![](media/image1.png){width="5.993055555555555in"
height="1.6208333333333333in"}

October 4, 2006

Mr. Jose Noriega

Santa Rosa Ranger District

1200 Winnemucca Blvd. East

Winnemucca, NV 89445

RE: OBJECTION to File Code 1950, Letter (September 27,2006) and Decision
Memo (September 27, 2006) of Humboldt-Toiyabe Forest Santa Rosa District
Ranger Noriega for the environmental analysis for the Buttermilk
Mechanical Treatment Project.

Western Watersheds Project (WWP) hereby files an Objection to the
Decision Memo (DM), letter, and environmental analysis of Santa Rosa
District Ranger Noriega, File Code 1950, Letter and Decision Memo
(September 27, 2006) for the environmental and "Healthy Forests"/fire
funding and analysis for the Buttermilk Mechanical Treatment Project, as
well as the segmentation of the process to which this is linked -- i. e.
the Buttermilk Burn March 31, 2005 DM and April 4, 2005 letter, signed
by Manager Noriega also.

The Forest's Decision Memo (DM) failed to address issues raised by WWP
and other members of the public in comments on this project over the
years. The Forest did not collaborate with the ALL of the Interested
Public - and instead shoved this project down our throats, ignoring
legitimate input and concern. The Forest held a tour on the Buttermilk
project in 2004, and excluded WWP and CHD - while inviting other
conservation groups.

The Forest has woefully segmented projects to avoid necessary analysis
at the level of an EIS -- and has carried out and may be planning even
more of a series of hazardous fuels and other projects within the
project area. This violates NEPA.

The Forest also violated the even the Bush Healthy Forest Initiative
regulations in conducting 2 projects totaling 4500 acres and 1000 acres
under the same process. See Buttermilk prescribed burn Decision Memo.
The Forest has already burned up and greatly fragmented significant
acreages of pygmy rabbit habitat, and greatly increased fragmentation of
habitats, in its prescribed burns, and now seeks to impose additional
killing and destruction of sagebrush on pygmy rabbit and other sagebrush
dependent species in the lands of the Martin Basin area.

Meanwhile, large areas of the Santa Rosa Ranger District are choked with
cheatgrass, all manner of thistles and other weeds -- yet the Forest
seeks only to generate more weed-causing disturbance, rather than
focusing its efforts on killing cheatgras and growing native vegetation
in such sites.

WWP has participated in various decisionmaking processes and commented
on ecological problems on the Forest and within the Santa Rosa Ranger
District -- ranging from comments on mining proposals to the Martin
Basin rangeland EIS. We have made repeated site visits to these lands,
including lands within the Project Area and neighboring BLM lands. We
have documented our concerns and observations of ecological conditions
here over the years.

Our members use these public lands - including those within the project
area, for recreational, scientific/nature study, hiking, birdwatching,
photography and other purposes. We have raised serious concerns with the
Forest about livestock grazing in the project area and nearby lands.

Our Appeal of the recent Martin Basin Rangeland EIS ROD was affirmed
last month by the Forest Appeals Officer.

The Martin Basin EIS documented serious ecological problems across the
EIS area, and within the Buttermilk project area. Ranger Noriega ignored
analysis of the impacts of the large new disturbance - on top of serious
ongoing cattle disturbance damage - that will result from the latest in
a series of segmented Buttermilk area vegetation and other Projects. All
of these projects attempt to mitigate or patch the pervasive damage
being caused by cattle to these lands.

The Forest previously signed a separate Decision Memo for a Burn as part
of the same Scoped project in 2005. Original joint scoping occurred in
April 2004. A field trip related to the was held in April 2004 to which
only a select group of the public, and not WWP or CHD, was invited.

The project area encompasses over **80 square miles --** demonstrating
the need for an EIS**.** See DM Map in various tones of gray "Buttermilk
Prescribed Burn". WWP notes the Forest could not even be bothered to
change its poor map to show sagebrush killing areas under the recent DM
separately, or to provide necessary detailed and readable mapping.
Instead it mailed out a map in various tones of gray with no named
geographic features of any kind named.

Examination of the BLM 1:100,000 Land Status Map for the area shows that
the projects lie within the watersheds of several streams, including LCT
streams.

Peering closely at the gray DM Buttermilk Prescribed Burn Map while at
the same time looking at BLM 1:100,000 Land Status Map shows that part
of Unit 5 that the Forest plans to treat is apparently private lands.
The Forest never assesses the ecological condition of nay lands -- let
alone the private lands, its ability/inability to control grazing, or
why taxpayers should spend money treating private lands, or any
essential information related to the complex land ownership in or near
the Project Area.

The Forest never reveals if its prescribed burning that was done stayed
within the confines of the "units" sketched on this "Prescribed Burn"
map, how many acres or in what pattern were burned, etc.

The Project Area is a lovely and beautiful sagebrush and
sagebrush-mountain mahogany landscape that will be seriously altered by
the sagebrush killing, re-seeding with species including non-native
vetch and large unspecified cultivars that are not the local native
grasses in order to promote cattle forage. There is great risk of
expanded weed infestation with the extensive soil and vegetation
disturbance of the sagebrush killing/cattle forage project of the DM.
The Project Area encompasses watersheds of streams occupied by, or
important for recovery of, LCT.

The project area contains important habitats for Forest Species of
Concern -- the pygmy rabbit and sage grouse, and declining
sagebrush-obligate migratory birds -- including loggerhead shrike and
Brewer's sparrow. It also contains diverse big and low sagebrush
communities, and these are not accurately or adequately described by the
Forest.

The pygmy rabbit is of particular concern. It digs burrows in the
ground, and burrows will be crushed or collapsed by this action. The
pygmy rabbit requires dense big sagebrush cover to escape predation and
for food -- this is precisely the type of habitat that the Forest seeks
to destroy in this project through Dixie harrowing and crushing. Plus,
this is the specific type of sagebrush habitat that the Forest
previously destroyed with prescribed fire by spending lavish amounts of
federal fire funds.

The habitat that the Forest seeks to destroy is also important as pygmy
rabbit dispersal habitat. By killing, smashing and harrowing the
sagebrush, the Forest will destroy habitat connectivity - further
harming viability of pygmy rabbit populations here. See Federal Register
Notice -- describing habitat needs of the Columbia Basin DPS of pygmy
rabbit. The habitat requirements of the pygmy rabbit across the rest of
its range -- including the Project Area -- are similar. This document
can be found at:
[http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov/2003/pdf/03-55507.pdf#search=%22pygmy%20rabbit%20federal%20register%20march%202003%22](http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov/2003/pdf/03-55507.pdf#search=)

. 50 CFR Part 17. Federal Register Vol. 68, No. 43, March 5, 2003.
"Endangered and Threatened Wildlife and Plants: Final Rule to List the
Columbia Basin Distinct Population Segment of the Pygmy Rabbit
(*Brachylagus idahoensis*) as endangered.

These lands have undergone chronic and extensive degradation by cattle
grazing and trampling. Yet the Forest in this project seeks to kill the
sagebrush that is critical for rare and declining species here -- and
plant cow food forage -- including exotic species and cultivars of
non-native ecotypes.

Over 2 years ago I commented on the original Scoping for the Buttermilk
project that has now morphed into two segmented actions. WWP also
commented on a series of three projects in the Buttermilk area and
specifically referred to the proposal to do a prescribed burn in
Buttermilk country in a letter of August 18, 2005. The Forest
purposefully segmented projects to avoid doing an EIS.

Now, Manager Noriega has morphed a prescribed burn proposal - after
having already burned a significant amount of important sagebrush
habitat acreage within the project area - into a sagebrush killing,
crushing and re-seeding project including with non-native vetch and
cultivars of grasses. Manager Noriega never reveals where and how much
acreage of sagebrush was consumed in the prescribed fire, or the
relation of the new treatments to the areas actually burned. The DM does
not discuss the extensive cattle trespass of the prescribed fire areas
that occurred -- as this would demonstrate the inability of the Forest
to control cattle across the Project Area. I observed cow manure in the
burned area that I visited in summer 2006.

WWP believes that the Forest has applied no real assessment of any need
for treatment of the area under the HFI or any other law, and has failed
to demonstrate why the public should spend thousands of dollars on this
project that would destroy sagebrush habitats important to many native
species.

We believe that the Forest is seeking to conduct projects in order to
keep a large amount of federal fire funds flowing to support personnel
and other purposes in the District or on the Forest, as well as to
promote forage for privately owned cattle at the expense of rare and
declining native species and recreational and aesthetic values of the
public lands. The public has not been told the planning and
implementation costs of this project.

The Forest's DM ignores information and comments on ecological
conditions and current and future livestock grazing impacts, soils,
microbiotic crusts, waters, watersheds, weeds and weed proliferation,
roading/road expansion or proliferation, rangeland health, the use of
fire science, linked pollutants such as increased sedimentation or
runoff containing chemical herbicides that may be used to suppress weeds
in these lands with serious weed infestation problems - and the
downstream transport of such substances and their impacts to the public,
recreational values, cultural values, scenic values, important wildlife
species habitats or Threatened Lahontan cutthroat trout values.

The Forest has not conducted necessary analysis to determine if this
watershed is capable of withstanding the accelerated erosion of soil and
water that will occur in the aftermath of the new disturbance, the
extensive existing cattle grazing impacts, or the effects of the removal
and further fragmentation of protective sagebrush cover that helps
buffer and slow runoff events from upland watersheds.

The Forest has not conducted necessary analysis to determine the
combined impacts of all of the various projects (See various Forest
Project documents Attached) - as well as harmful livestock grazing as
documented in the Martin Basin Rangeland EIS. See also Attached letter
of June 6, 2006, WWP letters of August 18, 2005 and August 24, 2005.

WWP has provided the Forest with new and updated information not
assessed in range Noriega's cursory "we'll do whatever we like and
ignore NEPA requirements" DM. Please see WWP Appeal of Martin Basin EIS,
and Attached Photos and other information. The Forest has been presented
with new information, and has ignored it.

# Impacts to Watersheds, Water Quality, Aquatic Biota

The Forest failed to address concerns and conduct necessary baseline
analysis to understand the deleterious impacts of this series of
segmented project/treatment disturbances to the watershed, including
soils, waters, and accelerated downstream transport of harmful
pollutants (such as mercury) into surface waters.

There is no baseline information provided on gullying, water quality,
sediment and other erosional concerns, temperature, or the aquatic biota
(such as Lahontan cutthroat trout populations and habitat health) within
the project areas, or downstream areas, that may be harmed by the
project -- or by the combined effects of burning, grazing and other
severe disturbance in the same watersheds. Thus, the Forest can not
conclude that this Decision is consistent with the CWA.

The Forest has failed to reveal the location, flows, or condition of
springs, seeps, meadows, intermittent drainages or perennial drainages
across the project area.

The Forest does not provide sufficiently clear and detailed mapping
necessary to understand the impacts of the Decision.

**Impacts to Important Biota**

The Forest has failed to demonstrate that it conducted adequate baseline
surveys for important wildlife and aquatic species during the
appropriate time of year to detect them, or that is studied the direct,
indirect and cumulative impacts of this and other projects on these
species. These species include especially pygmy rabbit, sage grouse and
migratory birds.

WWP has observed pygmy rabbit and sage grouse sign within the Project
area (biologist K. Fite, field observations - summer 2006). The Forest
knows there are pygmy rabbits in this area, and that sagebrush habitat
loss is a critical issue.

The Forest's Wildlife Specialist's Report for the Martin Basin EIS noted
**"critical" concern about the "loss of native sagebrush habitat for
native fauna that depend solely on sagebrush"** (at 2). The WS Report at
2-9 also described a host of concerns and harms to wildlife habitat that
are associated with livestock grazing under Alternative 1, which is the
current situation, in the lands of the DM Sagebrush Killing project. The
WS Report at 5 stated: "A common effect to vegetation from livestock
grazing in the allotments under this alternative is a reduction of
litter and residual ground vegetation". The WS Report at 7 states:
"Vegetation management standards and objectives have not been met in
many areas".

The WS Report described problems with habitat fragmentation yet the
Forest failed to systematically evaluate habitat fragmentation for
sagebrush dependent species including pygmy rabbit and sage grouse
across the EIS project Area, including that tied to current degradation,
vegetation degradation or loss, livestock facilities, treatments and
manipulation such as the current DM and its segmented predecessor
authorized. The EIS Admin Record contains scientific literature that
should have been incorporated into development of alternatives in any
sagebrush manipulation project -- including: 'Tools available for
Measuring Habitat Fragmentation", and "Habitat Fragmentation".

The WS Report at 8 **s**tates **"loss of habitat due to overgrazing is a
major concern" to the pygmy rabbit.** Nowhere in the DM does the Forest
assess the impacts of grazing loss of habitat on top of the new habitat
fragmentation and sagebrush loss, degradation and alteration of habitat
that will result form the sagebrush killing project, as well as that
which has already been caused by its segmented predecessor burns.

WS Report at 11 states; grazing significantly reduces the herbaceous
understory in sage grouse breeding habitat. Yet nowhere does it conduct
a science-based analysis of the extent of loss to and impacts to the
understory that would occur under the Alternatives or ROD. In parallel,
nowhere in the sagebrush killing project DM is there any analysis of the
effects of grazing in causing a supposed "need" for the DM sagebrush
killing project, or the effects of grazing post-treatment in harming
understories of seeded plants.

In its Martin Basin EIS Project Issue Paper of 5/20/03, the Forest
recognized that: "Livestock grazing has the potential to affect the
composition, structure and health of upland habitats ... these
communities make up a majority of the land base within the project area
\... adjacent upland plant communities have converted to cheatgrass
...". Yet, the Forest ignored presentation of data and science, and
analysis of such impacts of disturbance in the DM.

The impacts of deleterious grazing on top of the habitat loss that
removal of sagebrush will cause has not been assessed by the Forest --
despite the sagebrush killing project occurring within the degraded
lands of the Martin Basin EIS area. In the Rangeland EIS process, the
Forest admitted that it has little information at all about the
sagebrush upland communities, and still applies a woefully excessive
upland level of livestock utilization.

The Forest is required by its Forest Plan to manage lands and waters to
provide and protect habitat for these important species, yet has failed
to provide any detailed NEPA analysis of how this project may threaten
species habitats or populations.

# Migratory Bird Concerns Unanswered

The Forest has failed to identify the specific migratory birds and
habitats that will be harmed by this sagebrush killing and habitat
fragmentation project -- despite habitat fragmentation being a
well-known significant problem for many sagebrush-dependent birds. See
[http://sagemap.wr.usgs.gov/docs/Condor_105p611-634.pdf#search=%22knick%20teetering%22](http://sagemap.wr.usgs.gov/docs/Condor_105p611-634.pdf#search=)
, Knick et. Al. 2003.

The Forest has not revealed if it has conducted site-specific surveys
for migratory bird species during nesting periods or winter use periods
within the project area.

# Disturbance and Roading Impacts Ignored

The Forest has failed to identify existing roads in or near the project
area, and assess the impacts of the project on opening up vegetation
communities -- essentially reducing them to bare dirt -- in facilitating
crosscountry OHV use and damage. The DN provides no methods to control
or limit crosscountry OHV use or driving in the areas reduced to bare
dirt and where sagebrush is killed and crushed. Such impacts have not
been assessed. As the DN is tiered to the old Forest Plan, all areas
would be open to OHV use under that Plan.

The disturbance involved in project implementation -- on top of the
areas devoid of woody vegetation in the aftermath of the burning, the
network of livestock facility and management roading that exists here,
the lack of post-treatment vegetation restricting crosscountry travel,
the bare unvegetated soils disturbed by treatment, and increased
post-fire and post-sagebrush eradication treatment, will significantly
increase unauthorized roading across the project area. The Forest has
not addressed these concerns, and has failed to identify any motorized
closures or other actions to prevent public entry. The Forest has
repeatedly told WWP's Fite "we can't control OHV/driving use under the
old Forest Plan".

# Fire Science Lacking

The Forest has failed to identify key components of fuels, fire, or
wildlife science, and reveal how this and related projects -- such as
the extensive burning that has already occurred in an unknown and
unrevealed pattern within the project area. What are the effects of the
abundant fine fuels that the Forest seeks to have grow on the sites, vs.
the effects of fire in lands with limited fine fuels? What are the risks
of cheatgrass infestation and spread with or without treatment? How will
treatment affect this?

What is the interspersion of vegetation immediately adjacent to, or
within, the project, and how might it retard - or enhance - any wildfire
spread here? The Forest fails to study or provide this information,
which is essential to understand the need for the project.

The Forest study how "hazardous" the fuels were, or if topographic,
existing short sagebrush or rocks or gullies or other low fuel load area
would drastically constrain the spread of any "natural" ignition.

The Forest has failed to apply fire science to determine if its actions
may in a few years INCREASE dense fine fuel, and significantly heighten
fire danger. As the Forest has provided no specific information on fuel
loading and a location of all vegetation types currently within the
project area, or that may result from the project, it is impossible to
understand the impacts -- or the effects of increasing fine fuel loading
here -- or the effects of increasing risk of cheatgrass infestation.

The Forest has failed to provide sufficient information to understand
the existing fire environment, and how the project may alter this --
including adversely and actually result in increased fire risks due to
new roading or vehicle use into open areas, and weed or brushy growth
fuel characteristics post-fire.

The Healthy Forests legislation requires collaboration with the public.
The Forest slammed the door on the public it did not like (WWP and CHD)
at the initial stages of the Buttermilk Veg Treatment projects,
excluding us from a site visit it conducted with other conservationists
to examine conditions -- this is the 2004 site visit referred to in the
2006 DN.

# No Alternatives

The Forest failed to analyze any alternatives, such as limiting size of
areas within Project to be treated, or allowing natural processes such
as natural sagebrush mortality from insects, voles or other causes to
occur in some portions of project area. The Forest has failed to analyze
any alternatives such as reductions in livestock grazing use that would
enhance the understory of the sagebrush communities that it seeks to now
plant, including with exotic vetches and unspecified cultivars of
non-native ecotypes of grasses.

WWP suggested that Forest actions and funds: *"be re-routed to control
cheatgrass, and close roads where cheatgrass and weeds elevate fire
risk, rather than killing important sagebrush habitat for many declining
wildlife species".* NO such alternative actions were considered.

# No Current Information or EIS Necessary to Understand Impacts

The Forest just conducted a Rangeland EIS that has been held unlawful.
The EIS documented livestock-caused degradation, and admitted that
little if any information on uplands existed anywhere across the Project
area existed.

Now, the Forest seeks to conduct yet another sagebrush killing project
in an area already suffering from one such project and in a broader
sagebrush landscape that has suffered extensive recent fires. Plus,
Winnemucca BLM plans large-scale sagebrush killing projects as well.

There is no current information on ecological conditions of the project
area, health of native vegetation communities and soils and microbiotic
crusts, current extent or severity or risk of weed infestations -- or of
the likelihood of weed spread in the wake of the projects across the
area.

The Forest has failed to provide necessary site-specific information
that is required in order to understand the degree and severity of
environmental effects of this and a whole series of linked DMs here.

The Forest is purposefully issuing a series of separate decisions as CEs
or DNs to avoid necessary integrated and comprehensive environmental
analysis. Federal fire funds are burning a hole in the Forest's pocket,
and it is hellbent on spending them -- regardless of the impacts to
pygmy rabbit habitat or habitats of other declining species.

Forest Fails to Reveal Extent of Sagebrush Loss in Santa Rosa RD and its
Surroundings Including BLM and Private Lands

Northern Nevada has undergone widespread sagebrush habitat loss -- and
loss of mature and old growth sagebrush communities -- which are
precisely the communities that the Forest seeks to alter.

Large areas of the Santa Rosa RD have been converted to cheatgrass.

Large areas of private lands in and BLM lands contiguous with the RD are
greatly infested with white top, Scotch thistle, halogeton, cheatgrass
and a host of other weeds and have suffered large-scale sagebrush
removal projects, conversion to pasture, and other losses. Many areas -
disturbed by livestock, roading, or other disturbance factors on the
Forest lands -- have serious weed infestations.

**Santa Rosa RD is Becoming a Weed Hell -- This Project Will Propel New
Infestation and Spread -- with Unassessed Consequences**

The Santa Rosa RD is greatly infested with a variety of exotic species
and noxious weeds. These weeds thrive in zones of disturbance. The
Forest fails to address the serious risks of weed infestation and spread
as a result of this and other projects here.

During WWP's summer 2006 site visits, I observed the consequences of
livestock disturbance, weed infestation and treatment in the RD -- for
example, herbicides now used contain a bluish dye to indicate where they
had been sprayed. Weed infestations are so severe that the Forest is
spraying over cottonwood trees by water in some areas.

Across the uplands in the Project Area, cheatgrass is present in many
areas, and the disturbance associated with the project is likely to
foster its spread. White top is present in MANY sites across the project
area -- and the risk of white top infestation and from the project is
great. Many other exotic species will thrive in the zones of
disturbance. The Forest NEVER addresses the use of herbicides to control
weeds that may infest the project, or such effects.

On top of this, the environmental impacts of livestock grazing in
fostering weeds in and around the treatment-disturbed areas is not
assessed. The Forest has no current information, and so can not
understand the impacts of its drastic site disturbance. An EIS must be
prepared.

# Forest Used Improper Standard

Attached is a photo of the consequences of sagebrush killing and actions
similar to those that would be carried out here.

The Forest claims this project falls under the CE category of "...
wildlife habitat improvement activities that do not include the use of
herbicides or do not require more than one mile of low standard road
construction". The Forest never reveals or asseses that it will very
likely end up using significant amounts of herbicide on the project area
and in the killing zones them selves. This project occurs in the
landscape context of the Santa Rosa RD where numerous noxious weeds and
other exotic species are dominating large areas of the landscape.

In fact, during WWP's site visit in summer 2006 (see Attached letter of
WWP Fite to Ranger Noriega), I encountered a Forest weed spray truck
within the Project area, and spoke to the two weed sprayers -- I also
saw several sites where white top, thistles and other weeds had been
sprayed within the project area. I also saw many sites -- including
right along road ways and jeep trails in the project area that had not
been sprayed and where white and other weeds were thriving. The Forest
ignored the impacts of disturbance of 1000 acres --exposing and baring
all soils within the area.

Heavy equipment used in this project will transport weed seeds from
infested roads, salt licks, livestock facilities, degraded rangelands,
and other cattle concentration areas into the project area along their
path of disturbance.

The surface and vegetation killing and removal impacts will be
significant, and surface disturbance to soils and microbiotic crusts --
as well as collapse of pygmy rabbit burrows -will greatly exceed that
associated with the construction of a mile of road.

A typical road may disturb soils on say --generously - a 40 foot wide
swath. So, 40 feet times 5280 feet in a mile = a total surface
disturbance in one mile of 211,200 square feet.

Yet here in this Martin Basin project -- the Forest plans to kill and
remove vegetation AND disturb soils over large portions of the land
surface over 1000 acres -- in addition to the lands disturbed by fire
and motorized use of OHVs and other activities associated with the
segmented burn part of these linked projects. One acre is 27,878,400 sq.
ft. So -- multiplying 27,878,400 sq. ft. in an acre by 1000 acres -- one
gets a tremendous amount of land surface disturbance -- even if only a
portion of the soil area over **27,878,400,000** **sq. ft.** of the
project area is disturbed in each pass of the heavy equipment.

What the Forest is doing here is much like plowing and running over
large portions of a 1000 acre field. Imagine if this were a Forest
merchantable tree covered area -- an EIS would be done without question.
Instead, the Forest plans to destroy and fragment important mature and
old growth big sagebrush habitats over large areas of public lands --
with no qualms about the loss at all.

Extensive new fragmentation of sagebrush habitats for
sagebrush-dependent species is likely to occur, on top of an array of
unrevealed fragmentation from livestock facilities, salting sites, other
Forest projects and treatments, and other activities.

**Livestock Impacts Are Unaddressed**

The Forest has failed to provide any protection or limitation of any
kind on livestock grazing of the site it plans to drastically disturb --
other than claiming to rest the site for 2 growing seasons. The Forest
does not reveal how that will be done- will an array of harmful new
fences be constructed? Further, the Forest provides no information of
any kind to describe recovery criteria or to determine of a mere 2
growing seasons is sufficient to protect soils, or seeded species.

The Forest has failed to provide any information whatsoever on the range
condition or health of the lands of the project area, or what has caused
the "problem" that radical disturbance treatment is supposed to address.

The Forest has failed to assess the current or past impacts of livestock
grazing on these same lands. For example, WWP identified extensive
problems in our Appeal of the Martin Basin EIS and other
communications - large eroding headcut meadow, gullies,
livestock-damaged sagebrush habitats, cheatgrass and other weed
problems. The Rangeland EIS further shows some of the many ecological
problems here.

Yet the Forest never studied the effects of removal of protective native
vegetation on such sites.

The project area - see gray DM map outline - encompasses over 80
sections - 51,200 acres of lands -- and apparently sprawls onto BLM
lands on the east side. Portions have already been burned or otherwise
altered.

Yet, the Forest has provided no safeguard of guaranteed rest from
livestock grazing disturbance to bare exposed and erodible soils,
recovering vegetation, and recovering wildlife habitats across the
project area. The public has not been informed of the number of AUMs,
season and manner of use, utilization or riparian limits, or any other
measures that will apply to the lands either before livestock grazing is
allowed to resume, or as these lands are recovering. The Forest has
provided no criteria (measurable vegetation, soil, watershed stability
parameters) that would serve to allow grazing use of the area to resume
post-treatment.

We understand that in some areas here have suffered current grazing
abuses that have been so severe that the Forest is canceling the grazing
permit! However, that in no way guarantees that large-scale trespass
will not occur, or that the Forest itself will not dump cows on a
temporarily Vacant allotment -- if indeed a permit in a portion of the
area is really being canceled.

# Project Weed Impacts Are Ignored

The Forest has provided no evidence that it conducted a systematic
noxious weed or invasive species inventory prior to signing the DM. As
weed invasion may greatly alter fire cycles, this is critical to
understand how treatment disturbance may affect lands. Weeds thrive in
zones of disturbance, especially when coupled with livestock grazing
especially by domestic sheep, which are notorious vectors of weed
transport, infestation and spread.

# Loss of Security Cover for Big Game

The Forest has failed to study the impacts of vegetation cover loss from
the project area to big game.

# Cumulative Impacts of Past Fires and Vegetation Manipulation Are Ignored

The Forest has failed to examine the existing fires and other
disturbance that have affected watersheds and habitats for important
species in or near the project area, and the cumulative impacts of the
project on rare or declining species and populations that have been
affected by past fires, or Forest or BLM land treatments, or livestock
facility placement or management practices. ALL of these factors serve
to fragment or degraded habitats, and their impacts must be understood
in order to better understand the impacts of this latest ion a series of
segmented projects here.

This matter could be resolved if the Forest used the federal fire funds
(increasingly scarce taxpayer dollars) burning a hole in its pocket to
control cheatgrass and grow native vegetation to provide habitat, rather
than destroying intact native sagebrush communities. We would be happy
to talk to the Forest about this possibility.

Sincerely,

Katie Fite

Biodiversity Director

Western Watersheds Project

PO Box 2863

Boise, ID 83701

208-429-1679

Mailed and e-mailed to Ranger Noriega

Cc: Ed Monnig, Randy Sharp