February 9, 2005

Terry Smith

FMDA Project Manager

BLM

1111 N. 8^th^ Avenue

Pocatello, ID 83201

Here are comments of Western Watersheds Project on the Upper Snake River
District Fire, Fuels and Related Vegetation Management Plan Amendment.
We incorporate by reference past comments (scoping) of American Lands
Alliance and Committee for the High Desert on this process. We are also
submitting additional comments.

LIVESTOCK GRAZING AS A CAUSAL AGENT IN FIRE, FUELS, VEGETATION
"PROBLEMS"

The Draft EIS fails to adequately address the role of livestock, and BLM
and other agency management of livestock, on the ecological health and
fire regime of lands across the Project area. It fails to present
scientific information and analysis necessary to understand the role of
livestock in causing fuels problems -- including the role of ongoing
livestock grazing across the lands of the EIS area.

The EIS and alternatives are based on BLM's false premise that it can
impose fire and other treatments to bring about "historical" ranges of
fire occurrence and achieve an artificially derived "desired" future
conditions is not based on the facts that cattle and sheep grazing in
the USRD lands have created an UNNATURAL environmental setting -- often
with massive topsoil loss, lowered site potential, desertification, and
great vulnerability to weed invasion following disturbance. BLM's
complicated modeling fails to address this. BLM has not used current
ecological science in deriving its models, desired conditions, and
predicted outcomes of treatments.

BLM must fully update the livestock grazing and vegetation allocation
components of all 12 affected Land Use Plans in conjunction with this
process. The livestock grazing and vegetation portions of all these Land
Use Plans are woefully outdated. They allow extremely high utilization
rates on both upland and riparian sites. They lack quantified trampling
standards. Most of the old plans view threatened native sagebrush
vegetation communities as "brush", primarily suitable for burning,
spraying and discing up. These plans fail to consider current science,
such as stubble height standards necessary for riparian protection,
utilization levels necessary for successful sage grouse nesting, or
grazing systems that protect microbiotic crusts necessary for soil
health and keeping cheatgrass and other weeds that cause a fuels problem
from invading. As a result, we believe it is not possible for BLM to
tier to, or rely on, these documents in this planning effort. This is
especially the case as the EIS proposes large-scale alteration of
landscapes across hundreds of thousands of acres of public lands.

In addition, these old Land Use Plans do not provide for protections
necessary to slow down or halt weed invasions and alterations of the
fire cycle. The current scientific literature overwhelmingly shows that
livestock grazing is a primary cause of problems affecting native
vegetation, including altered fire frequencies and altered fuel
situations. See Attachment 1 to our scoping comments, an extensive
annotated bibliography provided with these comments, which we ask you to
carefully review in relation to the whole range of our comments. An EIS
grappling with fire, fuels and vegetation management on southern Idaho
lands must address livestock grazing as a causal agent, and analyze the
impacts of livestock grazing in causing "unnatural" fire cycles, and the
impact of livestock grazing on the ultimate
outcome/effectiveness/success of any treatments. Without including
significant changes in livestock grazing practices including reduced
stocking rates and/or removal of livestock from lands at risk to
cheatgrass invasion, or where restoration actions may be undertaken, and
more protective levels and standards of use, BLM will be wasting
taxpayer dollars on this Fire EIS effort.

BLM must fully address livestock as a causal agent in ecosystem
disruption, and alteration of composition, structure and function of
native ecosystems in the arid lands (see Fleischner 1994) covered by the
EIS. Thus, the role of livestock in causing any fuels problem must be
fully assessed, including all direct, indirect and cumulative impacts of
past and ongoing livestock use on rangeland health problems associated
with fire, hazardous fuels and weeds. A wide range of up-to-date
livestock management alternative components must accompany all
alternatives in this EIS process. These should include analysis of a
range of reductions in stocking rates, and their effects on ecosystem
processes, fire, fuels, weeds, restoration, rehabilitation efforts.

BLM must fully analyze cessation of livestock use/grazing permit
retirement as part of any treatment analysis that is conducted. Federal
fire funds should be used to buyout the grazing permits on lands that
are treated, or determined to be at risk to weed invasion, or determined
to be at risk of crossing thresholds from which recovery may not be
possible, and the inextricable link between fire/fuels problems and
livestock grazing effects must be addressed.

Information that needs to be acquired and assessed includes:

-   Current stocking rates (average actual use as well as active
    permitted use) in all allotments, and in all vegetation types

-   Utilization levels allowed in all allotments and in all vegetation
    types

-   Season of grazing use

-   Condition of soils, vegetation, habitats related to stocking rates,
    levels of use allowed, etc.

BLM must Conduct Population Viability, Persistence,
Extinction/Extirpation Models for species of Native Wildlife Under all
Alternatives. The Proposed Action would treat 646,000 acres over a
10-year period. The Preferred Alt. would treat 1,522,300 acres over a
10-year period. This will have a widespread, and drastic, impact on
special status species habitats and populations

ADEQUATE BASELINE INFORMATION ON VEGETATION COMMUNITIES MUST BE
COLLECTED

Unfortunately, the Draft EIS does not provide adequate information on
vegetation communities in the affected lands and their surroundings.

BLM must collect and analyze extensive baseline information on past fire
and vegetation conversion or manipulation projects in the affected
lands, and other factors that result in weed corridors, habitat
fragmentation, increase likelihood of human-caused fires or disturbance,
etc. Data and maps must be compiled and assessed that indicate where all
past treatments have been conducted by state and federal land managers
(and private -- where known) within the EIS area. Without understanding
the past dispersion and impacts of treatments and disturbance across the
landscape, BLM can not adequately assess the impacts of various
alternatives related to treatment and land health.

Information that needs to be acquired and assessed includes data and
maps of:

-   Past disturbance events on these lands (fire- prescribed or wild,
    chemical treatment, mechanical treatment, other);

-   Seedings or any other post-disturbance treatments that have occurred

-   Condition of seedings, including cheatgrass and other fine fuels and
    weeds in interspaces

-   Comparison of current seeding condition to stocking rate based on
    good or better condition seeding

-   Location of all livestock facilities

-   Location of all roads.

Assessment should include a study of the current ecological condition
and health of soils, vegetation, important wildlife habitats and other
important values of the affected lands, a comparison between these
conditions and conditions at the time of the disturbance.

For all 5.3 million acres, BLM must collect current information on:
Vegetation species composition, its current ecological condition;
livestock grazing regimen and standards of use; wildlife habitats and
populations occurring here. Information on periods of rest, trespass,
and other livestock factors must be included.

Current information on ecological condition, presence of weeds and other
exotic species, etc. on all lands within the 5.3 million acre project
area must be collected as part of this effort. It must be the basis for
decisionmaking on "acres to be treated" for various purposes in the EIS.

For example, how many acres of salt desert shrub communities, Wyoming
big sagebrush, or other communities have a significant component of
cheatgrass in the understory? How many of these lands have already
crossed thresholds, where succession is truncated? How many are at risk
of crossing thresholds? How many acres, and what is the location, of
each vegetation type is in good or better ecological condition?

After solid, on-the-ground collection of new information, BLM must
develop a rigorous protocol for determining all lands in need of
"treatment", and explain in comprehensive detail, with supporting
science, why these lands need treatment.

We are alarmed that BLM in the EIS proposes to NOT treat the extensive
crested wheatgrass seedings that have so altered and largely destroyed
wildlife habitats, and which often form the basis of continuing to graze
excessive numbers of livestock that also affect native vegetation in or
near these seedings. Many crested wheatgrass seedings have become
infested with cheatgrass, halogeton or other weeds and now contain
continuous fine fuels. They are now not acting to stop fires, but
instead are susceptible to burning. Plus, the harm and fragmentation of
native species habitats caused by these seedings must be assessed -- as
it is important to understand their role in habitat fragmentation on top
of the extensive alterations of habitat proposed by BLM under the Draft
EIS. The Burley BLM lands provide a perfect example of a woefully
fragmented landscape where crested wheatgrass seedings have greatly
fragmented sage grouse habitats across middle to lower elevations, and
many are in very poor condition and have rampant cheatgrass, halogeton
and other problems -- as well as loss of forage. Yet, BLM persists in
promoting the killing of native vegetation (junipers, mountain big
sagebrush, pinyon, and other species) in the Jim Sage and other areas,
while ignoring the habitat loss, and weed and fire risks, posed by the
creasted wheatgrass and other purposefully altered lands, including
those BLM itself "treated" with fire and which have become weedlands.

We attended the EIS Scoping meeting held in Boise, and were shocked that
BLM had no sound basis for estimates of acres proposed to be treated in
the information that was provided to the public. We were told that BLM
asked land managers in each field office to come up with estimates.
However, there was no protocol followed as a basis for these estimates,
and it appears no scientific methodology was followed. Our review of the
Draft EIS confirms that a systematic method to assess treatment "need"
has not been used.

Cohesive Strategy and Fire's Natural Role. The EIS must base its
analysis on science, and not the mis-begotten hope that fire still
retains a "natural" role in many of the highly disturbed systems here.
This is key to understanding that many of the DFCs are not attainable --
especially if large-scale chronic disturbance factors like grazing
continue unabated, and spread cheatgrass and weeds in their wake.

The EIS's discussion of Age, Seral Status and other elements ignores
alterations in composition, function and structure that exist in the
real world as a result of livestock grazing and other disturbances, past
vegetation treatments followed by livestock grazing, etc.

RISK ASSESSMENTS MUST BE CONDUCTED

Following careful and systematic data collection on current ecological
condition, current vegetation type, range trend, and current weediness
of the 5.3 million acres of lands, BLM must prepare honest and accurate
assessments of "risks" of and "need for" various treatment disturbances
or treatments to the affected lands, as well "risks" of invasions with
continued livestock grazing under the old Land Use Plan paradigms, and
under updated paradigms under the alternative actions that BLM needs to
develop for this process.

ICBEMP assessed lands and categorized them "at risk" to weed invasion.
This EIS effort can build on that, and take a much more detailed look at
the Upper Snake BLM lands affected by this proposal. Shockingly, ICBEMP
also found that only a very small portion of the entire USRD had even
"moderate" ecological integrity (PNW-GTR-385 at 118, Map 18). Nearly all
the USRD lands except for the Upper Little Lost and Birch Creek are in
"Low" ecological condition. The EIS fails to provide information to tie
proposed treatments to such land areas, and fails to assess the role
(and ecological condition) of past treatments past and current livestock
management (especially under out-dated paradigms and levels of use), and
develop new goals, objectives and allocations that better address the
pressing habitat needs of many important species and that address root
causes of hazardous fuels problems, and thus provide better and more
cost-effective protection from hazardous fuel problems.

SUITABILITY OF LANDS FOR TREATMENT -- WILDERNESS, ACECs, ROADLESS LANDS

We are very concerned about the lack of necessary analysis of the
impacts of the various alternatives on the integrity of, ecosystem
processes within, and important and special features of WSAs; relevant
and important values of ACECs; integrity and values to society and
watersheds of roadless lands. BLM's proposal will cause irreparable harm
to values ranging from recreational spiritual and aesthetic values, to
unroaded watersheds that do not release road sediment to streams.

SUITABILITY OF LANDS FOR LIVESTOCK GRAZING

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

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

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

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

All alternatives must include 25% or less allowable utilization of
upland vegetation, no grazing during critical growing periods for native
species, no grazing during nesting periods for migratory birds and sage
grouse, measurement of livestock trampling damage to native vegetation
and microbiotic crusts and means to minimize trampling damage, no
movement of livestock from lands infested with exotics to more intact
communities.

BLM MUST EXAMINE USE LEVELS, AND THEIR ROLE IN FUELS PROBLEMS

BLM does not take into account the scientific literature -- much of it
published in the Journal of Range Management -- demonstrating that
utilization limits historically followed by BLM (typically, 40%, 50% or
60% utilization limits) may contribute to degradation of native forage,
and plant community changes that result in fuel and weed problems.

A FULL RANGE OF PASSIVE TREATMENTS MUST BE EVALUATED

Passive treatments primarily minimize site disturbance, and generally
remove or minimize an environmental irritant that is affecting the
health of the plant community. Thus, they have less risk of soil
erosion, weed invasion or proliferation and other negative impacts
associated with them. They also have a high probability of being
beneficial to watersheds, native wildlife habitats and populations and
the economic well-being of western communities that are increasingly
dependent on tourism and recreational uses of public lands.

An array of passive treatments exist that will enable BLM to treat many
of the affected lands. Such treatments include:

Livestock grazing treatment: Livestock grazing treatments can reduce
spread of flammable invasive species, heal damaged understories so that
more natural, cool-burning fires can occur, and reduce the proliferation
of doghair thickets of dense young trees which serve as ladder fuels.
Treatments include significant reductions in livestock numbers
accompanied by prudent utilization and trampling standards in plant
communities found to have damaged understories vulnerable to invasion by
flammable exotic species.

Closure of pastures with known exotic infestations. Closure of lands to
grazing that have known exotic species infestations is a prudent first
step toward control of spread of flammable, watershed-altering exotics.

Closure of pastures "at risk" to weed invasion -- such as any Wyoming
big sagebrush, Basin big sagebrush, or juniper communities that still
contain relatively intact understories. This EIS process should map and
identify such areas, as well as all areas where cheatgrass already
dominates the understory.

Livestock removal treatment: Grazing permit buyout and permit retirement
using federal fire funds is a very reasonable treatment that will heal
damaged lands, help restore natural fire cycles, minimize the spread of
exotics and other hazardous fuels.

Livestock facility removal treatment: Livestock facilities (fences,
artificial watering sites -- especially troughs associated with
pipelines and water haul sites, corrals, etc.) serve as zones of
livestock concentration, and result in areas of severe disturbance
readily colonized by highly flammable exotic species. Removal of these
facilities and restoration of disturbed zones will limit spread of
invasive flammable species, and help develop healthy understories
necessary to carry cool, light fires in surrounding lands.

We are alarmed that BLM's Draft EIS casually casts aside Alternatives
development based on a series of passive livestock treatments, and fails
to explain the actions such treatments entail .

Road/ORV trail closure and rehab/restoration treatment: Closures and
restoration treatments quell the spread of flammable invasive species
from disturbed road and trail edges. Roads are known to serve as
conduits for weed invasion (Gelbard and Belnap 2003).

Road closure coupled with grazing reductions can have large-scale
positive effects, as roads as weed conduits can be closed, and livestock
reductions minimize spread of weeds already present within the area.

Allowing natural successional processes and healing processes to occur
in plant communities that are still relatively intact is the most
cost-effective method of attaining natural fire cycles, reducing buildup
of hazardous fuels over time, etc. Natural mortality occurs in
sagebrush, sagebrush-bitterbrush and other vegetation types. Allowing
natural processes to play out, while removing or minimizing those agents
that are disturbing natural ecological processes takes patience, but
minimizes risks of exotic invasion that accompany aggressive
intervention such as fire or mowing.

HAZARDOUS FUEL

If BLM plans on using this term in its analysis, we ask for a careful
and scientific description of the basis for its use. For example, Idaho
Falls BLM engaged consultants to prepare an EA for "hazardous fuels
reduction" in Sands Checkerboard. We are uncertain just what the hazard
is here. Who or what is threatened by the woody vegetation termed
hazardous fuels? Is cheatgrass a "hazardous fuel"? We certainly think
this term is far more apt for cheatgrass than it is for most other
vegetation situation where BLM applies it. BLM must develop a
methodology to prioritize any "treatments' of hazardous fuels. This is
necessary to most effectively spend scarce taxpayer dollars, best
protect habitations and areas that are truly "at risk". Instead of
spending hundreds of thousands of dollars planning 6-10 million dollars
or more of "treatments" in the Jim Sage Area, or drastic "treatment" of
the entire Samaria Mountain Range, These projects are primarily aimed at
killing woody vegetaiton top promote livestock grazing. BLM must use a
sound methodology to determine needs for treatment -- and focus should
always be on the areas withn approx. 1/8 mile of actual interfaces with
human habitation.

RESTORATION

Restoration of native vegetation communities and ecological processes
must be the goal of all treatments. Restoration means restoring and
maintaining ecological integrity. Ecological integrity is the ability of
an ecosystem to support and maintain a balanced, adaptive community of
organisms having a species composition, diversity and functional
organization comparable to that of natural habitats within the region.

Lands of primary focus for most active restoration should be: Lands that
have been invaded by exotics such as cheatgrass, medusahead, knapweed or
leafy spurge; Lands purposefully seeded to exotics such as crested
wheatgrass following past agency vegetation manipulation or fire. These
should be prioritized for treatment on the basis of: Geographic location
and continuity/connectivity of native habitats that restoration would
provide for native species. For example, crested wheatgrass seedings in
the Little Lost River Valley are located in an area of great importance
to sage grouse. Restoring the native sage-steppe vegetation on these
sites as habitat for sage grouse and pygmy rabbit should be top
priority, as well as prevention of any further degradation to
still-native communities.

BLM must focus significant treatment and restoration efforts and
spending of federal fire funds on restoration of natïve species
composition and function to crested wheatgrass that has been rampantly
seeded as following ill-conceived sagebrush removal or as post-fire
"rehab", and lands overrun by cheatgrass. The current abundance of
federal fire funds should be used to follow-through on BLM post-fire
rehab actions that have failed in the past (please evaluate all seddings
and identify failures and causes of failure), or where crested
wheatgrass and other exotics were planted as a first step in arid lands
rehabilitation. BLM now has the opportunity to complete post-fire
rehabilitation that has been undertaken, but has failed or had poor
results on likely millions of acres of USRD lands. As part of this
process, BLM should identify all lands where post-fire rehab/"emergency"
stabilization with crested wheatgrass, intermediate wheatgrass and other
exotics was conducted, and prioritize treatment of these lands to return
them to native vegetation and restore natural fire cycles.

Experimentation with new techniques, especially new chemicals, should be
limited to lands overrun by cheatgrass and crested wheatgrass seedings.

For lands still in reasonable health with reasonable ecological
integrity, passive treatments should primarily be applied. Techniques
which minimize soil and native vegetation disturbance should be the
first steps taken. Try these first. See if they work.

As the result of past proliferation of purposeful seedings of exotic
species by BLM in ESR situations, huge sterile monocultures of exotic
species dominate hundreds of thousands of acres of Idaho BLM lands.
These seedings, a result of activities to produce firage, sometimes
under post-fire ESR, have had disastrous consequences for native
ecosystems. Plus, instead of restoring lands seeded immediately after
fire to exotics, BLM instead has let these lands in a highly altered and
unnatural condition. BLM now manages these seeded lands as permanent BLM
sacrifice zones to the livestock industry -- issuing TNR, converting TNR
to permanent AUMs, etc. It is these post-fire seedings, a direct result
of BLM's short-sighted livestock forage or ESR efforts of the past, that
are facing massive AUM increases to wealthy permittees, such as JR
Simplot, in the Jarbidge Field Office.

You must fully assess the impacts of these past actions in order to
understand the context of your current decisionmaking process, as well
as to assess environmental impacts and reasonably foreseeable outcomes.

As part of this EIS, you must commit to restoration of native vegetation
on all lands seeded to exotics as a part of past or future ESR
activities. This NEPA document should include a timetable for
accomplishing this.

BLM also appears to be segmenting the NEPA processes associated with
this EIS, by preparing two separate small "EAs" for ESR activities that
occur on its lands throughout Idaho. No explanation is provided for why
this is occurring.

PREVENTION

Arid lands may become so degraded that they can never recover. These
communities have been described (Archer and Smeins 1991) as crossing a
"transition threshold" --with loss of topsoil, dominant species that
have become locally extinct, and introduced species that have become so
dense that weedy annuals become the climax species. All efforts must be
made to keep plant communities from crossing this threshold, and thus
requiring massive amounts of funds and elaborate treatments to attempt
restoration.

Moderately degraded communities can become severely degraded if
preventive action is not taken.

Pristine and near-pristine efforts should be protected using all
possible techniques, especially passive restoration techniques such as
immediate removal of all livestock disturbance as they typically serve
as important habitats for native species and protection of biodiversity.
Economically, it is a lot more cost-effective to keep lands from
becoming degraded than it is to conduct wide-scale treatments after they
have become degraded.

Prevention is especially critical in upland communities, as they are
less resilient to recovery following site disturbance than are riparian
areas. Plus, the greater the aridity, the greater the difficulty of
recover. This may even vary within the same geographic area, as south
and west faces are more likely to face cheatgrass invasion following
treatments.

Almost universally throughout the Upper Snake District, wetlands
(springs, seeps, streams, playas, etc.) have been heavily damaged by
livestock grazing and trampling activity. This has altered their
morphology, areal extent of water tables/wetted soil areas, plant and
animal species composition, plant and animal ecology. However, the
current path of livestock shifting use onto upland sites to take
pressure off riparian areas is an ecologically destructive path, and
prevention must be conducted in an integrated way. Both the riparian and
upland areas are undergoing desertification processes, which ultimately
make them less resilient, and less likely to be able to be restored to
native systems.

ROLE OF DESERTIFICATION IN FUELS AND FIRE PROBLEMS AND ECOSYSTEMIC
CHANGE

Please see our "Additional Comments" explaining the role of
desertification caused by livestock grazing and other activities in
causing fuel and weed problems.

WEEDS AND INVASIVE SPECIES

Exotic species are invading lands in the Interior Columbia Basin at an
alarming rate. Exotic species alter western ecosystems by increasing
fire frequency, disrupting nutrient cycling and hydrology, increasing
erosion, altering soil microclimates, reducing biodiversity, and
reducing wildlife habitat.

Disturbance related to livestock grazing, livestock grazing facilities,
ORVs and extensive road networks are causes of weed invasion. Removing
these sources of disturbance from "at risk" lands, and any lands that
have been treated is a vital and integral part of any treatment, as well
as prevention and restoration.

Livestock and ORVs are weed seed vectors. Livestock carry weed seeds in
fur, feces, mud on hooves, etc. They also disturb soils and created
ideal sites for weed seed establishment (Belsky and Gelbard 1999).

Recent observations show that exotics like cheatgrass and medusahead may
be only the first in a wave of exotics and that new infestations of
aggressive species such as white top or knapweed occur in areas
overtaken by cheatgrass and medusahead. Thus, BLM's current practice of
using these weeded areas as "sacrifice zones" for excessive levels of
livestock use, issuance of TNR, etc. only increases chances of invasion
by new and even more aggressive exotic species.

REMOVAL OF LIVESTOCK

Livestock grazing and trampling is the major cause of damage to upland
plant communities and western ecosystems. They are also the major factor
preventing recovery of these systems.

Removal of livestock, including through use of federal fire funds to
permanently buy out grazing permits, must be a treatment that is
evaluated under all alternatives. USRD lands should be prioritized for
buyouts, based on the need for passive and active treatment measures to
be applied.

It makes no sense to spend hundreds of dollars an acre on "restoration",
or \$40 an acre on a "prescribed" fire treatment if livestock grazing
disturbance is then to again occur. Livestock are the primary cause of
vegetation/fuels problems. Allowing the primary causal agent of
ill-health to then again be allowed to graze and trample these same
lands, and cause a "need" for future treatments, makes no sense at all.
BLM typically receives around 13 cents an acre annually for livestock
grazing on these lands, so the economic folly of returning livestock to
treated lands is extreme -- just like the ecological folly.

REST FROM LIVESTOCK

BLM's EIS and the "updated" EFR plans are woefully deficient in
providing adequate periods of rest from livestock grazing following
treatments. In order to determine necessary rest periods, BLM must
understand the condition of the community pre-treatment (see, for
example, Eddleman et al 1994). Specific time periods must be applied,
along with measurable recovery standards for soils, microbiotic crusts,
herbaceous and woody vegetation recovery before livestock grazing can
resume.

FIRE

BLM can not use "natural fire regimes", historical ranges of variability
and other models as a basis for any fire planning. The potential for
anything resembling a "natural "fire regime has been drastically altered
by 150 years of livestock grazing and other disturbance so that natural
fire regimes no longer exist in many areas. As part of its assessment,
BLM must first determine the current condition of all the vegetation
communities in the affected lands in the planning area. This information
must be newly collected as part of this process, since most BLM
inventories, especially in these lands with ancient LUPs, are nearly 25
or more years old. This necessary is critical to understanding the risks
of any treatment disturbance to these lands.

We believe that until effective answers are found for the vexing
problems of noxious weeds and exotic annual grasses, a cautious and
prudent fire suppression plan must be in place. This is also necessary
because of the dramatically altered and unnatural condition of many
sites caused by 150 years of livestock grazing.

FUELS REDUCTION

Shrub-Steppe Communities: Livestock grazing has fundamentally altered
(and continues to alter and degrade) native understories, by killing and
weakening native grasses and forbs and harming microbiotic crusts. As
native bunchgrasses have been replaced by cheatgrass and other exotics
in the wake of livestock grazing, USRD plant communities are now subject
to hot, early season fire instead of cooler, late-season fires.
Cheatgrass provides dense, continuous fuel that causes fires to flash
across the landscape. Cheatgrass results in frequent re-occurrence of
fire, preventing regrowth of native vegetation. Plus, cheatgrass litter
chokes soil surfaces, preventing germination of native shrubs
(sagebrush, rabbitbrush). Fuels reduction in sage-steppe communities
should focus on restoration of these cheatgrass-invaded sites and
damaged understories. This is the primary active restoration
measure/treatment that needs to be taken to fundamentally alter the
nature of fire in these arid lands.

Low Elevation Forests: Here too, livestock grazing has fundamentally
altered (and continues to alter and degrade) native plant understories.
By creating abundant areas of bare soils, it creates ideal conditions
for increased densities of young trees. These become the fire-prone
doghair thickets of young trees that create ladder fuels and other
incendiary conditions in arid forests.

Before Euro-American settlement, periodic fire cleared Ponderosa pine
and Douglas fir understories, and the build-up of fuels was too slow to
create hot canopy fires. With Euro-American settlement, and continuing
to the present: 1) Selective logging of large trees occurred, and small,
highly flammable trees were left; 2) Fire control was instituted; 3)
Domestic livestock consumed grasses that carried low-intensity fires,
and such fires became less frequent, and woody fuels built up.

Hot fires occurred in the past, and were a part of natural forested
ecosystems. In many areas away from human habitation, fuel reduction may
not be necessary.

To prevent buildup of woody, highly flammable fuels in arid forests at
times need to be let burn under carefully controlled conditions. This
should only occur in lands that are not at risk to exotic species
invasion in the post-fire environment. Selective logging of old,
fire-tolerant trees must be halted. Domestic cattle and sheep grazing
must be decreased or ended.

JUNIPER

Juniper and other woody vegetation throughout Idaho have been vilified
by the ranching industry. Juniper in the USRD-BLM managed lands have
been greatly fragmented by purposeful fire, escaped prescribed fire and
wild fire. NO additional acreage of juniper should be removed until
BLM-prescribed fire-ravaged lands, such as those at Rice Canyon in the
Burley District, are fully restored with native species.

Any juniper removal should be highly selective, individual tree cutting
of smaller-sized trees. Fire or extensive soil disturbance paves the way
for weedy species invasion in juniper communities. Grazing causes
juniper expansion by destroying and weakening native understories, and
altering natural cool burning fires and fire cycles.

A CRITICAL AND METHODICAL EXAMINATION OF SUCCESS/FAILURE OF PAST BLM
TREATMENT PROJECTS IS NECESSARY

A careful scientific evaluation and assessment of past BLM "treatments"
on USRD lands must be prepared. How many acres have been burned in
prescribed fires? What post-fire management was done by BLM? What were
the results? What are their current vegetative communities? What past
herbiciding has been done by BLM? Where? How many acres? What were the
results? How many acres, and where, was post-fire rehab. done? What is
the current condition and vegetation of these lands? Please provide maps
that adequately depict the above information.

FIRE SUPPRESSION

Fire suppression is critical in areas of high ecological value habitats
that are "at risk" to exotic species invasion following fire, areas
where irreplaceable ecological values, human life, or cultural resources
are at stake. Effective fire suppression plans must be in place for
these lands.

Minimum impact suppression tactics should be followed.

PRESCRIBED FIRE

Prior to conducting any prescribed burn, BLM must thoroughly consider
and analyze in an open NEPA process with full public comment and review
periods:

Long-term damage to microbiotic crusts, soil erosion through wind and
runoff events, long-term loss of nutrients from already
nutrient-deficient landscapes, loss of native species, radionuclide
levels in surrounding vegetation, interrelation between prescribed burns
and other "treatments" on neighboring federal/state/private lands,
increased risks of exotic species invasions, impacts on habitat for
native wildlife, indigenous uses of plants that may impacts, air quality
impacts. BLM must also conduct a

We are very concerned that BLM may initiate a program of widespread
"prescribed" burns on lands that have been, and continue to be,
seriously damaged by livestock grazing and other abuses, and which will
are very vulnerable to exotic invasions in post-fire environments.

All fuels reduction projects must be based on comprehensive restoration
assessments before any reduction takes place.

USE OF LIVESTOCK AS A "TOOL"

Livestock should not be used as a "tool". They are only a temporary,
stop-gap measure and simply mowing weeds to ground level does not
address the fundamental problem of eliminating weeds, and getting native
species to grow. Native species will not recover if sites are grazed by
livestock. In fact, the extreme disturbance caused by livestock will
make sites MORE fire prone. In most instances, it would be just as
effective to mow weeds as to use livestock, and would have far less
impacts to soils. Plus, the possibility of introduction of new weedy
species as a result of livestock disturbance would be minimized. BLM
should examine the appalling fire history of the Jarbidge FO and assess
how seeding of crested wheatgrass, heavy grazing, high stocking rates,
etc. --have resulted in extensive and large acreage fires.

USE OF HERBICIDES

Herbicide use should be kept to an absolute minimum under all
alternatives. Herbicides are known carcinogens. Many herbicides migrate
in soils and infiltrate water supplies. USRD's own disastrous experience
with the herbicide Oust demonstrates the dangers of herbicide use in
wild land settings, and how despite reassurances in EAs, things can go
very wrong. Here, Oust blew on soil particles into neighboring fields,
and inhibited crop germination. We have seen wild settings where
application of Oust has likewise had disastrous results -- including in
the "dad zone" it created in Rice Canyon and in the Jarbidge WSA. For
several years prior to the Oust drift disaster, the corporation that
manufactured Oust aggressively marketed its use at seminars attended by
federal agencies. We are quite suspicious of the role of chemical
corporations in pushing the use of herbicides.

At the best, herbicide use is only a temporary measure or intermediate
step to be used, and it does not address the basic causes of weed
problems. Sulfonylurea and acetolactate synthase-inhibiting herbicides
should not be used due to their demonstrated ability to damage off-site
plant species.

We often encounter areas on public lands -- such as leafy sprurge
spraying in the Lost River Area -- where all native veg. has been killed
by herbicides, and leafy spurge continues to thrive. The role of
continued livestock grazing post-treatment in continuing weed invasion
must be addressed -- and the EIS does not do this.

MECHANICAL TREATMENTS

BLM should use mechanical methods of weed control that have been
identified as effective in current scientific literature (mowing, spot
fire (flamer), weed eaters, mulching).

Any mechanical removal of woody vegetation must be carefully conducted.
Any removal of trees must be based on individual tree marking.

All off-road travel should be minimized.

All fuels reduction projects must be based on comprehensive restoration
assessments before any reduction takes place.

MIGRATORY BIRDS/CRITICAL PERIODS/SAGE GROUSE

No treatments of any kind should be allowed during nesting periods for
migratory birds, or in important or critical wildlife habitats during
sensitive times of year. The role of all past and proposed treatments on
habitat fragmentation must be assessed. See Knick et al. 2003, Connelly
et al. 2004 to understand the tremendous fragmentation that exists.

BIOMASS

Use of material for biomass fuels should not be allowed. Biomass
projects export nutrients from often nutrient-deficient sites, and is an
extractive, commercial use of public lands with widespread harmful
ecological impacts.

USE OF CONSULTANTS

We are very concerned that BLM is in such a rush to spend federal fire
funds that it is turning far too much environmental analysis over to
consulting firms, and removing local agency specialists who are most
familiar with land conditions from the data acquisition and analysis
loops. What protocols will BLM use to ensure sound decisionmaking,
adequate knowledge of local conditions and necessary site specific
analysis?

PREVENTION

BLM's vegetation efforts can not be limited to disturbance-style
treatments alone. Plant communities which are still healthy should be
managed in a way to effectively: 1) prevent their conversion to
weed-dominated communities; 2) prevent loss of biodiversity; 3) prevent
changes in their fire frequencies and intensities; 4) prevent the
conversion of shrub lands to woody thickets.

ASSESSMENT

An independent assessment by qualified ecologists not tied to Western
Land Grant universities of the "need" for the proposed actions, and the
risks of undertaking new disturbance must be conducted as part of this
process. We would like to be involved with this effort, and would be
happy to provide you with a list of names of scientists that could be
involved in this. Since BLM's scoping notice discusses "collaboration",
this is an important part of the collaborative process to us -- i.e. BLM
working with us to ensure its EIS is based on current ecological science
and the science of arid lands restoration.

A component of this should be an assessment of risks of new, additive or
cumulative disturbances associated with the projects on top of existing
disturbances. For example, if an area unrelentingly subjected to
livestock grazing has previously been "thinned" by old herbiciding, or
fire, what will the impact of a new treatment disturbance be on soils,
vegetation, watersheds, water quality, native wildlife, etc.?

We urge you to focus on actual Interfaces with habitation, and not the
large-scale wild land disturbance you propose.

ADDITIONAL SPECIAL STATUS, T&E SPECIES

The actions of the EIS will have large-scale effects - ranging from
increased sedimentation of bull trout and redband trout streams to major
fragmentation of sage grouse, Brewer's sparrow and other declining
species habitats. The EIS fails to address this fragmentation, on top of
the fragmentation that already exists -- see, for example, the analysis
of fragmentation on the Sage Grouse Conservation Assessment (Connelly et
al. 2004). The EIS is lacking in basic information on soil stability,
erosion hazard, wind and water erosion risks, etc. related to lands in
the EIS area. This is critical for understanding likely sedimentation
into streams, site soil stability post-treatment, likelihood of
increased gullying, and other factors. Special status species habitats
are faced with a broad array of escalating synergistic and cumulative
impacts to habitats and populations -- ranging from development of new
livestock infrastructure and expanded water-hauling to energy
developments such as wind or geothermal and associated roading and
disturbance across public and private lands of southern Idaho.

MONITORING AND MITIGATION

We are extremely concerned that monitoring and mitigation in the DEIS
are not adequate and do not even begin to address the large-scale
disturbance of plant and animal community composition, function and
structure that undertaking the large-sale treatments will affect.

Monitoring. The EIS fails to provide necessary monitoring, and decisive
actions that will occur post-treatment if treatment protocols, livestock
rest, etc. is violated. BLM should establish weekly post-treatment
monitoring for livestock trespass, sound studies of soil health and
stability, vegetation community recovery and health, etc.
post-treatment.

Mitigation. Large blocks of land (\> 10,000 acres) should be established
within watersheds where no fuels treatments are conducted, as reference
areas for the outcomes/effectiveness/damage of the treatments that are
proposed. These lands should be identified in the EIS. Other mitigation
includes termination of grazing post-treatment, termination of grazing
on reference areas,etc.

POST-TREATMENT ACTIONS

BLM current enforcement of grazing closure restrictions is incredibly
lax -- we have documented burn trespass after burn trespass where BLM
has failed to administer more than a handslap - or simply ignored --
permittee trespass of burns. For example -- Rice Canyon -- Burley BLM;
Diamond A -- Simplot livestock -- Jarbidge BLM. Thus, we have no
assurances that any livestock-related post-treatment measures will be
followed, and these can not be used as "mitigation" for treatments.

MITIGATION AND MONITORING

BLM must develop adequate mitigation for activities carried out under
this EIS. For example, if BLM wants to burn 10,000 acres of sage grouse
habitat, it should be removing livestock use from a nearby 10,000 acres
of land to provide better quality nesting and wintering habitat.

BLM must develop a comprehensive monitoring plan, with all monitoring to
be funded as part of the original "treatment" cost. Otherwise, timely
and necessary monitoring will never occur.

USE OF NATIVE PLANTS AND LOCAL ECOTYPES

BLM must commit to using all native species in all post-treatment
plantings. BLM cannot rely on the old excuse of seed being unavailable
or too expensive for use. Use of all native seed with commitments to
reseed repeatedly must be part of the planning and funding for all
projects. Planned development of reliable supplies of native seed
sources is essential.

WILDLANDS-URBAN INTERFACE

Any habitation interface projects must focus on projects at the actual
interface with inhabited lands. This is an area of 1/8 mile or less. Any
interface projects must be tied to private landowners taking strict
efforts to control any fire danger on their own private lands. Intensive
wildland-urban interface treatments include thinning, pruning, mowing,
roof cleaning, replacement of flammable landscape and building
materials). These actions should be limited to the interface, and the
private property, and be use to create 1/8 mile of defensible space.

In reality, the interface is to be the area where most federal fire
funds are being spent. Instead, USRD BLM and BLM across-the-board is
roaming far from any real interfaces in projects being conducted.

As part of this EIS, BLM should provide detailed maps of all interfaces,
and a list and report of all criteria used to determine the existence of
an interface.

COST:BENEFIT ANALYSIS

BLM must provide an adequate cost:benefit analysis of all actions. For
example, what are the costs vs. the benefits of spending \$100 an acre
to treat/restore lands where livestock grazing will again soon resume?

What are the costs to recreational uses of public lands of large-scale
treatments? We have been repeatedly contacted by hunters, hikers and
birdwatchers who have had recreational outings -- or favorite
recreational sites - ruined by BLM "treatments". What impact do such
losses have on the local and regional economy?

For example, in BLM's recent flawed and soon-to-be-withdrawn Jim Sage
EA, BLM planned to spend 6 million dollars to kill junipers across an
entire mountain range, despite widespread weed problems throughout the
lower and middle elevations -- BLM grazing proposals would have
increased grazing on the "treated" lands. Thus, taxpayers would have
been funding increased livestock forage under the guise of fuels
projects, while receiving only tiny amounts of grazing fee dollars in
return.

BLM must adequately analyze a full range of alternatives based on sound
economics. All alternatives should include use of federal fire funds to
purchase grazing permits and permanently remove livestock from degraded
lands, as this is a very foreseeable action during the life of this
plan. We support an alternative that uses preventive measures and
passive restoration techniques, addresses causal agents of
fire/fuels/vegetation problems such as livestock and ORV use, and which
minimizes risks of invasive species spread stemming from any treatment
that is applied.

WIND AND WATER EROSION

Actions under the Alternatives will bring about widespread soil erosion
and relocation in wind and water. In order to understand the impacts of
the actions, the current condition of all lands (soils, veg, microbiotic
crusts, etc.) must be thoroughly assessed. The EIS fails to assess how
multiple or overlapping treatments, for example, how will herbicide
runoff be accelerated in burned landscapes? This also relates to air
quality problems, and possible increased air or water pollution.
Recently discovered mercury contamination of Idaho waters and lands from
gold roasting in Nevada must be considered in this analysis, also.

RELATED ACTIONS

The USRD BLM is embarking on many other fire-related projects in USRD
lands. The interrelationships of all ongoing or planned activities in
this region, including across ownership boundaries, must be fully
explored.

COMMITMENT TO OPEN NEPA PROCESS

The USRD BLM must ensure that all future projects that are tiered or
related to this EIS undergo, further environmental review at the level
of an EA or EIS with and full and open public comment and participation
process.

POST-TREATMENT, EFR

BLM's recent ESR updates were big disappointments. BLM should use this
EIS process to redo the flawed USRD EFR document.

Use of Native Species: BLM must commit to use native species in all
restoration seedings in all instances. In the past, BLM has used exotic,
soil depleting crested and Siberian wheatgrasses, and aggressive,
invasive, weedy forage kochia and intermediate wheatgrass. Instead of
focusing on larger exotic plants (primarily because they produce
livestock forage, no matter how limited its palatability), BLM must use
natives, especially species like *Poa sandbergii*, bottlebrush
squirreltail and bluebunch in lower elevation sites. In the past, BLM
has failed to rest lands for sufficient periods of time to allow
successful establishment of seeded native species.

As part of this EIS, please provide a science-based (not
livestock-forage-based, but ecological science-based) assessment of
predicted establishment times for seedings of native vegetation under
the various environmental settings in the USRD, and include in this
predictions of "success" with and without livestock grazing. Please also
thoroughly describe and assess the ecological impacts of the exiting
seedings -- impacts on soils, waters, vegetation, weeds, native biota,
recreational and cultural concerns.

BLM must closely study the lessons provided by the bluebunch wheatgrass
seeding in an ungrazed area near Kuna Butte in the LSRD -- and any
examples the agency may have in the Upper Snake or throughout the West,
where, due to no grazing for a decade, seeded bluebunch wheatgrass was
surviving and thriving at low elevations. In addition, please use
existing exclosures as reference areas for comparison of effects of no
grazing for several years following a fire, vs. BLM's typical woefully
inadequate 2 growing season's rest. There are also exclosures in the
Jarbidge FO that can serve as reference sites and comparative examples.
One is located north of Winter Camp Butte, others are near Roseworth.
Please visit these sites, and quantify the differences between
vegetation inside and outside these exclosures, and use this information
in developing a realistic time frame for livestock exclusion from seeded
lands.

Sagebrush and other appropriate native shrubs (winterfat, shadscale,
rabbitbrush) must be included in all seedings, and repeated efforts must
be made to establish native shrub cover, due to its importance to many
native wildlife species.

BLM must use some of its burgeoning fire funding to set up a reliable
network and system for supply and storage of native seed, including
locally adapted ecotypes, so that this native seed is readily available
in the wake of fire. BLM will then no longer have the time-worn excuse
that "we couldn't get native seeds, so had to plant cwg". It is time to
act responsibly, and apply federal fire funds to setting up a reliable
system of seed supply.

BLM must also commit to re-seeding in subsequent years, if initial
seeding attempts are not successful due to drought or other factors.
This must be factored into any

No Need to Seed Herbaceous Species in Many Higher Elevation Sites: Many
higher elevation sites require NO seeding of herbaceous species at all.
Only sagebrush or other native shrubs should be seeded in these lands.
It is essential, however, that these sites receive adequate rest from
livestock grazing so that understory components, including microbiotic
crusts, can recover -- this is essential to prevent new weed invasion.
The two graing seasons'rest --maybe -- is not sufficient.

Livestock Trespass, Other Post-Fire Non-Compliance: As part of this NEPA
process, BLM must review all records of livestock trespass (including
warning letters, not only decision-level action - and assess its
frequency and detail the lands where it has occurred. What are the
impacts of trespass on outcome of rehab efforts? BLM must also provide
strict penalties for post-fire trespass by livestock on burned areas. As
taxpayers often have spent hundreds of thousands of dollars on post-fire
rehab and other ESR activities, accountability and effectiveness of
rehab is essential. Please describe how trespass may harm any site
recovery. Trespass has been a tremendous problem in Burley BLM lands,
and documented by Miriam Austin of WWP and others over the years. The
destroyed public lands at Rice Canyon and in the Goose Creek watershed
provide a perfect example of BLM Post-fire failures to control
livestock.

Livestock Facilities: The EFR must sharply limit the use of federal fire
funds in construction of post-fire livestock facilities. BLM's typical
response to fire is to place a fence, often permanent, as around the
perimeter of a fire, and often to develop additional water facilities.
These actions (permanent fence, new water facilities) are NOT part of
post-fire rehab, they are part of livestock management on surrounding
lands. Such projects inflict, in an unplanned and unnecessary manner, a
new array of disturbances to wildlife habitats already impacted by fire
disturbance.

There are many harmful impacts of barbed wire fences and other livestock
facilities -- posts serve as perches for predators, observation points
for brown-headed cowbirds. Plus, fences cause avian mortality from
collisions. New water sources lead to rapid disturbance and depletion of
lands in the areas surrounding them, placing additional stress on native
ecosystems and dependent species.

WWP strongly supports using existing unburned pasture or allotment
boundary fences as the structures that restrict livestock from burned or
treated lands. By closing these somewhat larger land areas to livestock
grazing, BLM will also provide some better grass cover and habitat for
species like sage grouse, who face habitat loss and fragmentation as
lands burn. A 4-5 year closure of the pasture or allotment will result
in ungrazed areas that help to provide grasses of sufficient height, or
other necessary habitat components, for sage grouse and other native
wildlife. Only temporary facilities should be allowed, if any are used
at all -- primarily electric fences. All post-fire rehab plans must
specify removal dates for any livestock facilities that result from fire
rehab activities. However, temporary electric fences have a long track
record of failure -- please review informaiton in Burley and Challis BLM
files concerning woeful trespass of burned areas or sensitive riparian
areas that resulted from the use of temporary fences, rather than
removing livestock to exisiting pasture or allotment boundary fences .

AUMs Should Not Be Shifted Elsewhere: BLM should not shift AUMs from
treated lands to other areas. All AUMs from burned lands should be
placed in temporary suspension until rehab, or restoration, success
occurs.

Regrettably, in recent JFO post-fire documents, BLM has merely been
shifting livestock use elsewhere, and thus impacts of livestock on
watersheds, wildlife, habitat, etc. are magnified and amplified to the
detriment of native species and the ecosystems upon which they depend.
BLM has never assessed the impacts of these shifted AUMs.

Area of Rested Lands Must Provide Habitat for Native Wildlife: BLM must
protect land areas sufficient to provide habitat for sustaining viable
and healthy populations of native wildlife as part of all treatment or
ESR activities and decisions. This is particularly important for
declining shrub-steppe species that are facing accelerated habitat loss
and fragmentation (Knick et al. 2003, Connelly et al. 2004). BLM must
assess the status of populations and habitats within the larger
landscape area, and determine the likely effect of a fire on special
status species and other important biota. BLM must also act to take
protective measures -- not only on the fire-affected allotments, but
also on surrounding lands, and to buffer habitat loss until the habitat
that has been lost can be restored.

Watersheds/Water Quality: Resting sufficient areas -- burned and
unburned, treated and untreated - is essential for watershed protection.

Risk Assessments: BLM must conduct assessments of the risks of seeding
failure/loss, increased depletion, weed invasions, under various
post-treatment grazing strategies and across a broad range of
alternatives. What are the risks of seeding weakening and depletion if
grazing is allowed to resume too soon?

Minimal Use of Chemicals: BLM must strive to minimize use of chemicals
in wild land settings. An increasing segment of the public has health
problems related to chemical sensitivities. Chemicals may leach into
water, blow on eroding soils into other sites. Wind erosion is far more
significant in post-fire environments, as dark bare soil surfaces heat
up, with the result of funnel-cloud erosion/dustdevils blowing soils
away. Cancer, respiratory problems and many other human health effects
of herbicides and other treatment chemicals are well-known.

If BLM chooses to use chemicals, the treated lands, and surrounding
areas, must be posted with signs that warns the recreational public of
chemical use and possible exposure. BLM's disastrous use of Oust
demonstrates the uncertainty associated with use o chemical sin wild
land settings, where wind erosion or water runoff may transport
chemicals to unintended areas with unintended consequences.

Periods of Rest: BLM must require adequate periods of rest from all
livestock grazing to ensure that full recovery, or establishment of
seeded vegetation, occurs. This time period is much longer than BLM ever
requires, and is often dependent on the condition and health of
vegetation communities pre-fire. Eddleman et al. (1994) described 4-5
year periods of rest as necessary for degraded western juniper
communities.

Low elevation sagebrush-steppe communities may require a decade or more,
and repeated seeding efforts during periods of favorable weather, to
allow re-establishment of native vegetation. The EIS plan must address
these necessary periods of rest, and not base its actions on the
convenience of the livestock industry.

Commitment to Rehab: BLM's scoping letter states that "rehab" occurs up
to three years after a fire. This must be expanded, to the time period
sufficient to achieve adequate and healthy native vegetation
communities, and no upper time limit put in place. A reasonable time
period would be 10 years, given the vagaries of weather and drought
cycles in depleted arid low elevation lands.

What About Restoration? "Rehabbing" in the BLM sense, is vastly
different from restoration to a full component of native vegetation and
ecological processes. Under what circumstances will BLM undertake
Restoration? Is this NEPA document intended to cover that? How will
BLM's ESR activities relate to restoration?

Analysis of Past EFR/Rehab/Restoration Actions. As part of this NEPA
process, BLM must assess all its post-fire rehab efforts in the past
30-40 years, or however long records have been kept. For example, which
cwg seedings in the Jarbidge were planted, when? With what species?

Following this, BLM must collect site-specific data on the current
condition, health, wildlife, recreational and other values of these
areas seeded post-fire. How many new fences, pipelines, troughs, etc.
have been built using ESR funds? What impacts have they had? A complete
analysis must be presented in this NEPA document.

Economics: A complete analysis of the costs and benefits of ESR
seedings/rehab efforts must be provide. What is the per-acre dollar cost
of all actions under all alternatives? What are the ecological
costs/benefits of these actions?

BLM must also assess impacts of poor pre-fire land conditions and
management on the outcomes of any post-fire recovery, and of the
likelihood of success of any post-fire rehab.

We believe you must provide extensive analysis of the impacts of
post-fire "salvage" logging or thinning. What are its impacts to soils,
vegetation, weed invasion risks, wildlife habitats, fisheries,
recreational and other uses of the affected lands? What have been the
impacts to, and what is the condition of, lands where this has occurred
in the past?

Please keep us closely informed of all steps in this process.

Sincerely,

Katie Fite

Western Watersheds Project

PO Box 2863

Boise, ID 83701

208-4291-1679

CD of Juniper-Bird Study Submitted