![](media/image1.png){width="5.992361111111111in" height="1.8125in"}

Mr. Terry Lee Smith, Project Mgr.

BLM Pocatello Field Office

4350 Cliffs Drive

Pocatello, ID 83204-2105

April 2, 2007

# Here are additional comments of Western Watersheds Project and the Idaho Wildlife Federation on the Pocatello RMP DEIS. Discussions below of desertification and watersheds, livestock grazing impacts, loss and fragmentation of habitats and populations of wildlife species are critical to BLM understanding and analysis of the impacts of its actions and compliance with FLPMA. Please apply these in developing a Supplemental EIS with a greatly expanded range of alternatives that fulfill BLM's mandates under NEPA, FLPMA and other environmental laws and policies for the protection of sensitive species and other values of the public lands.

# Range of Alternatives

Instead of structuring this process to develop a range of alternatives
centered around the need to intensively alter and treat still relatively
intact native vegetation, and maximizing disturbance and extractive
activities on nearly all public lands in the PFO, BLM must develop a
SEIS that considers a range of alternatives that focus on restoring
depleted, cheatgrass, bulbous bluegrass, crested wheatgrass and other
near-biological deserts, that protect native vegetation and important
wildlife habitats from disturbance as much as possible. Expansion of
invasive species pushes communities across thresholds from which natural
recovery is difficult - if even possible Livestock grazing is only one
of many competing uses on these fragile and much-abused arid lands which
are already undergoing accelerated habitat fragmentation.

# 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 deterioriation** **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**.

The BLM must assess the levels and degree of desertification that have
occurred across the EIS area. This is necessary to understand the
suitability of these lands for livestock grazing, the productivity and
carrying capacity of these lands for grazing, the current or likely
future extent of cheatgrass and other hazardous fuels, the likely
success of any treatments undertaken under the EIS, the effects of
alternatives developed here, the ability to meet any objectives, and the
ability of actions under the EIS to maintain, enhance or restore
habitats and populations of special status and other important species
and native plant communities. For example, how has the extensive
depletion of understories in many areas of Wyoming big sagebrush
vegetation or Utah juniper affected the degree and rate of
desertification processes across the EIS area? How has this affected
livestock patterns of use, acres per AUM, invasion of hazardous fuels
like cheatgrass, increased densities of woody vegetation, 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 in the lower salt desert shrub or Wyoming big sagebrush
communities of these allotments? 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 to address hazardous fuels problems.

Even PRIA acknowledged that production on many BLM lands was below
potential, and would decline even further. To continue the current level
of grazing while interjecting or superimposing massive disturbance - as
proposed under the EIS, will result in even further loss of soil,
microbiotic crusts, water, watershed integrity, wildlife habitat, and
forage on these allotments. 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, 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 arid EIS
landscape periodically plagued with severe drought, and which is facing
increasing heat and aridity due to global warming. Such effects must be
thoroughly assessed if BLM is to understand the impacts of any
alternatives, treatments, management actions or disturbance under the
EIS.

The near-absence of many species of larger stature native bunchgrasses
from many areas of the EIS, such as the diminished state of the once
abundant Indian ricegrass, or bluebunch wheatgrass, signals stress of
overgrazing (CEQ at 19).

A new United Nations Report on the role of livestock in the colossal
problem of Global Warming processes (see below) highlights the impacts
of livestock grazing and depletion of woody and other vegetation in
accelerating desertification processes, global warming, and loss of
biodiversity.

BLM must fully address the complete Footprint of livestock grazed on
these BLM lands on desertification and global warming processes.

BLM must fully understand effects of desertification that has occurred,
and is continuing to occur, across the project area, and effects of
livestock grazing, mining, other human disturbance, vegetation
treatments, etc. Absence of plant litter (post-fire, or with excessive
grazing) makes germination of natives more difficult. Recovery of lower
elevation areas 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). As
described elsewhere in WWP comments, degradation and desertification
processes in PFO lands have resulted in stocking rates and use levels
being grossly out of balance with "sustainable" uses here.

Even though it is well recognized that "**the way to end overgrazing is
to reduce the** **number of livestock in the end**" (Sheridan CEQ at
22), political pressures from ranchers results in strong political
opposition to reduced grazing. Political pressures have hamstrung
implementation of the Taylor Grazing Act. Such political pressures are
also discussed in Connelly et al. 2004 as constraining decisionmaking
processes on public lands.

This EIS process provided BLM an opportunity to gain a better
understanding of the actual capability and productivity of the
vegetation and soils that meets the desires and needs of the public on
these lands. Unfortunately, that did not occur.

Sagebrush, juniper and other vegetation communities are now showing
signs of "extensive changes" and significant stresses, with livestock
grazing and aggressive non-native weeds recognized as among important
causal factors. 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.

### Global Warming and Desertification Processes

We want to call your attention to a new United Nations report on the
role of livestock in causing and exacerbating global warming,
desertification, loss of biodiversity, etc. Here is a link to this
document: Please see new U N Report available at:

You can download the full report at:\
 \
<http://www.virtualcentre.org/en/library/key_pub/longshad/A0701E00.pdf>
.

BLM Must develop a range of expanded actions and mitigations that will
be employed to decrease or mitigate global warming effects of livestock
grazing degradation, veg/fuels treatments, mining, energy or other
disturbance here. What levels of desertification exist across these
lands, and where are particular desertification processes occurring
and/or have occurred? How is this contributing to increased site aridity
and heating?

# Loss of Biodiversity

Levels of domestic livestock grazing disturbance, energy development,
mining use, roading and other actions under the RMP's pro-industry
alternatives will have significant adverse effects to terrestrial
wildlife. These include:

-   Loss of breeding, foraging and cover habitats

-   Increased animal displacement and loss

-   Reduction in prey availability

-   Reduction in overall biodiversity

-   Loss of genetic diversity

-   Reduction in regional carrying capacity

-   Possible population declines

BLM must fully assess all impacts of these actions and adverse effects
to habitats and populations, and loss of native species diversity. This
has not been done in the EIS.

Grazing causes incremental habitat loss and incremental extirpation of
native species. Please see the United Nations Report 2006, Connelly et
al. 2004, Dobkin and Sauder 2004, Knick et al. 2003 to understand the
significance and irreversible nature of the habitat alteration through
fire, weed invasion and other disturbance from livestock grazing and
facilities on the Forest. These effects must be openly and honestly
analyzed in an EIS.

For example, domestic livestock grazing leads to accelerated and
increased rates of loss of critical ecological components of public
lands. You must analyze all direct, indirect and cumulative impacts to
soils, microbiotic crusts, vegetation, watersheds, water quality and
quantity, native vegetation communities, wildlife habitats and
populations, biodiversity, aquatic species, rare plants, recreational
and scientific uses of these lands.

Information from new studies conducted in Wyoming related to the impacts
of habitat disturbance, loss and fragmentation and energy development on
sage grouse and other sagebrush-dependent species must be fully
incorporated in your analysis. Energy-development studies include study
of the effects of roads, developments, noise, human activity, etc. and
so are very relevant to the effects of livestock grazing activities on
these lands, plus potential disturbance associated with gas pipeline
corridor. See Holloran 2005, for example and other studies available
on-line at:

[http://www.voiceforthewild.org/SageGrouseStudies/index.html
.Please](http://www.voiceforthewild.org/SageGrouseStudies/index.html .Please)
incorporate all of this information into your decisionmaking process,
analysis of effects, and development of appropriate mitigation.

This information also discusses West Nile virus. In this process, you
must assess the role of livestock and livestock facilities and livestock
trampling promoting standing stagnant water, in transmission and spread
of West Nile or other diseases.

What livestock, energy, other development or exploration may result in
cumulative disturbance impacts to these lands?

**Imperilment of the Sagebrush Biome**

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 important and
sensitive species presence and habitat presence and quality on the lands
of the EIS area as a baseline for understanding the current status of
many species. Numerous studies were conducted in areas of Southeastern
Idaho related to occurrence, habitats or ecology of species such as the
pygmy rabbit, native reptiles, and other species in association with
research conducted at INEEL. Much of the research occurred in the 10 or
more years ago. A comparison between species occurrence and habitat
conditions and parameters documented in those studies, compared to
species occurrence and conditions at present would provide a solid
baseline for understanding changes under Land Use Plan management
schemes, and developing new approaches.

BLM has ignored the opportunity in this EIS process to act to identify
important components of native biodiversity on these lands -- and, armed
with this knowledge, develop a full range of alternatives to allow it to
take management action to enhance and restore these species habitats and
populations before it is too late.

# Sagebrush Mammal Summaries (based on Dobkin and Sauder 2004) 

Eleven of 24 species of mammals in the report by Dobkin and Sauder
(2004) are endemic to the Intermountain 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**." This demonstrates why BLM must systematically conduct
non-lethal site-specific surveys for small mammals in representative
habitat types, and assess habitat conditions, across the allotments.

The report authors concluded: 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.

A very large 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
-- including across these allotments and surrounding 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).

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).

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 the
sagebrush biome. However, management for the various "DFC" conditions
artificially arrived at in the RMP provides a very poor basis for
management of sagebrush species -- as it is premised on massive
disturbance and manipulation to try to "farm", groom and alter native
public lands vegetation to meet artificial conditions in the face of
continued livestock degradation and disturbance.

The bottom line in the PFO, given the highly fragmented nature of many
land areas, the serious invasive species problems, and the current
degradation and alteration of microbiotic crusts and herbaceous
understories, is that minimizing disturbance to these communities is
critical to prevent more weeds from overrunning them ,and more habitat
from being lost.

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, USGS Great Basin Mojave-Desert Region, Dobkin and
Sauder 2004). Species dependent on sagebrush ecosystems (Brewer's
sparrow, Sage Sparrow, Sage Thrasher), may be important predictors of
ecological collapse. Many of these species (such as the Brewer's
sparrow) thrive in areas of sagebrush canopy cover that exceeds the
artificial "DFC" levels BLM basis its manipulation schemes on.
Manipulation and disturbance that BLM seeks to impose under the RMP
alternatives, will only lead to additional loss of habitats and
populations of important sagebrush-dependent species.

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.

Virtually no areas in the Intermountain West exhibited much riparian
species diversity. For riparian birds, areas of highest species
diversity were areas of highest community stability.

Patterns of high mammal species richness were concentrated within the
three primary shrubsteppe ecoregions. Species richness was high in much
of the Great Basin. Remarkably little is known about the actual
distribution or conservation status of small-mammal species -- there is
no standardized survey. Alarmingly, there was **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**.

Many species of small mammals exist as scattered, disconnected
populations. One cannot assume species presence based simply on presence
of appropriate habitat in shrubsteppe landscapes of the IM West.

A pattern of high species richness is much more concentrated for small
mammals, and the number of endemics may represent more habitat
specificity. The authors note that very little attention is paid to
conservation needs of small mammals. Conservation efforts should
integrate areas of high species richness for birds and mammals.

Across the Intermountain West, altered fire frequencies - in the case of
the PFO especially increased fire frequencies due to cheatgrass and
other invasive species - 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, the weeds produce fine
continuous fuels that promote more frequent fires. Each successive fire
promotes 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!

Thus, it is critical that instead of seeking to impose continued
excessive, or even more, disturbance to vegetation communities, soils
and habitats on the wild lands of the PFO under all alternatives as is
done in the RMP, BLM must develop a new range of alternatives that serve
to minimize fragmentation, and restore native vegetation communities.
Also, an astonishing number of fences and other livestock developments
that serve to fragment habitats are found across the sagebrush biome
(see Connelly et al. 2004).

Biome-wide, accelerated Oil and Gas development is occurring in Wyoming.
This places landscape-scale fragmentation and soil disturbance on an
even faster trajectory. See Holloran et a. 2005 discussing many of the
adverse impacts of Oil and Gas development. We are alarmed at the
limited and inadequate range of alternatives, mitigation and monitoring
related to Oil and Gas, mining including phosphate mining, and also
energy development in the RMP. BLM must use current data and analysis on
species occurrence and habitat and develop much larger areas Closed
under the RMP to these destructive activities.

**Sagebrush Bird Species Summaries (Dobkin and Sauder 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.

All of the upland bird species, and all the riparian species listed in
Dobkin and Sauder (2004), Table 1 at 9 are likely to occur in the EIS
Project 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'sSparrow, 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.

Upland Species (summarized from Dobkin and Sauder (2004):

\* Greater Sage-Grouse. Causes of Declines: Habitat destruction,
degradation and fragmentation, altered fire frequency (both lower and
higher), livestock grazing converting shrubsteppe to annual monocultures
are Threats, range "improvements", and West Nile virus are threats.
Also, muddy cow tracks, such as at the margins of stock ponds or other
livestock trampled areas may provide necessary breeding sites for
mosquitoes in arid landscapes. Plus, large numbers of livestock may
provide an unnaturally large blood food supply for mosquito populations.

\* Ferruginous Hawk. Open areas, isolated trees, and edges of juniper
woodlands are used for hunting perches and nesting. "Prey abundance,
particularly jackrabbits and ground squirrels, is correlated
significantly with the number of breeding pairs in an area and with
reproductive success. (Dobkin and Sauder 2004, citing Jasikoff 1982 and
Deschant 2001 b) (at 36). Habitat destruction and degradation are
greatest threats, and directly influence prey abundance, important to
reproductive success. Ferruginous hawks can be particularly sensitive to
human disturbance (at 37).

\* Prairie Falcon. Open habitats with moderate grass cover and
low-growing sparse shrubs. Nest-site availability and ground squirrel
populations are important factors in habitat

selection. Activities affecting ground squirrel abundance, include
livestock grazing, frequent fires, ag conversion, poisoning. Disturbance
near nest sites (cliffs) can reduce breeding success.

\* Long-Billed Curlew. Livestock grazing can be negative if cows trample
nests, or disturb birds and cause nest abandonment.

\* Burrowing Owl. Requires low vegetation and a suitable nest burrow.
BOs may expand other species burrows, but do not dig their own.
Excavation by ground squirrels, marmots and badgers is important in nest
burrow availability. Threats are habitat degradation and destruction,
and shrub-steppe degradation by livestock or ag conversion. Pesticides
can reduce populations of insect prey and fossorial mammals. Badgers,
coyotes, birds of prey and vehicle collisions may also be problems.

\* Gray Flycatcher. Shrub-steppe, mountain mahogany and juniper. In
shrubsteppe, gray flycatchers are associated with tall, dense sagebrush.
Manipulation such as chaining or burning of sagebrush and juniper areas
is known to eliminate gray flycatchers (at 46). This species is also
parasitized by the brown-headed cowbird, a nest parasite whose numbers
are greatly increased with the presence of livestock. Habitat
fragmentation also likely increases nest parasitism and predation rates.

\* Loggerhead Shrike. Shrubsteppe, open woodland, field edges, and
occasionally riparian areas. Presence and abundance in shrubsteppe is
positively correlated with the diversity, density and height of shrubs.

\* Horned Lark. May be susceptible to trampling, and affected by
invasion of annual grasses.

\* Sage Thrasher. Habitat destruction, degradation and fragmentation are
threats, including activities that destroy shrub cover (fire, chaining,
herbicide) eliminate local populations. Although authors note that
livestock grazing may increase shrubs, livestock grazing also alters
shrub structure, especially that of taller sagebrush or other shrubs
which are the specific sites where sage thrashers nest.

\* Virginia's Warbler. P-j, mountain mahogany, mixed deciduous
shrublands. Habitat destruction, livestock grazing are threats.

\* Green-tailed Towhee. Shrublands and disturbed coniferous zones. In
shrubsteppe, its presence and abundance are positively correlated with
increased shrub species diversity, shrub cover, and taller shrubs.
Threats are habitat destruction and degradation -- livestock grazing and
frequent fire have impacted shrubs. Simplification of shrub cover
results in population reduction or elimination.

\* Brewer's Sparrow. Its presence is positively correlated with total
shrub cover, bare ground, taller shrubs, patch size, and habitat
heterogeneity -- and negatively correlated with grass and salt shrub
cover. Large population declines have occurred the in Columbia Plateau
and Great Basin. It is a cowbird host. Threats include habitat
destruction and degradation. Activities that destroy shrub cover include
fire, chaining, herbicide use, etc. A cowbird host. Positive (increased
shrubs -- see previous comments about shrub structure) and negative
responses to grazing.

\* Vesper Sparrow. Inhabits short, patchy herbaceous vegetation, low
shrub cover bare ground, forbs. Habitat destruction and degradation --
frequent fires, in conjunction with invasive grasses, heavy livestock
grazing (which increases shrub cover), and poor range conditions created
by livestock grazing during drought increase rates of nest abandonment
and failure. Cowbird host.

\* Lark Sparrow. Threats are fire and livestock grazing converting lands
to annual grass monocultures are threats.

\* Black-throated Sparrow. Desert shrub, shrub-steppe, open
pinyon-juniper. Correlated with moderate shrub cover, tall vegetation,
shrub species richness, and dead woody vegetation. Drought reduces the
number breeding attempts and clutch size.

\* Sage Sparrow. Particularly associated with big sagebrush, or may be
found in mixed shrub communities with greater shrub cover, abundant bare
ground, sparse grass cover. Shows high site fidelity. Habitat
destruction, degradation and fragmentation are chief threats, and are
caused by frequent fire, livestock grazing, range "improvements" (shrub
treatments, exotic grass plantings) -- and these promote other impacts
-- predation and nest parasitism.

\* Savannah Sparrow. It has been assumed that Savannah Sparrow
populations benefit from conversion to annual monocultures. However,
converted habitats may not be equivalent to native grassland habitats
and may serve as population sinks.

\* Grasshopper Sparrow. Livestock grazing degrades habitats. While
benefits from natural fire, annual grass conversion resulting from fire
is negative.

\* Western Meadowlark. May be affected by fire.

Other summaries of species trends support Dobkin and Sauder (2004). Many
species with downward trends in population size are associated primarily
or exclusively with shrub-steppe or riparian habitats. In shrub-steppe,
this includes northern harrier, mourning dove, horned lark, loggerhead
shrike, green-tailed towhee, vesper sparrow, sage sparrow (USGS
Mojave-Great Basin at 33-51). Populations up in one area, down in
another: rock wren, sage thrasher, Brewer's sparrow, black-throated
sparrow, western meadowlark. Population sizes of mourning dove and
loggerhead shrike, whose abundances are declining widely in western
North America are also declining in the Great Basin. The preponderance
of downward trends in shrub-steppe indicates continuing problems with
the health of this community. Likewise, many riparian species also had
downward trends: killdeer, violet-green swallow, warbling vireo, yellow
warbler, lazuli bunting, savannah sparrow, song sparrow, yellow-headed
blackbird, Brewer's blackbird. Downward trends in riparian species are
indicative of continuing deterioration of riparian habitats across the
biome.

Given the known habitat problems and downward trends across the region,
the harmful effects of vegetation manipulation and other disturbances
that form the basis of the narrow and limited range of the alternatives,
the RMP simply can not be viewed as a valid analysis under NEPA. The RMP
can not be considered to present a viable range of alternatives for
management of important and sensitive species and their habitats, nor of
the many human recreational uses and enjoyment activities conducted on
public lands tha are dependent on healthy public lands and wildlife
populations.

# Conservation Strategies, and Exotic Species/Degradation of Native Communities

Landscape-scale conservation is also a critical component of ICBEMP
assessments (see Wisdom et al. 2002). Microbiotic crust occurs in areas
that are not, or lightly, grazed. As a result, livestock grazing and
trampling impacts cause extensive, chronic and often irreversible harm
to soils, vegetation and habitats of native species. This results in an
alteration of composition, function and structure of plant and native
animal communities (Fleischner 2004)

Salt desert communities: Invasive species have impacted shadscale and
greasewood communities, and have altered their composition and function.
Livestock grazing is the most common disturbance that leads to weed
invasions and altered fuels and fire regimes at these lower elevations.
Cheatgrass and halogeton invades dry sites, exacerbated by livestock
grazing. These communities are increasingly threatened by the
proliferation of non-native annual grasses. Historically, they did not
burn.

BLM's Standards and Guides and other recent Assessments and documents
across the Project area are replete with descriptions of cheatgrass and
other invasive species being a serious problem. However, BLM nearly
always grossly under-estimates the extent of cheatgrass, bulbous
bluegrass or other weed infestations and conditions of the understory,
and fails to undertake more than token cuts, if even that, in livestock
use. In fact, BLM may allow extra grazing on degraded lands (under the
Temporary Non-Renewable Use) that may lead to further degradation, fuels
problems, and introduction of even more aggressive exotic species.

Sagebrush semidesert is highlighted for conservation because of decline
of sagebrush-obligate species. Species dependent include: sage sparrow,
Brewer's sparrow, sage thrasher, sage grouse, pygmy rabbit, sagebrush
vole, sagebrush lizard, pronghorn (Paige and Ritter 2000). Fire
regulates the density of fire-intolerant shrubs. Invasion of exotic
annual grasses has increased fire frequency in stands causing a decline
in abundance of sagebrush and other non-sprouting shrubs. In some areas,
knapweed or other noxious weed species may be invading annual
grass-dominated sites. Grazing decreases the importance of tall
bunchgrasses and increases rabbitbrush, forbs and non-native grasses.
Grazed sagebrush usually lacks altogether, or has poor condition and
highly altered microbiotic crusts. Large tracts of sagebrush semidesert
and sagebrush-steppe are needed to adequately protect these systems.

Lower montane ecological systems and middle elevations, including
juniper, low montane shrubland, mountain mahogany. Half of the species
inhabiting these sites are endemic to the region. Areas of Utah juniper
in SE Idaho are important habitats for several bird species. Under
current management, and the aggressive manipulation of the proposed
actions, these habitats are greatly threatened. Please see
"Pinyon-juniper and Juniper Birds", 2004, prepared by Red Willow
Research for the Idaho Department of Fish and Game.

Juniper habitats are threatened by grazing, fire and BLM manipulation
schemes. Many are in degraded condition, and the RMP alternatives, based
on little to no information about their current age class or structure,
seeks to radically alter juniper communities to try to create forage for
livestock.

Montane forest and woodlands. Montane islands in the Great Basin and
areas in eastern Idaho may be important for resilience of natural
communities and species responses to climate change. GBCB at 113, citing
Wharton et al. 1990.

The Partners in Flight North American Landbird Conservation Plan (Rich
et al. 2004) identifies a critical need for strategic approaches to
landbird conservation, and describes overarching threats faced by
landbirds, including: significant direct loss of major bird habitats
(including loss of western riparian, pinyon-juniper and sagebrush
habitats); fragmentation and degradation of remaining habitats due to
intensified agricultural practices, inappropriate grazing, spread of
exotic vegetation and other factors; failure to identify and properly
protect or manage habitat used during spring migration, fall migration,
and winter. Birds stressed during migration require quality habitats for
food and cover; a steady, widespread increase in dispersed mortality
factors. These factors collectively contribute to a **high proportion of
population declines and anticipated future threats.** BLM RMP planning
efforts must fully address this necessary conservation and habitat
protection and enhancement in a suitable range of alternatives.

The PIF Plan describes the growing recreational importance of birds, and
the economic importance of bird-associated recreational activities.
Birds also contribute to the maintenance of ecosystems -- from
dispersing native plant seeds to consuming insect pests. Conserving
habitat for birds will contribute to meeting needs of other wildlife.

The Plan stressed it does not advocate conservation based on single
species only, and encourages planners to identify common issues or
habitats among suites of high priority species. It assesses conservation
vulnerability based on biological criteria. PIF Assessment Factors
include: Population size, breeding distribution, non-breeding
distribution, threats to breeding, threats to non-breeding, and
population trend.

Species of Continental Importance: Includes Watch List and Stewardship
Species. Watch List: Greater Sage-Grouse, Swainson's Hawk, Short-eared
Owl, White-throated Swift, Pinyon Jay, Brewer's Sparrow, Mountain Quail,
Calliope Hummingbird, Black-capped Gnatcatcher, Virginia's Warbler.
Stewardship Species: Gray Flycatcher, Sage Thrasher, Black-throated Gray
Warbler, Green-tailed Towhee, Black-throated Sparrow, Sage Sparrow,
Grasshopper Sparrow (?), Yellow-headed Blackbird, Rough-legged Hawk
(winter?). Rosy Finch species (winter?).

Conservation of Stewardship Species will be a step towards maintaining
broader suites of species within all biomes. LCP at 31 states:
"**habitat loss remains the paramount factor for most species", and
"habitats in danger of significant loss in the near future include
western pinyon-juniper, sagebrush, and wetlands**. It describes the
impacts of habitat fragmentation, and the growth in dispersed recreation
such as OHV use.

Sadly, the series of Alternatives that would inflict large-scale
disturbance and that cast aside reasonable examination and analysis of
the impacts of the massive intervention and disturbance that would be
imposed under the RMP on these species, and the viability of populations
that will be drastically fragmented under the EIS actions.

Sage grouse are threatened by "extensive degradation of its sagebrush
habitat by overgrazing and invasive plants" (LCP at 31). Livestock
grazing "has had **enormous** **effects** on native vegetation -- a
century of selective removal of palatable plant species, soil
compaction, water developments and livestock management activities" (LCP
2004, citing Saab et al. 2004. Habitat loss and fragmentation are also
occurring on migration routes and in wintering areas.

The PIF plan promotes landscape-level natural resource planning. One
example of "measurable criteria" is number of agency plans into which
landbird objectives have been incorporated. This EIS effort provides
just such an opportunity -- yet if BLM does not prepare Supplemental EIS
and openly and honestly develop a range of conservative use
alternatives, the landbirds of the PFO will suffer accelerated
population and habitat losses

Issues identified that transcend biomes, include:

-   Habitat loss, degradation and fragmentation

-   Forestry management

-   Fire management strategies

-   Wetland Issues

-   Exotic or invasive species

-   Resource extraction/energy

-   Livestock grazing management

-   Climate change

-   Contaminants and pesticides

-   Lack of information.

The Intermountain West Avifaunal Biome is composed of 3 Bird
Conservation Regions (BCRs). "Extensive mountain ranges and broad basins
produce large elevational gradients that create a complex and variable
environment - including coniferous forest, pinyon-juniper woodland, and
cold semidesert shrubsteppe, and important wetland complexes. The IM
West is center of distribution for many birds, and over half the Biome's
SCSI have 75 percent or more of their population here. "**Threats and/or
declining trends face Species of Continental Importance that use
coniferous forest, pinyon-juniper woodland, shrubsteppe, and riparian
habitats".**

For example:

\* Coniferous forest: Species of Continental Importance (SIC) include:
Flammulated owl, Cassin's finch, others.

\* Deciduous forest: Aspen forest is a declining habitat type: SIC
include Red-naped Sapsuckers, Mountain Bluebird.

Shrubsteppe species comprise the largest number of Species of
Continental Importance in this biome. Conversion for agriculture,
invasion of non-native grasses and forbs, development, sagebrush
eradication and changes in fire frequency are major threats. This has
caused extensive loss and degradation of habitat, with subsequent
population declines. Cheatgrass has invaded over half of the existing
sagebrush habitat. It is the highest conservation priority in the
Interior Columbia Basin (Saab and Rich 1997, Paige and Ritter 1999), and
species include: Greater Sage-Grouse, Sage Sparrow, Sage Thrasher,
Brewer's Sparrow, Green-tailed Towhee. "Montane shrublands embedded in
the forests provide many species with valuable food and cover -- and may
be critical to hummingbirds during migration. Montane Shrubland SCI
include: Dusky Flycatcher, Virginia's Warbler, Calliope Hummingbird,
Green-tailed Towhee, Rufous Hummingbird, and Mountain Bluebird.

Riparian Habitats. Characteristics of riparian habitats vary widely
depending on matrix and elevation, from cottonwood gallery forests to
willow thickets. Nearly all riparian areas have been substantially
degraded by development or alteration of many types -- including
de-watering, and alteration of flows, road construction, invasion of
non-native species, logging, severe overgrazing, recreation.

Conservation issues include: Inappropriate livestock grazing, invasion
of exotic plants change in fire intensity and frequency, logging
practices affecting forest structure, and composition -- especially
mature, continued degradation of riparian habitat, conversion of
sagebrush and pinyon-juniper habitats, including through land management
practices, water diversion, alteration of flows, and spring development,
recreational OHV use.

Recommended actions: Retain large tracts of forested areas;
Maintain/promote growth of native grasses and forbs in shrub-steppe;
prevent large scale wildfire; restore with native plants following
disturbance. Maintain water quality and quantity and vegetation in
embedded springs, seeps and riparian areas. Restore degraded habitats
and habitats that have been converted to non-native grasslands. Protect
high quality riparian habitat. Restore natural flows and flooding
regimes.

Interfacing Communities/Natural Diversity and Inherent Complexity of
Plant Communities. The ferruginous hawk illustrates the importance of
understanding interfacing habitats. Ferruginous hawks typically nest in
junipers at the edge of, or interfacing with sagebrush habitats. It is
critical that BLM examine the already complex interspersion of plant
communities across the landscape. Sagebrush communities often exist as
complex mosaics with inherent natural diversity (Montana Department of
Fish, Wildlife and Parks 1995, Welch and Criddle 2003).

The ecological integrity of native plant communities is the foundation
of healthy habitats for special status species, raptor prey species, and
healthy watersheds and watershed processes that replenish aquifers for
scarce desert springs. The RMP narrow and industry-biased alternatives
take the dead opposite path, as they will result in continued and
accelerated disturbance and loss to key ecosystem components.

**Species Data and Analysis Needs**

As part of the Supplemental EIS process, BLM must conduct on-the-ground
inventories of species, and habitat conditions and populations across
the EIS area. BLM must use its current special status species list,
Partner in Flight species lists, information from the Conservation Data
Center, and other important recent summaries, such as Connelly et al.
2004 and Dobkin and Sauder 2004, and Wisdom et al. 2002, to examine
species of concern and their habitat needs. It must conduct
on-the-ground surveys for species of concern, and collect thorough and
up-to-date information on the quality and quantity of habitats across
the PFO and surrounding lands.

BLM must carefully review these lists, and updated information, and
assess habitat conditions for these species. BLM must conduct systematic
baseline surveys for breeding birds, migrants, wintering species. BLM
should work with experts to assess populations, genetic uniqueness,
etc.). BLM must also fully consider the changing dynamics in wildlife
populations -- such as the gray wolf, elk, and the high priority
segments of the public place on these species, as well as antelope and
mule deer. Then, BLM must develop a plan that will protect, and restore,
already fragmented habitats, and that protects intact areas.

Juniper is of high conservation concern (USFWS 2002, Rich et al. 2004).
Yet, these habitats are among the **most consistently
under-represented** habitat types in biological and ecological survey
efforts (Red Willow Research 2004).

High-priority species include: Ferruginous Hawk, Plumbeous Vireo,
Virginia's Warbler, and Black-throated Gray warbler. Pinyon-juniper and
juniper woodlands/pygmy forest provide important breeding habitat for
many wildlife species. Pinyon-juniper provides provides important food
for birds and other wildlife. Juniper berries remain on trees in winter,
and are important for Cedar Waxwing, Townsend's Solitaire, Pinyon Jay,
Clark's Nutcracker, Western Scrub Jay, Grosbeak sp., American Robin
(Martin and others 1951; Johnson 1998; PIF 2000). Townsend's Solitaires
establish winter territories based on juniper berry presence and
abundance.

Extensive alteration has occurred to juniper in many areas -- chaining,
spraying, and prescribed fire have been used to remove pinyon-juniper
and juniper to plant livestock forage, especially at lower elevations on
upper portions of alluvial fans and toeslopes of ranges. Often, exotic
crested wheatgrass was planted. Wildfires have consumed large acreages,
including across southern Idaho, northern Nevada and northern Utah.
Plus, large-scale die-offs of sagebrush have occurred. BLM must assess
the integrity and continuity of communities, identify higher quality
communities, and protect them from new disturbance, and act to
ameliorate ongoing, chronic disturbance of livestock grazing or other
land use practices. These areas will also provide reference areas for
unfragmented habitats.

BLM has failed to reveal the very significant manipulation and
alteration of sagebrush, juniper and forested habitats that has occurred
across the PFO. Such information is critical to understanding the
current ecological conditions, and the manipulation that has occurred in
the past. It is also essential in understanding the effects of the major
manipulation and alteration schemes to be imposed under the narrow and
limited range of aggressive and highly invasive manipulation
alternatives proposed.

Wisdom et al. (2002) provide additional information on understanding
animal species habitat needs. See Wisdom Summaries for Groups 30-35, for
example -- with two specific examples provided below. Please apply
information in this document to species and habitat needs analyses in
the EIS area. Examples:

*Group 30.* Ash-throated flycatcher and bushtit depend on a mix of
source habitats. Retain contiguous blocks of mature juniper/sagebrush,
especially old juniper with nest cavities. Consider site-specific
ecological potential and response to management before removing juniper
trees. Retain old growth, cavities, restrict pesticides, restore native
understories, minimize likelihood of exotic invasion.

*Group 31*. Ferruginous hawk, burrowing owl, vesper sparrow, lark
sparrow, western meadowlark, short-eared owl and pronghorn. Ferruginous
hawk populations fluctuate in response to prey populations. Breeding
populations of short-eared owls are nomadic, and may occur when rodent
densities are high. Burrowing owls rely on burrows provided by burrowing
mammals (ground squirrels, marmots, coyotes, badgers) and may be closely
tied to these mammals. Broad-scale changes in source habitats -- have
dramatic "decreasing" and "strongly decreasing trends". Source habitat
loss -- is tied to loss of big sagebrush. Ag. conversion, conversion to
exotics. Burrowing owl populations have declined as the result of pest
control programs. Meadowlark and lark sparrow nesting success is
correlated with grass. Removal of grass cover may have detrimental
effects, presence of livestock may attract brown-headed cowbirds and
increase brood parasitism.

Any juniper expansion may have benefited ferruginous hawks. Microbiotic
crusts have been widely destroyed by livestock. Roads, human activities
and domestic dogs. Recreational shooting of marmots or ground squirrels
impacts burrowing owls, and pesticide use may lead to direct mortality.

Management implications. Most of Wisdom habitat clusters 5 (Owyhee
Uplands ERU) and 6 (northern Great Basin, Owyhee Uplands, **Upper Snake
ERU**), with the potential risks to ecological integrity are: continued
declines in herbland and shrubland habitats.

Primary issues: Permanent and continued loss of shrubsteppe due to ag
coversion, brush control, cheatgrass invasion; Soil compaction and loss
of micrbiotic crust; Adverse human disturbance.

Strategy: **Identify and conserve large remaining areas (contiguous
habitat) of shrubsteppe vegetation where ecological integrity is still
relatively high, and to provide long-term habitat stability for
populations and provide anchor points for restoration, corridors, and
other landscape-level management. Restore grass and forb components.
Restore microbiotic crusts, maintain burrows. Minimize adverse effects
of human intrusion**.

In support of conserving shrub-steppe, identify large areas of high
ecological integrity to be managed for sustainability, on large areas of
federal land. Criteria for protect and enhance include: maintaining or
increasing the size of smaller patches, preventing further habitat
disassociation, protecting or increasing the size and integrity of
corridors, all in connection with the location of core areas. Use fire
suppression and prevention to retard the spread of cheatgrass. Restore
cheatgrass monocultures. Restore native vegetation. Design livestock
grazing to promote abundance of forbs and grasses in understory,
encourage development of microbiotic crusts. Allow burrows to persist or
expand (Wisdom et al. 2002).

We stress that the narrow and limited range of alternatives of the
current RMP fails to provide reasonable and necessary conservative
management direction and actions that are required to limit new
fragmentation and loss, and to begin to heal and recover damaged
habitats.

**Predator Killing**

BLM must assess the impacts of predator control actions across these
lands on special status animal species and native plant communities. BLM
must outlaw aerial gunning of coyotes on all PFO lands, and prohibit WS
activities that confcit with public uses of these lands. It causes
intrusive disturbance in wild land areas and may disturb sensitive
wildlife species during critical periods of the year. Activities of
Wildlife Services can damage public lands. For example, WS may harm
public lands and values by: driving roads when muddy, disturbing
wildlife during sensitive times of year; cross-country travel by OHVs
spreading weed seeds, crushing vegetation or harming soils; trapping in
sensitive species habitats or near popular recreation areas or important
wildlife habitats; altering population structure of native predators;
removing badgers that are important in providing burrows for burrowing
owls; reducing predator kills and thus reducing carrion for bald eagles
and some other raptors; accidental mortality of golden eagles or other
raptors in traps, etc.

Purposeful drastic alteration of predator communities takes place on an
annual basis in many wild lands of the West as a result of predator
killing activities conducted by APHIS/WS as a subsidy to the western
public lands livestock industry. Public lands livestock grazing is often
accompanied by aerial gunning, trapping, snaring, den gassing, poisoning
and other methods of predator removal, aimed primarily at coyotes.
Harmful impacts of removal of resident adult coyotes is discussed below
under Predation. Predator removal may also actually increase predation
by smaller predators in localized areas. Removal of larger predators
like coyotes may result in meso-predator release where smaller predators
thrive in absence of larger ones.

The placement of artificial water sources (wells, pipelines and water
troughs) for livestock may increase predator impacts on sage grouse,
pygmy rabbits and other sensitive species, by increasing predator
distribution and density. Removal of those facilities may lessen
conflicts with predators.

BLM must propose alternatives that constrain or remove WS activities
from sensitive species habitats on these lands, and fully assess the
current and foreseeable levels of predator removal and the effects of
this on the environment. Removal of native predators only results in
increased predation problems, and upsets the stable social structure of
coyotes or other native predators. If a rancher claims a predation
problem, then that rancher should be responsible for protecting
livestock by increased herding and vigilance. If the rancher is
unwilling to do that, the livestock should be removed from the public
lands.

BLM must present accurate and detailed information on the areas where
predator control activities currently occur, and the amount and timing
of such activities. BLM must develop an expanded range of alternatives
that minimize predator conflicts based on timing of livestock use,
management of livestock, and rest or avoidance of "problem" areas or
"problem" times of the year.

We are alarmed at recent proposals to expand predator killing under mule
deer or other initiatives that are being promoted by various
livestock-industry-affiliated groups. Under this RMP, BLM should fully
assess foreseeable impacts of such activities -- dubbed research or any
other names. A full suite of livestock, development and other avoidance
actions should be undertaken to minimize conflicts with gray wolf and
other important native predators.

# BLM "Range"/Vegetation Data

At present, BLM has very little current information on ecological
conditions and the health of native plant communities across the
landscape. When BLM (especially in the Upper Snake River District)
conducts its limited and narrow FRH assessments and allotment
evaluations, it relies on old data, data in databases, and often fails
to re-visits the sites where ESI data had been collected. Key Area sites
are located in only the most accessible areas, and are clustered in
particular areas of the allotments, leaving vast land areas with no
monitoring information at all collected. BLM also fails to collect
necessary data on degradation caused by livestock facilities and
management activities. Such information is critical to understanding
sources of flammable cheatgrass or other weed invasion, causes of
roading, the inter-relationship and cumulative impacts of grazing
facilities and roading. Current, comprehensive data on condition of
soils vegetation, and habitats must be systematically collected.

Plus, BLM can not ignore evidence that its limited old data does show -
i. e, only a small fraction of larger size grasses are present in most
sites that should be dominated by these species. Thus, any estimates of
"production" must be based on the reality that is much less than that of
good or better condition sites. Note: This is explained in detail
elsewhere in WWP comments. BLM must also tie water developments, water
hauling or other livestock management practices to site depletion and
alteration of species structure, composition and fuels and fire
problems. As part of this process, BLM must revisit its limited
monitoring sites, and must also establish a series of new ESI and
monitoring sites across the allotments, in all vegetation types, and
that represent levels of livestock use that occurs across these lands.

**BLM Treatments Pose Grave Dangers to Native Species**

BLM's EIS for these lands involves large-scale vegetation manipulation
proposals -- ranging from massive burning and "treatment" of conifers
and aspen communities to imposing additional and extensive fragmentation
"mosaics" across remaining big sagebrush, juniper and other habitats.
All of these proposals have serious risks for the perpetuation of native
species -- and pose great threats of escalated weed invasion and
permanent losses of native plants, animals species and biodiversity.

BLM must conduct a comprehensive analysis of pre-existing projects and
disturbance across the landscape, and include analyses of treatments and
disturbance factors across land ownership boundaries. BLM must also
assess significant ecological problems that may have arisen in the wake
of treatments.

Plus, in our past experience with BLM, the agency has much exaggerated
the needed scale of any fire prevention treatment projects that may be
necessary to protect plant communities from large-scale fires. For
example, in the Ely-Mount Wilson Urban interface near Ely, NV -- only
around 13% of the land area proposed by the Ely FO was actually found
necessary to be treated when BLM's own national-level fire experts,
having assessed the situation, developed a sane and reasonable approach.

# Grazing Suitability and Capability Analysis 

BLM must conduct a current livestock grazing suitability analysis. BLM
is aware that it has based livestock use areas and stocking rates on old
adjudication processes -- where AUMs claimed and then assigned in the
adjudication process were often greatly inflated by ranchers. These
"adjudicated" AUMs were not based on the ability of the land to sustain
such high numbers of livestock and levels of use.

In the EIS analysis, BLM must examine:

Slope, distance to natural water, dispersion of "forage" across the
landscape -- i.e. many lands have been so depleted that it takes dozens
of acres to support an AUM -- so the costs (including in weight
gain/loss of livestock) are often so great that grazing is a
resoundingly losing proposition, areas inaccessible due to winter snow,
summer desiccation, etc. Directly relevant to the RMP, much of which is
largely derived from Modeling and other efforts related to an apparently
abandoned USRD Fuels EIS process, is an assessment of the Risk that
continued livestock grazing may push habitats over ecological thresholds
from which recovery may be very difficult. Examples: Continued heavy
stocking and degradation of mountain big sagebrush opening the door to
cheatgrass invasion of understory; continued heavy stocking and
degradation of juniper leading to cheatgrass invasion of understory;
continued heavy stocking and degradation of sagebrush leading to both
juniper and cheatgrass invasion of sagebrush. See additional WWP
comments, submitted by Utah Office.

# Sagebrush and Other Habitat Assessments

Assessments of the quality of the existing sagebrush, salt desert shrub,
juniper, montane conifer, aspen and other important habitats are
necessary because: habitats and populations of species continue to
decline across vast areas; there are many sagebrush species of concern;
threats to sagebrush are regional in scale; regional knowledge
facilitates development of consistent, efficient and credible management
strategies for a comprehensive set of species. Federal land managers
have legal responsibilities for effective management of habitats for
sagebrush-associated species of conservation concern.

In order to conduct a valid EIS process, and develop a reasonable range
of alternatives, such information is essential, and despite WWP
commenting on this need to PFO in planning the USRD fuels and other
planning efforts, it still has not been done. Taxpayers appear to have
spent hundreds of thousands -- if not millions of dollars -- on
artificial Fire and other models, ad basic data is still not provided as
a basis for planning efforts.

Analysis procedures include: Ecoregion and spatial extent, identify
species of conservation concern, delineate ranges, identify habitat
requirements, identify regional Threats and Effects, estimate and map
the Risks posed by each threat, Calculate Species-Habitat effects from
all risks and other steps. Other Analyses include: **Fragmentation,
connectivity and patch size analyses, Consideration of non-vegetative
factors affecting species of concern, change detection studies**.
Regional knowledge provides essential context for land use planning.

We have reviewed the local sage grouse plans, and they fail to provide
information/conduct several necessary analyses at the appropriate scale,
and fails to present necessary information to the public, and do not
integrate necessary information to understand scale and extent of
Threats (such as livestock grazing, cheatgrass presence in understory or
domination, livestock facility fragmentation, etc.) and other habitat
degradation or fragmentation effects -- especially for mammals, reptiles
and many migratory birds. They also fail to describe or map attributes
necessary to understand the **quality of habitats** that do exist. For
example, there is no mapping or other information that shows sagebrush
habitats dominated by cheatgrass; no mapping or other information to
show where large understory grasses have been largely eliminated and
weakened, and replaced by cheatgrassor bulbous bluegrass, or
small-statured less productive *Poas*, or squirreltail.

**Threats to Sagebrush and Other Shrub-Dependent Species and Habitats
that must be Assessed in the EIS**

BLM must assess the following threats to native vegetation and special
status species and other important wildlife:

Wells and windmills

Water hauling

Pipelines

Troughs

Pipelines

Roads (often linked to livestock facilities and livestock management
activities)

Salting Sites

Weed Infestations

Powerlines

Fences

Loss of areal extent of riparian zones

Aquifer depletion

Cheatgrass-dominated understories

Cheatgrass, few shrubs

Altered understory species composition

Altered understory species structure

Altered overstory species composition

Altered overstory species structure (see, for example, Katzner and
Parker 1997, and Federal Register 68 (43): 10389-10409) describing
impacts of livestock-altered or thinned sagebrush to pygmy rabbit)

Vegetation Treatments (chainings, seedings, railings, herbicidings,
mechanical such as mowing) lacking key habitat components and associated
roading

Grazing season/disturbance conflicts with nesting, birthing, wintering
or other critical period in species life cycle

Grazing use levels fail to provide necessary habitat components (cover
or food) based on nest available science

Livestock structural alteration of shrubs

Energy project siting (wind, geothermal, other) and associated roading

Mines and mining exploration and associated roading

OHV races

Areas of high OHV use

Unregulated motorized use

Road densities

Communication towers. Powerlines, other facilities or vertical
structures

Often overlooked threats from livestock facilities and structures
include:

-   Physical harm to species - obstacles such as fences that can cause
    injury or mortality;

-   Structures cause species avoidance of areas, i.e. sage grouse avoid
    vertical structures.

-   Increased predation through providing elevated predator perches and
    nest predator perches (in the case of songbirds -- brood parasite
    perches).

-   Attracting predators and act as sinks

-   Attracting brood parasites

All of these impacts may act directly, indirectly, cumulatively or
synergistically with the effects livestock degradation associated with
lands over broad areas surrounding these facilities may have to
vegetation, soils and other habitat components. The end result is
degradation and fragmentation of habitats for important and special
status species. This must be determined before BLM can evaluate impacts
of the large-scale disturbance that it seeks to impose under the RMP
aggressive manipulation and livestock grazing, mining, Oil and Gas,
roading and other disturbance regimes under all alternatives.

The impacts of grazing during sensitive periods of the year for native
wildlife must be assessed. For example, inundating sage grouse nesting
or brood rearing habitats with large numbers of cattle or sheep during
nesting season may cause:

Removal of cover necessary to protect nesting birds and to hide and
provide essential insect food for chicks; cause flushing of birds from
nests -- thus revealing nests to predators; cause separation of broods
and increased vulnerability to predation; strip essential cover to hide
hens and nests and conceal chicks from aerial vision-oriented predators
and screen scent from ground-based predators.

BLM has failed to conduct necessary inventory, discussion and analysis
of these threats, and develop appropriate alternatives to alleviate
harms, stem new losses, and comply with sensitive species and other
important agency requirements. The whole expensive, elaborate and
contrived Modeling and Manipulation of Vegetation and Fuels schemes of
the RMP's aggressive manipulation and disturbance alternatives and
maximizing grazing, Oil and Gas, mining and other actions will not
provide for species needs.

BLM must face the reality of the extent of cheatgrass and other weeds in
understories, and degradation of understories. BLM must assess the risk
of weed invasion of understories with continued or extended livestock
use or disturbance. BLM cannot gloss over the role of ongoing livestock
grazing in continuing disturbance that spreads cheatgrass and other
weeds, retarding recovery and weakening of native vegetation in plant
communities that still have a significant component of native species
present, etc.

BLM must assess how the presence of cheatgrass and other weeds may
affect the Outcome of any disturbances to be imposed, and the effects on
habitats and populations of special status species. Plus, in any
discussion of plant communities where BLM claims the fuels/fuel loading
is too heavy, BLM must examine chronic effects related to livestock
degradation, topsoil loss and change in site potential, climate change,
etc.

# Altered Composition and Structure/Lost Productivity

Over large areas of the EIS lands, larger sized native bunchgrasses and
forbs have been eliminated, or significantly weakened. Only smaller
stature native grasses and weeds remain. How do these smaller stature
grasses affect fire behavior, outcomes of various treatments, etc.?
Appropriate stocking levels for any areas grazed must be based on the
amount of forage present on a sustainable level, and Risk of exotic
species invasions must be minimized. In addition, with extensive
depletion over large areas, BLM must assess the diminishing returns --
and increased ecological damage done by livestock having to roam over
dozens if not hundreds of acres to sustain themselves/harvest an AUM.
This leads to more trampling impacts, more weeds, etc. BLM must identify
areas where grazing is unsustainable, or where it will cause harm to
still-intact communities, as part of the Suitability analysis conducted
under the EIS.

Grazing systems, grazing intensity and season of use: Financial returns
from livestock production, trend in ecological condition, forage
production, watershed status and soil stability are all closely
associated with grazing intensity (Holechek et al. 1998). Short-term
rest or deferment can not overcome periodic heavy use. The conflicts
with wildlife habitat needs, including food, cover, nutritional
composition, space, lack of disturbance and other factors, must be
studied.

Plant Communities - Dispersion across the Landscape: The RMP does not
adequately map or assess this dispersion. BLM must inventory and assess
(including using accurate ground-truthed mapping) the full range and
diversity of native plant communities that exist across the landscape.
BLM must assess the condition of these communities, including soil
stability, erosion, presence of microbiotic crusts, possible loss of
soil horizons, susceptibility to wind and water erosion, and their
ecological integrity.

**Drought**

All impacts of livestock grazing on all elements of these lands must be
assessed during drought, and stocking rates based on non-drought years.
How does drought affect productivity of vegetation? What are the
additive, synergistic and cumulative impacts of grazing depletion and
drought on loss of plant vigor, weakening, or death?

How much are plants of good vs. poor vigor affects by drought? What
utilization levels are appropriate on drought-stressed vegetation? What
stocking rates are necessary to prevent depletion during drought? How
does drought affect fuels and fire danger in plant communities weakened
by the combined effects of grazing and drought. Do they become
vulnerable to cheatgrass and other weeds that increase fire dangers and
cause fuels problems?

# The Snake River Birds of Prey Area: Case Study in How NOT to Manage Lands 

BLM must closely examine the woeful management failures of BLM in the
Snake River Birds of Prey National Conservation Area to understand the
consequences of continuing near status quo forage allocations, livestock
project construction/water hauling, roading, etc. The 1995 USDI
BLM/IDANG report details the ongoing destruction of habitat caused by
fire, grazing and other human activity (including military training).
The loss of sagebrush in the SRBOPA is clear to even the most casual
observer driving through the area. A proliferation of exotic species --
cheatgrass, medusahead, bur buttercup, and now white top, rush
skeletonweed, and other noxious weeds - have occurred in the wake of the
excessive livestock seasons of use and numbers that have been authorized
here in the past. The grazing levels in the SRBOPA (high allowable
utilization of 50%, and many harmful grazing practices similar to those
across the RMP area, including construction of new livestock projects or
providing water in arid uplands through facilities and water hauling),
are very similar.

Over the years since the BOP has designated, we have watched as BLM has
continued to allow grazing during periods of the year that are known to
be harmful to native bunchgrasses and forbs, to allow use at high
levels, including during drought years, and generally continue
management in a manner biased towards the livestock industry.

Regrettably, instead of learning from this experience, BLM has proceeded
with the Pocatello RMP to continue on a path of continued and/or
accelerated disturbance to and fragmentation of native vegetation
communities.

**Need for Measures to Provide Increased Herbaceous Cover to Benefit
Sage Grouse And Other Special Status Species**

Sage grouse depend on a variety of shrub-steppe habitats, and
populations may move over large areas of land in the course of a year.
Overhead cover of sagebrush and tall residual native grass cover are
critical to successful sage grouse nesting (DeLong et al. 1995; Connelly
et al. 2000; Hockett 2003; 69 Federal Register (77) 21489; Connelly et
al. 2004). The sage grouse is reliant on sage-steppe communities, and
its populations have plummeted westwide. Excessive livestock grazing
strips required nesting cover that screens nests of ground- and
shrub-nesting birds from ground and aerial predators, and alters
long-term diversity of native forbs that produce insects essential to
the diet of sage grouse chicks. Sage grouse eat only sagebrush in
winter, and require intact stands for winter survival. Physical breakage
of sagebrush and nipping by livestock also alter and decrease sagebrush
cover essential for sage grouse and other sagebrush species.

The "Guidelines to Manage Sage Grouse Populations and their Habitats"
(Connelly et al. 2000), have been adopted by the Western Association of
Fish and Wildlife Agencies (WAFWA) guidelines, and present
well-established information on essential habitat components and
management based on sage grouse needs. The WAFWA guidelines are now
buttressed by the recent WAFWA Conservation Assessment of Greater
Sage-Grouse and Sagebrush Habitats (Connelly et al. 2004).

The WAFWA Guidelines and the recent WAFWA Conservation Assessment
(Connelly et al. 2004) underscore the following points with respect to
sage grouse biological and habitat needs:

• The great importance of herbaceous cover in nesting habitats (WAFWA at
968; CA at 4-4 to 4-8). Grass height and cover are important to nest
success. Herbaceous cover provides scent, visual and physical barriers
to predators. (WAFWA at 971; CA at 4-4 to 4-8);

• Successful sage grouse nesting occurs under larger bushes. Nesting
habitat has greater canopy cover, taller live and residual grasses, more
live and residual grass cover, and less bare ground (WAFWA at 970-971;
CA at 4-4 to 4-8);

• Successful nests occur in stands with greater canopy cover (WAFWA at
971; CA at 4-4 to 4-8);

• Early brood rearing habitats should have greater than 15% canopy cover
of grasses and forbs. After chicks hatch, these grasses and forbs
produce insects for chicks to eat and canopy cover to screen them from
predators. Later, forbs are eaten by maturing chicks. Forbs are also
important in providing adequate pre-laying nutrients to hens (WAFWA at
971; CA at 4-8 to 4-9);

• As upland vegetation desiccates, hens with broods seek out late brood
rearing habitats comprised of areas with succulent green forb
vegetation, such as wet meadows and riparian areas (WAFWA at 971; CA at
4-9 to 4-11);

• Winter habitats have relatively dense sagebrush canopy cover, with
sagebrush exposed above the snow (WAFWA at 972; CA at 4-14).

105\. Habitat protection management actions for sage grouse are
summarized in the WAFWA Guidelines, and include:

• Manage breeding habitats to support 15-25% canopy cover of sagebrush,
18 cm. or greater perennial herbaceous cover height (grasses and forbs)
(WAFWA at 977);

• In late summer brood rearing habitats, "avoid land use practices that
reduce soil moisture effectiveness, increase erosion, cause invasion of
exotic plants, and reduce abundance and diversity of forbs" (WAFWA at
980);

• "Avoid developing springs for livestock water." If this must occur,
"design project to maintain free water and wet meadows at the spring,"
as "capturing water from springs using pipelines and troughs may
adversely affect wet meadows used by grouse for foraging" (WAFWA at
980).

In addition, US Fish and Wildlife Service (69 Federal Register (77) at
21491 describes studies showing that losses of hens and nests are
related to herbaceous cover surrounding nests. "Enhancing Sage Grouse
Habitat, a Nevada Landowner's Guide" (Northwest Nevada Sage Grouse
Working Group) also cites studies showing that sage grouse nests were
least preyed upon when a residual cover of 7 inches or more of
herbaceous vegetation was present.

Thus, there is strong scientific support for application of grazing use
standards that provide for 7-9 inches of residual stubble height left
uneaten on native grasses. Unfortunately, the livestock utilization
levels now being applied across the USRD and adjacent Forest and other
lands do not adhere to these requirements, and **will not provide for
necessary residual stubble heights and cover for sage grouse nesting**,
even under normal circumstances -- let alone under drought, or weakened
or low vigor conditions.

An EA from the BLM's Jarbidge Field Office (BLM Jarbidge EA, Ch. IV, pg.
88-89). The public lands of the BLM's Jarbidge Field Office are similar
to the Upper Snake and PFO, and are shrubsteppe and other communities,
with species of native bunchgrasses that are similar to the Jarbidge
lands. BLM has found that with 50% utilization levels, as allowed across
the EIS lands, bluebunch wheatgrass is grazed to 4.5 inches, Idaho
fescue is grazed to 2.0 inches, Thurber's needlegrass is grazed to 2.8
inches, bottlebrush squirreltail is grazed to 1.5 inches, and the exotic
crested wheatgrass is grazed to 3.5 inches. All of these residual
stubble heights are thus far less than the 7-9 inch stubble heights
called for under the best scientific information available, such as the
WAFWA guidelines discussed above; and demonstrate that grazing under
BLM's current management will result in far more utilization and
seriously inadequate cover for sage grouse on the allotments in
question. Plus, BLM's woefully inadequate upland utilization levels and
hand full of riparian stubble heights are not required Terms and
Conditions on grazing permits, so there is no assurance that compliance
will occur.

In many areas across the EIS area, livestock grazing has caused
depletion of larger-sized native bunchgrasses capable of providing grass
heights sufficient to mask sage grouse nests and to protect nests and
chicks from predation. These larger "decreaser" grass species have been
replaced with smaller "increaser" grasses like small *Poas*
(bluegrasses) or unpalatable weeds. The direct, indirect, synergistic
and cumulative impacts of the any treatments under the various EIS
alternatives must be assessed in relation to such livestock impacts to
sage grouse and other species habitat components.

# Harmful Impacts of Livestock Facilities: Habitat Degradation and Fragmentation 

A growing body of scientific evidence demonstrates the negative impacts
of fences and other vertical objects, as well as the increased
fragmentation of sagebrush-steppe and other wild land habitats that
result from placing vertical objects in sage grouse habitats. (Connelly
et al. 2004).

BLM must conduct a full inventory and assessment of all existing
livestock facilities and developments on the allotments, all water haul
and salting sites, and all vegetation treatments that have been
conducted on these lands. The full array of direct, indirect, cumulative
and synergistic impacts of these projects and activities must be
assessed, and facilities identified for de-commissioning or removal
under a range of alternatives.

A substantial body of scientific information demonstrates the harmful
impacts of fences and other range developments on sage grouse. Sage
grouse evolved in an open landscape without vertical structures, and
they naturally avoid using areas near these structures - which include
fences and fence posts. Sage grouse habitats are fragmented by fences
and other facilities associated with grazing (USFWS 69 Federal Register
(77) at 21490). Fences and other facilities (as associated with wells,
pipelines, troughs and water developments in the three allotments)
provide perching locations for raptors, and associated roading that
grows up along fences or in association with other livestock facilities
provides both travel corridors for predators and conduits for weeds (69
Federal Register (77): 21490). Mechanical treatments and seeding with
exotics degrades sage grouse habitat by altering structure and
composition of vegetative community (69 Federal Register (77): 21488).
Development of springs and other water sources to support livestock in
upland shrub-steppe habitats can artificially concentrate domestic and
wild ungulates in sage grouse habitats, and worsen grazing impacts (69
Federal Register (77) at 21489). Direct mortality of sage grouse from
collisions with fences is described in the WAFWA guidelines at 977, and
USFWS in 69 Federal Register (77) at 21492.

Sage grouse are a landscape-scale species, inhabiting large,
interconnected expanses of sagebrush. A mosaic of fragmentation now
exists across many parts of the landscape, including portions of these
allotments, and BLM's Proposed Action would extend and worsen
fragmentation effects across the landscape. Causes of habitat
fragmentation include vegetation treatments and removal of sagebrush,
wild and prescribed fire, livestock facilities and zones of livestock
concentration. There is mounting evidence of long-term negative effects
of fire on sage grouse populations (WAFWA Conservation Assessment at
4-16, 7-28), 80% of the land area in the Great Basin is susceptible to
displacement by cheatgrass (WAFWA CA. at 7-17 and Fig. 7.10). Wyoming
and basin big sagebrush shrub cover types occupy large areas in the EIS
lands and are the cover types most susceptible to displacement by
cheatgrass (these areas comprise large portions of the three
allotments). The ecological effects of livestock grazing grazing may
alter vegetation communities, water and nutrient availability and soils
so that **lands cross thresholds from which the system can not recover**
(WAFWA CA. at 7-29 to 32). Habitat treatments have consequences for the
habitat dynamics and wildlife use of habitats -- and "each potentially
decreases the suitability of sagebrush for wildlife" that depend on
large, unfragmented sagebrush habitats" (WAFWA CA at 7-32). Evaluation
of sagebrush communities primarily based on their ability to produce
livestock forage (as in the case of these lands), may result in
extensive alterations that are unsuitable for sage grouse and other
species dependent on sagebrush habitats (WAFWA CA at 1-3).

Fences influence livestock and predator movement, facilitate spread of
exotic plants, provide travel and additional access for human
disturbances, increase mortality due to direct collisions, and increase
predation rates by providing perches for raptors (WAFWA CA at 7-34 to
35).

Fences used to control grazing (or in the aftermath of the treatments
that may result under various EIS alternatives) modify the landscape by
creating an artificial mosaic (WAFWA CA at 7-35), and allow more
intensive grazing and loss of necessary habitat components such as
residual grass cover for nesting. Intensified or more uniform use inside
fenced areas results in patterns of unusable habitat across the
landscape. Water developments influence the composition and relative
abundance of plants (WAFWA CA at 7-35). Thus, infrastructure to support
grazing programs including fences and water developments have both
direct and indirect effects on the landscape (WAFWA CA at 13-9). Grouse
may not commonly use water developments, and "water developments tend to
attract other animals, and may serve as a predator "sink" for sage
grouse, i.e. grouse fall victim to the many predators attracted to water
developments (WAFWA CA at 4-12).

The Conservation Assessment describes impacts of disturbance of
sagebrush habitats by vegetation treatments (at 13-6); depletion of
native vegetation facilitating cheatgrass invasion (at 13-7); problems
associated with blocks of crested wheatgrass and exotic seedings (at
13-7 to 8); landscape-level concerns -- including that areas with larger
patches of sagebrush remaining receive lower precipitation and are the
least resilient to disturbance (such lower precipitation areas
characterize much of the Owyhee, Big Springs and Sheep Complex
allotments, and this highlights why careful management of these lands is
crucial) (at 13-8 to 9).

An unknown array of livestock facilities has already been constructed
throughout the three allotments (on both BLM and private lands) to
facilitate, extend and concentrate livestock grazing. These facilities
include wells, windmills, spring developments and water diversions,
pipelines, troughs, stock ponds -- at times dug into and destroying
springs, fences and corrals. Some have fallen into abject disrepair --
windmills lie crumpled on the ground, junk tanks and troughs are strewn
across the landscape. Fences have improper spacing. Not only do these
facilities concentrate large numbers of livestock with deleterious
impacts to soils, vegetation and wildlife habitats in their vicinity and
radiating outward over broad areas, unplanned roading is often directly
related to construction or maintenance of these facilities. Plus, there
are innumerable livestock salting or mineral supplement sites, too,
which also result in zones of intensive livestock disturbance and
incidental roading. All of these areas of livestock concentration, where
heavy and severe livestock use has compacted soils and destroyed cover
and food for wildlife, exhibit harmful impacts to vegetation and native
wildlife habitats. These developments and zones of intensive disturbance
fragment habitats, and cover and food, for native species including sage
grouse (Braun 1998; Freilich 2003; Connelly et al. 2004). Such projects
have been constructed throughout habitats critical for sage grouse and
other shrub-steppe species. New pipeline spurs incrementally constructed
would extend and shift livestock use to new and less grazed areas, as
the vegetation has been depleted by livestock around existing artificial
or natural water sources (Sada et al. 2001).

BLM's EIS lands that are not close to livestock water sources often
comprise the best remaining healthy native vegetation communities and
are thus very important habitats for native sagebrush-steppe species --
precisely because they have been far less altered by livestock impacts.
BLM should identify these lands as part of the RMP process, and develop
alternatives that prevent new facilities development across these areas.

On top of the existing network of facilities BLM treatments may result
in plans to construct dozens of new projects (such as fences and/or
water sources), thus greatly expanding the zones of disturbance and
intense livestock concentration. Networks of roads associated with
livestock facilities (and which will likely grow dramatically as
vegetation is burned or otherwise treated and thus cleared under the RMP
disturbance alternatives) serve as conduits for exotic plant invasions
(Gelbard and Belnap 2003), and travel corridors for predators (Braun
1998, Connelly et al. 2004). The development of a maze of roads
fragmenting the landscape has resulted from the proliferation of
livestock facilities across the landscape. Roads grow up as projects are
constructed and maintained.

Instead of attempting to rest to enhance habitats or jump start
recovery, or place strict use limits on degraded riparian areas, BLM
typically relies on the construction of band-aid fenced exclosures, with
accompanying development and de-watering of wetland areas through piping
water to troughs. Large areas outside exclosures then become a
wasteland. An increasing body of science demonstrates that fences are
harmful to sage grouse and many other species of native wildlife, and
that sage grouse may avoid use of areas near fences. BLM's
post-treatment actions may in fact further fragment habitats beyond
removal of vegetation, and rendering patches of remaining untreated or
native vegetation unusable by grouse, while creating extended wasteland
areas in their surroundings, causing expanded environmental harm.

Instead of taking strong and decisive action to restore and enhance
habitats and populations, BLM's RMP pursues a path of new and extended
habitat alteration and fragmentation across these lands under the guise
of Fuels, a contrived and artificial DFC, and restoring an historic fire
interval that can no longer be considered natural under the chronic
disturbance caused by livestock and in the face of exotic species
invasions.

Degradation, fragmentation and loss of sagebrush across landscapes has
imperiled the sagebrush-steppe avifauna. Besides the many effects
described for sage grouse, these habitat changes and fragmentation have
been shown to affect abundance of shrub-steppe birds Paige and Ritter
1999, Knick et al. 2003, Connelly et al. 2004 at 1-3.

The habitat for many native wildlife species across the EIS lands is
already fragmented. Fragmentation would continue and escalate with new
livestock developments, livestock management practices that result in
zones of livestock concentration, and other disturbances under the EIS
actions as laid out in the DEIS. Disturbance and depletion associated
with livestock grazing and associated rangeland developments serve to
break up and fragment the continuous cover of native sagebrush-steppe
vegetation necessary for many sagebrush-dependent wildlife species
survival (Knick and Rotenberry 1995; Knick et al. 2003; Freilich et al.
2003; 69 Federal Register (77), Connelly et al. 2004).

This all demonstrates why BLM must abandon its alternatives that would
radically alter large areas of the PFO, impose continued or increased
disturbances. Instead, BLM must prepare a Supplemental EIS and develop a
range of new alternatives to enhance and restore public lands, native
vegetation and important and special status species habitats.

**Paleontological Values**

The impacts of livestock grazing and facilities, and the land disposal,
development, energy, mining and other actions of the RMP must be much
more completely examined in relation to impacts on paleontological
values of these lands. Paleontological values are threatened by
haphazard collection (exacerbated by exposure of soils due livestock
erosion, facilities, networks of roads, mining, logging, treatment and
other disturbances). Livestock grazing and trampling results in site
erosion, exposure of fossils or strata and other impacts. BLM must
inventory and assess paleontological sites, evaluate impacts of grazing
activities and facilities on these sites, and identify measures to be
taken to protect them from damage or loss.

**Road Rehab/Restoration**

A large number of the roads have been pioneered or constructed due to
ranchers driving salt to the top of hills, because they access cattle
installations, or have just spring up on the path of a pipeline due to
construction and subsequent maintenance.

Incursions on unroaded lands are routine -- such as those undertaken by
livestock permittees to develop or maintain water sources, place
livestock installations, place salt licks and minerals,, etc. As part of
its analysis, BLM must examine roading in the context of livestock
activities. Roads and jeep trails whose primary purpose is placing salt
or checking on a water trough should be closed and restored/obliterated.
Livestock permittees own horses, and can and should use them in pursuing
public lands livestock grazing.

BLM, as part of this Travel/Recreational Use Planning, must identify
methods of road closure and restoration and set a time table for
accomplishing this.

All direct, indirect and cumulative impacts of existing, and foreseeable
new roading linked to mining, wind, geothermal, and other energy
development or corridors on populations of special status species and
other important values across the region must be considered.

### Economic Analyses of Livestock Costs

BLM must detail its annual cost of administration of livestock grazing
on affected lands under the current and alternative systems. BLM must
provide the percentage of these administrative costs that are covered by
BLM's income from the approx. very meager grazing fee, and present this
to the public in its economic analysis.

BLM must detail its other costs in administration of these lands
(recreational opportunities lost, weeds invading and treatments,
increased fire treatments and/or suppression costs with livestock-caused
weeds like cheatgrass) and present this to the public in its economic
analysis. This is necessary to understand the administration of
livestock grazing. Of particular concern is the lesser funding
traditionally spent on wild lands restoration, habitat enhancement,
collection of baseline biological data, etc.

## Roads Dissect Habitats and Provide Weed and Predator Corridors

Direct effects of roads are destruction of habitat and disruption of
dispersal corridors. Indirect effects of roads are cumulative and
involve changes in plant and animal community structure and ecological
processes. Roads fragment and isolate populations in species that are
hesitant to cross them. Direct habitat loss, facilitated invasion of
weeds, pests and pathogens, altered predation rates -- are all a
consequence of roading.

Many weedy plants dominate and disperse along road sides. Opportunistic
animals benefit from roads. Edge effects are now seen as harmful
consequences of habitat fragmentation for many native species. Indirect
effects include increased human access, OHV use, hunting, human-caused
wildfires, Roads diminish native diversity of ecosystems. Many roads in
rugged western terrain follow streamcourses, so are constructed through
the middle of big sagebrush sites following drainages and draws that are
critical as dispersal corridors for pygmy rabbits.

Roads further fragment wildlife habitats and dispersal corridors, and
serve to isolate wildlife populations. Energy development and production
activities require vast networks of new roads, cutting across sagebrush
habitats, as previously described.

Mining, oil and gas, geothermal and wind development, cause extensive
new roading. Roading associated with exploration and development
results. Roading facilitates weed spread.

**Utility Corridor, Powerlines Dissect Wildlife Habitat, Provide Raptor
Perches, Result in Increased Predator Travel Corridors and Weed Spread**

Powerlines are known to isolate and impact sage grouse populations. Sage
grouse use of areas near powerlines increases as distance from the
powerline increases for up to 600 m., plus powerlines reduce the
security of sage grouse populations in linear strips up to greater than
1 km. in width (Braun 1998). Powerlines may follow roads, or cut cross
country through otherwise unfragmented sagebrush habitats.

Residential development throughout the Intermountain West is accompanied
by networks of powerline and utility lines, and a resulting myriad of
raptor perches. Communication tower sites also introduce vertical
features with adverse effects into shrubsteppe habitats -- how will the
RMP limit such development -- especially in the highly fragmented
landscape of the PFO where all remaining shrubsteppe should be managed
to prevent further fragmentation or loss?

Powerlines often cut cross country, accompanied by maintenance roads
that may serve as travel corridors for predators, weed infestation,
hunters, etc. Geothermal and wind development are accompanied by
extensive powerline proliferation and agency issuances of
rights-of-ways. This planning process must develop a range of new
alternatives that sharply limit new powerlines, communication sites,
etc.

Military Training Impacts Must Be Assessed

Impacts of military activities or overflights on public lands must be
fully assessed in this land use plan process, and the impacts -- use of
flares causing fires, noise or low level flights interfering with
wildlife or recreational uses, etc. must be fully addressed. Do military
training activities occur on these lands, or in airspace, and if so,
what are the levels, and what are the effects, and how might they change
over the life of the Plan?

# Weeds/Exotic Species

BLM must take all possible steps to prevent the spread of weeds into
native vegetation communities. Weeds are spreading at alarming rates on
arid western lands. BLM must first recognize that domestic livestock are
the primary cause of weed infestation on BLM lands. Livestock: Travel
cross-country transporting weed seeds in mud on hooves, in fur, in
feces. They create zones of intensive disturbance that are ideal sites
for initial infestation by weeds. They prime sites for weed invasion by
harming and weakening native plant communities, providing bare soil
sites for aggressive exotic species invasion. See Belsky and Gelbard
(2000).

BLM must inventory all lands and assess their vulnerability to weed
infestation. Strong preventative measures necessary to stem and reverse
the tide of weed invasions must be identified and put into action. In
the past. BLM has shrugged off and ignored the role of livestock in wed
infestation. Its only attempt at control was spraying the most obvious
weed patches, taking no efforts to revegetate the "nuked" sprayed sites,
and continuing to let livestock graze as normal and continue to spread
weeds. This head in the sand approach has resulted in the alarming weed
problem we now face.

White top is rapidly expanding in Planning area lands. These are spread
by livestock, and once established in disturbed areas move aggressively
into surrounding lands. They are also spread along disturbed road areas,
and by vehicles.

Livestock should be quarantined for a period of 4 days before entering
public lands, and be fed only weed-free hay. Any lands with known weed
infestations should not be grazed until the weed problem is addressed,
and weeds have been eradicated. Livestock grazing must be sharply
restricted or ended on lands at risk to weed invasion. Livestock
projects that result in concentrations of animals and epicenters of weed
infestation should be removed, and disturbed sites restored. BLM develop
a range of alternatives that focs on integrated weed management.

Roads and vehicles are also a major source of weed transport, and soil
disturbance that creates ideal sites for weed infestation. Banning
cross-country travel by ORVs, closing and restoration of roads and ways
in wild lands are logical ways to limit spread of weeds. Limiting road
maintenance activities is also important, as the blading of
ever-widening shoulders on gravel and dirt roads provides an ideal site
for weed infestation and then outward spread.

Various mineral and energy exploration activities involve significant
cross-country travel by heavy equipment that disturbs soils and/or
spreads weed seeds. These activities should be prohibited in all lands
with known weed infestation, or which are identified as being "at risk"
for weed invasion or spread.

BLM must make land use allocations that prevent lands from undergoing
weed infestation. As you may be aware, WWP, CHD, ALA, NCAP and others
have submitted a Citizens Alternative to BLM for its Programmatic
Vegetation/Weed EIS, that we understand may be near finalization. Our
alternative addressed causes of weed infestation, and provides actions
to address those causes. These actions included
changes/reductions/cessation of livestock grazing, road closure and
other actions that are aimed at effectively addressing causes of weed
invasion and spread. Unfortunately, BLM ignored nearly all elements of
our proposal as well as comments, and instead develop a large-scale
disturbance PRMP with an Attached Manipulation report of that will
greatly expand disturbance, loss and fragmentation of habitats without
addressing CAUSAL factors of weed invasion and spread across the public
lands. Thus, it is imperative that you act in this RMP to develop a
broad range of alternatives based on passive restoration and maintaining
integrity of currently less-fragmented habitats.

BLM must also address measures to restore lands where weeds have been
treated. Instead of spraying large areas with lingering herbicides that
result in large "dead zones" in soils, and then continuing status quo
grazing -- which typically results in weeds thriving while all native
vegetation on the site perishes -- you must remove livestock
grazing/vehicles -- whatever the disturbance factors are to a site --
until it is fully restored with native vegetation, healthy microbiotic
crusts. This is essential, as the "Programmatic" weed document is not
sensitive to the already much-fragmented and altered lands of the PFO.

Sincerely,

Katie Fite

Biodiversity Director

Western Watersheds Project

PO Box 2863

Boise, ID 83701

208-429-1679

Russell Heughins

Idaho Wildlife Federation

921 S. Orchard, Suite H

Boise, Idaho 83705