June 10, 2005

Mr. Dave Rosencrance

Field Manager

Challis BLM

801 Blue Mountain Road

Challis, ID 83226

RE: [Morgan Creek Water Developments EA, including Watts Spring Pipeline
Reconstruction and Ellis Creek Pipeline Construction AND Pahsimeroi
Water Developments including Yribar Pipeline Supplement, Poison Springs
Pipeline, Bert Springs Pipeline, and Squaw Creek Pasture Water
Developments]{.underline}

Dear Mr. Rosencrance,

WWP requests to be kept fully informed of actions that may occur, and
opportunities for further public involvement, and of the final
decisions, in regards to the above listed projects.

WWP hereby incorporates by reference all of our previous comments
submitted to you over the years on the Morgan Creek allotment, recent
comments on the Hat Creek, Dry Creek and other rangeland health
assessment processes and EAs, comments and litigation over the Burnt
Creek allotment, and comments on numerous grazing allotments and our
documentation of degraded conditions in the Upper Pahsimeroi watershed.

First, we are puzzled that BLM is proposing such large-scale projects
before finalization of an EIS or new grazing assessments for many of
these lands. In addition, there are other processes being conducted by
the Forest that may have bearing on these watersheds, such as analysis
of diversion effects, and other components of the public lands in these
watersheds.

The Salmon-Challis Forest, in its recent SOPA, likewise proposes a gamut
of harmful spring and other livestock projects. It is time for a
much-needed comprehensive, landscape-level look at the impacts of
livestock grazing, fences, spring developments and water diversions to
the irreplaceable resources of the public lands; the suitability,
capability, productivity and carrying capacity of BLM lands; the
inter-relationship between Forest and BLM lands; the relative scarcity
of resources such as intact pygmy rabbit habitat, scarce natural
springs, wetlands and wet meadows, other projects being proposed, such
as in the Sage Grouse Working Group newsletters, etc.

WWP is concerned that the BLM is proposing a large number of spring
developments, pipelines, fences and associated projects without
considering the impacts of these projects in the context of the whole
allotment or the larger watersheds or landscapes. BLM cannot simply
implement these projects piece meal without consideration of the direct,
indirect and cumulative impacts of both existing projects and facilities
(fences, springs, stock ponds, pipelines, troughs, corrals, salt and
mineral placement sites, etc.) on native biota, watersheds, riparian
areas, important native plant and animal species, recreational and other
values of the public lands. Such a comprehensive and integrated view is
essential in a landscape where, for example, constructing a livestock
trough system ostensibly to protect bull trout streams may permanently
alter and destroy pygmy rabbit habitat due to intensified and shifted
livestock use. WWP also believes that consultation under the ESA is
necessary to understand the watershed-level impacts of existing and

now these proposed facilities, and the interaction with
watershed-degradation,

has never been conducted for the SC BLM or Forest lands.

If the BLM persists in its proposal to construct an array of new
projects as proposed in the recent mailings a separate EIS (or series of
EISs) to address site-specific impacts, will be required.

BLM must adequately assess and evaluate the current condition and health

of all riparian areas, wetlands, meadows and springs in the affected
areas of

the allotments where these projects are proposed. BLM's continued spring

development and pipeline construction will, if it hasn't already, result
in the development of nearly all the natural upland springs in an
allotment or watershed. Additionally, many past spring development and
trough projects have caused severe diminishment of water

flows, even total loss of surface flows - in developed springs. In
addition,

development of upland springs may cause flows to diminish in downhill
springs,

or in streams essential to native fish species. Many existing spring,
pipeline

and trough projects are in shambles and do not function properly. This
is

demonstrated in WWP's report to the adjoining SC Forest of the Spud and
Marco Creek

allotments. Spring, trough and fence developments are also causing
shifted and

intensified livestock use - for example, where exclosures are
constructed

around a spring and a trough constructed outside, and livestock use is

intensified on remaining unexclosed riparian areas, and on fragile
upland

communities.

BLM must conduct a full inventory and assessment of the location,

condition and characteristics of all spring, seep and wet meadow areas,

including historically wetted sites, that may be affected by the
projects or

shifts in livestock or other uses. The Forest must study the role of
historic

and ongoing/chronic livestock grazing and trampling activity (and other

disturbances such as roads) in altering, degrading or desiccation of
these

scarce sites. The inextricable link between the health of intermittent

drainages, springs, seeps and wet meadows and the health of entire
watersheds

must be addressed. A full suite of restoration actions for damaged,
degraded or

diverted riparian areas must be assessed under all alternatives
including an

array of passive treatments, such as stubble heights on all riparian
areas,

ample rest to jump start recovery of uplands and riparian areas, or rest
until

recovery followed by limited grazing in areas found to be suitable.

Despite the damage the agency has caused with the construction of
livestock

facilities in the past, the Forest proposes to develop and irreversibly
alter

even more fragile springs, and ignores the health of spring systems
across the

allotments and on adjacent or surrounding lands.

Springs are "hot spots of biodiversity in arid lands.\" 75 percent of
505

springs surveyed by Sada in northern Nevada were highly or moderately
disturbed

(Sada and Herbst 2001), and our continued observations in the Upper
Pahsimeroi and lands in the morgan Creek and nearby watersheds support
those of Sada. Degradation of springs in the Great Basin and Challis BLM
lands is widespread.

Their isolation and small size render many spring communities
particularly

vulnerable to disturbance and loss. Upland springs in the BLM or Forest
lands are often

isolated and small in size. "The continued development of springs for
livestock

by ranchers and state and federal agencies also poses a threat to the
continued

existence of spring biota". These actions typically involve fencing off
an area,

immediately adjacent to springs, piping most or all of the water off the
site to

livestock tanks.

Livestock grazing (especially trampling damage) also poses a serious
threat to

spring communities and interfacing uplands. Livestock trampling reduces

substrates to mud, can completely eliminate vegetation, alters flow

characteristics, and runoff from watershed (rapid instead of slow
release from

watershed).

Sada and Pohlman (2003) provide a series of protocols to be followed to
assess

spring conditions. Given the importance of upland or headwater springs,
and the

extreme damage to them that has been caused by livestock grazing and
other

disturbance, and existing ill-designed or damaging developments that may
kill

all natural water flows at spring sources, the Forest must consider a
broad

range of actions aimed at restoring, not destroying, more springs.

In order to determine the feasibility in order to determine the
feasibility and

ecological impacts of placing spring and trough developments and fences
in the

various watersheds, the Forest must conduct detailed monitoring. This is

essential because the Forest Service has failed to conduct any detailed

monitoring of these areas to date. Such monitoring and data collection
includes,

but is not limited to: locate and provide reconnaissance level
characterization

of ALL springs in affected watersheds; delineate important species
distribution

and salient aspects of habitat, and unique circumstances/challenges;

qualitatively sample riparian and aquatic communities to determine
community

structure; quantitatively sample salient physiochemical elements to
identify

aquifer affinities; and quantitatively sample to determine aquifer
dynamics;

sample riparian and aquatic communities and habitats to determine
spatial and

temporal variation in environmental and biotic characteristics, and to

quantitatively determine biotic and abiotic interactions. After
identifying and

characterizing all sites, the Forest must follow this with surveys that
fully

assess the ecological setting, and the effect of management and
livestock use

and other uses. This must include collecting information necessary to
assess the

extreme importance of springs and the continuum of hydric and mesic
vegetation

communities in their vicinity to sage grouse, especially in providing
essential

summer brood rearing habitats (green forbs); to migratory birds
(deciduous

shrubs and trees); and many other important attributes vital to other
native

animals. In addition to all the important issues raised for
consideration, the

importance to sage grouse and other wildlife must be fully considered.
We

believe this elevates ALL spring areas here (especially since so much
damage -

including harmful development - has been allowed to occur, and the
potential at

many sites so greatly reduced) that ALL springs, seeps, wet meadows here
are

worthy of restoration to whatever potential can be achieved.

BLM must also conduct studies of all desiccated, dried up, or otherwise

altered springs or wet meadows, and develop plans for restoration of
riparian

area structure (to historic areal extent of wetted area, healthy and
fully

functioning native vegetation components), and historic flows. The
benefits of

restored or more natural springs to native species must be assessed. For

example, what are the characteristics of a riparian community
sufficiently

restored to support nesting yellow warblers or Cooper's hawks in the
vicinity?

BLM must also study all intermittent and ephemeral drainages, as well.

Often, water not only persists in intermittent and perennial drainages
in

pockets as a result of runoff, but seep, spring and mesic areas may be
present,

and interspersed along the length of drainages. Erosion, downcutting and
lowered

water tables stemming from chronic livestock grazing degradation is
often a

primary cause of perennial reaches becoming intermittent. The Forest
must also

determine if stock ponds or other livestock facilities have been

built/placed/gouged into or on top of spring, seep or meadow areas.
Restoration

potential must be assessed, and plans must be developed to restore such
sites

and increase perennial flow under all alternatives.

BLM must also assess geological attributes of springs. Spring sources
may

include Aquifer sources where springs are supported by precipitation
that seeps

into soil and accumulates in aquifers, through fault zones, rock cracks,
or

orifices that occur where water creates a passage by dissolving rock,
where it

is then stored. The hydrology of springs is affected by regional and
local

geology, and how water moves through an aquifer. Each spring and seep is
a

unique combination of physical and chemical conditions (Sada and Herbst
2001,

Sada and Pohlman 2003). These, coupled with disturbance factors, are
dominant

influences on riparian and aquatic plant and animal communities. Highly
modified

springs have less diverse riparian communities, and may include
non-natives, and

upland-associated species. Plant and animal communities associated with

spring-fed wetlands are a function of physical and chemical
characteristics of

water and soils, proximity to other aquatic habitats, and prehistorical

connections with regional drainage systems (Sada and Herbst 2001, citing
Hubbs

and Miller 1948, van der Kamp 1995, McCabe 1998). Primary abiotic
factors that

influence biotic qualities of unmodified springs include habitat
persistence,

geographical and geological settings, and aquifer dynamics Sada and
Herbst 2001

(citing Ferrington 1995, van der Kamp 1995). Springs have a more
integral

connection with ground water than streams (Sada and Herbst 2001).

Many aquatic species have suffered population losses and 62 percent have

suffered major decreases because of channelization, impoundment,
removing water

and the introduction of non-natives in to spring and spring brook
systems in the

Great Basin (Sada et al. 2003). Our review of many Idaho Forest and BLM

documents lead us to believe that in many instances, the majority of
Idaho

springs and springbrooks have suffered similar impacts -- especially
those in

areas where grazing occurs. Removing water from springs through
diversion

reduces habitat for vegetation and aquatic biota by decreasing
springbrook

length, water width, water depth, and quantity of water available for

vegetation. Groundwater pumping and surface diversion have decreased and
dried

up many springs and springbrooks in the arid West, causing loss of
populations

and extinctions.

Riparian vegetation at springs may be restricted to the area just along

immediate boundaries of aquatic habitat, or may extend outward over much
larger

areas. Wider riparian areas occur where water seeps outward and moistens
hydric

soils. Certain aquatic species may be restricted to spring sources.

Rheocrene-inhabiting species are more similar to stream-inhibiting
species, and

limnocrene species to lake or pool inhabitants. Springs tend to be more
constant

environments than other aquatic habitats.

Spring size and habitat conditions influence biodiversity of springs
(Sada and

Pohlman 2003, citing Sada and Nachlinger 1996 and 1998), with different
species

inhabiting spring sources than downstream reaches/springbrooks.
Ephemeral

springs and seeps with harsh environments may have fewer species.

Spring-fed riparian habitats are of great importance to wildlife species
for

roosting, food, and shelter. Higher quality springs have high structural

diversity created by a dense undergrowth of tangled vegetation and
debris. This

vegetation may be reduced by diversion, burning, vegetation control and
grazing,

so suitable habitat is eliminated or degraded, with the result that the
songbird

nest parasite brown-headed cowbird can more readily invade and
parasitize the

nests of migratory birds. Migrating birds may use spring waters to
drink, and

vegetation and insects associated with springs to refuel. Migration
stresses may

cause insectivorous and frugivorous bird species to drink. Plus,
granivorous

species are more dependent on water. Birds are vulnerable to predation,
and seek

watering sites with greater tree and shrub cover. Areas with larger
intact

riparian vegetation may attract more migrants, and thus provide more
prey for

raptors such as Cooper's hawk.

A spring creates a continuum of soil conditions from wet to moist to
dry, each

harboring plant and animal associations adapted to those habitat
conditions.

BLM must systematically inventory native fauna present in and near

springs, seeps and springbrooks, as well as flow characteristics, over
at least

two years. As an example of breeding bird inventories (that should also
be

performed in the full spectrum of vegetation communities across a range
of

ecological conditions in the allotment), see Red Willow 2004,
"Pinyon-Juniper

and Juniper Birds". In this two-year study, breeding bird surveys were
conducted

in and near riparian habitats primarily in forested (pinyon-juniper) and

interfacing big sagebrush communities, which are typical - though
different

conifers - of much of the vegetation in watersheds supporting springs in
the

project area.

Aquatic biota must also be assessed. Sampling for invertebrates must
include

collection from all habitat types within a spring (spring, springbrook,
degraded

reaches, any undegraded reaches). All springs within the project area
must be

sampled for invertebrates. The link between the condition (health) of
the

watershed and the functionality springs and springbrooks must also be
assessed.

BLM must research and present to the public in detail any existing
information on spring characteristics flow rates, aquifer depletion, the
BLM and the Forest's own records and project files regarding any spring
or other developments, any water rights filings, any water rights
surveys done by the Forest, BLM, state lands, private interests, etc.
BLM should also research any water rights filings by other parties on
spring flows, or any waters where diversion/drilling/depletion may
affect flow rates from springs in the project area (which includes other
nearby lands important to special status species

here, or to which springs may be linked).

BLM must provide detailed descriptions of past projects on affected

watersheds, and these and surrounding allotments. How many springs
remain

undeveloped (vs. developed)? What are their characteristics (as
described above)

vs. those slated for development? Agency promises made during past

authorizations, funding agreements, NEPA, etc. for springs, fences and
other

projects must be fully described, and an assessment made of current
conditions

compared to conditions that existed, and promises for projects that were
made in

the past. This is necessary to understand all direct, indirect and
cumulative

impacts of actions affecting spring flows, health and hydrologic
integrity. BLM must describe spring provinces/complexes/clusters, also.

What type of spring is it? What functional changes or changes in
biodiversity

have occurred? How can function and/or biodiversity be restored? What
are flow

rates throughout the year under drought or normal conditions? What is
the

current areal extent of wetted area vs. historical? (Examine soil
profiles and

characteristics, remnant plant communities, etc.). What vegetation would
be

present in an undisturbed site? What is the potential of the site
(watershed

recovery, vegetation community composition, flows, habitat) if livestock
grazing

or other disturbance is removed? Reduced by one half? Reduced by 75%?
How are

livestock grazing, developments, roads, logging, "hazardous fuels"
treatments,

wild fires, mining or other disturbances in the watershed affecting
aquifer

recharge or flow rates?

How do runoff rates (and also recharge rates) from a watershed in
pristine or

good condition compare to the rates from watersheds in poor or fair
condition?

What is the condition of intermittent or ephemeral drainages in the
watersheds?

Is gullying, rilling, head-cutting or other erosion occurring, and how
is

grazing or other disturbance affecting this? What aquifer is each spring
part

of, and what are past, current or anticipated threats to these aquifers?
How

long will it take to recover flows to ¼, ½, all historically wetted
areas of

springs that have been highly degraded or altered through diversion (for

livestock water or for irrigation)? What are values of each spring as

sheltering, rearing, feeding areas for sage grouse chicks, refueling
stops for

migratory songbirds, water for nesting songbirds across a land area?

BLM must commit to regular scheduled monitoring of many parameters water

quality, flow rates, aerial extent of wetted area, plant species
composition

trampling, etc.

In review of many agency riparian documents, such as subjective PFC
assessments,

we have frequently noticed a bias towards rating areas in better
condition if

livestock grazing has not yet occurred in an area at the time the
assessment is

conducted. Thus, baseline surveys must be conducted over multiple years,
and

must also include surveys during periods when livestock have been
present for a

significant amount of time for comparison with any studies conducted in

livestock-free periods. Springs and riparian vegetation should be
managed as

wetlands, and they can generally be protected by terms applied to manage
similar

wetland systems such as riparian zones. Thus, it is very reasonable to
apply and

enforce stubble heights, bank trampling and browse terms and conditions,
rather

than relying on de-watering, piping and fencing projects.

Macroinvertebrate and vegetation surveys should be conducted prior to

implementing management actions that may adversely affect spring biota
(Sada and

Herbst 2001 at 14). These also serve as an environmental baseline to
gauge any

management changes. In order to be able to understand cumulative,
synergistic or

indirect impacts of proposed actions (and to adequately understand
current

conditions).

Degradation/loss of springs and other riparian areas may be caused by
diversion,

roading, mining or other activities. BLM must weigh the relative
scarcity

of undeveloped springs, the threats faced by, and demands on, local and
regional

aquifers.

For all streams and springbrooks in or related to the project area and
species

of interest, BLM must assess the following: How has vegetation been

changed, reduced, eliminated? How have channels been widened or
degraded? Have

water tables been lowered? Has erosion potential increased? How have
these

effects impacted habitats for raptors, sage grouse and other special
status and

important species?

How does livestock consumption of overstory vegetation, elimination of
shady

cover, trampling of banks, etc. affect water quality (temperature,
sediment,

bacteria, algae) and aquatic species presence and habitats? What are the

characteristics of the banks in areas accessible to livestock use? How
is

livestock grazing affecting recruitment of young willows and other
riparian

plants, and altering structure of older or mature shrubs and trees?

What is was the historical potential of the site? What would the
potential of

the site be under rest from livestock grazing (coupled with flow
restoration if

large volumes are diverted or the spring is damaged by diversion) in 5,
10, 15,

20 or more years? How much more quickly would sites heal if livestock
were

removed to jump start recovery?

How is livestock grazing or other current disturbance (of the stream and
its

watershed) affecting vegetation, banks, water quality, aquatic species,
flow,

stream morphology? How is livestock grazing or other disturbance
contributing to

the intermittent or ephemeral conditions of the stream or spring brook?

For all riparian areas, BLM must pay particular attention to livestock

trampling impacts, as over time, trampling of clay soils near springs
may seal

the spring, causing it to dry up completely. Plus, BLM must assess the

impacts of intense or concentrated livestock use in areas in the
vicinity of

riparian areas, i.e. troughs or dug out ponds outside exclosures, and
any areas

to which livestock use will be increased or intensified due to the
projects

under consideration. BLM must collect detailed water quality
measurements

throughout the time when livestock are present, as well as during spring
runoff

to assess livestock impacts to water quality. BLM must fully consider
the

relative scarcity of these values in the arid landscape when balancing
uses.

Has the BLM actually determined, for any of these projects, how much
water is

in the spring or stream proposed for development and whether there is
enough

water for the number of cattle on the allotment or in a particular
pasture? This

is essential, as WWP has demonstrated to the Yankee fork Ranger
District, on the

Spoud and Marco Creek allotments, the spring developments do not provide
enough

water for the number of cattle permitted to graze in the pasture. This
is a

problem in many allotments across the Forest and BLM lands in central
Idaho.

Desertification and Watersheds

There is an extensive body of scientific literature on desertification
of

watersheds, including in the western United States. Desertification is
defined

as: "a change in the character of the land to a more desertic
condition",

involving "The impoverishment of ecosystems as evidenced in reduced
biological

productivity and accelerated deterioration of soils and in an associated

impoverishment of dependent human livelihood systems". See Sheridan
1981, CEQ

Report 1981 at iii. Major symptoms of desertification in the U. S.
include:

declining groundwater tables; salinization of topsoil or water;
reduction of

surface waters; unnaturally high soil erosion; desolation of native
vegetation

(Sheridan CEQ at 1). The existence of any one can be evidence of

desertification. As lands become desertified, they become less
productive, and

activities such as livestock grazing become less sustainable. Continuing

activities like livestock grazing may result in grazing becoming
permanently

unsustainable across the landscape. In many areas of these allotments,

ecological conditions because of desertification and degradation
processes that

has already occurred and which is still underway, have already crossed
the

threshold between sustainability and, essentially, "mining" of
increasingly

non-renewable natural resources. Desertification can be both a patchy

destruction, often exacerbated by drought, as well as the impoverishment
of

ecosystems within deserts.

In fact, these very Challis BLM-managed lands were featured in
discussions of

desertification on the Sheridan CEQ report. The poor condition of the
BLM lands

often reflects impacts that have occurred throughout watersheds
including the

depleted headwaters on Forest lands.

In analyzing impacts of its actions, BLM must assess the levels and

degree of desertification that have occurred across these allotments and

surrounding lands. This information is essential to understanding
ecological

processes and watershed and native vegetation community and riparian
health.

This is also necessary to understand the suitability of these lands for

livestock grazing, the productivity and carrying capacity of these lands
for

grazing, the effects of any alternatives developed here, the ability to
meet any

objectives, and the ability to sustain, enhance or restore habitats and

populations of special status and other important species and native
plant

communities, and the impacts of any proposed new livestock facilities.
For

example, how has the extensive depletion of understories affected the
degree and

rate of desertification processes? How has this affected livestock
patterns of

use, acres per AUM, etc.? What are the acres per AUM across all
vegetation

types in all conditions across these allotments? How many acres per AUM
are

required to sustain cattle or sheep here? How will the livestock
projects in the

SOPA affect livestock use patterns, and linked desertification
processes,

degradation of intermittent and ephemeral drainages, etc.? What actions
can be

undertaken to halt desertification processes and begin recovery? BLM
must

also assess the combined effects of desertification and exotic
species/weed

increase and infestation and develop a full range of alternatives
focused on

halting ongoing desertification, and stabilizing and restoring important

habitats.

Many of the affected lands are below potential, and would decline even
further.

To continue the current level of grazing while constructing even more
livestock

facilities in these watersheds, will result in even further loss of
soil,

microbiotic crusts, water, watershed integrity, wildlife habitat,
endangered and

threatened species habitats, and forage on these allotments. WWP fears
he

facility construction would be used to try to perpetuate unsustainable

AUMs/stocking rates, and will result in continued desertification and
loss of

productivity on these lands.

Desertification symptoms in arid lands include: Sparsity of grass;
presence of

invading plant species - both native and non-native; in grass areas that
have

survived: plants are of poor vigor; topsoil losses - in many places,
topsoil is

held only by pedestals of surviving plants. Surface signs of soil
erosion

include: pedestaling, gullies, rills, absence of plant litter to
stabilize

soils.

Desiccation and erosion caused by livestock can cause water tables to
drop, and

rilling, gullying and arroyo cutting to occur, and result in sediment
flow from

degraded areas (Sheridan CEQ at 14). Grazing creates extremely dry site

conditions for plants due to removal of litter, loss of soil cover, and

trampling of the ground that prohibits rainfall from reaching plant
roots (CEQ

at 15). Livestock grazing exacerbates any climate changes and shifts
that may be

occurring.(CEQ at 16). This is of particular concern in the southern
Idaho

landscape which is periodically plagued with severe drought, and which
is facing

increasing heat and aridity due to global warming.

The depletion or near-absence of many species of native grasses from
many areas

of the allotment, such as the diminished state of the once abundant
bluebunch

wheatgrass in lower elevations, signals stress of overgrazing (CEQ at
19).

Absence of plant litter makes germination of natives more difficult.
Recovery of

lower elevation areas or south or west facing slopes will be exceedingly
slow,

especially considering the aridity of the project area. Arid land
recovers very

slowly; massive soil erosion has exposed soils that are less able to
support

plant life because of lower organic content; and invader species have
become

well established and have the competitive edge (Sheridan CEQ at 21). It
is well

recognized that "the way to end overgrazing is to reduce the number of
livestock

in the end" (Sheridan CEQ at 22). Yet political pressures from ranchers
results

in strong political opposition to reduced grazing, and instead agencies

construct expensive and ecologically damaging livestock facilities,
despite past

failures of these projects in many sites.

As part of its analysis of all projects, BLM must conduct necessary

baseline studies for special status species, MIS species, T&E species,
and all

important wildlife species in the affected lands. Sagebrush, aspen and
low and

middle elevation conifer communities in Idaho are now showing signs of
extensive

changes and significant stresses, with livestock grazing and aggressive

non-native weeds recognized as among important causal factors. WWP notes
that

the Salmon Challis Weed EIS documents alarming levels of weeds in areas
of

roading or other disturbance in these lands already. Continued or
shifted

grazing disturbance, degradation and weed invasion will cause native
plant

communities to cross thresholds from which recovery is very difficult,
if not

impossible. The decline in sage grouse populations and other species
dependent

on arid land shrub habitats is a landscape-scale biological indicator
that the

loss of functions and values of sagebrush ecosystems are serious and
widespread.

These are also signs of desertification processes across the landscape.
It has been pour experience that BLM lands are often MORE infested with
weeds than Forest lands, so the SC Weed EIS paints a truly dire picture
for BLM lands that you manage.

Lower elevation lands are important to the persistence of pygmy

rabbit, sage grouse, Brewer's sparrow, green-tailed towhee, and raptor

populations in the region. A recent analysis, Dobkin and Sauder

2004,"Shrubsteppe Landscapes in Jeopardy: Distribution, abundances, and
the

uncertain future of birds and small mammals in the Intermountain West",
examined

bird and small mammal species in the sagebrush biome. The authors found
that

"very little of the sagebrush biome remains undisturbed", the inherent

resilience of the ecosystem has been lost and the ability to resist
invasion and

respond to disturbance has been compromised (Dobkin and Sauder at 5). At
least

60% of sagebrush steppe now has exotic annual grasses in the understory
or has

been converted completely to non-native annual grasslands (citing West
2000).

More than 90% of riparian habitats have been compromised by livestock or

agriculture.

The authors distilled a list of 61 species of birds and small mammals
that are

completely or extensively dependent on shrubsteppe ecosystems, and
conducted an

analysis of their distributions, abundances, and sensitivity to habitat

disturbance to assess current state of knowledge and conservation needs
of these

species, with focus on Great Basin, Interior Columbia Basin and Wyoming
Basin,

based on BBS data and other studies.

The Columbia Plateau, Great Basin and Wyoming Basin are among the least
sampled

of all physiographic provinces covered by the Breeding Bird Survey.
Remarkably

little is known about the actual distributions or population trends of
small

mammals. "Range maps created by connecting the dots among sites where a
species

has been captured do not paint a realistic picture, especially in the
highly

altered and fragmented shrubsteppe landscapes of today. For small
terrestrial

mammals ... our results support the view that many of these species now
exist only

as small, disconnected populations isolated from each other ... it is
completely

untenable to assume species' presence based on simply on presence of
appropriate

habitat in shrubsteppe landscapes of the Intermountain West". Also, the
authors

"find no reason for optimism about the prospects in the Intermountain
West of

any of the 61 species" (at 3). "The results of our analyses present an
overall

picture of an ecosystem teetering on the edge of collapse (citing Knick
et al.

2003)".

This highlights the need for BLM to conduct a systematic and

comprehensive on-the-ground survey and assessment of species presence
and

habitat presence and quality on these allotments and surrounding lands,
as

livestock facilities have great potential to degrade and fragment even
more of

an already greatly fragmented sagebrush landscape. BLM must act to

identify important components of native biodiversity on these lands and,
armed

with this knowledge, take management action to develop a range of
alternatives

to enhance and restore these species habitats and populations before it
is too

late.

11 of 24 mammals in the report by Dobkin and Sauder (2004) are endemic
to the IM

West, representing a high degree of endemism. Many of the small mammal
species

whose status is reviewed in the report are important prey for raptors
and some

other special status species. In addition, the high degree of endemism
is

likely even greater than species-level ranges would indicate, and
genetic

analyses of upland and riparian small mammals may provide more examples
of

"cryptic" species like has now been found in endemic ground squirrels in
Idaho.

Only one of the 19 species of small mammals for which adequate trapping
data was

available was found in more than 62% of potentially suitable localities.
This

analysis of field studies is the first comprehensive attempt to quantify

presence or absence across a region. The report found that 21 of the 24
small

mammal species respond negatively to the effects of livestock grazing.
Eleven of

18 small mammal species responded negatively to the presence of exotic
plants,

with riparian mammal species exhibiting neutral responses if vegetation
was

thick enough.

Geographic patterns of species richness and community stability raise
concern.

Despite range maps showing occurrence over broad areas, many species of
small

mammals now exist only as small, disconnected populations isolated from
each

other by unsuitable habitats." Thus, it is completely untenable to
assume

species' presence based simply on presence of appropriate habitat in
shrubsteppe

landscapes of the IM West."

The report authors conclude: We find no reason for optimism about the
prospects

in the Intermountain West for any of the 61 species identified.
Sagebrush

distribution is highly fragmented, and much less extensive than
large-scale maps

suggest. Extraordinary fragmentation and degradation of sagebrush-steppe

landscapes has been caused by livestock grazing practices, purposeful
removal of

sagebrush and/or seedings through prescribed fire, mechanical treatment,

biological agents and herbicides, invariably done to provide forage for

livestock, especially as native vegetation communities have become
increasingly

depleted, as well as ag-conversion, roads, mining and mining exploration

fragmentation, powerline and pipeline corridors.

An untold number of livestock facilities or zones of intense disturbance

(fences, spring projects, pipelines, trough systems salting sites,
corrals,

wells, salt or mineral sites, water haul sites, etc.) have been
constructed or

placed on public lands including across the Salmon-Challis Forest and

BLM, state and private lands. Roads almost inevitably grow up either as
a

direct result of facility construction/placement, or of continued
facility use

and maintenance. Then, roads become travel corridors for predators
(Braun 1998,

Federal Register 2003, Federal Register 2004, Connelly et al. 2004,
Freilich et

al. 2003, Connelly et al. 2004, Dobkin and Sauder 2004), and conduits
for weed

invasion (Gelbard and Belnap 2003). Many of these facilities have
unforeseen

effects, and exert influence over much larger areas than anticipated.
For

example, water developments may attract sage grouse predators and be
"sinks"

(Connelly et al. 2004).

Such ecological changes have pushed many sagebrush landscapes beyond
ecological

thresholds for recovery. Cumulative effects of land use and habitat
degradation

are moving sagebrush habitats toward ecological collapse and dysfunction
(Knick

et al. 2003, Dobkin and Sauder 2004).

The Columbia Plateau, Great Basin and Wyoming Basin are among the least
sampled

of all physiographic provinces covered by the Breeding Bird Survey.
Remarkably

little is known about the actual distributions or population trends of
small

mammals. "Range maps created by connecting the dots among sites where a
species

has been captured do not paint a realistic picture, especially in the
highly

altered and fragmented shrubsteppe landscapes of today. For small
terrestrial

mammals ... our results support the view that many of these species now
exist only

as small, disconnected populations isolated from each other ... it is
completely

untenable to assume species' presence based on simply on presence of
appropriate

habitat in shrubsteppe landscapes of the Intermountain West". Also, the
authors

"find no reason for optimism about the prospects in the Intermountain
West of

any of the 61 species" (at 3). "The results of our analyses present an
overall

picture of an ecosystem teetering on the edge of collapse (citing Knick
et

al. 2003)".

This highlights the need for BLM to conduct a systematic and

comprehensive on-the-ground survey and assessment of species presence
and

habitat presence and quality on these allotments and surrounding lands.
The

BLM must act to identify important components of native biodiversity on
these

lands and, armed with this knowledge, take management action to develop
a range

of alternatives to enhance and restore these species habitats and
populations

before it is too late.

11 of 24 mammals in the report by Dobkin and Sauder (2004) are endemic
to the IM

West, representing a high degree of endemism. Many of the small mammal
species

whose status is reviewed in the report are important prey for raptors
and some

other special status species. In addition, the high degree of endemism
is

likely even greater than species-level ranges would indicate, and
genetic

analyses of upland and riparian small mammals may provide more examples
of

"cryptic" species like has now been found in endemic ground squirrels in
Idaho.

Only one of the 19 species of small mammals for which adequate trapping
data was

available was found in more than 62% of potentially suitable localities.
This

analysis of field studies is the first comprehensive attempt to quantify

presence or absence across a region. The report found that 21 of the 24
small

mammal species respond negatively to the effects of livestock grazing.
Eleven of

18 small mammal species responded negatively to the presence of exotic
plants,

with riparian mammal species exhibiting neutral responses if vegetation
was

thick enough.

Geographic patterns of species richness and community stability raise
concern.

Despite range maps showing occurrence over broad areas, many species of
small

mammals now exist only as small, disconnected populations isolated from
each

other by unsuitable habitats." Thus, it is completely untenable to
assume

species' presence based simply on presence of appropriate habitat in
shrubsteppe

landscapes of the IM West."

The report authors conclude: We find no reason for optimism about the
prospects

in the Intermountain West for any of the 61 species identified.
Sagebrush

distribution is highly fragmented, and much less extensive than
large-scale maps

suggest. Extraordinary fragmentation and degradation of sagebrush-steppe

landscapes has been caused by livestock grazing practices, purposeful
removal of

sagebrush and/or seedings through prescribed fire, mechanical treatment,

biological agents and herbicides, invariably done to provide forage for

livestock, especially as native vegetation communities have become
increasingly

depleted, as well as ag-conversion, roads, mining and mining exploration

fragmentation, powerline and pipeline corridors.

An untold number of livestock facilities (fences, spring projects,
pipelines,

trough systems salting sites, corrals, wells, windmills, water haul
sites, etc.)

have been constructed or placed on public lands here. Roads almost
inevitably

grow up either as a direct result of facility construction/placement, or
of

continued facility use and maintenance. Then, roads become travel
corridors for

predators (Braun 1998, Federal Register 2003, Federal Register 2004,
Connelly et

al. 2004, Freilich et al. 2003, Connelly et al. 2004, Dobkin and Sauder
2004),

and conduits for weed invasion (Gelbard and Belnap 2003). Many of these

facilities have unforeseen effects, and exert influence over much larger
areas

than anticipated. For example, water developments may attract sage
grouse

predators and be "sinks" (Connelly et al. 2004).

Ecological changes caused by livestock grazing and linked facilities
have pushed

many sagebrush landscapes beyond ecological thresholds for recovery.
Cumulative

effects of land use and habitat degradation are moving sagebrush
habitats toward

ecological collapse and dysfunction (Knick et al. 2003, Dobkin and
Sauder

2004).

Although sage grouse have been the flagship species for this ecosystem,
and

publicity over concerns have focused mainly on grouse, it is not just
sage

grouse that are in trouble. Sage grouse have become a surrogate for
numerous

species of animals and plants that depend on sagebrush communities, and
many of

these species may also use salt desert shrub communities.

Shrubland and grassland birds, representing an important component of
the

biodiversity of the western United States, are declining faster than any
other

group of species in North America (Saab and Rich 1997, Paige and Ritter
1999,

Dobkin and Sauder 2004). Species dependent on sagebrush ecosystems
(Brewer's

sparrow, Sage Sparrow, Sage Thrasher), may be important predictors of
ecological

collapse.

A review of field studies of small mammal response to livestock grazing

(compared moderately to heavily grazed upland or riparian areas with

exclosures), found overwhelmingly negative responses (decreased
abundance or

productivity) to the effects of livestock grazing for 12 species (Table
8):

Upland: Paiute ground squirrel, Washington ground squirrel, little
pocket mouse,

Great Basin pocket mouse, Chisel-toothed kangaroo rat, desert woodrat,
sagebrush

vole, Riparian: Water shrew, Western harvest mouse, long-tailed vole,
montane

vole, western jumping mouse. 9 species have an extremely high likelihood
for

negative responses to livestock grazing (Table 8) are: Upland: Merriam's
shrew,

Preble's shrew, pygmy rabbit Idaho ground squirrel, Merriam's ground
squirrel,

Townsend's ground squirrel, Townsend's pocket gopher. Riparian:
Townsend's

pocket gopher. Plus, negative responses to presence of exotic species
have been

demonstrated for eight upland species, and can be inferred with high
likelihood

for three others.

Alarmingly, the authors found a high frequency in which species were
missing

from studies focused on suitable habitat. This should raise concern
about the

current actual extent of populations. It must be understood in the
context of

the high degree of fragmentation and altered disturbance regimes (Knick
et al.

2003), the "overwhelmingly negative response to livestock grazing", and
the

limited dispersal capabilities of small mammals (Dobkin and Sauder
2004). "Our

results support the view that many of these species now exist as small,

disconnected populations isolated from each other by unsuitable habitats
across

which they cannot disperse". Catastrophic decline of the largest
population of

northern Idaho ground squirrels illustrates this. The combined effects
of

altered fire cycles, (loss of fire here - as this species occurred in
meadows in

forest), livestock grazing and exotic species introduction is the
reality faced

by many small mammal populations.

Across the IM West, altered fire frequencies combined with ubiquitous
grazing

drives the loss of native plant community structure and composition on
which

birds and small mammals depend. Grazing reduces competition from native
grasses,

and cheatgrass and other weeds flourish, with each successive fire
promoting

invader expansion, resulting in self-perpetuating monocultures of exotic
plant

species with very short fire return intervals (Whisenant 1991, Anthony
and

Vitousek 1992, Billings 1994, Knick et al. 2003). Exotic plant dominated

landscapes are uninhabitable for nearly all native bird and small mammal
species

(Dobkin and Sauder 2004). Shrub-steppe habitat has diminished greatly -
at

least 44% of potential habitat for Greater Sage-Grouse has disappeared

(Schroeder et al 2004) - and this study did not evaluate fragmentation
of the

rest!

Biome-wide, accelerated Oil and Gas development is occurring in Wyoming.
This

places landscape-scale fragmentation and soil disturbance on an even
faster

trajectory. Also, an astonishing number of fences and other livestock
projects

that serve to fragment habitats are found across the sagebrush biome
(see

Connelly et al. 2004).

There are significant declining trends for 16 of 25 upland bird species
(64%) in

the regions of the Intermountain West (Dobkin and Sauder 2004). Only 3
species

showed a significant increasing population trend. 5 of 12 riparian
species

declined significantly over both the short and long term. "Birds that
depend on

native vegetation for their nests clearly are jeopardized by the loss or

degradation of vegetation. Nearly all 25 upland species are obligate

ground/shrub nesters, with 18 of the 25 species dependent on native
shrubs for

nesting and foraging.

Species richness for upland birds was concentrated in the three primary

shrubsteppe ecoregions, with areas of highest species richness extending
across

the Columbia Plateau from southeastern Oregon to easternmost Idaho, the
eastern

two-thirds of the Great Basin, and southwestern Wyoming Basin. There was

constancy in bird species composition in upland bird communities between

1968-1983 and 1984-2001. However, the community \\composition of
riparian bird

communities varied substantially between periods, with a decrease in
species

composition of riparian communities. Plus, ecologically unsuitable
habitats are

now embedded in matrices of suitable habitats.

Nearly all of the upland bird species, and all the riparian species
(except the

yellow-billed cuckoo) listed in Dobkin and Sauder (2004), Table 1 at 9
are

likely to occur in the Hardtrigger area, likewise, nearly all of the
small

mammal species found in Table 2 at 10 are likely to occur in the Project
area.

For some species, such as loggerhead shrike, declines were especially
severe in

the three primary shrubsteppe ecoregions with population losses across
large

geographic areas.

Geographic patterns of species richness for birds found that areas of
highest

upland avian species richness correspond with areas of lowest
shrubsteppe

fragmentation. Bird species "Entirely" dependent on sagebrush: Greater

Sage-Grouse, Sage Thrasher, Brewer' Sparrow, and Sage Sparrow. Birds
"Nearly"

dependent: Gray Flycatcher, Gray Vireo, Green-tailed Towhee,
Black-throated

Sparrow.

Riparian birds have distributions that extend beyond the IM West, as do
riparian

mammals. Given the relative rarity and ecological importance of riparian

habitats within shrub-steppe landscapes, the high degree of instability
in

riparian bird community structure found in the report, reflects the poor

condition of riparian habitats across the Great Basin, Columbia Plateau
and

Wyoming Basin ecoregions (Dobkin and Sauder 2004, citing Saab et al.
1995,

Dobkin et al. 1998, Tewksbury et al. 2002, Krueper et al. 2003, Earnst
et al.

2004\) and the dewatering of riparian zones (Dobkin and Sauder 2004,
citing Rood

et al. 2003), causing damage to avifauna and habitats.

For all allotments where projects are proposed, BLM must provide

monitoring data that shows utilization levels, use pattern mapping,
stubble

heights, trampling, etc., and actual numbers of livestock grazed during
all

years or periods when monitoring was conducted.

BLM must also assess impacts on special land areas such as WSAs,
adjacent Forest roadless lands, ACECs, etc.

BLM must analyze the impacts of existing and foreseeable roading and

motorized use linked to these proposed facilities on wildlife, T&E, MIS
and

special status species.

BLM must analyze the Impacts of fences on sage grouse, pygmy rabbit and

other birds and small animals. Full impacts to big game winter range,
antelope

fawning, or other important habitats must be included. Shifts in high
stocking

rates of cattle and high allowable utilization will accelerate depletion
of food

for wildlife on winter range as projects are constructed. Fences are
often

barriers to wildlife movement or use of an area.

Fences are not panaceas for riparian area conflicts. Permittees often
hold

exclosures in low regard, and trespass routinely occurs. Please review
the extensive information that WWP has provided to you in relation to
Burnt Creek and other exclosure areas that you manage. Thus, agency
claims of problems being solved by exclosures may not be realized.

Full assessment of more intensive herding of livestock must be
conducted, as a

viable alternative to more projects. Such analysis, and assessment of

comparative impacts impacts of herding vs. project construction, or
restoration

(removal of many existing projects), and thus limiting livestock damage
to

soils, native vegetation, cultural sites and other important elements of
the

public lands must be assessed.

Full assessment of costs of all projects (including recreational,
wildfire, or

other resources damaged) must be presented and analyzed.

A current analysis or inventory of the weeds that may be present on
state,

private, BLM and Forest lands in affected watersheds must be conducted

ESPECIALLY weed occurrence in relation to livestock facilities or
trailing

areas.

Full assessment of impacts of salting or other activities, in shifting
livestock

use, along with projects, must also be conducted.

Facilities may cause extensive depletion of surrounding lands,
degradation of

rare plant habitats, cultural sites, etc. Shifts in livestock use may
influence

watershed processes on downstream lands, serve as an epicenter for
sediment,

weed infestation, etc. All elements of grazing here and on other lands
must be

assessed.

Again, please keep us fully informed of all steps you take in relation
to these

or similar projects on Challis BLM lands.

We are also very concerned about impacts of various forest or rangeland
health projects, or "hazardous fuels" projects being conducted in the
middle of nowhere, and how any of these actions may be related to, or
affect, the above watersheds where the massive spring de-watering is
contemplated.

Last, these are extraordinarily scenic public wild lands, and the
gashing of pipeline scars, and new zones of livestock disturbance and
weed infestation across them will be permanent, irreversible impacts
that mar the visual and aesthetic setting of Central Idaho. These
short-sighted projects will permanently scar world class wild lands and
recreational areas.

Please be sure to keep me on your mailing list for receiving ANY further
information on these projects, or associated grazing allotments, or any
agency actions (such as fuels) within these watersheds.

Sincerely,

Katie Fite

Biodiversity Director

Western Watersheds Project

PO Box 2863

Boise, ID 83701

208-429-1679

Much Literature, Directly relevant to these projects, is in the
bibliography below.

**[Relevant Literature]{.underline}**

Anderson, L. D. 1991. Bluebunch wheatgrass defoliation: effects and
recovery. USDI Bureau of Land Management Technical Bulletin 91-2.
Salmon, ID.

Anderson, D. C., K. T. Harper and R. C. Holmgren. 1982. Factors
influencing development of cryptogamic soil crusts in Utah deserts.
Journal of Range Management 35(2):180-185.

Anderson, J. E. and K. E. Holte. 1981. Vegetation Development over 25
years without grazing on sagebrush-dominated rangeland in southern
Idaho. Journal of Range Management 34(1):25-29.

Anderson, Jay E. and Richard S. Inouye. 2001. Landscape-scale changes in
plant species abundance and biodiversity of a sagebrush steppe over 45
years. Ecological Monographs 71(4):531-556.

Belnap, J. 1995. Surface disturbances: their role in accelerating
desertification. Environmental Monitoring and Assessment 37:39-57.

Belnap, J. and D. A. Gillette. 1997. Disturbance of biological soil
crusts: impacts on potential wind erodibility of sandy desert soils in
southeastern Utah. Land Degradation and Development 8:355-362.

Belnap, J., R. Rosentreter, S. Leonard, J. H. Kaltenecker, J. Williams
and D. Eldridge. 2001. Biological soil crusts: ecology and management.
USDI BLM. Technical Reference 1730-12.

Belsky, A. J. and J. Gelbard. 2000. Livestock grazing and weed invasions
in the arid west. Oregon Natural Desert Association. Bend, OR.
\[available on-line at
[www.onda.org/library/papers/index.html](http://www.onda.org/library/papers/index.html)
\]

Belsky, A. J., A. Matzke, and S. Uselman. 1999. Survey of livestock
influences on stream and riparian ecosystems in the western United
States. Journal of Soil and Water Conservation 54:419-431.

Beymer, R. J. and J. M. Klopatek. 1992. Effects of grazing on
cryptogamic crusts in pinyon-juniper woodlands in Grand Canyon National
Park. Am. Midland Naturalist. 127:139-148.

Billings, W. D. 1994. Ecological impacts of cheatgrass and resultant
fire on ecosystems in the Western Great Basin, in S.B. Monsen and S.G.
Kitchen, eds. Proceedings - ecology and management of annual rangelands.
USDA Forest Service. General Technical Report INT-GTR-313. Intermountain
Research Station. Ogden, UT.

Bonnichsen, Bill. 1982. Cenozoic geology of Idaho. Idaho Bureau of Mines
and Geology Bulletin 26, Moscow, ID.

Bonnichsen, Bill. 1982. Rhyolite lava flows in the Bruneau-Jarbidge
eruptive center, southwestern Idaho. (pp. 283-320). *In* Bill Bonnichsen
and R.M. Breckenridge (eds.) Cenozoic geology of Idaho. Idaho Bureau of
Mines and Geology Bulletin 26, Moscow, ID.

Braun, C. 1998. Sage grouse declines in western North America: what are
the problems? Proc. Western Assoc. State Fish and Wildlife Agencies 78.

Chaney, E., W. Elmore, and W. S. Platts. 1990. Livestock grazing on
western riparian areas. Report prepared for the U.S. Environmental
Protection Agency by Northwest Resources Information Center, Inc. Eagle,
ID.

Chaney, E., Elmore, W. and W. S. Platts. 1993. Managing change:
livestock grazing on western riparian areas. Northwest Resource
Information Center. Eagle, ID.

Clary, W. P. and B. F. Webster. 1989. Managing grazing of riparian areas
in the Intermountain region. General Technical Report INT-263. USDA
Intermountain Research Station.

Collopy, M.W. and J. Smith. 1995. National status and trends; the
Pacific Northwest (Draft). UDI/NBS Forest and Rangeland Ecosystem
Science Center, Corvallis, OR.

Connelly, J. W., M. A. Schroeder, A. R. Sands, and C. E. Braun. 2001.
Guidelines to manage sage grouse populations and their habitats. Western
Association of Fish and Wildlife Agencies. Wildlife Society Bulletin
2000, 28(4):967-985.

Connelly, J. W., S. T. Knick, M. A. Schroeder and S. J. Stiver. 2004.
Conservation assessment of greater sage grouse and sagebrush habitats.
Western Association of Fish and Wildlife Agencies. Cheyenne, Wyoming.
\[available on-line at
[www.ndow.org/wild/sg/resources/assessment.shtm](http://www.ndow.org/wild/sg/resources/assessment.shtm)
\]

Conservation Biology Institute. 2000. Importance of BLM roadless areas
in the western US. Full report can be viewed at
[*www.consbio.org*](http://www.consbio.org/).

Coulter, I. Davidison, L. Dickson. N. Edelson, R. Eliot, R. M. Erwin, S.
Hatch, S. Kress, R. Milko, S. Miller, K. Mills, R. Paul, R. Philips, J.
E. Saliva, B. Syderman, J. Trapp, J. Wheeler, and K. Wohl. 2002.
Waterbird Conservation for the Americas: the North American Waterbird
Conservation Plan, Version 1. Waterbird Conservation for the Americas.
Washington, DC.

Donahue, D. 1999. The western range revisited: Removing livestock from
public lands to conserve native biodiversity. University of Oklahoma
Press, Norman, OK.

DeLong, A. K., J. A. Crawford, and D. C. DeLong. 1995. Relationship
between vegetation structure and predation of artificial sage grouse
nests. J. Wildlife Management. 59(1):88-92.

Dobkin, D. S. and J. D. Sauder. 2004. Shrubsteppe landscapes in
jeopardy. Distributions, abundances and the uncertain future of birds
and mammals in the Intermountain West. High Desert Ecological Research
Institute. Bend, OR.

Duff, D. A. 1977. Livestock grazing impacts on aquatic habitat in Big
Creek, Utah. *In* Proceedings of the workshop on livestock and wildlife
--fisheries relationships in the Great Basin.

Dyksterhuis, E. J. 1949. Condition and management of range land based on
quantitative ecology. Journal of Range Management 2:104-115

Federal Register. March 5, 2003. Endangered and threatened wildlife and
plants; Final Rule to list the Columbia Basin Distinct Population
Segment of the pygmy rabbit (*Brachylagus* i*dahoensis*) as endangered.
Vol. 68, 43:10389-10409.

Federal Register. April 21, 2004. Endangered and threatened wildlife and
plants; 90-day finding for petitions to list the greater sage grouse as
threatened or endangered. Vol. 69(77):21484-21494

Fleischner, T. 1994. Ecological costs of livestock grazing in western
North America. Conservation Biology 8:629-644.

Freilich, J. E., J. M. Emlen, J. J. Duda, D. C. Freeman and P. J.
Cafaro. 2003. Ecological effects of ranching: a six-point critique.
BioScience 53(8):759-765.

Galt, D., G. Mendez, J. Holechek and J. Joseph. 1999. Heavy winter
grazing reduces forage production: an observation. Rangelands
21(4):18-21

Galt, D., F. Molinar, J. Navarro, J. Joseph and J. Holechek. 2000.
Grazing capacity and stocking rate. Rangelands 22(6):7-11

Gelbard, J. L. and J. Belnap. 2003. Roads as conduits or exotic plant
invasions in a semiarid landscape. Conservation Biology 17 (2):420-432.

Gerber, M.F.. J.C. Munger, A. Ames and J. Stewart. 1887. Reptiles and
amphibians in deep canyons: the Big Jacks and Little Jacks Creek
drainages of Owyhee County, Idaho. BLM Technical Bulletin 97-1.

Groves, C. 1994. Idaho's amphibians and reptiles: description, habitat
and ecology. Nongame Wildlife Leaflet No. 7. Idaho Department of Fish
and Game. Boise, ID.

Haferkamp, M. R., P. O. Currie, J. D. Volesky and B. W. Knapp. 1992.
Mortality of crested wheatgrass and Russian wildrye during drought. J.
Range Management. 45(4):355-357.

Hockett, G.A. 2002. Livestock impacts on herbaceous components of sage
grouse habitat: a review. Intermountain Journal of Science 8(2):
105-114.

Holechek, J. L. 1996a. Financial returns and range condition on southern
New Mexico ranches. Rangelands 18(2):52-56

Holechek, J. L. 1996b. Drought and low cattle prices: hardship for New
Mexico ranchers. Rangelands 18(1):11-13

Holechek, J. L., H. de Souza Gomes, F. Molinar and D. Galt. 1998.
Grazing intensity: critique and approach. Rangelands 20(5):15-18

Holechek, J. L., H. Gomez, F. Molinar and D. Galt. 1999a. Grazing
studies: what we've learned. Rangelands 21(2):12-16

Holechek, J. L., M. Thomas, F. Molinar and D. Galt. 1999b. Stocking
desert rangelands: what we've learned. Rangelands 21(6):8-12

Holechek, J. L., H. Gomez, F. Molinar, D.Galt and R. Valdez. 2000.
Short-duration grazing: The facts in 1999. Rangelands 22(1):18-22.

Holechek, J. L., R. D. Pieper and C. H. Herbel. 2001.Range Management:
Principles and Practices, Fourth Edition. Prentice-Hall, New Jersey.
587p

Holmes, A. L., G. A. Green, R. L. Morgan, K. B. Livezey. 2003. Burrowing
owl nest success and longevity in north central Oregon. Western North
American Naturalist 63(2):244-250.

Hutchings, S.S. and G. Stewart. 1953. Increasing forage yields and sheep
production on Intermountain winter ranges. U.S. Department of
Agriculture Circular 925. 63p.

Kay, C. E. and D. L. Bartos. 2000. Ungulate herbivory on Utah aspen:
assessment of long-term exclosures. J. Range Management 53: 145-153.

Knick, S. T. and J. T. Rotenberry. 1995. Landscape characteristics of
fragmented shrubsteppe habitats and breeding passerine birds.
Conservation Biology 9:1059-1071.

Knick, S.J. and J.T. Rotenberry. 1999. Spatial distribution of breeding
passerine birds habitats in a shrub steppe region of southwestern Idaho.
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June 8, 2005

David Rosencrance

Challis BLM

801 Blue Mountain Road

Challis, ID 83226

Dear Mr. Rosencrance,

Here are further comments of WWP on the Morgan Creek, Watts Spring,
Ellis Creek, AND Pahsimeroi water developments including Yribar, Poison
Springs, Bert Springs, and Squaw Creek, and also in relation to the
Falls Creek Rip. Restoration Project (Letter and EA of June 1, 2005
ID-3330-01-EA034 and FONSI). Please also apply our earlier letter
(actually dated June 10) to the Falls Creek project, as well.

Please send us a copy of the BAs for these projects that are referred to
in your EA analyses.

These projects appear to be a part of a series of connected actions.
First, you incrementally fenced off sections of stream. The stream
fencing which was always claimed to solve problems -- never did, and
more and more barbed wire hazards have been constructed across these
areas. As soon as one fence or spring development/de-watering project
was built, you claimed you needed another, and that this would solve
problems. It did not -- and now you are proposing a whole series of
developments, without having conducted necessary landscape --level
analysis of livestock grazing and facility impacts on soils, waters,
watersheds, native wildlife, special status species, cultural sites,
recreational values, WSAs, etc., and cutting livestock numbers so that
they can be appropriately managed here.

Some of the projects originate on Forest land, and de-water springs
there, so complete analysis of direct, indirect and cumulative impacts
must be conducted there as well.

How many other pipelines, troughs, and spring developments exist in the
Upper Pahsimeroi? In Morgan/Ellis/Hat Creek? How many undeveloped vs.
developed springs are there? How have you weighed the scarcity of values
here?

Please conduct a full study of exiting habitat fragmentation for
sagebrush --dependent species, and develop a restoration pan to
reconnect already fragmented habitats.

How do any of these projects relate to conversion of sheep AUMs to
cattle AUMs? Have AUMs been converted in the past in any of these
allotments? If so, at what proportionality?

We reiterate that we do not believe you have conducted a study of the
carrying capacity suitability, productivity and other necessary factors
that would demonstrate that you are authorizing sustainable levels of
livestock use across these and neighboring allotments.

Do the same parties that would benefit financially from these
developments also graze on adjacent BLM or Forest allotments?

How might any of the projects be extended in the future?

How much forage (lbs/acre) is produced on cattle-usable lands where
these projects will be placed?

What is the current condition of the lands that will be grazed by
livestock using these projects. Please provide all past or current
Ecological Site Inventory data. If there is no current data, this must
be collected as part of the environmental analysis for these projects.

What is the compliance and maintenance and trespass history of all
permittees affected by these projects?

Please provide all livestock monitoring data -- including locations
where all data was collected -- for all allotments affected by these
projects -- both BLM and Forest Service lands, for the past 10 years.
This includes all monitoring of spring conditions across the allotments,
including trampling, stubble height, water quality, as well as all other
riparian and upland monitoring data. Please provide a detailed study of
patterns of livestock use and management that havebeen applied across
these lands.

Please provide all water quality monitoring data, including data for
springs, seeps, and intermittent drainages.

What is the condition of intermittent or ephemeral drainages across
these allotments and watersheds?.

Please explain the impacts of increased or shifted use, and construction
or maintenance activities within the WSA or roadless lands. Please
provide all monitoring information on livestock, OHV, roading and other
impacts to the WSA.

We ask that you develop a wide range of alternatives that would focus on
removal of fencing and agents of fragmentation, and employ mandatory
measurable use standards of livestock across these lands.

Please provide better maps for all of these projects. Projects should
show all existing livestock facilities in the affected allotments, as
well as adjacent allotments. This is necessary to understand the context
in which the action will occur.

Please also provide a chronology of project developments across these
allotments.

When did permittees file for water rights here? Why was the Interested
Public not informed of this in a timely manner so that the water rights
could be Protested, and scoping could determine the extent of analysis
required? Is this part of plan that is unfolding?

We alarmed at the lack of information on weeds across these allotments
and surrounding lands -- especially in relation to livestock facilities
and associated roading. We are also very concerned that you have not
assessed all impacts of livestock facility construction on proliferation
of roading across these lands.

What streams are all springs as such as Watts Springs, in watersheds of?
Do any of these projects lie in ESA-listed species watersheds? You claim
that there will be no impacts to ESA species, yet extending livestock
degradation and desertification across these watersheds will result in
diminishment of surface flows.

In many areas of the District, sheep AUMs have been converted to cattle
AUMs, with no intensive "look" taken at the impacts of sheep vs. cattle
use, and the often decreased suitability of steep, rocky or other
terrain for cattle use (vs. sheep). In other areas, overlapping sheep
and cattle grazing or trailing occurs.

This suitability of lands for livestock grazing must be assessed as part
of this process. Please see USFS methods used in development of the
Boise, Payette and other recent southern Idaho Forest Plans.

BLM and the Forest have failed to employ the analytical procedures
described by Professors Holechek, Galt and others, and which the Forest
Service uses in its grazing management, in setting stocking levels by
first determining the amount of land area that is both "capable" and
"suitable" for grazing.

Under the "capability", an evaluation is made to determine the number of
acres of lands that are "capable" of livestock grazing, based on
specific slope, distance from water, rockiness, and other factors. Then,
out of the "capable" lands, a further determination is made about which
acres are "suitable" for grazing, based on considerations such as
special management areas, fragile ecological resources, or other
considerations. After this analysis is done, then the remaining lands
that are both "capable" and "suitable" are assessed to determining
grazing levels by setting proper stocking rates. This analytical process
is central to ensure a proper grazing management system that does not
degrade range resources, and must be considered as part of the
determination under various alternatives of the impacts or effects of
the outcomes of any of the many large-scale disturbance treatments or
fuels projects such as this. Plus, BLM and the Forest must understand
that current stocking rates in many areas, and the actions needed to
sustain them, results in grazing unsuitable lands and is a major
contributing factor to rangeland health woes, and fuels and weeds
problems.

Last, these are extraordinarily scenic public wild lands, and the
gashing of pipeline scars, construction of many barbed wire fences on
top of those that already exist, and new zones of livestock disturbance
and weed infestation across them will be permanent, irreversible impacts
that mar the visual and aesthetic setting of Central Idaho. These
short-sighted projects will permanently scar world class wild lands and
recreational areas.

Please be sure to keep me on your mailing list for receiving ANY further
information on these projects, or associated grazing allotments, or any
agency actions (such as hazardous fuels) within these watersheds and
your District.

Sincerely,

Katie Fite

Biodiversity Director

Western Watersheds Project

PO Box 2863

Boise, ID 83701

208-429-1679