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February 20, 2007

Mr. David Loomis

Ms. Margaret Wood

Humboldt-Toiyabe Forest

Bridgeport Ranger District

HCR 1 Box 1000 Bridgeport, CA 93517

Dear Forest Service,

Here are comments of Western Watersheds Project on the DEIS examining
the impacts of livestock grazing on the Bridgeport Ranger District's -
the "Great Basin South" Project involving the Conway, East Walker,
Huntoon, Larkin Lake, Masonic, Aurora, Nine Mile, Powell Mountain, Rough
Creek, Whiskey Flat, and Wild Horse allotments.

First, what has become of the other Grazing-related EIS being prepared
in Bridgeport? In examining documents my computer, I came across Scoping
comments e-mailed to Ranger Lucich in 2002 on a separate process. Is
that the same process as this?

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>
.

What range of alternative actions and mitigations will be employed to
decrease or mitigate global warming effects of this action?

We are very concerned that the Forest may not be planning to consider
the full and damaging array of livestock grazing disturbance and impacts
to these significant wild land areas. The bioiversity and recreational
values of these public lands are very important. They are being
seriously harmed by livestock grazing practices. For example, livestock
destroy vegetation necessary for native wildlife, de-stabilize fragile
soils and impacts waters and aquatic biota, aid the proliferation of
exotic species, and diminish recreational experiences.

Current ecological science and the Forest's long years of managing
livestock in arid mountain ranges provide a wealth of information that
should allow you to adhere to firm criteria, methodology, and livestock
use standards that are triggers for livestock removal and which are
required to be met on an annual basis in order to protect the streams,
watersheds, wildlife habitats and a wealth of uses of the public lands.

Some Wildlife Concerns

Domestic livestock grazing has 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

Grazing causes incremental habitat loss and incremental extirpation of
native species. Please seethe United Nations Report, 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.

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, biodvesity,
aquatic species, rare plants, recreational and scientific uses of these
lands.

Information from new studies conducted in Wyoming related to the impacts
of 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. 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.

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

# Alternatives

The Forest must develop a wide range of alternatives aimed at protecting
and enhancing these nationally significant lands and waters. These
alternatives should include establishment of large ungrazed scientific
reference areas so to serve as yardstick for measurement of the degree
of disturbance and loss caused by livestock in the project area.

Alternatives development should also focus on a range of actions to
enhance breeding, foraging and cover habitats; decrease animal
displacement; increase prey availability; increase native species
biodiversity; stave loss of genetic diversity; increase regional
carrying capacity; increase populations of important native biota.

Alternatives should include a range of facilities removal and
science-based restoration actions.

Sharp Constraints and Clear Methodology Must be Placed on "Adaptive
Management" and Full Public Involvement in All Forest Process Must be
Bedrock Principle of EIS

We are alarmed at the Forest's trend towards "adaptive management" in
the grazing-related and other actions. A specific set of management
actions must be established, with specific steps to be taken if these
are not met. This must be laid out in detail. Open-ended "adaptive
management" provides no certainty in public lands management, and leaves
the door open to spur-of-the-moment decisions that may result in
irreversible ecological harms. Resorting to "adaptive management" is now
in vogue as a way for agencies to avoid full public involvement, public
disclosure, and public participation in new or expanded environmental
analyses.

The Forest needs to establish specific actions to be taken, in a
targeted and systematic manner, if use standards are not met, or if new
or unforeseen circumstances arise. These should include specific
reductions in season of use, reductions in livestock numbers, rest from
grazing, or other specific actions must be taken as specific remedial
steps if measurable standards of use are not met.

You can not rely on "adaptive management" where specific Actions are NOT
triggered. Problems or failure to meet any standard must trigger a list
of clear, specific actions to be taken promptly.

The Forest, through systematic baseline inventories, must identify all
areas (including providing the public with detailed maps) that it
considers in ecologically satisfactory at present (based on current
systematic and comprehensive inventory), identify all areas that require
improvements, and provide a time frame and specific measurable criteria
for improvement. These criteria must be tied to specific measurable
standards of use and other specific actions attached to all grazing
permits.

Great Uncertainty Surrounds Use of "Adaptive Management". Flexibility
should be minimized. Term grazing permits must have reduced flexibility
-- with flexibility comes error -- and often irreversible environmental
harm. For example, extending grazing use by a couple of weeks may result
in trampling if trout redds, livestock-related human disturbance
flushing sage grouse from nests and increasing predation risk, etc.

The Forest currently has much ability to change management, and does so
during annual meetings, and can do so at any time by issuing new
decisions. Unfortunately, in other processes, we have seen the HT Forest
make statements about the need, essentially, for lax management. With
this Bridgeport EIS, the Forest must tighten up loose and unaccountable
grazing by permittees. This will better protect place the lands, waters,
wildlife and other resources of the district.

The Forest must also require open public involvement in grazing
decsionmaking processes, and prepare at a minimum, and EA for ALL
livestock grazing-related actions and facilities.

As part of all alternatives, the Forest must include the public, through
NEPA actions, in the all steps of garzing and facilities processes.

Under NO circumstances should the Forest be allowed to conduct
Decisionmaking, on grazing, the dominant and most significant land and
water degrading, desertifying and destructive land use occurring across
the District, behind closed doors, or in dealings solely with livestock
permittees.

If you are pursuing an "adaptive" model, the HT Forest's typical AM
diagram shows already planned steps as: Assess Design Implement,
Monitor, Evaluate, Adjust. EACH of these steps must occur in full and
open view of the public, and have specifically defined, measurable,
quantifiable and specifically triggered actions developed as part of the
Plan amendment. For example, if a stubble height/utilization standard on
a spring is not met, the specific action to be triggered would be that
the agency will cut livestock numbers by 20%, and continue cutting until
herd size becomes able to be managed by permittee and standards are met
for 3 consecutive years.

Additionally, the Forest omits critical and important steps in AM, and
those include: Proper Problem Definition, Identify Key Uncertainties,
Management Experience. These must be included, and the many
uncertainties with each analyzed in the EIS. Given the constant shifting
of agency personnel in the Forest, management experience is often
lacking, plus later in this same Notice, the forest claims it can't do
enough on-the-ground monitoring of grazing impacts, so wants to turn
this over to the permittees. We thus have little faith that appropriate
management oversight and experience will be applied to an AM process.

You must conduct a risk assessment of each specific triggered step in
any AM or other system and alternatives that you develop. Please present
Tables of "Vulnerability" of Resources to Adverse Change in relation to
any action that may occur. This is necessary to gauge the irreversible
impacts to soils, waters, watersheds, native biota populations and
habitats, cultural sites, recreational and other uses of the public
lands.

A formal structure must be established for monitoring, and it must
include during-grazing, annual, and periodic monitoring regimes. Then,
with whatever results monitoring shows, specific actions must be set
triggered and taken.

Any unanticipated or unforeseen uncertainties (through monitoring) must
trigger public notification and either kick into play a specific set of
actions, or new NEPA at least at the level of an EA with full public
input must occur.

If sufficient funds are not provided for every specifically scheduled
monitoring point (necessary for feedback into the AM model), then a very
conservative "Default" system must be put in place -- designed to
minimize livestock use and other disturbance. This is necessary to
safeguard the very important public resources for loss or degradation.

Plus, if significant new actions occur (mining-related exploration or
development, Oil and Gas, wind or other energy development, shrub or
tree die-off, new weed invasions, aquifer drawdown, etc.), an
extra-cautionary level of management should be put in place.

The Forest can no longer view each activity that it may authorize on
public lands as separate. Often, and current science increasingly shows,
they are linked. For example, invasive species thrive and gain footholds
in areas of livestock and facility-disturbed soils. A County
road-blading spree --or just blading extra-wide berms through existing
weed patch -- or mining exploration disturbance - or herding cows and
sheep from weed-infested private lands onto forest lands - can spread
weed seed sources into new areas. Then, cattle or sheep grazing or
trailing use on top of grazing

The process must first and foremost be based on current ecological
science. Without firm moorings in science, and specific triggering of
specific actions as a result of feedback, political bias will pervade
land management decisions. In the rural West, that will mean the
livestock industry will exert political power to cut, stall, delay or
dilute necessary protective changes for public lands.

Grazing management should be set up to maximize insulation from
political tampering. Otherwise, policy turbulence will dominate, and the
land, resources, and the public will suffer.

Full openness of decisionmaking processes to the public and shining the
full light of day on all aspects of livestock management is key.
Allowing full public awareness, input and review of all management steps
(including the currently closed-door meetings on AOPs or permittee
protests of administrative actions should be part of management here.

Otherwise, public lands and resources will be subject to significant
adverse effects, and are very likely to show no improvement and will
deteriorate. The consequences of deteriorating resources may be
large-scale soil erosion and loss -- with fragile arid land soils never
(at least for several millennia) being able to be recovered. Even worse,
populations of important and rare wildlife such as sage grouse or pygmy
rabbit may disappear from habitats, or lands become overrun with
uncontrollable invasive weedy species. All results of during-grazing
season, annual, and other periodic monitoring must be presented in
detail to the public, and posted on the Internet. Any deviation from
specifically triggered steps laid out in AM scheme must be fully
revealed, and subsequent actions subject to NEPA, with full public
comment, and conducted at the level of at least an EA, with an EIS often
being required.

Without explicit, timely, and constantly funded monitoring over the
lifetime of the plan, necessary feedback to enable any accountable or
credible adaptive monitoring will be impossible. This, since the Forest
is chronically underfunded, and the US government is currently facing
large-sale cutbacks in funding, and will face such well into the future
as trillions of dollars of debt have been amassed under the current
President, there is no hope that your 'adaptive' plans will be able to
work effectively.

Any mention of meetings between the Forest and permittee must be
inclusive of any member of the public that wishes to participate. Annual
meetings should NOT include open-ended changes in livestock use such as
timing, salt, and especially CHANGING TRIGGERS.

They should also not set in motion use of "temporary" fencing or other
livestock facilities that would seriously intensify or shift livestock
use into new areas. This would result in damage to watersheds, native
biota, cultural sites, recreational values, roadless areas (please
provide maps overlaying all roadless lands with grazing allotments and
grazing-related roading), and other important values of the public
lands.

Again, ANY change should be based on science, and part of a specifically
triggered science-based action/step.

## AMP Concerns

Vintage AMPs based on outdated and scientifically deficient
understanding of the ecological impacts of livestock grazing may already
exist. Please provide very detailed information on allotments with AMPs,
and the specific provisions and requirements of the AMPs. Which have
been implemented, and monitored, and how often has monitoring of these
provisions, occurred since the AMP was developed? What has past
compliance been with all AMP provisions? This is essential to understand
how successful any new AMPs will be. Please provide the same detailed
information for all AOPs. From this information, you should readily be
able to include very specific overarching actions, as well as crisp and
clearly defined allotment-specific actions, in this EIS process and save
everyone a tremendous amount of time in the long run. This EIS process
is the ONLY place where the necessary hard and intensive look at how all
existing AMPs, AOPs, Permit requirements, and other agency actions
related to livestock grazing have been implemented, and how they have
effected or will impact the landscape and important values of the public
lands.

## Rest From Grazing Use

The Forest must establish a mandatory five years rest from grazing
following fire (wild or prescribed) and ANY other vegetation "treatment"
it undertakes.

Fire or other disturbance kills or weakens native grasses and forbs, and
significantly reduces habitats for native biota as well as greatly
increases watershed vulnerability to erosion, sedimentation and runoff
events.

**Current Ecological Site and Watershed Information Must be
Systematically Collected**

Critical information on the current ecological site conditions and
health of the pubic lands must be systematically complied and assessed.
Very old inventories done at the time of the Forest Plan are not
sufficient.

The Forest is subject to large-scale fluctuating forage production due
to drought and now increasingly invasive species proliferation, judging
"trend" on short-term events is even more questionable.

# Grazing Impacts 

Overwhelming scientific evidence demonstrates the many harmful impacts
of livestock grazing on arid western lands, and the huge ecological
problems ranging from weed invasions to soil erosion to imperilment of
native species that this causes. See, for example, Fleischner 1994,
Belsky and Gelbard 2000, Wisdom et al. 2002 PNW-GTR-405, UN Report on
Global Warming.

Grazing affects plant and animal communities in interlocking ways,
including plant defoliation, nutrient redistribution, and mechanical
impacts to soils and plant material through trampling.

Grazing annually directly affects: amount of vegetation present, degree
of soil compaction, amount of ground cover, ungulate forage
availability, effectiveness of terrestrial habitat, level of
reproductive success for aquatic species, and these contribute to
short-term and cumulative impacts.

Grazing indirectly effect; composition of herbaceous and shrub
vegetation, degree of canopy closure, vegetative age class patterns,
plant productivity, individual plant vigor, surface water erosion, water
quality, soil productivity, aquatic and terrestrial habitat
effectiveness, fire regimes, susceptibility to exotic plant invasions,
shrub and tree regeneration, forage production, individual and community
income (or loss of income from recreational activities harmed by grazing
impacts).

Plus grazing affects plant physiology and succession, and push
communities over ecological thresholds that lead to truncated or altered
successional processes.

The Forest must present an honest and science-based assessment of such
information, based on CURRENT data in its discussion of the Affected
Environment in the EIS.

**Invasive Species**

Livestock grazing is a serious causal factor in invasive species
infestation and spread. Noxious weeds, cheatgrass and other invasive
species are spreading at an alarming rate across Nevada wild lands.
Livestock are a key factor in infestation and spread of weeds in wild
land settings. See Pyke (1999), and Belsky and Gelbard (2000), Wisdom
(2003) - available on-line at [www.onda.org](http://www.onda.org/) in
Resource Library. Exotic weedy species like cheatgrass, white top,
knapweed, rush skeletonweed are able to very quickly spread into sites
disturbed by livestock or fire, and then be spread outward by livestock
and sweep across large areas of the landscape very quickly.

We request that the Forest provide actions that minimize spread and
infestation of weeds as part of all EIS alternatives. Methods involve
closing areas that are vulnerable to weed infestation and spread to
livestock use, closing weed-infested areas to livestock use and movement
until weeds are eradicated, quarantining livestock for several days
before entering Forest lands, and other measures. We request that the
Forest conduct a risk assessment that assesses the susceptibility of all
lands to weed invasions, and then provide specific actions for
minimizing weed invasion and spread. The DEIS has failed to do this. The
Interior Columbia Basin Ecosystem Management Project (ICBEMP) provides a
scientific template for determining risk factors and community
susceptibility associated with weed invasion. See, for example, USDA
1996 Map 10 "Areas Susceptible to Potential Exotic Weed Invasion",
providing a landscape-level overlay. Agencies have long known that
cheatgrass or exotic brome understories dominate large areas of Nevada
and California (Pellant and Hall 1992). 2003 studies in Nevada, Wisdom
et al. 2003 and iother sources provide cheatgrass and weed information
that must be presented as part of the EIS, along with a 2006-2007
update.

As part of this EIS, a specific study of zones of disturbance
(livestock, livestock and fire) within the EIS Area must be conducted,
susceptibility of lands assessed, and specific measures identified to
limit alien species infestation and spread, as well as to restore lands
that are infested. We believe that the Forest must incorporate actions
as part of all alternatives, as well as develop a range of "Minimize
Weed Spread/Restore Wild Lands Alternatives".

The Forest must fully consider the role of livestock as a causal factor
in altering fire cycles through spread of flammable invasive species or
increased density of woody vegetation; creating or exacerbating
hazardous fuel situations; and the destruction of herbaceous
understories that opens plant communities up to weed invasion and/or
increases in woody species.

# Suitability and Capability

The Forest must conduct a new grazing suitability analysis, a capability
analysis, a productivity study, and a stocking rate study for all lands
in the EIS area. Factors to be considered in a suitability or capability
determination are: steepness of slope; erosion hazards; conflicts with
water quality; reductions in water quantity; conflicts with native
wildlife or T&E species; distance from natural water; risk of
weed/invasive species infestation and spread due to grazing; conflicts
with recreational uses of the affected land, conflicts with pygmy
rabbit, sage grouse or other important ore declining species habitats;
conflicts with T&E species habitats, etc.

You must integrate all new scientific information on suitability and
capability (since the original HT plan studies or whatever earlier info
any preceding studies were based on) into the current analysis.

Many of the lands in the District are steep and highly erodible. Often,
present-day livestock stocking rates are based on the past conversion of
sheep to cattle allotments. Many of these conversions were
across-the-board 5 sheep AUMs = 1 cow AUM conversions, with no analysis
or reduction of the AUMs based on the limited ability of cattle to use
most steeper slopes and other limiting factors. Cattle are notorious for
loafing near wetlands and riparian areas on flatter sites, and avoiding
steeper terrain, thus maximizing disturbance to soils, vegetation,
wildlife, cultural sites, etc. found on flatter areas or in the vicinity
of surface waters. Thus, far fewer cattle than sheep may be grazed on
landscapes characterized by mountainous lands.

Often, agencies try to compensate for the unsuitability or incapable
lands by constructing a proliferation of livestock facilities. These
facilities often serve to create intensive new zones of livestock
disturbance, with significant and often irreversible harmful impacts.
For example, the district continues to develop/gut springs, and try top
pump water up steep hills to flatter hill tops. The end result is
desiccation of springs and accelerated soil erosion and invasive species
spread. The hideous spring development and solar panel in the Diamond A
allotment is a classic example of how the Forest killed a spring in a
harmful attempt to force cattle to the top of steep hills. All such
projects should be examined for ecological impacts, and harmful projects
(fostering soil erosion, weeds, killing springs, etc.) should be
removed.

Were any of the current cattle allotments/permits formerly sheep
permits? If so, were sheep AUMs converted across the board to cattle
AUMs? Please provide this information to the public in the EIS document.
As part of this process, the Forest must assess the need for AUM
reductions that reflect the realities of grazing cattle in steep arid
landscapes with fragile soils --i.e. that lands stocked with livestock
based on conversion of sheep AUMs to cattle AUMs without necessary
reductions in AUMs may be tremendously over-stocked.

In its recent Martin Basin effort, the Forest spent a lot of time in the
EIS describing past grazing in broad terms, but specific information and
the details (such as AUM conversions, range project development over
time, etc.) necessary to understand and assess the current situation in
the project area were woefully lacking. For example, there was no
mapping provided to show all range developments (fences, wells,
pipelines, troughs), salting sites, water haul sites, vegetation
treatments (including post-fire seedings that may have included alien
species such as crested wheatgrass, intermediate wheatgrass species,
smooth brome, forage kochia), and roading that has developed in
association with these projects.

We believe that the Forest must present up-to-date information on
Suitability and Capability as an integral part of the EIS process This
is necessary to understand the impacts of various alternatives, and
feasibility of continuing to graze \-\-- or refrain from grazing \-\--
large portions of these lands. Suitable acres may very by alternative
\-\-- and you must provide information that details this.

Are any lands infested with cheatgrass or noxious weeds or other alien
species currently suitable and capable of sustainable grazing? Is there
bighorn sheep habitat that is unoccupied or jeopardized due to conflicts
with domestic sheep? If so, where, and is this land really suitable for
grazing, and grazing by domestic sheep in particular? What do current
studies of MIS species habitats and viable populations tell you about
possible conflicts with livestock? Would habitats and populations be
able to support more robust, more viable populations if livestock
grazing was discontinued in key habitat or use areas? Is it necessary to
eliminate livestock grazing -- i.e. lands aren't suitable -- to support
the population levels that are desired? Is there competition for forage
between mule deer, bighorn sheep, or other ungulates and livestock?

The assignment of suitable rangelands to certain management
prescriptions will affect the response to disturbance/perturbation, and
influence the rate of recovery (or lack of recovery) from degradation.

The Forest must provide in detail information on acreage of the acres
that are suitable, the acres capable and their location in the EIS
project area. It is also important to understand the connectivity or
isolation of these lands across the landscape, as that is a critical
component of their ability to be grazed, and has bearing on the damage
done by livestock movement across the landscape.

If lands are in very poor condition, they should be found non-suitable.
Watersheds containing small, isolated populations of native fishes,
amphibians, springsnails or other biota, are not really suitable for
grazing. The Forest should establish threshold levels of populations or
habitat quality that trigger cessation/non-suitability of watersheds for
livestock grazing and trampling.

Additional factors that may influence determinations of suitability
include: protection of T&E species habitat; limited funding or staff to
monitor or otherwise manage; voluntary or involuntary reductions for
resource protection; permit waivers back to the government; livestock
market and ranch economies reactions; recovery for wildlife.

# Complex Vegetation Communities, and Old Growth or Mature Communities

The importance and complexity of the vegetation communities in the EIS
area must be fully described. All old growth and mature communities must
be identified, goals must be established to protect these communities,
and specific criteria must be put in place to do so. Any vegetation
criteria must be based on protection of old and mature communities, and
not manipulation and alteration to meet some industry-biased "DFC".

Big sagebrush uplands. Scientists have become increasingly alarmed at
the loss of sagebrush habitats in the arid West. We are very concerned
that, due to an abundance of federal fire funds, the Forest may be
embarking on spurious an unneeded projects that have significant adverse
impacts to the human environment. We have recently reviewed the other HT
Forest manipulation of sagebrush in these fragile wild lands. The very
LAST thing that any sagebrush plant communities here need is more fire
and fragmentation. Extensive acreages have burned across northern Nevada
and southern Idaho. Presence of cheatgrass or other weeds has increased,
or come to dominate, many of these sites. Others have been seeded to the
exotic soil-depleting crested wheatgrass or the highly invasive, weedy
forage kochia. The Forest must honestly assess the conditions of
existing fire or other disturbance areas -- both wild and prescribed.
These same principles should be applied to all vegetation types,
including forested vegetation types, across the project Area.

# Vegetation Manipulation

It has also been our experience that many "hazardous fuels" and other
vegetation manipulations or treatments being undertaken by agencies are
the same as the livestock forage burns of the past -- they are just
being called something else, as agencies seek to support staff and
budgets through the fire program.

Agencies love to claim that sagebrush, mountain shrub, pinyon-juniper or
other woody vegetation communities are "old" or decadent", and lacking
in diversity, and so thus in need of disturbance. In fact, many of the
vegetation communities in reality display inherent diversity with
various age classes of shrubs, and are often complexly interdigitated
with other communities across the landscape (example -- mountain big
sagebrush in moist snow accumulation zones interspersed with other
sagebrush on shallower wind-swept soil areas; mountain big
sagebrush-bitterbrush communities, or with groves of forested
vegetation.

If the Forest plans to assess impacts of vegetation manipulation, it
must develop specific sets of criteria for determining lands capable of
withstanding the severe disturbance of vegetation
manipulation/treatment, as well as the resumption (if ever) of livestock
grazing disturbance post-"treatment". Plus, there is no study of the
effect of ongoing livestock grazing on weed, soil erosion, and other
problems in existing burns. You must provide a scientific framework for
undertaking these necessary actions, or for understanding the ecological
outcome of any vegetation manipulation/"treatments".

The primary goal of any vegetation management here should be maintaining
and truly restoring native plant and animal communities, with emphasis
on "treatment" of burned or weed-infested lands, and lessening/removing
sources of disturbance to remaining better condition lands. Removal and
restoration of unnecessary or eroding or otherwise harmful roads must be
assessed as part of this process. Many roads on wild lands grew as
livestock projects were constructed and maintained.

Please identify all vegetation communities in the District in poor,
good, fair or excellent ecological condition, or with significant weed
problems, and provide detailed maps as part of this EIS. Communities in
poor or fair condition may be graely vulnerable to weed invasion if
disturbed.

The Forest must assess the health of current vegetation and the
ecological condition of all lands here, and identify specific measures
that will be taken to keep good or better condition lands in that shape,
and to improve degraded lands. The Forest must provide this information
for all riparian areas, including intermittent and ephemeral drainages,
and springs seeps and wet meadows. In addition, all upland communities
must be surveyed.

Please provide all information on past, proposed or foreseeable
deforestation, thinning, burning, chopping, plowing or other activities
that may affect pinyon-juniper, sagebrush, or other vegetation here.

# Native Biota

We ask that you conduct systematic baseline inventories for a broad
range of native biota -- reptiles, amphibians, bats, migratory birds --
as part of this process. This is necessary to understand the impacts of
your various alternatives, and identify lands where special management
attention is required.

You must identify critical or important habitats for native wildlife
species here, especially in upland vegetation communities. Please
describe the role of native vegetation communities in providing habitat
for declining species or species of concern. Please also identify the
deficiencies in habitat that exist, and describe both riparian and
upland fragmentation.

# Reconnecting Habitats

These lands contain a wealth of important species and habitats, many of
which are part of populations shared between Nevada and California.
Sadly, large areas of lands have been fragmented due to livestock
grazing impacts and developments, roading, mining, de-watering and other
factors. Restoring and re-connecting habitats should be a focus of all
alternatives.

Please describe how you will achieve functioning metapopulations of
aquatic species species here. How will you reconnect
disconnected/fragmented habitats aquatic habitats -- especially habitats
that have been altered for fragmented due to livestock grazing impacts
and developments?

As part of the EIS, we ask that you identify all livestock projects or
facilities that may be altering watersheds or drainages that contain
important aquatic species. These include stock ponds that block water
flows downstream, ponds dug into springs that impair water quality in
the very headwaters of stream systems, livestock pipelines that de-water
or reduce flows. Livestock water gaps that contribute large volumes of
sediment and fecal pollutants to streams, roads related to livestock
grazing projects/activities that affect streams or produce large volumes
of sediment.

Please pay close attention to the impacts of livestock grazing to
intermittent and ephemeral drainages, and whether many of these
drainages are partially (or wholly) intermittent or perennial due to the
impacts of livestock grazing disturbance and livestock-caused erosion to
these watersheds.

What are the estimated current populations of aquatic species here, by
age class? What is the current condition of all watersheds (including
upland components) of LCT watersheds. What are population recovery
goals? What progress has been made towards meeting them? What actions
are necessary to provide habitat and thus population connectivity? What
are the combined effects, as well as cumulative and synergistic effects,
of grazing, roads, irrigation diversions, fire, etc. on all streams,
springs, springbrooks and watersheds here?

Amphibian and other aquatic species populations may be greatly affected
by: Past and ongoing habitat degradation has resulted from livestock
grazing, spring development, agricultural development, urbanization and
mining activities. These activities eliminate vegetation necessary to
protect fogs from predators, and UV-B radiation; reduce soil moisture;
create undesirable changes in water temperature, chemistry and
availability; can cause restructuring of habitat zones through
trampling, rechanneling, or degradation which can in turn negatively
affect the invertebrate food source. The Forest must assess the impacts
of these activities, across the spotted frog habitats of the District.
This EIS should serve as a basis of a specific restoration activities
and large-scale changes in livestock grazing impacts to spotted frog
habitats. This is critical, as conditions have not improved over time
(Source: USFWS 2005, comments on Programmatic Elko Oil and Gas EA). A
study of fragmentation of habitats, and actions needed to restore or
reconnect such habitats must be conducted. We are VERY concerned about
the impacts of existing and newly proposed livestock facilities such as
spring developments, water gaps, etc. on aquatic species.

Sage-grouse. Sage grouse may move over large areas of wild lands, and
sage grouse that use the Forest lands as critical brood rearing habitat
my lek and nest on BLM lands including Idaho lands to the north. This
species faces accelerated threats in Elko County -- including massive
habitat alteration from mining exploration and development - including
such impacts as de-watering and desiccation of critical brood rearing
areas, the new threat of Oil and Gas exploration and development, and
long-term degradation, loss, desertification and weed infestation of
important habitats from livestock grazing, and behavioral disturbance or
interference from human and livestock management or facility-related
activities (roading, facilities, herding, grazing stripping nest cover
or otherwise exposing birds or nests to predation).

Pygmy rabbit. We have been dismayed at recent Forest proposals that
would fragment habitats through mining exploration, vegetation
manipulation and livestock facility development. This EIS must put an
end to these practices, and focus on reconnecting and restoring altered
pygmy rabbit habitats.

Pygmy rabbits require dense, structurally diverse sagebrush as cover.
Retention of dense stands of sagebrush must be a management goal for
pygmy rabbit. Restoring fragmented sagebrush habitats must also be a
primary goal. Removal of poorly sited livestock facilities will help
restore habitats. Please see Federal Register (March 5, 2003) for
description of pygmy rabbit habitat needs, and impacts of livestock on
pygmy rabbit, including trampling and collapse of burrows.

Water quantity concerns. Each time we visit the District, we are alarmed
at the small volume of water in most streams. This situation has
worsened, as the Forest has allowed cattle to be turned out in drought
years, and they have greatly damaged the banks of the remaining wetted
areas of streams. As you are aware, the health and condition of
watersheds determines the rapidity of runoff and erosion events, as well
as theability of the watershed to retain water, and the fast or slow
release of water over time. A primary aim of your analysis must be
addressing the integrity of the whole watershed, and developing
management actions that result in significant and rapid watershed
improvement. The EIS must provide watershed-level analyses and
hydrological data, and to provide any estimations of flow, changes in
flow over time, relations between upland watershed condition and soil
erosion, water quality parameters, etc.

Please also detail the impacts of livestock grazing and trampling on
soil erosion, runoff, perennial vs. intermittent stream flows, etc.

Please provide as much data as possible on past stream flows, past fish
and other aquatic species presence and abundance, as well as current
data. This is necessary so that you can determine the degree of
ecological change, and make management changes necessary to heal
livestock-damaged watersheds that should be quickly put into action upon
completion of this decisionmaking process.

Attributes of the health of upland and riparian soils must be assessed.
These include the presence of microbiotic crusts in uplands, the amount
and type of ground cover and litter, estimates of topsoil loss -- in the
past as well as at present, etc. Soil compaction, erosion, gullying and
other impacts caused by livestock must be fully assessed, and an outcome
of the assessment must be quantifiable trampling and soil compaction
standards for all riparian and upland sites. The effects of trailing,
overlapping sheep and cattle use, grazing when soils are wet, grazing
when soils are dry, etc. must be detailed. Impacts of various management
schemes on sol health and erosion must be assessed.

Specific trampling standards must be applied to all riparian areas. We
have observed serious soil disturbance and streambank erosion on
allotments across the district. Regrettably, the Forest is ignoring
Forest Plan provisions related to streambank soils. This EIS should
comply with the Plan, and put in place specific measurable standards of
trampling for livestock-accessible banks of al riparian areas.

The EIS must provide information on the percent of allotments within the
project area that are meeting original Forest Plan objectives, those
that are not meeting objectives, and those that are moving towards
meeting objectives.

The Forest must lay out in detail for the public in both maps and text
descriptions and analysis the acres that are not considered part of the
grazing base due site accessibility (availability), low productivity,
soil erosion or other factors. As sediment is a common serious problem
in the EIS area streams and watersheds, we are very concerned that you
may mask its impact from the public.

You must deduct acres with significant invasive or noxious species
presence or infestations, or high risk of this occurring under continued
livestock grazing and trampling disturbance. In what lands should
grazing be curtailed to limit further spread/infestation? What lands are
at risk of invasive species expansion? How does all this factor into
suitability and capability analyses?

How many acres of each allotment or land area can produce greater than
200 lbs/acre forage?

How many areas have slopes between 20% and 40%, and water within ½ mile?
Where are they located? How many areas have slopes 0 to 20% and water
within 1 mile? Note: Configuration of facilities may alter this.

Which lands have naturally unstable soils? Which soils (and lands), and
where, are susceptible to soil erosion?

**Rare Plants and Insects**

The Scoping Notice was greatly devoid of information --such as a current
species list -- needed to effectively comment on the proposed action. We
note that there are many animal species of importance that are not
addressed in the DEIS. However, a simple Google search presents such
information:

U.S. Forest Service: Lisa Sims (Bridgeport Ranger District) has surveyed
15 new populations of *Astragalus oophorus lavinii* in CA and NV, also 1
new population of *Streptanthus oliganthus.* About 1.5 mi^2^ of
*Cusickiella quadricostata* habitat are being affected by the Borealis
mine on the other side of Lucky Strike Pass; some tailings have already
been dumped. Several populations of *Polyctenium williamsiae* are being
monitored on USFS lands; there has been some horse use; fencing may be
an option. (1998 rare Plant Conference). How is grazing affecting all of
these species, and any other rare plants or rare insects here?

And :***Goodmania luteola*** (yellow spinecape) - collected from only
one site in Nevada, at Alkali Lake in Mineral County, this monotypic
genus is otherwise known from adjacent Mono County, the southern San
Joaquin Valley, and the northwestern edge of the Mojave Desert in
California. According to Reveal, the species is rapidly becoming rare
and frequently locally extirpated throughout its range. Heritage ranks
G3, S1 in Nevada, S3.2 in California. On CNPS List 4, R-E-D code 1-2-2.
Add to the NNPS Watch or Marginal list? Recommend for addition to the
Humboldt-Toiyabe National Forest sensitive species list? **Discussion:**
rapidly declining rangewide according to Reveal, was common west of
highway by Lancaster, CA, but now covered by housing developments. TNC
preserves in Central Valley protect it, but gone outside those sites. In
grazed pastures around Crowley Lake. On BLM lands along the southern
Sierra Nevada front. Alkali Lake area in Nevada remote, but there is OHV
habitat on the lake bed, similar habitat and threats as Williams
combleaf (***Polyctenium williamsiae***). Blooms mid-summer. On USFS
lands, Bridgeport Ranger District? **Consensus: add to the NNPS Watch
List. Recommend for Humboldt-Toiyabe National Forest Sensitive Species
List.** (2004 Nevada rare plant conference).

There are many other on-line references to rare or imperiled species in
this District. As part of this EIS, you must provide a systematic and
detailed inventory of all such species and science-based assessment of
impacts of livestock grazing on rare plants (including impacts to
pollinators), and native animal species.

Adverse Impacts of "Treatments" and Livestock Role in Treatment Need
Must Be Fully Examined

The Forest is also conducting many vegetation manipulation projects that
may have serious adverse impacts to native species habitats -- and
further fragmenting disturbing habitats. Cumulative impacts and costs of
such proposals in relation to chronic and post-project livestock
disturbance and degradation must be fully assessed. How has the Forest
monitored livestock impacts to such projects, or assessed the role of
livestock in exacerbating any claimed "forest health" concerns or
projects in pinyon-juniper or other habitats? Please see Belsky and
Blumenthal 1997, available on-line at www. onda. org Resource Library.
Please also see new work by Baker and Shinneman, that re-examines some
of the claims of fire frequency intervals in pinyon and juniper.

[http://www.sagebrushsea.org/pdf/Baker\_&\_Shinneman_Fire_Restoration_PJ_Woodlands.pdf](http://www.sagebrushsea.org/pdf/Baker_%26_Shinneman_Fire_Restoration_PJ_Woodlands.pdf)
.

This challenges some of the human-imposed HRV and fire frequency
criteria claimed by the Forest as justification for vegetation
manipulation, in for example, the Decision Memo at :
<http://www.fs.fed.us/r4/htnf/projects/bridgeport/Bald_DM_08072006.pdf>
.

The Forest must honestly assess the role of domestic livestock
--including ongoing chronic impacts -- under all alternatives as part of
this process.

**Other Concerns**

Are there any RNAs? If not, why have you not examined establishment of
rare plant or other important veg. community RNAs as part of this
process?

The Forest must retain standards of utilization as triggers for
livestock movement. We ask that you specifically state this in the EIS.

All Vacant Allotments must remain Vacant and not be used for grazing, as
they provide valuable scientific reference areas.

What streams, springs, springbrooks or areas, currently have standards
of less than 45%? We are very concerned that this EIS may be stripping
protection form important damaged springs, spring brooks and streams
here.

The EIS must present information on current population numbers,
viability, and recovery plans for LCT, redband trout, sage grouse, pygmy
rabbit, Columbia spotted frog, and MIS species.

Actual Use. Please provide year-by-year and pasture-by-pasture data on
numbers of livestock turned out in each allotment. This is necessary to
understand the real stocking that has occurred on these lands.

Monitoring. We believe the monitoring plan must provide adequate
information to track conditions, and to make necessary adjustments in
livestock use or numbers.

Regular scheduled compliance monitoring should occur at throughout the
grazing period.

All livestock should be required to have ear tags, or some numbering
system so that actual numbers turned out can be verified by Forest
personnel.

If funds are not available for adequate annual compliance monitoring,
livestock turnout should not be allowed to occur.

The public should be informed of all annual operating plans, and
monitoring or other compliance results through timely posting on the
Internet, and should not have to submit FOIAs to receive this basic
information.

NEPA and the NHPA, what will be done about all the sites that are
causing ongoing damage? How will you deal with them?

Please present adequate systematically collected site-specific data of
livestock impacts on on soils across all soil types and habitats of the
District, waters, watersheds., flows, sediment, vegetation, cultural
sites, wildlife, special status and ESA species, and MIS species to
allow understanding of all the direct, indirect and cumulative impacts
of the projects that you list.

### ­We also incorporate by reference the Petition to list the Mono Lake sage grouse and the recent irrational and politically biased decision by USFWS to deny listing -- and which will undoubtedly be challenged in federal court. These documents provide information on the high level of environmental threats that exist here and that must be fully assessed in relation to livestock grazing as part of this grazing disturbance EIS process. 

Sincerely,

Katie Fite

Western Watersheds Project

PO Box 2863

Boise, ID 83701

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

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Anderson, J. E. and K. E. Holte. 1981. Vegetation Development over 25
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Anderson, Jay E. and Richard S. Inouye. 2001. Landscape-scale changes in
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Belnap, J. 1995. Surface disturbances: their role in accelerating
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\[available on-line at
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\]

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We hope to submit additional scoping comments as time allows.

Sincerely,

Katie Fite

Biodiversity Director

Western Watersheds Project

PO Box 2863

Boise, ID 83701