastures of the allotment".**

Owyhee NDOW letter. (AR at 72): describes habitat ratings that are
"**severely compromised**" because the same vegetative components were
not compared.

Owyhee AE at "Carrying Capacity Section" Appendix. The Dry Creek Pasture
is around half the total land area of the allotment -- see Map "Owyhee
Allotment and Land Ownership". BLM used 1991 data, so there is no
current data of any kind for half the allotment.

Grazing Schemes proposed by BLM do not require removal of livestock when
any utilization goals, stubble height, etc. is met. Thus, year after
year, degradation can occur. NDOW Owyhee letter (AR at 72): "our
experience has shown that rest rotation systems which do not include
specific stipulations on the removal of livestock follow\[ing\] the
achievement of utilization goals fail to obtain the veg. improvement
that they seek.

SAC MASR (AR 49) at 3: "the fact that 9 of 15 key area sites showed a
downward ecological trend, combined with the fact that several LUP and
RPS objectives were met does not provide a good argument for potentially
increasing livestock use on the allotment complex" ... **how does the
Bureau expect to meet LUP and RPS objectives in the future when any
reductions in livestock use are simply on paper and do not extend into
the field?".** As the woefully deficient EIS shows, BLM has ignored this
and all comments related to stocking rate.

MASR at 15. NDOW: "Since many of the allotment objectives were not met,
it would be beneficial to know what level of livestock use ..."
occurred.

Plus, BLM repeatedly claims its grazing systems will do great things --
yet Owyhee AMP, Big Springs (see Visser Memos), already has grazing
system or movements, and not season-long grazing in place, Yet, the many
ecological problems stem from grazing management not very different from
that proposed under the various Alternatives.

BS MASR at 2 identified MANY specific areas of concern over utilization
spanning pastures across the allotment: "Specific areas of concern
include use on white sage in the IV pasture, North Pequop mtn, Collar
and Elbow Pasture, Payne Basin Pasture, East Pequop Bench Pasture,
Shafter Pasture. Plus, concern with use of large-sized native
bunchgrasses -- bluebunch, Indian ricegrass (ORHY).

**DEPLETION**

Widespread depletion and desolation of vegetation amounts to
desertification. WWP commented and provided references demonstrating
that BLM needed to assess desertification (Sheridan CEQ 1981, Knick et
al. 2003, Connelly et al. 2004), as depletion of larger-statured
grasses, forbs, shrubs, or other important components of native
vegetation communities are critical to sage grouse, raptor prey,
migratory birds, and other important wildlife species, and are essential
to protect soils from erosion, help prevent weed invasions, etc.

Owyhee AE at 21, found "no" forbs at monitoring sites.

Owyhee AE at 22: "in 1994, forage production data indicated that forb
production was poor at OW-04 (Chimney Creek pasture) and nonexistent to
marginal (0.0% to 4%) at other key areas.

The same is found in almost all Owyhee AE Key Areas, Big Springs AE Key
Areas, SAC AE Key Areas -- a drastic depletion of forbs or productive
and larger-sized native bunchgrasses across the allotments, with serious
impacts to habitats.

Depletion and Sage Grouse: Owyhee AE at Table 3: "Summary of habitat
conditions for sage grouse in the vicinity of established key areas ..."

-   Perennial grass basal cover: **Not** **measured** at 7 of 9 Key
    Areas 94-96

-   At 2 of 9 Key Areas where it was measured as "recently" as 94-96,
    AY-T 6.7% and 5.8% on "unknown" species, and AY-1-03 total of 5.1%.

-   The last basal cover data at **7 sites** was under 8%.

These conflict with sage grouse habitat requirements.

How much worse have habitat parameters for important and special status
species gotten since this data was collected??? The DEIS provides no new
information whatsoever.

# SAGE GROUSE

BLM has claimed that the local SG Working Group plan has found livestock
grazing to not be a problem. This is of course dead wrong. However, if
BLM was to be believed, then these allotments are exceptionally
degraded. BLM's own findings in the Owyhee allotment found that grazing
was harming sage grouse habitats. This is also not consistent with the
science BLM uses (Gregg 1994) nor is it consistent with an abundance of
other peer-reviewed lit, and current WAFWA science, and Connelly et al.
2004.

Owyhee MASR at 20, in response to public comment on residual cover, BLM
responded: "**any proposed residual cover objectives are in conflict
with key upland species utilization objectives**". As the same
Objectives are carried forward under the various increased Alternatives
in the EIS, BLM has demonstrated that cow and sheep use trumps special
status species habitat requirements.

This is a violation of the Land Use Plans! This to illustrate what
drives the whole system -- cows and sheep and not inconveniencing
permittees. BLM's responses to WWP's comments and legal submissions have
consistently claimed any deviation from its MUDs would inconvenience
permittees. BLM ignores its own RMP protections and objectives for
special status species, FLPMA, and its own policies.

**Stubble Height**. SAC -- In areas where livestock are removed by March
31, BLM claims no problems for sage grouse. BLM ignores the science that
shows that sage grouse rely on **residual** grass cover **and**
sagebrush canopy cover. Sheep consume, break or trample both. Removal of
livestock does not ensure adequate residual cover, which is last year's
growth, and that is especially true under the high utilization levels.

Gregg et al. 1994. "information from other Oregon 1994 studies indicates
that ... and specific height and basal cover of understory vegetation
surrounding nest sites were factors that improved nest success".

Owyhee AE at 24: "Basal cover of all perennial grass species encountered
during monitoring that do or do not potentially allow at least a
seven-inch height of residual growth, where measured, ranged from 1% to
6.7%". This means there were VERY FEW larger sized native grasses
remaining, indicating depletion of the site.

This demonstrates that the composition of larger-sized grasses is very
poor, and much below levels that science shows are needed for sage
grouse nesting, or broodrearing habitats.

AND: "from 1994 to 1997, "average **forb composition ranged from none to
12.9% and would be considered a limiting factor ... at most key
areas**". YES, indeed as: Owyhee AE at 22: "in 1994, forage production
data indicated that forb production was good at OW-04 (Chimney Creek
pasture) and nonexistent to marginal (0.0% to 4%) at **all** other key
areas. Owyhee AE at 25: "Key Areas where "monitoring has indicated forb
composition is a limiting factor" ....

Owyhee AE at 24: "Ocular surveys ... indicated that livestock-accessible
riparian areas potentially used by sage grouse are characterized by
heavy grazing, lowered water tables, **severe** erosion, and loss of
plant species associated with moist soil profiles" ... riparian areas in
poor condition would be considered a limiting factor in
brood-rearing/summer habitat since they are major foraging areas as the
summer season progresses".

Owyhee AE at 24, discussion of Key Area near lek and Silver Lake
(vegetated playa), describes **concern** about potential excessive
utilization of native vegetation ... Improper use ... could affect range
site dynamics and allow decreases in perennial native grass and forb
species, and mosses, and increases in annual vegetation".

Under all of BLM's DEIS Alternatives, numbers of livestock greatly in
excess of those grazed in the past would be stocked on these depleted
areas.

*The extraordinarily limited* data in relation to sage grouse or other
wildlife species is illustrated by Owyhee AE at 41-42: There is only one
Key Area in the allotment where evaluation of veg. near any leks
occurred. And, at this Key Area, there was **concern** about potential
excessive utilization of native vegetation .... Improper use ... could
affect range site dynamics and allow decreases in perennial native grass
and forb species, and mosses, and increases in annual vegetation". "AE
at 42: "**this site is highly susceptible to disturbance as indicated by
low densities of cheatgrass and high composition of povertyweed ...**
NRCS description ... when management results in abusive livestock use,
Nevada bluegrass and mat muhly decrease as povertyweed and other annual
forbs increase in composition".

BLM's management response to its own analysis? Dramatically increase
stocking rates above the very use levels that had caused these problems
in the past - under all alternatives in the DEIS.

**RIPARIAN**

BLM's Own Spring Developments and Rangeland Projects Are Cause of
violations of rangeland health standards, and the cause of
Functioning-At-Risk and Non-Functioning NF condition, so BLM claims that
"developments" and projects will improve conditions are false.

Big Springs EA (AR 107) at 32: re: springs: "the areas assessed as FAR
or NF "were rated as such mostly due to livestock use **and water
development**".

Owyhee EA at 30: Under the NAA: "hot season grazing would continue in
accordance with the 1987 AMP. "Hot season grazing would continue and
even if it would include rest every other year, it would not allow for
recovery of stream and riparian habitats". BLM perpetuates harmful hot
season grazing in this manner in the Big Springs and Owyhee allotments.

Owyhee AE at 24: "Ocular surveys ... indicated that livestock-accessible
riparian areas potentially used by sage grouse are characterized by
heavy grazing, lowered water tables, **severe** erosion, and loss of
plant species associated with moist soil profiles" ... riparian areas in
poor condition would be considered a limiting factor in
brood-rearing/summer habitat since they are major foraging areas as the
summer season progresses".

# 

# Riparian Protection Criteria What BLM terms "protection", is very often actually development - and photos (BLM's, WWP's), and NDOW comments show that past developments have resulted in failures -- and complete nonfunctionality of these rare spring oases. See discussions of the "NON-functional projects in Big Springs, and BLM's photos of developed springs in SAC and BS in the AR.

Photos of Spring Developments: Big Springs AR in loose binders:

Upper ?acon Spring (developed troughs, muck, labeled #71).

#74 spring is ALL developed, with muck, shown on two sheets,

#80 ALL pipe visible

#82 Middle Fork E. Squaw, several sheets, mainly developed

#83 E. F. Squaw. Developed

#110. Developed?

#111. Developed.

#116. Developed.

BS NDOW letter (AR 98) at 8: "BLM identifies 25 springs/seeps/ponds
within the allotment and admits that 13 are nonfunctional and that four
are at risk of not functioning (68%) \... reasons states are **livestock
grazing feral horse grazing, and/or water development design**". NDOW
then stresses importance of riparian oases, and BLM's plans to improve
only 5 to good or excellent condition are unacceptable. .

BS NDOW letter (AR 98) at 9, "Data inferred from individual pasture use
indicates average actual use has been 10,827 AUMs since 1987. If
permittees were to stock up to the new proposed permitted use, a 57%
increase in actual use would be realized. **Given the poor condition of
riparian habitats and the trend toward invasion of the allotment by
exotic forbs and grasses, we don't believe this allotment can sustain
this use without further resource damage. It is our opinion that data
does not support any increase in stocking rates for the North Pequop
Pasture particularly from a riparian condition standpoint ...".**

BS NDOW letter (AR 98) at 9: "no more than 50% use on herbaceous
riparian species or 4-6" stubble height remaining in **all** riparian
habitats ... once objectives are met, cattle would be moved". vs. BLM -
only some areas it claimed 4" end of season oon riparian areas would
occur, but 4 " was not met, and was not a use trigger.

BS MASR NDOW "Of extreme concern is the state of existing riparian
habitats in the BS allotment ... most areas are heavily impacted by
grazing and developments. Only 23% of the springs on the allotment are
in PFC. " ... to provide suitable habitats ...improvement of these
riparian areas must be a priority. ...the Bureau must examine all
developed springs to see if they can be modified to recreate historic
stretches of riparian habitat.

BS MASR NDOW AT 13: All 17 springs, that are not PFC, should be
**improved to good or excellent condition within three years ...
redesigned \... improved management of livestock** .

Owyhee MASR (AR 75) at 10, BLM claims: "riparian habitat problems on the
SFO in the Star Ridge and Lower Four Mile Pastures area function of
**season of use**". Yet, BLM did not develop a range of alternatives
that would restrict or alter season of use, and instead relies on
increased stocking rates and harmful livestock facilities that will
destroy critical sage grouse and raptor habitats in uplands.

NDOW: "rest rotation seasons that do not include specific stipulations
for **the removal of livestock follow \[ing\] the achievement of
utilization goal levels fail to obtain** the veg. improvements they
seek".

Owyhee EA at 17: recognizes "reductions in grazing on floodplains would
lead to an improvement", yet BLM increases stocking rates on flood
plains under all DEIS alternatives.

Big Springs EA at 13-14" -- only in North Pequop Mtn. Pasture (EA at
12), and Squaw Creek Ranch Field (EA at 13).

BLM did not systematically assess the condition of Fourmile Creek,
Winters Creek, Chimney Creek, Threemile Creek and other intermittent
drainages and playas in the Owyhee AE. This has not been done in the
EIS, and maps do not even show some of these drainages. In order to
understand impacts of its actions, it was essential for BLM to assess
these critical sage grouse brood rearing areas and raptor and special
stats species habitats.

Livestock concentrations and other impacts to playas have been
documented concerns in the Owyhee allotment, with threats of heavy to
severe grazing in vicinity of playas. BLM has conducted **no systematic
assessment** of the health of these important and unique areas and
habitats for sensitive species and raptor prey . Under the EIS
alternatives, stocking rates will be increased above past actual use on
all playa areas.

Owyhee AE at 14. Dry Creek pasture -- "moderate and heavy use" --
Chimney Creek, Threemile Creek (intermittent). Chimney Creek pasture:
Fourmile Creek (intermittent).Upper 4-mile Pasture: "heavy use along
Fourmile Creek". Lower 4-mile: "heavy use in one year. Winters Creek
seeding: "heavy use along Winters Creek (intermittent)". These all
contain mesic areas important to sage grouse brood rearing.

SAC Riparian PFC Assessments -- for Tunnel Spring, Rock Spring, Spring
Gulch Spring, Sidehill Spring, Blue Lakes Spr9ing, Little Mud Spring,
Felt Spring, Serviceberry Spring, Perkins Spring -- all were done on
6/02/99 (SAC AR 161), long after winter sheep use tracks would not be
evident. Thus, BLM had no monitoring data to show whether or not
domestic sheep grazing was impacting these areas, but instead blamed it
all on horses.

SAC AE 41: Notes **"more than 26 springs and seeps**". Yet the AE at
42-43 describes assessment of only 8 of these. Despite being required to
evaluate the impacts of grazing to all riparian areas and special status
species habitats, BLM ignored this, and wasted taxpayer dollars with a
flawed and incomplete analysis.

SAC AE at 65. UT/NV #1 allotment. This described 14 other springs
(**unassessed**) in similar topography with similar uses. Nowhere does
the EIS present any information on these riparian areas.

Owyhee EA at 19: BLM recognizes that "increases in growth and
establishment of herbaceous and woody riparian vegetation along the SFO
would improve its ecological condition", and describes healthy riparian
zones. EA at 21: describes harms of "hot season grazing" -- "tends to
result in overuse of riparian areas as uplands become desiccated and
water sources become limited" at 23 "soil compaction is greatest when
soils are moist". Well, BLM allows hot season grazing to continue on
other riparian areas in the Owyhee and Big Springs allotment under the
DEIS, and there is no certainty, with the extreme flexibility, of any
controls on season of use.

# SCIENCE

Even the very lit. BLM relies on includes Gregg et al. 1994.
Vegetational cover and predation of sage grouse nests in Oregon. Journal
of Wildlife Management. 58 (1):162-166. This supports 7-9" of residual
(last year's) cover for sage grouse, which can only be achieved under a
much more conservative stocking rate and utilization levels of 25% or
less, that should form the basis of all DEIS alternatives. Plus, it is
critical that lower use levels, as well as lower browse
use/nipping/breakage standards on all shrubs be required under
alternatives to protect remaining better condition communities and
important and special status species habitats. Under BLM's high use
levels, largely carried forward in the DEIS, and to be intensified even
more under high stocking rates, grazing has caused weed invasion, and
grass, forb and sagebrush, winterfat and other shrub decreases or loss.
These are critical habitat components for the important ad special
status species.

SAC MASR at 2. **"Viable management decisions can not be made until
current surveys ensue"**. These surveys were NOT conducted in the AE
process, or in the DEIS. BLM knows it can not make viable management
decisions until it conducts necessary current baseline surveys.

NDOW describes habitats as "critically important" to the long term
health of the ferruginous hawk and golden eagle nesting populations
(NDOW comment letter of September 5, 2000).

# NO TERMS AND CONDITIONS TO LIMIT USE OF VEG

In the permits, there is no Term and Condition of the permit that
requires permittees to meet ANY utilization level identified in the EA -
or RMP - or any other docs. Yet, in

Owyhee MASR at 23: BLM states: "the Elko RMP/EIS contain the needed
elements for site specific analysis, i. e. **specific levels of
livestock use are identified**, forage conditions are projected into the
future, specific range improvements are identified, and the related
impacts of these proposals on other resources are specifically
analyzed.".

"The Elko Rangeland RPS further refined the degree of allowable use to
an objective level not to exceed 50% utilization on key native forage
species" (Owyhee MASR at 21).

Big Springs (EA at 11, for example) was full of promises of %
utilization -- yet this was not part of Terms and Conditions, and is not
in the DEIS, so there is NO requirement that ANYTHING will be met.

**BLM PHOTOS**

BLM Response Brief photos of Independence Valley Pasture Key Area, KA-01
demonstrate weed problems, ignored and covered up by BLM throughout this
process.

Big Springs FMUD (AR 108), Appendix 1, (unnumbered page 2) discussion of
Allotment Specific Objectives for **KA 01**: "maintain or improve the
ecological condition rating of this shallow calc. loam". Revise the
frequency trend objective to read "maintain or increase the percent
frequency of Indian ricegrass and the needlegrass component". " This
ecological site is normally dominated by black sagebrush, Indian
ricegrass, and needle and thread grass, with white sage being a small
component. However, the percent composition of white sage at this key
area is at least twice as high as the percent allowable in a range site
description; therefore increasing white sage will not improve the
condition rating. To increase the condition rating significantly, Indian
ricegrass will need to increase" The percent composition for Indian
ricegrass that is allowable is 35%; however it currently represent
**only 2%** composition by weight, whereas both black sagebrush and
rabbitbrush exceed the allowable composition".

BLM admitted that its Key Areas in BS didn't accurately or adequately
reflect/track conditions/trends. Big Springs FMUD, Appendix 1 (AR 108)
at 3. For Key Areas 4306-03 and 04 and 06: "delete the condition and
trend objectives ... develop condition and trend objectives for the
proposed new key areas following collection of baseline data ...
**Rationale: "the establishment of new key areas will better represent
the highly preferred forage grasses in areas that are preferred sites
for livestock grazing in this pasture. The existing key areas have not
received consistent use by livestock and/or the studies didn't capture
the highly preferred key forage species". Thus, BLM's whole carrying
capacity analysis, that uses Key Area Utilization, is bogus and INVALID.
This flawed and extremely limited data is carried as the basis for
stocking under all DEIS Alternatives!**

This demonstrates that to understand impacts to habitats, BLM needed to
collect new systematic vegetation, soils, watershed, habitat, etc. data,
and it has not done a thing for this EIS. New Fundamental of Rangeland
Health Determinations also need to be made.

Of Upland Key Areas:

Key Area 4306-2 "this area has been disturbed in the past and now
support only rabbitbrush along with a small amount of wildrye \... the
community won't change significantly as along as rabbitbrush dominates.

Then, "delete KA objectives for THREE sites": 4306-03 and 04 and 06.

4306-5: "the previous objective called for significant increases in
bluebunch wheatgrass, Thurber needlegrass and western wheatgrass." But,
there was very little blueunch wheatgrass left over the period of the
evaluation, so BLM now essentially forgets about bluebunch, and revises
focus on others. This demonstrates depletion over "recent" time -- just
like SAC Key Area data in AE. Thus, this is **NOT HISTORICAL**
depletion, as BLM repeatedly claims, but ongoing and chronic depletion
under the Actual Use that occurred in the past.

4306-19. Key area was burned twice in the 1990s, and area was seeded.

SAC AE Tables 11-18 at 21-27 shows that Key Area declines in Indian rice
grass, winterfat seen in Leppy Hills, UT/NV 1, Lead Hills, White Horse,
Sugarloaf, Ferber Flat, West White Horse allotments.

SAC AE at 33-35. **Pronghorn Habitat** is plagued with **"poor forage
diversity**" -- Leppy Hills, UT/NV#1, Lead Hills with "poor forage
diversity, White Horse "poor forage diversity", Sugarloaf "poor forage
diversity", Ferber Flat "poor forage diversity", West White Horse
--"poor forage diversity", Boone Springs "poor forage diversity". (These
are also areas where vast cheatgrass weedlands are known to occur. As
examination of data sheets shows:

Leppy Hills KA-1007 1988 ORHY 33% frequency to 1999 5% frequency, and
winter fat (white sage) 1988 - 39.5% to 1999 - 23% .

Despite these large-scale depletions, and losses, BLM's only response is
to develop an EIS that examines increased stocking rates greatly above
average actual use under all alternatives, and apply very high
utilization and browse levels.

**PROJECTS/FRAGMENTATION**

In the Big Springs FMUD Response to Protests, BLM claims "the completed
EA for \[Big Springs\] FMUD analyzed the impacts of projects "**at the
activity plan level**". Since this was not adequate, BLM needed to do
this in the EIS, and of course has not done so, Only the sketchiest of
information is provided.

Plus, BLM pays lip service to cleaning up past project junk -- yet never
guarantees that it will do this.

Owyhee AE (AR 68 at 25): "**man-made structures near lek areas have been
identified ... High Risk Assessment** for sage grouse include fences,
pit reservoir berms, corrals that serve as perches/rests for avian
predatory species, and vertical structures that could limit vision of
sage grouse or act as intimidating factors ... These structures exist
near several leks on the allotment ... sage grouse fly low and direct in
their habitat, at, or just above standard fence heights. Mortalities
have been documented ...".

Owyhee AE (AR 68 at 42). "Manmade structures near leks. Repeats High
Risk Assessment ...

AE at 65 "recommendation 4": complete actions to mitigate effects on
wildlife resources ... predatory bird proofing, visually outline
objects, etc.

NDOW Big Springs letter (AR 98 at 9): 'The Bureau has developed a series
of elaborate systems to accommodate continued livestock use at current
or increased levels. It has been our experience that **the more
complicated the grazing system, the less likely it is to be followed"**.
MASR NDOW at 14. -- NDOW: Harmful impacts of fences: "we would be
opposed to any permanent fence structure running along the crest of the
Pequop Range due to conflicts with big game movements".

# SOILS

BLM has tried to argue that its limited or old, utilization, actual use
data somehow translate into an assessment of soil health. The truth is
that it has no data on soils and their health.

As several species of raptor prey are burrowing mammals (ground
squirrels, kangaroo rats), direct impacts of trampling, soil compaction,
burrow collapse, etc. must be assessed.

Standards and Guides. Upland Sites. Soils exhibit infiltration and
permeability rates that are appropriate to soil type, climate and land
form. BLM provides no sampling methodology (not even a map of soils),
various erosion hazards, etc. that examines and systematically samples
various soil types across the allotments. BLM provides no information of
any kind on infiltration and permeability.

Plus, BLM tries to argue that it's extraordinarily limited - and
acknowledged-to-be inappropriate, sites in the BS allotment (see
preceding discussion of **inappropriate Key Area** sites) are sufficient
for FRH evaluation of soils. These are NOT sufficient for determining
the condition or health of soils or microbiotic crusts under the Taylor
Grazing Act, FLPMA or the FRH. Plus, photos BLM submits of BS Key Areas
illustrate that soils are largely unprotected from both wind and water
erosion. The weedlands of SAC provide poor soil protection. Large fires
have de-stabilized Owyhee soils, on top of livestock impacts.

Yet, BLM provides has NO systematically collected information on soils
across the allotments that would allow it to determine soil and
watershed health, and the condition of habitat for burrowing mammals
(raptor prey) as well as burrows used by burrowing owl and pygmy rabbit.
This is essential too for determining wind and water erosion hazards,
etc.

# HORSES ARE NOT THE PROBLEM

7/26/94 Gallegos Memo in the SAC: There was **little sign of horse use
at several springs**. Rosebud, Summit, Mud, Felt. Plus, if springs are
trashed by horses, they should be doing it in the summer. If sheep can't
get to springs in winter, don't expect horse use then, either.

NDOW AR at 44 (SAC): " ... although there is evidence of damage done by
horses, we have also documented significant damage by domestic livestock
on Perkins Spring in the Boone Springs allotment".

BLM PFC assessments occurred as one point in time - nearly a decade ago
during summer period, and never examined sheep use periods.

> Lococo letter, (AR at 73) at 3-4: Actual use of AUMs in the three
> Owyhee pastures that support horses was:

-   Dry Creek pasture -- 89% cattle. 8% horses;

-   Chimney Creek pasture -- 95% cattle, 5% wild horses;

-   Star Ridge pasture -- 89% cattle, 11% wild horses.

This demonstrates that cattle and/or sheep are the overwhelming
disturbance and degradation agents across these lands.

SAC -- Old Developments: AR at 161, 0003 (Tunnel), 0004 (Rock), 0005
(Sidehill).

SAC AR 161, 0006 -- 7/26/94. Gallegos Memo. **Mud** Spring -- "spring
doesn't appear to be getting a lot of wild horse use", **Felt Spring**,
"some light horse use", Serviceberry -- dry - **no horse use.**

SAC AR 0008 -- Felt PFC was Functional at Risk. 0008 -- with cheatgrass.
This demonstrates how BLM over-estimates the condition of springs.

0006\. Notes "old posts and barbed wire", evidence of past, failed
projects at springs.

# BLM HAS FAILED TO ASSESS IMPACTS OF PRIVATE LAND

IN response to WWP Photos in Declarations in Briefs (taken in the
Independence Valley in 2005), BLM claimed that some photos used to be
private land. All lands over the vast area on the east side of the
Independence Valley where photos were taken are managed as a whole.
Fences do not separate BLM from private lands. In fact, a distance of 20
miles north-south from the I-80 in the IV area of the Big Springs
pasture, lands are managed as a whole.

BLM has also ignored important BLM riparian areas. BLM claimed that
Independence Creek is "private". BLM land status map copy "Map 1 East
West Division" shows reaches of Independence Creek, including where
photo was taken, as BLM Lands.

BLM has never systematically assessed and studies the Suitability and
Capability of all lands acquired in the BSR land exchange for livestock
grazing. It has not been allocated or adjudicated properly under the
Taylor Grazing Act.

# CURRENT GRAZING DEPLETION

As evidence that 1) Things are depleted, and 2) Current livestock
grazing  - not historical - is a cause, an examination of BLM\'s
Long-Term Objectives, and Key Area discussions shows, for example:

 

SAC Complex FMUD, Appendix 1: Long-Term Objectives for Upland Key Areas:
Most of these set a goal to **increase % frequency of ORHY** (ricegrass)
or other perennial grasses, and show how low the current composition of
ORHY is at Key Areas.

 

Big Springs FMUD, Appendix 1: Long Term Objectives: Most of these set a
goal to improve. Plus**, key species described here that BLM is supposed
to be managing FOR, are all larger sized native bunchgrasses** - to
counter BLM claims that the grasses (made in relation to why Nevada
doesn't have to follow best Available Science on sage grouse) can\'t
grow to 7\".  (Note: in the case of BS, these appear to be the same as
the previous Long-Term objectives, and they are just being carried
forward. It it has been part of BLM\'s Long-Term plan to improve these
larger stature grasses - so all is not the fault of \"historical\" use. 

The preceding shows that the limited info that BLM collected in the past
demonstrates large-scale problems of habitat loss and depletion across
the allotments under the Use that occurred in the past. It also
demonstrates BLM has ignored its own findings, and degradation that is
widespread, and instead seeks to continue wildly unsustainable livestock
stocking rates and management schemes across the important wildlife
habitats of these allotments. This will cause undue degradation.

A Supplemental DEIS must be prepared that accurately reflects current
conditions and develops management that protects important and special
status species habitats and populations, and other wild land values.

Sincerely,

Katie Fite

Biodiversity Director

Western Watersheds Project

PO Box 2863

Boise, ID 83701